Privacy Policy

This Privacy Policy is effective as of August 1, 2008

Turn Inc. ("Turn") provides advertisers and publishers ("Web Partners") access to a set of technologies and processes designed to display advertisements to consumers viewing a publisher's website(s) (the "Turn Ads").

This Privacy Policy describes Turn's privacy practices as they pertain to (i) visitors to our website located at www.turn.com (our "Site"), and (ii) our targeted advertising technology service ("Technology"). If you'd like to understand our privacy practices as they pertain to information collected from and about our Web Partners, please click here.

If you have any questions about this Privacy Policy, please feel free to contact us at privacy@turn.com.

1. Site Privacy Policy

The Site is intended primarily to offer information about Turn and the services we provide.

Information Collected via the Site

We collect Personally Identifiable Information ("PII") from the Site when you choose to provide it to us. PII is any information that can be used to identify or locate a particular person or entity. This includes, but is not limited to: name, postal address, telephone number, or email address. For example, you may choose to send us PII about yourself in an email or by completing an online form on this Site. We use this information only to contact you to respond to your inquiry. Once collected, we will store your PII for a reasonable time for record keeping purposes. The information that we store is usually deleted as space requires or in the normal course of business.

We also collect Non-Personally Identifiable Information (Non-PII) via the Site. Non-PII cannot be used to contact any single person or entity and may include your IP address, pages viewed on this Site, browser type, Internet Service Provider, the time/date of your visit to this Site, and your computer's operating system (e.g., Windows XP). Turn uses this information for internal purposes such as to administer the Site, improve and customize the Site, help Turn understand and analyze how the Site is being used and to track aggregate Site usage.

Cookies and Web Beacons

We use "cookies" and web beacons to help us manage this Site. Cookies are small text files that contain a string of alphanumeric characters. We also use persistent cookies on this Site in order to help us manage the opt-out process for our Technology. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser's "help" file. Web beacons (also known as "1X1 pixels" or "clear GIFs") are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data. For more information about cookies and web beacons please visit http://www.allaboutcookies.org/cookies/.

Third Party Websites

The Site may contain links to other websites. Such websites may use cookies and/or other data collection tools. Turn is not responsible for the privacy practices, policies or content of such other websites. Turn encourages everyone to read the posted privacy policies whenever interacting with any website to learn more about the privacy practices of that website. Turn has no control over the use of information by third party websites, and you should exercise caution when deciding to disclose any PII to those websites.

Updating / Deleting your PII

If you'd like us to update, correct, delete, or deactivate any PII that you have provided to us on this Site, please send your request to us at privacy@turn.com and we will process your request within a reasonable period of time after receipt.

2. �Technology Privacy Policy

Overview of Turn's Technology

Our Technology collects information about the website(s) that you visit and the advertisements that you see while online. You may encounter our Technology: when Turn or one of our Web Partners purchase online advertisements on a website that you visit; and/or when one of our Web Partners places one of our web beacons on its website, which you visit.

We use the information collected by our Technology in order to help make the Turn Ads you see more relevant to you, and for ad delivery and reporting purposes.

What information is collected?

Turn does not collect PII via our Technology. Our Technology does collect and use Non-PII, including: the IP address used to access the Internet, the type of browser used, which and how many Web Partner web pages have been viewed, search terms entered on Web Partner websites, referring/exit pages, and the date and time a Turn Ad was viewed.

Turn uses this information to analyze trends, identify the audience most likely to respond to an advertisement and to tailor advertisement placement for our Web Partners accordingly. We also may aggregate this information and share it with Turn's affiliates, advertisers, employees, customers and Web Partners.

Cookies and Web Beacons

Turn uses cookies and web beacons in connection with our Technology. Cookies help Turn better understand the effectiveness of a Turn Ad (for example, by tracking the way in which you may respond to, selectand interact with a Turn Ad or any content provided therein, or the location and context in which you view a Turn Ad). Turn's cookies also help control the number of times you view a Turn Ad. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to enjoy the full functionality of many of the websites you visit.

Turn also uses web beacons, in combination with cookies, to analyze usage patterns. The use of a web beacon allows Turn to record that someone has visited a particular webpage, along with additional Non-PII that the website may choose to include with the beacon.

Third Party Links and Websites

Turn Ads may contain links to other websites, including those of our Web Partners. Such websites may use cookies and/or other data collection tools. Turn is not responsible for the privacy practices, policies or the content of such websites. Turn encourages everyone to read the posted privacy policies whenever interacting with any website to learn more about the privacy practices of that website. Turn has no control over the use of anyinformation by third party websites, and you should exercise caution when deciding to disclose any PII. Similarly, Turn does not have access to, or control of, the cookies and/or other data collection tools that may be placed on any advertisement by a third-party, including those of our Web Partners, and this Privacy Policy does not cover the use of cookies and/or other data collection tools by any third party.

Storage of Non-PII

We retain the Non-PII collected via our Technology for up to 90days in order to ensure that our Technology is functioning properly. After 90 days, we render this information anonymous and store it for up to three years.

Controlling the use of your information

Opting out from Cookies

If you'd like to opt-out from having Turn collect your Non-PII in connection with our Technology, please click here. When you opt out, we will place an opt-out cookie on your computer. The opt-out cookie tells us not to collect your Non-PII to tailor Turn Ads to your interests. Please note that if you delete, block or otherwise restrict cookies, or if you use a different computer or Internet browser, you may need to renew your opt-out choice.

Deleting your PII

Although we don't collect PII via our Technology, if you'd like us to update, correct, delete or deactivate any PII that you have provided to us on the Website, please send your request to us at privacy@turn.com and we will process your request within a reasonable period of time after receipt.

3. General:

Information Security

The security of your information is important to us. We have implemented reasonable security measures to protect the information in our care, both during transmission and once we receive it. This includes, but is not limited to the use of encryption. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

If you have any questions about our security practices, please send an email to us at privacy@turn.com.

Information Relating to Children

Our products and services are designed for those 18 years of age and older. We do not knowingly collect PII from anyone under the age of 18. If we are made aware that we have received PII from someone under 18, we will use reasonable efforts to remove that information from our records.

Disclosure of Information to Third Parties

We do not collect PII via our Technology, and we do not sell, rent or share PII collected on the Website with non-affiliated third parties without your consent. We may, however, share your PII with trusted third party contractors who provide services for us. These third party contractors are prohibited from using the information we provide for purposes other than performing services for us.

We may share Non-PII collected via our Technology with Web Partners. Similarly, we may enhance the Non-PII collected via our Technology with Non-PII collected from Web Partners. This information cannot be used to contact or identify any person individually.

We may disclose your information to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person.

Finally, we may transfer information, including any PII collected via the Site, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.

Changes to this Privacy Policy

This privacy policy is subject to change. If we make any material or substantive changes in the way that we use the PII collected through this Website, we will post a clear and conspicuous notice of those changes on the Website and in this privacy policy.

Contact Information

For questions or concerns relating to privacy, please send us an email at privacy@turn.com. Alternatively, you may contact us at: Privacy Officer, Turn Inc., 1600 Seaport Boulevard, Suite 300, Redwood City, CA 94063.