Last Modified: June 26, 2019
“Turn” means AutoGravity Corporation, doing business as Turn, and any of its current or future affiliated companies, agents, successors and assignees. Turn administers the web and mobile app platform providing information about vehicle subscription services and related car inventory available through Turn Operators, and administers certain other aspects of the subscription services.
“We,” “us,” or “our” means Turn (including where it is acting as Turn Operator if so specified in a Subscription Agreement).
1. Information We Collect.
“Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or anonymized information that is maintained in a form that is not capable of being associated with or reasonably linked to you.
We collect Personal Information from and about you through the Services, including:
a. Information You Provide. You may provide Personal Information to us in various ways, such as through fillable forms, features or other means offered through the Services, when you register an account or express interest in subscribing for a car, or when you complete and application and enter into a Subscription Agreement.
This information may include: names; street addresses; phone numbers; email addresses; driver’s license number and expiration date or photographs of your driver’s license; social security number, income; your proof of liability insurance; gender; age or birth date; income information; employer; demographic information; and your preferences regarding vehicle subscription, including information regarding your marketing preferences or information you provide in the course of participating in surveys or promotional offers. Information that cannot identify you personally, but that can be used to identify your household, is also treated as Personal Information
b. Vehicle and Geolocation Information Collected Automatically. The Turn Car will be equipped with a Telematics Device which utilizes global positioning satellite (GPS) technology that enables location services and collects Vehicle Data as described below. Some or all Telematics Device functionality will be active during your possession of the Turn Car, as permitted by law, but will only be used in the circumstances described below.
While the Telematics Device will be active and collecting Vehicle Data throughout the duration of your Turn Car subscription, we will not use Vehicle Data, except as may be necessary in the following instances: (1) accidents, (2) roadside assistance, (3) theft or similar situations, (4) repossession or failure to return a Turn Car. In addition, we will use Vehicle Data to perform periodic, GPS-derived odometer checks and to obtain exception event notifications such as excessive speed and harsh braking.
“Vehicle Data” includes information from your vehicle such as details about your vehicle’s use, operation, performance and maintenance status through the Telematics Device, which will be associated with your Personal Information, such as:
· Precise geolocation and other driving data, such as real-time latitude and longitude;
· Operational condition and mileage reporting of vehicles; and
· Driver behavioral information (such as trip durations and routes, speed, braking and acceleration, and trip start/end locations and times), as permitted by law.
We use the Vehicle Data to provide the service to you, improve our products and services, protect and enforce our interests, and for our internal business purposes.
We may offer Touch ID or fingerprint authentication as an alternative log-in method to password if you access the Service through an Apple or Android device equipped with authentication technology. We are only notified as to whether the authentication was successful and cannot access the data associated with the enrolled fingerprint. For more details, please refer to the fingerprint security guides offered by your device provider.
d. Publicly Available Sources. We may collect Personal Information about you that we do not otherwise have, including contact information, employment related information and product interest information, from publicly available sources. We may combine this information with the information we collect from you directly. We use this information to contact you, to send you advertising or promotional materials or to personalize our Service, to pre-populate online forms, and to better understand the demographics of our users.
e. Information Turn Automatically Collects. In addition to Personal Information that you provide to us, Turn may automatically collect certain information about how you access and interact with the Services. Turn may use session and persistent cookies, browser web storage, session logs, spotlight ads/web beacons/GIF/pixel tags, banner ads or links, and third-party click tracking analytics tools (such as Segment, Mixpanel and Google Analytics, among others; these companies may also use such tools) to collect aggregate or other information, such as demographics, about site visitors. Information that Turn collects generally falls into one of the following categories:
i. Device Information. This is information about how you access the Services, such as the operating system, hardware model, application or browser type and version, and unique identifiers associated with your device.
ii. Usage Information. There are certain pieces of information Turn automatically collects in system logs or similar files about how you interact with the Services, such as which features you use and your search and shopping behavior. This Usage Information may also include things like your IP address, browser or device configuration, date and time of access and length of your use, the information you access, cookie information, and the addresses of website or applications that you use to link to and from the from the Services.
iii. Location Information. Turn may use certain information like your IP address or other Device Information or Usage Information to estimate your physical location. Turn may also request to use location-enabled services on your device which will provide sufficiently precise location information for Turn to specifically locate you or your device.
f. Information Third Parties Provide About You. Some of the Services’ features or the provision of the subscription service under the Subscription Agreement rely on information about you that Turn collects from third parties. For examples, we receive information about you from Turn Operators, including Personal Information and Vehicle Data, that is collected when negotiating, entering into, and performing under a Subscription Agreement with you. We or Turn Operator may also receive information from your insurance provider (policy and claim information), referral programs, credit reporting agencies. Service providers, such as any third party customer support providers, customer survey providers, and marketing providers may also provide us or Turn Operator information about you. We or Turn Operator may also receive information from third party payment processors about your payments under the Subscription Agreement.
We may also combine information that you provide us and the information we automatically collect together with information from third parties to provide us with insight about your use of the Services, your use of other websites, devices, mobile applications, and your use of vehicles pursuant to the Subscription Agreement.
2. How We Use Information About You.
We use the Personal Information we collect from you and third parties in the following ways:
a. To Provide Our Services to You, Enter into a Contract with You, and Verify Your Identity. We use the information we collect for our regular business purposes, such as to establish and manage your account, to offer and assist in the transactions you request or that may be suitable to you, to enter into a contract with you, to verify your identity to provide customer support or service related to your interactions with us, maintain your account, or, with your consent, to process eligibility requirements and conduct investigations that require credit report and consumer report inquiries.
b. To Communicate with You. We use the information we collect to contact you via telephone, text, chat, or email, in order to provide Turn’s Services, communicate important information about your vehicle subscription, or to respond to your comments and requests for information. We will obtain your consent to contact you when and in the manner required by law.
c. To Improve Our Services and Develop New Products and Services. We use the information we collect to improve our business, including, for example, evaluating the performance of our staff; developing new products and services and analyzing the effectiveness of products, services, applications and websites and the customer experience. We may also compile data, statistics and analysis about our customers’ use of Turn’s website, Turn’s App, or our products and services for use in providing better customer service, products, features and functionality to you and other customers in the future. We also use the information to diagnose and address technical and service problems.
d. To Develop a Profile of You and Promote Our Services. We use the information we collect to develop a profile of you and your interactions with us in order to promote our services, including marketing products and features to you that may be of interest to you. We will obtain your consent to contact you when and in the manner required by law. We may also use the information to perform data analyses, including market and consumer research, trend analysis, demographic analysis and financial analysis.
e. To Comply with Legal Requirements or for Legal Reasons and to Protect Against Fraud and Abuse. We may access, use, preserve, transfer or disclose information, at any time without notice to you, any information, including personal information as reasonably necessary to: (1) protect or defend our interests and our legal rights or property and those of our affiliates; (2) share information with government and regulatory authorities when required by law or in response to legal process, obligation or request; (3) protect the rights, interest, safety and security of users of the Services, or members of the public; (4) protect against fraud or for risk management purposes; (5) or comply with prudent legal practice as we may determine, and applicable law or legal process.
3. When We Share Information About You.
We share your information in the following ways:
a. With Turn Operators (as Applicable in Instances where the Turn Operator is a Third Party) When You Shop for a Vehicle and/or Enter into a Subscription Agreement When the Turn Operator is a third party, Turn may share information about you, including Personal Information, with the Turn Operators, their agents and third-party service providers, when you indicate interest in subscribing for a vehicle via the Services, to provide the Services to you, such as to establish and manage your account and payments, to offer and assist in the transactions you request or that may be suitable to you, to enter into a contract with you, to verify your identity, to establish creditworthiness, and to provide customer support or services related to your interactions with us.
c. When We Collaborate with Third Parties to Provide or Improve Our Services. We may sometimes share information about you, including Vehicle Data, with third parties we collaborate with to provide the Services or to improve it. This may occur, for example, when we’re providing an integrated or co-branded feature with a partner, or sharing information for their own marketing purposes in compliance with applicable laws and subject to their separate privacy notices.
d. Testimonials. Turn may post customer testimonials on its website, subject to your consent, which may contain Personal Information.
e. As Part of a Corporate Transaction. We may share Personal Information as part of a corporate business transaction, such as in connection with or during negotiation of any merger, sale of company assets, financing, or acquisition of all or a portion of our business. We may transfer Personal Information to a third party as one of the business assets in such a transaction. We may also disclose Personal Information in the event of insolvency, bankruptcy, or receivership. You will be notified via email and/or a prominent notice on any affected Service of any change in ownership, as well as any choices you may have regarding Personal Information about you as a result of the transaction.
f. When the Data is Anonymized or Aggregated. We may share information about you when the data is anonymized or aggregated in such a manner that the information about you does not reasonably identify you directly as an individual.
g. To Comply with Legal Requirements or for Legal Reasons and to Protect Against Fraud and Abuse. As discussed above, we may access, use, preserve, transfer or disclose information, at any time without notice to you, any information, including personal information as reasonably necessary to: (1) protect or defend our interests and our legal rights or property, or those of our affiliates; (2) share information with government and regulatory authorities when required by law or in response to legal process, obligation or request; (3) protect the rights, interest, safety and security of users of the Services or members of the public; (4) protect against fraud or for risk management purposes; (5) or comply with prudent legal practice as we may determine, and applicable law or legal process.
h. With your consent. We may share information about you in other limited circumstances with your express consent.
4. Communications and Privacy Preferences.
You can make certain choices about how we use your Personal Information to communicate with you.
b. Email Communications Preferences. From time to time, we may send you emails regarding updates to our Services, notices about our company, or information about products or services we offer. If you do not want to receive marketing emails from us, you can follow the unsubscribe link provided in those emails. Note that you may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
c. Vehicle Data. Please note that you will not be able to opt-out of the Telematics Device Vehicle Data tracking, which includes the geolocation tracking of the Turn Car vehicle. If you do not consent to this tracking, you may not use our Services (see “Vehicle and Geolocation Information Collected Automatically” in Section 1 above for more information). You may, however, opt-out of the sharing of the Vehicle Data with third parties who are not part of the provisions of the Servces. To opt-out of this sharing, please email firstname.lastname@example.org
5. Interest-Based Advertising Practices.
We may partner with third party advertising networks, marketing partners, or publishers who advertise our products and services on websites not affiliated with us (“Advertising Providers”).
b. Social Media Widgets and Advertising. Our Service may include social media features, such as the Facebook Like button, LinkedIn, Snapchat, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Service, and they may set a cookie or employee other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
We display targeted advertising to you through social media platforms, such as Facebook, Twitter, LinkedIn, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Service while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks. For example:
· Facebook. To learn more about your advertising preferences on Facebook, click here https://www.facebook.com/help/109378269482053.
· Twitter. To learn more about privacy controls for personalized ads on Twitter, click here https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads.
· LinkedIn. To learn more about advertising preferences on LinkedIn, click here https://www.linkedin.com/psettings/advertising.
c. Cross-Device Linking. We, or our third party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We may do this by collecting information about each device you use when you are logged in to our Service. We may also work with third party partners who employ tracking technologies, or the application of statistical modeling tools, to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns.
d. Third-Party Partners. The following is a sample of the third-party service partners we work with to provide cross-device linking and/or advertising services. We will strive to update this list if or when we work with new partners which offer you choices about the collection of your information, but as partners change and new technologies become available, this list is likely to change over time and may not always reflect our current partners.
· Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our site or Service on your browser or mobile device, login to your account on our Service, or otherwise engage with us. We may share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners' sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising, analytics and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
6. Do Not Track Signals.
7. International Users.
8. Notice to California Residents.
Under California Civil Code Section 1798.83, users of the Services or people who have signed a Subscription Agreement who are also California residents may request certain information about our disclosure of personal information during the prior calendar year to third parties for their direct marketing purposes. You may make such a request by contacting us as indicated in Section 16.
9. Children’s Privacy.
We do not knowingly collect or solicit any information from anyone under the age of 13 on these Services. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at email@example.com
10. Links to Third Party Websites and Services.
The Services may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party sites.
11. User Generated Content.
12. Data Security.
We use commercially reasonable administrative, technical, personnel, procedural and physical security measures intended to protect information about you in our possession against loss, theft and unauthorized use, disclosure or modification. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
13. Records Retention.
Due to our recordkeeping and information retention requirements, we do not delete information about you upon deactivation of your account. Upon your request, your account will be disabled and you will not receive further communications in connection with your account. Except to the extent necessary for legal or regulatory recordkeeping purposes, we may, at some point in time and at our sole discretion, anonymize the data in your member profile after you deactivate your account.
14. Access and Correction.
In some circumstances, you will have access to information that we collect and maintain about you. If you have created a password-protected account to access the Services, you can access that account to update the information you previously provided. If you believe that other information we maintain about you is inaccurate, subject to applicable law, you may request that we correct, amend, or remove the information by contacting us as indicated in Section 16.
16. Contact Us.