Mobile App Privacy Policy

Last modified: July 2021

Introduction

Turing Video, Inc. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

  • The types of information we may collect or that you may provide when you purchase, download, install, register with, access, or use the Turing Vision Mobile App (the “App”).
  • Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to personal information we collect in this App , in email, text, and other electronic communications sent through or in connection with this App. “Personal information” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” under applicable data privacy laws, rules or regulations.

This policy DOES NOT apply to information that:

  • We collect offline or on any other Company apps or websites, including websites you may access through this App.
  • You provide to or is collected by any third party (see Third-Party Information Collection).

Our websites and apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App after we revise this policy means you accept those changes, so please check the policy periodically for updates.

Children Under the Age of 13/16

The App is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@turingvideo.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect and How We Collect It

We collect information from and about users of our App:

  • Directly from you when you provide it to us.
  • When you create an account or use the App.
  • When you voluntarily provide information in free-form text boxes through the App or through responses to surveys or questionnaires.
  • When you send us an email or otherwise contact us.
  • Automatically when you use the App.
  • Through Cookies (as described below).
  • We may receive information about your location and your mobile device, as applicable.
  • We may receive and collect information transmitted from your mobile device for the purpose of providing you the relevant services, such as information regarding when you are logged on and available to receive updates or alert notices.
  • The charts below detail the categories of personal information that we collect and have collected over the past 12 months:

1. Enterprise Customer Personal Data

The App permits our enterprise customers (“Enterprise Customers”) to collect certain personal information from you for their own purposes (“Enterprise Customer Personal Data”). We collect this Enterprise Customer Personal Data only on behalf of each Enterprise Customer. The collection, use and disclosure of your Enterprise Customer Personal Data will be governed by the applicable Enterprise Customer’s policies, including its privacy policy. Each Enterprise Customer is responsible for all its activity in connection with the App, including obtaining all necessary consents or approvals from or by you, and providing all necessary notices to you. Each Enterprise Customer is responsible for compliance with any applicable federal or state privacy laws and regulations. The Enterprise Customer Personal Data that we collect depends on the particular services and the particular Enterprise Customer.

Enterprise Customer Personal Data may include:

Category of Personal Information Examples of Personal Information We Collect Categories of Third Parties With Whom We Share this Personal Information:
Sensory Data
  • Photos, videos or recordings of your environment
  • Enterprise Customers
  • Service Providers
  • Parties You Authorize, Access or Authenticate
Professional or Employment-Related Data
  • Job title
  • Enterprise Customers
  • Service Providers
  • Parties You Authorize, Access or Authenticate

2. Cookies and Information Collected Automatically

The technologies we use for automatic information collection may include:

  • Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.
  • Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

3. Tracking

When you download, access, and use the App, it may use technology to automatically collect:

  • Device Information. We may collect information about your internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information.
  • Location Information. This App does not collect real-time information about the location of your device.

If you do not want us to collect this information you may opt out at any time by changing settings in the app. For more information, see How We Use Your Information and Disclosure of Your Information.

4. Other Categories of Personal Information

We may also collect other categories of personal information about you to enable use of the Services, including:

Category of Personal Information Examples of Personal Information We Collect Categories of Third Parties With Whom We Share this Personal Information:
Profile or Contact Data
  • First and last name
  • Email
  • Phone number
  • Unique identifiers such as passwords
  • Service Providers
  • Analytics Partners
  • Parties You Authorize, Access or Authenticate
Geolocation Data
  • IP-address-based location information
  • Service Providers
  • Parties You Authorize, Access or Authenticate
Other Identifying Information that You Voluntarily Choose to Provide
  • Identifying information in emails or letters you send us
  • Service Providers
  • Parties You Authorize, Access or Authenticate
Other
  • Information about your use of the Services
  • Service Providers
  • Analytics Partners
  • Parties You Authorize, Access or Authenticate

5. Third-Party Information Collection

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may] include:

  • Advertisers, ad networks, and ad servers.
  • Analytics companies.
  • Your mobile device manufacturer.
  • Your mobile service provider.
  • Business partners and other third parties.

These third parties may use tracking technologies to collect information about you when you use this app. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Choices About Our Collection, Use, and Disclosure of Your Information.

How We Use Your Information

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

  • Providing and Customizing the Services
    • Creating and managing your account or other user profiles.
    • Providing you with the products, services or information you request.
    • Providing the services and support to our Enterprise Customers.
    • Verifying and authenticating your identity and user accounts.
    • Meeting or fulfilling the reason you provided the information to us.
  • Meeting Legal Requirements and Enforcing Legal Terms
    • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
    • Protecting the rights, property or safety of you, the Company or another party.
    • Enforcing any agreements with you.
    • Resolving disputes.
  • We also may use your personal information in other ways with your express consent, for example when you choose to use a service or participate in a program we offer with another entity.Additionally, we may also use personal information that is not Enterprise Customer Personal Data for:
    • Providing, Customizing and Improving the Services
      • Providing support and assistance for the App.
      • Processing orders or other transactions; billing.
      • Improving the App, including testing, research, internal analytics and product development.
      • Personalizing the App, content and communications based on your preferences.
      • Doing fraud protection, security and debugging.
      • Carrying out other business purposes stated when collecting your personal information or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
    • Marketing the Services
      • Marketing and selling the Services.
    • Corresponding with You
      • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about the Company or the Services.
      • Sending emails and other communications according to your preferences or that display content that we think will interest you.

The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:

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

Disclosure of Your Information

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

In addition, we may disclose personal information that we collect or you provide:

  • Enterprise Customers. We share your Enterprise Customer Personal Data only with the particular Enterprise Customer(s) on whose behalf we collected your Enterprise Customer Personal Data.
  • Service Providers. These parties help us provide the services or perform business functions on our behalf. They include:
    • Hosting, technology and communication providers.
    • Security and fraud prevention consultants.
    • Support and customer service vendors.
    • Product fulfillment and delivery providers.
    • Payment processors.
      • Our payment processing partner Stripe, Inc. (“Stripe”) collects your voluntarily-provided payment card information necessary to process your payment.
      • Please see Stripe’s terms of service and privacy policy for information on its use and storage of your personal information.
  • Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
    • Companies that track how users found or were referred to the Services.
    • Companies that track how users interact with the Services.
  • Business Partners. These parties partner with us in offering various services. They include:
    • Businesses that you have a relationship with.
  • Parties You Authorize, Access or Authenticate
    • Third parties you access through the services.
    • Other parties authorized by you.
  • 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 the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our App users is among the assets transferred.
  • To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website or App, we will transmit the contents of that email and your email address to the recipients.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce our rights arising from any contracts entered into between you and us, including the App EULA, and for billing and collection.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.
  • We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process personal information of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your personal information as a service provider, you should contact the entity that collected your personal information in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this policy and you are a California resident, the portion that is more protective of personal information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@turingvideo.com.

Access

You have the right to request certain information about our collection and use of your personal information over the past 12 months. In response, we will provide you with the following information:

  • The categories of personal information that we have collected about you.
  • The categories of sources from which that personal information was collected.
  • The business or commercial purpose for collecting or selling your personal information.
  • The categories of third parties with whom we have shared your personal information.
  • The specific pieces of personal information that we have collected about you.
  • If we have disclosed your personal information to any third parties for a business purpose over the past 12 months, we will identify the categories of personal information shared with each category of third party recipient. If we have sold your personal information over the past 12 months, we will identify the categories of personal information sold to each category of third party recipient.

Deletion

You have the right to request that we delete the personal information that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your personal information to provide you with the services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal information, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use personal information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request. We take the security and privacy of your personal information seriously, and we will not provide access to certain types of personal information such as financial account number, an account password, security questions and answers, or unique biometric data. We may require a notarized affidavit to verify your identity.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

Call us at: (866) 816-7426

Email us at: support@turingvideo.com

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Personal Information Sales

In this section, we use the term ‘sell’ as it is defined in the CCPA. Based on our current understanding of the CCPA, we do not believe we sell your personal information. However, as described in this policy, we have incorporated Cookies from certain third parties into our App. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our App or on other websites you visit.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of personal information that we receive from you.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of personal information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@turingvideo.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at support@turingvideo.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

Data Security and Retention

We seek to protect your personal information from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of personal information and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain personal information about you for as long as you have an open account with us or as otherwise necessary to provide you with our services. In some cases we retain personal information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally. The following are examples of security measures we use to safeguard your personal information:

  • The Company maintains no personal information at any facility or place of business or on any computer, server or device accessible by the Company’s employees, contractors or agents acting on behalf thereof. Storage of any retained personal information is provided by Amazon Web Services
  • The Company’s employees, contractors and agents are explicitly prohibited from accessing personal information and only the Company’s employees whose role in maintaining the systems and technologies required to store securing customer data have access to said systems.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and notify you by email.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

(866) 816-7426

https://turingvideo.com/

support@turingvideo.com

1730 South El Camino Real, Suite 350 San Mateo, California 94402