Privacy Policy

Last updated October 19, 2021

Turntide Technologies Inc. (“Turntide” or “we” or “us”) has created this privacy policy in order to demonstrate our firm commitment to the privacy of users of our websites, www.turntide.com and our related sites (the “Website”) and to inform you on how we process your information if you are a purchaser or user of Turntide’s products and/or services.

Except as explicitly provided herein, this policy applies to (i) your use of the Turntide Website and is incorporated into and forms a part of the Website Terms of Use, and (ii) any data Turntide collects from you through its products, cloud subscription services offerings or any other service offered by Turntide that links to this policy (collectively, the “Services”).

Please read this policy carefully to understand how we handle your information. This policy describes the types of information we may collect from you or that you may provide when you visit our Website or use or access the Services, and our practices for collecting, using, maintaining, protecting, and disclosing that information. By using or accessing the Website and/or Services, you agree to this policy. If you do not agree to this policy, please do not access or use the Website or the Services. This policy may change from time to time. Your continued use of this Website and/or the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

This policy applies to information we collect:

  • On the Website (including on any other website operated by a Turntide affiliate or subsidiary).
  • Through the Services (including through your use and/or access thereof).
  • In email, text, and other electronic messages between you and the Website.
  • Through mobile and desktop applications you download from the Website, which provide dedicated non-browser-based interaction between you and this Website.
  • When you interact with our advertising and applications on the Website.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

This policy does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by any third party (not including our affiliates and subsidiaries); or
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Children Under the Age of 18

Our Website and Services are not intended for children under 18 years of age. Additionally, no one under the age of 16 may provide any information to or on the Website or via the Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use the Services or use or provide any information on this Website or on or through any of its features or register on the Website, use any of the interactive or public comment features of this Website, if available, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@turntide.com

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website. We obtain other information about you when you use or otherwise access the Services. Please note that we need certain types of information to provide the Services to you, the deletion of which may render the Services unusable. The types of information that we collect include information:

By which you may be personally identified, such as your name, mailing address, e-mail address, and telephone number (“personal information”); That is about you but individually does not identify you, such as the name of the company you work for, job title; and/or

About your internet connection, the equipment you use to access our Website and/or the Services and usage details.

We collect this information:

  • Directly from you when you provide it to us (including through your use or access of the Services).
  • Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties, for example, our business partners.
  • Communication with us, including for customer support, technical assistance, marketing, and billing.

Information You Provide to Us. The information we collect on or through our Website and/or the Services may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to one of our Services or requesting further Services. We may also ask you for information when you report a problem with our Website and/or Services.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Your search queries on the Website.
  • Information that the Services collect (which may include name, username, password, title, email address, address, telephone number, postal code, country, product functionality, temperatures, the physical and environmental surroundings of the location where the products are being used, and like information)

Information We Collect on the Website Through Automatic Data Collection Technologies.
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.
  • We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically via the Website is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our Website audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Turntide, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).


Links to Third Party Websites

Our Website may contain links to third party websites, such as Facebook or Twitter. These links are provided only for your convenience and you are free to use them, but you do so at your own risk. We do not control these third parties’ or their websites. The third parties who operate such websites may use tracking technologies. Please read the privacy policies of these third-party websites carefully before browsing or providing any information on such websites. We are not responsible for your activities or any collection or tracking of your information on such sites.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To provide Services to you.
  • Communicate with you regarding the Services, including providing customer service, support and sales.
  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • Promote and market Turntide products and services.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Services and/or Website or any products or services we offer or provide though it.
  • Analyze use of the Services.
  • Improve any services or products we provide and research or develop other products or services.
  • Keep our Services operational.
  • Create or maintain aggregated, anonymized and/or de-identified information, which we may use and disclose without restriction.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Website Terms of Use, our Terms and Conditions of Sale and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, our customers, or others.

Security

The Website and Services have security measures in place intended to protect loss, misuse and alteration of the information under our control. These security measures include state-of-the-art firewall, physical protection in a data center, and strong password protection for data administration. Please note, however, that “perfect security” does not exist on the Internet.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to the Services and certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. You should also update your password periodically to help reduce the risk of unauthorized access not by you.

Your Choices
You may unsubscribe from marketing communications from us by following the directions in those communications. Please note that even if you opt out of, and unsubscribe from, receiving marketing communications, we may still send you certain communications relating to your use of the Services.

Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of this policy. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Additional Rights Regarding Personal Data under GDPR
The following notices and disclosures apply to all natural persons who provide personal data to Turntide, i.e., data subjects, who are covered by the EU General Data Protection Regulation (Regulation EU 2016/679):
• Length of Data Use: Personal data of a data subject is maintained while the data subject or the data subject’s employer is a customer of Turntide, and for a reasonable time afterwards to make it easier for Turntide to serve the data subject or his or her employer if either re-subscribe to Turntide’s services and to contact them about subscription renewal and new products and services.
• Right to Access and Rectification: A data subject has the right to demand access to and the rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability.
• Withdrawal of Consent: A data subject also has the right to withdraw the consent provided by his or her acceptance of this policy at any time, without affecting the lawfulness of any data processing based on consent before its withdrawal.
• Right to Lodge Complaint: A data subject also has the right to lodge a complaint with a supervisory authority regarding Turntide’s processing of his or her personal data.
• Need for Personal Data & Consequences of Withdrawing Consent: The personal data provided by the data subject under this policy is required for Turntide to perform its obligations under any contract between Turntide and the data subject or an employer of the data subject because this information is needed to identify authorized users and provide customer service. A data subject that no longer provides consent or requests erasure of his or her personal data will no longer be able to use Turntide services or products because this information is needed to ensure that the data subject is an authorized user.
• Providing Personal Data to Data Subject: Turntide can provide to a data subject—upon request—remote access to a secure system that provides that natural person with direct access to his or her personal data. This type of request will not be fulfilled in way that may adversely affect the rights or freedoms of others, including trade secrets or intellectual property, and, in particular, the copyrights, protecting Turntide’s software. Depending on the amount of data that falls within this type of request, Turntide may request that, before the information is delivered, the data subject specify the information or processing activities to which his or her request relates.
• Data Transfer outside the EU: Turntide transfers your information, including personal information of natural persons, outside the European Union to the United States or Canada because the transfer is necessary for the performance of the services contract between you and Turntide or the implementation of pre-contractual measures taken at your request. Not all states in the United States have data-protection and privacy laws as comprehensive as the European Union. If European Union data-protection and privacy laws apply to you, then Turntide will maintain measures to protect your personal information identifying natural persons in a manner commiserate with the protections required under European Union law. The EU has not determined that the United States has adequate legal safeguards outside of certain self-certification programs that Turntide currently does not participate in.
• Who to Contact: A data subject can use the following email to contact Turntide regarding any of the privacy rights provided for or granted under law or under this policy: privacy@turntide.com

California Consumers Only: This additional provision applies only to California consumers.
Turntide does not sell personal information. If Turntide changes its policy and decides to sell consumer’s non-anonymized personal information to third parties—which it currently does not—a consumer will have the right, at any time, to direct Turntide not to sell the consumer’s personal information. This right is referred to as the right to opt-out. Turntide will provide notice of any change in its current policy before engaging in any sale of consumer’s personal information. Turntide will not discriminate against a consumer because the consumer exercised any of the consumer’s rights. Nothing in this California-consumer provision prevents Turntide from collecting, using, retaining, selling, or disclosing consumer information that is anonymized or in the aggregate consumer information to the extent otherwise allowed under this policy. Nor does it prevent Turntide from collecting or selling a consumer’s personal information if every aspect of that commercial conduct takes place wholly outside of California to the extent otherwise allowed under this policy. For purposes of this provision, commercial conduct takes place wholly outside of California if the business collected that information while the consumer was outside of California, no part of the sale of the consumer’s personal information occurred in California, and no personal information collected while the consumer was in California is sold. You represent that any users of Turntide’s products or services are at least 18 years old.


A consumer has the right to request that Turntide disclose to that consumer the categories and specific pieces of personal information that Turntide has collected. Turntide does not have to provide information upon consumer request more than twice in any twelve-month period. Turntide uses and collects the following types of personal information as described in the sections of this policy marked by the following headings: Information We Collect About You and How We Use It, How We Use Your Information, and Disclosure of Your Information. These categories of types of data and collection correspond to the following required disclosure of categories of use and collection found subdivision (c) of Section 1798.110 and subdivision (c) of Section 1798.115 (additional information is provided in italics below):
Section 1789.110:
(1) The categories of personal information it has collected about that consumer.
Turntide collects name, address, password, email address, phone number and employer information.
(2) The categories of sources from which the personal information is collected.
Turntide gets personal information from you, your employer, and from Your computer and interaction and use of the Turntide Website, Services, and products and software.
(3) The business or commercial purpose for collecting or selling personal information.
Turntide does not sell personal information. Turntide uses personal information to identify authorized users, provide customer service, track use of Turntide products and services, follow up with communications for new sales, services and renewals, and coordinate provision of products and services with Value Added Resellers, third-party developers, and Turntide vendors.
(4) The categories of third parties with whom the business shares personal information.
As stated above, Turntide shares personal information with third-party developers and Turntide vendors that help Turntide provide, develop, troubleshoot, or modify products or services.
Section 1798.115:
(c) A business that sells consumers’ personal information, or that discloses consumers’ personal information for a business purpose, shall disclose, pursuant to subparagraph (C) of paragraph (5) of subdivision (a) of Section 1798.130:
(1) The category or categories of consumers’ personal information it has sold, or if the business has not sold consumers’ personal information, it shall disclose that fact.
Turntide does not sell consumers’ personal information.
(2) The category or categories of consumers’ personal information it has disclosed for a business purpose, or if the business has not disclosed the consumers’ personal information for a business purpose, it shall disclose that fact.
As explained above, Turntide discloses consumers’ personal information only to vendors for customer service, product development, troubleshooting, customer sales, and verification purposes.
A consumer has the right to request that Turntide delete any personal information about the consumer which Turntide has collected from the consumer. Turntide is not required to comply with a consumer’s request to delete the consumer’s personal information if it is necessary for Turntide to maintain the consumer’s personal information in order to:
(1) Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of Turntide’s ongoing business relationship with the consumer, or otherwise perform a contract between Turntide and the consumer.
(2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
(3) Debug to identify and repair errors that impair existing intended functionality.
(4) Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
(5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
(6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
(7) To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with Turntide.
(8) Comply with a legal obligation.
(9) Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
A consumer may contact Turntide at the following email address privacy@turntide.com to request the information, deletion, or exercise any right to opt out provided under this policy or California law, which has not been or cannot be waived by the requesting consumer. Turntide will use any personal information collected from the consumer in connection with the business’s verification of the consumer’s request solely for the purposes of verification.
Definitions: “Consumers” means a natural person who is a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, as that section read on September 1, 2017, however identified, including by any unique identifier. “Aggregate consumer information” means information that relates to a group or category of consumers, from which individual consumer identities have been removed, that is not linked or reasonably linkable to any consumer or household, including via a device. “Aggregate consumer information” does not mean one or more individual consumer records that have been anonymized. For California consumers, “anonymize” and its derivatives in this policy will have the same meaning as “deidentified” in the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.100, et seq. For California consumers, “personal information” will have the following definition as found in the California Consumer Privacy Act of 2018: “Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household:
(A) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
(B) Any categories of personal information described in subdivision (e) of Section 1798.80.
(C) Characteristics of protected classifications under California or federal law.
(D) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
(E) Biometric information.
(F) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
(G) Geolocation data.
(H) Audio, electronic, visual, thermal, olfactory, or similar information.
(I) Professional or employment-related information.
(J) Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
(K) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
(2) “Personal information” does not include publicly available information. For these purposes, “publicly available” means information that is lawfully made available from federal, state, or local government records, if any conditions associated with such information. “Publicly available” does not mean biometric information collected by a business about a consumer without the consumer’s knowledge. Information is not “publicly available” if that data is used for a purpose that is not compatible with the purpose for which the data is maintained and made available in the government records or for which it is publicly maintained. “Publicly available” does not include consumer information that is deidentified or aggregate consumer information.