TURNING TECHNOLOGIES, LLC
Turning Technologies, LLC (“Turning”) has created this privacy statement to demonstrate its commitment to privacy and the transparency of personal data processing. This statement discloses our information gathering and dissemination practices. By accessing and/or using Turning’s website and products, you consent to the collection, use and disclosure of your information, including your personally identifiable information as described in this document.
Lawful Basis for Processing Your Data:
Turning will process your personal data based on the following Legal Basis for Processing according to Article 6 of the European General Data Protection Regulation (GDPR):
- Consent: you have given consent for the processing of your personal data for a specific purpose. If you reside in a country governed by GDPR, then you must actively “opt in” for Turning to have your consent. Regardless of where you reside, you always have the right to “opt out” at any time.
- Legitimate interests: the processing is necessary for the legitimate interests of Turning as we work with your organization to provide you the services.
Types of Personal Data Collected:
In the course of setting up and using an account or completing a form via our website, Turning may collect the following personal information as you provide it to us:
– Organization name
– Postal code
– Attendance data (snapshot of geolocation when used for GPS attendance)
– We may also collect information when you voluntarily complete customer surveys, or provide feedback to us.
Purposes of Personal Data Collection and Use:
In order for you to set up an account and use our response technologies, you need to provide Turning with certain personal information that can associate you with your specific account.
Your Rights Regarding Personal Data Provided to Turning:
- The right to be informed – meaning Turning must make clear what they are processing, why, and who else the data may be passed to.
- The right of access – which is your right to see what data is held about you by Turning.
- The right to rectification – which is your right to have your data corrected or amended if what is held is incorrect in some way.
- The right to erasure – which is your right, under certain circumstances, to ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
- The right to restrict processing – which gives you the right to ask for a temporary halt to Turning’s processing of personal data, which may impact your ability to use our software
- The right to data portability – which is your right to ask for any personal data supplied to Turning, to be provided in a structured, commonly used, and machine-readable format.
- The right to object – which is your right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
- The right to consent and withdraw consent related to how your personal data is used.
- The right to lodge a complaint with a supervisory authority.
These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your personal data, you may request a data access form at firstname.lastname@example.org. We may request specific information from you to confirm your identity. Requests will be responded to without delay and within one month of request being submitted. In some circumstances we may charge a reasonable fee for access to your information. You have the right to receive your personal data in a structured, commonly used and machine-readable format.
We may share information with third party data processors acting on our behalf to provide you with services in connection with your account with us. Turning will enter into data processing agreements with any such third parties consistent with the requirements of the GDPR.
Turning will retain the personal data that we collect about you for as long as necessary for the purposes set out in the Turning Technologies Policy. Please be aware that we may also be required to retain your personal data for legal and accounting reasons.
Use By Children:
We do not intend to collect personally identifiable information from children through the Website. If you are considered a minor as defined in your jurisdiction (i.e., country, state or territory), you should consult with a parent or guardian about the use of the Website.
Turning maintains reasonable and appropriate security measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the GDPR.
Turning may use the personal data that you provide through an online form to send information to you, for example, information about our company and products. Your personal data may also be used to contact you when necessary or desirable. You may opt-out of receiving marketing information.
Our emails provide users the opportunity to opt-out of receiving Turning’s marketing communications. Please keep in mind that, even if you choose not to receive marketing communications, you will continue to receive account communications related to services or products that you are using (e.g. purchase confirmation and receipts) and/or important product and legal updates related to those services and products.
California residents have certain rights spelled out in the California Consumer Privacy Act or “CCPA”.
Turning does not sell the personal information we collect. The types of personal information we collect in order to set up an account are described above. The purposes for sharing any information we collect are also described above. Turning does use third-party cookies as described above.
California consumers may make a request regarding the types of data disclosed and information about the third-party to whom data was disclosed under the CCPA by contacting us at: email@example.com. We will verify your request using the information associated with your account. Additional identification may be required.
Turning Technologies, LLC is headquartered in the United States at 255 West Federal Street, Youngstown, OH 44503. Any questions or concerns regarding this document and your privacy rights may be directed to:
Data Protection Officer
Turning Technologies, LLC
255 West Federal Street
Youngstown, OH 44503
Turning Technologies, LLC is registered with the Information Commissioner’s Office as our Supervisory Authority. Concerns about our efforts to maintain your privacy in the EU can be directed to:
The Information Commissioner’s Office – Northern Ireland
14 Cromac Place, 3rd Floor
Telephone: 028 9027 8757 / 0303 123 1114