PRIVACY POLICY FOR TURN APP

1. Who We Are
1.1 Turn App Services

Welcome to Turn App! We are a platform dedicated to bringing people together

through events and experiences. Through our platform, mobile apps, and services,
we enable people all over the world to create, discover, share, and register for
events.

Turn App’s products, features, and offerings are available:

 Online through our website at https://turnapp.net and any other Turn App
properties (collectively, "Sites");

 Off-platform, including without limitation, entry management, sponsorship,

and marketing or distribution services;

 Through mobile applications, webpages, application programming interfaces,

and subdomains ("Applications").

Collectively, (a), (b), and (c) are referred to as "Turn App Properties" or our
"Services."
1.2 Who's Who

When this Privacy Policy uses the term "Organizer" we mean event creators using
the Services to create events for consumers using our Services (a) to consume
information about, or attend, events ("Consumers"), or (b) for any other reason.
Organizers, Consumers, and third parties using our Services are all referred to
collectively as "Users," "you," or "your."

Turn App, Inc. is a [Insert Jurisdiction] corporation with its principal place of
business at [Insert Address] ("Turn App," "us," "we," or "our"). If you have any
questions or concerns at any time, please do not hesitate to contact us at the address
above or by contacting us at [email protected].
2. Our Privacy Statement
2.1 Application

This Privacy Policy sets forth our policy with respect to information that can be
associated with or which relates to a person and/or could be used to identify a
person ("Personal Data") that is collected from Users on or through the Services. We
take the privacy of your Personal Data seriously. Please read this Privacy Policy as it
includes important information regarding your Personal Data and other
information.

"Non-Personal Data" as used in this Privacy Policy is any information that does not
relate to a person and/or cannot be used to identify a person. When you interact
with the Services, we may collect Non-Personal Data. The limitations and
requirements in this Privacy Policy on our collection, use, disclosure, transfer, and
storage/retention of Personal Data do not apply to Non-Personal Data.
3. Personal Data That We Collect

When you use or interact with us through the Services, we may collect Personal
Data. This will sometimes be on our behalf and other times on behalf of an
Organizer using our Services to run an event.
3.1 Information Collected From All Users

 Information You Provide to Us: For all Users, we collect Personal Data when
you voluntarily provide such information to the Services, such as when you
register for access to the Services, contact us with inquiries, respond to one of
our surveys, register for or purchase tickets to an event, or browse or use
certain parts of the Services. The Personal Data we may collect includes
without limitation your name, address, email address, content you have
signaled you are interested in, and any other information that you choose to
provide and/or that enables Users to be personally identified.

 Information We Automatically Collect: We also automatically collect certain

technical data that is sent to us from the computer, mobile device, and/or
browser through which you access the Services ("Automatic Data").
Automatic Data includes without limitation, a unique identifier associated
with your access device and/or browser (including, for example, your IP
address), characteristics about your access device and/or browser, statistics
on your activities on the Services, information about how you came to the
Services, and data collected through Cookies, Pixel Tags, Local Shared
Objects, Web Storage, and other similar technologies.
3.2 Information Collected From Organizers

 Information You Provide to Us: If you are an Organizer, we will collect

additional Personal Data from you, including credit card information to
secure certain payments, financial information for payment processing, and
information required for tax purposes.
3.3 Information Collected From Consumers

 Information You Provide to Us: If you are a Consumer, we will collect

additional Personal Data from you when you register for a paid event or
provide information in connection with an Organizer’s event. This may
include financial information such as your credit card number and billing
address.
4. How We Use Your Personal Data
We collect and use Personal Data in a manner that is consistent with this Privacy
Policy and applicable privacy laws. We may use Personal Data as follows:
4.1 Specific Reason

If you provide Personal Data for a certain purpose, we may use the Personal Data in
connection with the purpose for which it was provided. For instance, if you contact
us by email, we will use the Personal Data you provide to answer your question or
resolve your problem.
4.2 Access and Use

If you provide Personal Data to obtain access to or use of the Services or any
functionality thereof, we will use your Personal Data to provide you with access to
or use of the Services or functionality and to analyze your use of such Services or
functionality.
4.3 Internal Business Purposes

We may use your Personal Data for internal business purposes, including without
limitation, to help us improve the content and functionality of the Services, to better
understand our Users, to improve the Services, to protect against, identify, or
address wrongdoing, to enforce our Terms of Service, and to generally manage the
Services and our business.
4.4 Marketing and Advertising

We may use your Personal Data for our marketing and advertising purposes,
including by email, SMS marketing, and display media, to inform you about services
or events we believe might be of interest to you, develop promotional materials, and
display content and advertising that we believe might be of interest to you.
5. How We Disclose and Transfer Your Personal Data
5.1 Business Transfers

In the event of a corporate sale, merger, reorganization, dissolution, or similar event,

Personal Data may be part of the transferred assets. We may also disclose your
Personal Data in the course of due diligence for such an event.
5.2 Parent Companies, Subsidiaries, and Affiliates

We may share your Personal Data with our parent companies, subsidiaries, and/or
affiliates for purposes consistent with this Privacy Policy.
5.3 Agents, Consultants, and Service Providers

We may share your Personal Data with contractors and service providers who
process Personal Data on behalf of Turn App to perform certain business-related
functions.
5.4 Organizers

When you register for an event or provide information to Turn App in conjunction
with an Organizer event, that Organizer will receive the information you provide.
Organizers may use this information for their own marketing or other purposes.
6. How We Store Your Personal Data
6.1 Data Security Measures

We take reasonable steps to protect the Personal Data collected via the Services from
loss, misuse, unauthorized use, access, inadvertent disclosure, alteration, and
destruction. These steps include implementing physical, technical, and
administrative security measures. Some of the specific measures we take include:

 Encryption: We use industry-standard encryption technologies to secure your

personal data both in transit and at rest. This means that data transmitted
between your device and our servers, as well as data stored on our servers, is
encrypted to prevent unauthorized access.

 Access Controls: We implement strict access controls to ensure that only

authorized personnel have access to personal data. Access to personal data is
granted on a need-to-know basis and is subject to regular reviews.

 Firewalls and Intrusion Detection Systems: Our network is protected by

firewalls and intrusion detection systems that monitor and block
unauthorized access attempts.

 Regular Security Audits: We conduct regular security audits and assessments

to identify and address potential vulnerabilities in our systems. This includes
vulnerability scanning, penetration testing, and code reviews.

 Data Anonymization and Minimization: Where possible, we anonymize and

minimize the personal data we collect and store. This reduces the risk
associated with data breaches and unauthorized access.
6.2 Data Storage Locations

Your personal data may be stored on servers located in various jurisdictions,

including the United States and other countries. We ensure that data stored in these
locations is subject to appropriate safeguards and protection measures, regardless of
where it is stored.
6.3 Retention of Personal Data

We retain your personal data for as long as necessary to fulfill the purposes outlined
in this Privacy Policy, unless a longer retention period is required or permitted by
law. After this period, your data will be deleted or anonymized. Specifically:
  Account Information: We retain your account information for as long as your
account is active and for a reasonable period thereafter in case you decide to
re-activate the Services. We also retain some information to comply with our
legal obligations, resolve disputes, enforce our agreements, support business
operations, and continue to develop and improve our Services.

 Transaction Data: We retain transaction data related to purchases, ticketing,

and other financial transactions for audit, tax, and compliance purposes.

 Communications: We may retain communications with you (including emails

and chat logs) for a period necessary to address your requests, provide
customer service, and for training and quality assurance purposes.
6.4 Data Breach Response

In the event of a data breach that compromises your personal data, we have a data
breach response plan in place. This plan includes:

 Immediate Containment and Investigation: We will take immediate steps to

contain the breach and conduct a thorough investigation to determine the
scope and impact of the breach.

 Notification: If your personal data has been compromised, we will notify you
as soon as possible, in accordance with applicable laws and regulations. This
notification will include details about the breach, the data affected, and steps
we are taking to address the breach and prevent future incidents.

 Remediation: We will take all necessary steps to mitigate the impact of the
breach and prevent future occurrences, including enhancing our security
measures and processes.
6.5 User Responsibilities

While we take significant measures to protect your personal data, it is also important
for you to take steps to protect your data. This includes:

 Choosing a Strong Password: Ensure that you use a strong and unique
password for your Turn App account and change it regularly.

 Protecting Your Account Credentials: Do not share your account credentials

with others, and be cautious of phishing attempts or other forms of social
engineering.

 Keeping Software Updated: Ensure that your devices and software,

including your browser and operating system, are kept up-to-date with the
latest security patches and updates.

By implementing these measures, both Turn App and its users can work together to
ensure the highest level of data protection and security. However, it is important to
acknowledge that no method of transmission over the Internet or method of
electronic storage is completely secure. Therefore, while we strive to use
commercially acceptable means to protect your personal data, we cannot guarantee
its absolute security.
7. How You Can Access, Update, Correct, or Delete Your Personal Data

You can access, delete, or correct your Personal Data by contacting us at

[email protected]. We will consider and respond to all requests in accordance
with applicable laws.
7.1 Accessing Your Personal Data

You have the right to request access to the personal data we hold about you. This
includes details about the types of personal data we have collected, the purposes for
which we use it, and with whom it may be shared.

To request access to your personal data, you can:

 Email Us: Send an email to [email protected] with the subject line "Access
Request" and include your name, email address, and a description of the data
you wish to access.

 Online Account: If you have an account with Turn App, you may be able to
access certain personal data directly through your account settings.

We will respond to your request within a reasonable timeframe, typically within 30

days, and provide you with a copy of your personal data, unless an exception
applies under applicable law.
7.2 Updating and Correcting Your Personal Data

It is important that your personal data is accurate and up-to-date. If you believe that
any of the information we hold about you is incorrect or incomplete, you have the
right to request that we update or correct it.

To update or correct your personal data, you can:

 Email Us: Send an email to [email protected] with the subject line

"Update/Correction Request" and include your name, email address, and the
details of the information that needs to be updated or corrected.

 Online Account: If you have an account with Turn App, you may be able to
update or correct certain personal data directly through your account settings.

We will respond to your request within a reasonable timeframe and make the
necessary updates or corrections.
7.3 Deleting Your Personal Data
You have the right to request the deletion of your personal data under certain
circumstances, such as when the data is no longer necessary for the purposes for
which it was collected or when you withdraw your consent.

To request the deletion of your personal data, you can:

 Email Us: Send an email to [email protected] with the subject line

"Deletion Request" and include your name, email address, and a description
of the data you wish to be deleted.

 Online Account: If you have an account with Turn App, you may be able to
delete certain personal data directly through your account settings.

We will respond to your request within a reasonable timeframe, typically within 30

days. Please note that we may retain certain data as required by law or for legitimate
business purposes (e.g., to comply with legal obligations, resolve disputes, or enforce
our agreements).
7.4 Verifying Your Identity

To protect your privacy and ensure that your personal data is not disclosed to
unauthorized parties, we may ask you to verify your identity before processing your
request. This may involve providing additional information or documentation to
confirm your identity.
7.5 Authorized Agents

If you would like to designate an authorized agent to exercise your rights on your
behalf, please email us from the email address we have on file for you. In your email,
please include the name and email address of your authorized agent. We will
require verification of both your identity and the identity of your authorized agent
before processing the request.
7.6 Response Time and Process

We strive to respond to all requests promptly and within the timeframes required by
applicable laws. Typically, we will respond within 30 days of receiving your request.
If we need more time to process your request, we will notify you of the reason for
the delay and the extended timeframe.
7.7 Exceptions and Limitations

There may be circumstances where we are not able to fulfill your request, such as
when we are legally required to retain certain data or when fulfilling the request
would interfere with our legal obligations or legitimate business interests. In such
cases, we will inform you of the reason for the denial and any available options.
8. How Long We Retain Your Personal Data
8.1 Retention Period
At Turn App, we take the privacy and security of your personal data seriously. We
retain your Personal Data for a duration that is deemed necessary to fulfill our
obligations to you as a user of our Services. This includes providing you with the
services you've subscribed to and ensuring compliance with legal requirements,
resolving disputes, and enforcing agreements.
8.2 Purposes for Retention

We retain your Personal Data for the following important purposes:

 Service Provision: Your personal data is retained for as long as it is necessary

to provide you with our Services. This ensures that we can continue
delivering the functionalities and features you rely on to create, discover, and
participate in events through our platform.

 Legal Compliance: We retain personal data to comply with applicable laws,

regulations, and legal obligations. This includes data retention requirements
stipulated by regulatory authorities or governmental agencies.
 Dispute Resolution: In the event of disputes or conflicts, retaining personal
data is essential for investigation, evidence, or resolution purposes. This
enables us to address any issues that may arise during your interactions with
our platform effectively.

 Enforcement of Agreements: Personal data may be retained to enforce

agreements or contracts between Turn App and its users. This ensures that
both parties adhere to the terms and conditions outlined in our agreements.
8.3 Review of Retention Period

We periodically review the retention period for personal data to ensure that it is kept
only for as long as necessary for the purposes outlined above. Once the data is no
longer required for these purposes, we take steps to securely dispose of or
anonymize it to protect your privacy and data security.
8.4 User Rights

As a user of Turn App, you have the right to access, update, correct, or delete your
personal data in accordance with our policies and applicable laws. For more
information on how you can exercise these rights, please refer to Section 7 of our
Privacy Policy.
9. Cookies and Similar Technologies
9.1 Introduction

At Turn App, we utilize cookies and similar tracking technologies on our website
and within the services we offer. These technologies play a crucial role in enhancing
user experience, providing personalized content, and improving the functionality of
our platform. This section of our privacy policy aims to provide you with detailed
information about the use of cookies and similar technologies.
9.2 Purpose of Cookies

Cookies are small text files that are stored on your device (such as a computer or
mobile device) when you visit our website or use our services. These cookies serve
several purposes, including:

 Authentication: Cookies help authenticate users and ensure secure access to

specific areas or features of our platform.

 Session Management: Cookies assist in managing user sessions, allowing us

to remember your preferences and settings as you navigate through different
pages or sections.

 Personalization: Cookies enable us to personalize content and advertisements

based on your preferences, browsing history, and interactions with our
platform.

 Analytics: Cookies facilitate the collection of anonymous usage data, which is

valuable for analyzing platform performance, identifying trends, and making
improvements to enhance user experience.
9.3 Types of Cookies

Turn App may utilize various types of cookies, including:

 Essential Cookies: These cookies are necessary for the functioning of our
platform and cannot be disabled. They include cookies related to
authentication, session management, and security.
 Functional Cookies: These cookies enhance the usability and performance of
our platform by remembering your preferences, such as language settings or
font size.

 Analytical Cookies: These cookies collect anonymous data about your

interactions with our platform, such as pages visited, time spent on each page,
and click-through rates. This data is used for analytics purposes to improve
our platform's functionality and user experience.

 Advertising Cookies: These cookies are used to deliver targeted

advertisements based on your interests and behavior across different websites
and online platforms.
9.4 Cookie Policy

For more detailed information about how we use cookies and similar technologies,
the types of cookies we use, and how you can manage or disable cookies, please
refer to our Cookie Policy. Our Cookie Policy outlines your options for controlling
cookie settings and provides guidance on managing cookies through your browser
settings.
10. Your Choices
10.1 Introduction

At Turn App, we believe in empowering our users to make informed decisions

about their personal data. You have several choices available when it comes to the
collection, use, and management of your Personal Data. This section of our privacy
policy outlines these choices and how you can exercise them.
10.2 Limit the Personal Data You Provide

You have the option to limit the Personal Data you provide to Turn App. While
certain features and functionalities of our platform may require the provision of
specific information, you can choose to browse the Services without providing any
Personal Data beyond what is necessary for basic functionality.
10.3 Opt Out from Electronic Communications

You have the right to opt out of receiving electronic communications, including
marketing communications, from Turn App. If you no longer wish to receive such
communications, you can opt out by following the unsubscribe instructions
provided in the messages you receive or by contacting us directly. We respect your
preferences and will promptly honor your request to opt out of electronic
communications.
10.4 Do Not Track

Turn App currently does not respond to "Do Not Track" signals from web browsers.
While some web browsers may offer a "Do Not Track" option that allows users to
express their preferences regarding online tracking, our platform does not currently
recognize or respond to these signals. However, we are committed to monitoring
developments in this area and may update our practices in the future to align with
evolving standards and regulations.
10.5 Review and Update of Choices

We encourage you to review and update your choices regarding the collection and
use of your Personal Data regularly. By accessing your account settings or contacting
us directly, you can modify your preferences and choices to ensure they reflect your
current preferences and requirements.
10.6 Contact Us

If you have any questions, concerns, or requests regarding your choices related to
your Personal Data, please don't hesitate to contact us. Our dedicated privacy team
is available to assist you and address any inquiries or requests you may have.
11. Exclusions
11.1 Personal Data Provided to Others
11.1.1 Introduction

This section of our privacy policy addresses the handling of Personal Data provided
to others through our Services. It is important to note that this Privacy Policy applies
specifically to the collection, use, and disclosure of Personal Data by Turn App.
However, there are certain exclusions regarding Personal Data that you provide to
other users or visitors through our platform.
11.1.2 Personal Data Shared with Users or Visitors

This Privacy Policy does not apply to any Personal Data that you voluntarily
provide to another user or visitor through our Services or through any other means,
including interactions with Organizers on event pages. When you share Personal
Data with other users or visitors, such as through messaging features or public
forums, you do so at your own discretion and risk. Turn App is not responsible for
the privacy practices or policies of other users or visitors, and we encourage you to
exercise caution and discretion when sharing Personal Data with others.
11.2 Third-Party Links
11.2.1 Introduction

Turn App may contain links to third-party websites or services that are not operated
or controlled by us. While we strive to provide a safe and secure environment for
our users, it is important to recognize that third-party sites have their own privacy
policies and practices that may differ from ours.
11.2.2 Policies and Procedures

The policies and procedures described in this Privacy Policy apply solely to Turn
App and the services provided by us. They do not extend to third-party websites or
services linked from our platform. We advise you to review the privacy policies and
terms of use of any third-party sites you visit, as Turn App is not responsible for the
privacy practices or content of these sites.
11.2.3 Contacting Third-Party Sites

If you have any questions or concerns about the privacy practices of third-party sites
linked from Turn App, we recommend contacting those sites directly for
information. Turn App is unable to control or influence the privacy policies and
practices of third-party sites, and we cannot accept responsibility for any
information you provide to or actions you take on those sites.
12. Changes to This Privacy Policy
At Turn App, we recognize the importance of keeping you informed about how we
handle your Personal Data. As part of our commitment to transparency and
compliance with evolving privacy standards and regulations, we reserve the right to
update or modify this Privacy Policy at any time. Here’s how we manage changes to
our Privacy Policy:
12.1 Right to Modify

We may update or modify this Privacy Policy to reflect changes in our practices,
technologies, legal requirements, or other factors. These changes could include
adjustments to how we collect, use, disclose, store, and protect your Personal Data.
We make these updates to ensure that our Privacy Policy remains relevant and up-
to-date with industry standards and regulatory requirements.
12.2 Notification of Changes

When we make changes to this Privacy Policy, we will post the updated policy on
our Site. The "Updated" date at the top of this Privacy Policy will be revised to
indicate the date of the most recent changes. This allows you to quickly identify
when the Privacy Policy was last modified and what changes have been made.
12.3 Continued Use of Services

By continuing to use our Services after any changes to this Privacy Policy are posted,
you acknowledge and agree to the updated terms. It is your responsibility to review
the Privacy Policy periodically to stay informed about how we are protecting your
Personal Data. If you do not agree with any changes to the Privacy Policy, you
should discontinue your use of the Services.
12.4 Material Changes

In the event of material changes to this Privacy Policy, we will provide additional
notice to you, such as via email or a prominent notice on our Site, before the changes
take effect. Material changes may include, but are not limited to, significant
alterations in how we handle your Personal Data, changes in data sharing practices,
or updates required to comply with new legal obligations.
12.5 Your Feedback and Inquiries

We welcome your feedback and inquiries regarding any changes to our Privacy
Policy. If you have questions or concerns about the modifications or how they may
impact you, please do not hesitate to contact us at [email protected]. Our team is
here to assist you and ensure that you feel confident and informed about how your
Personal Data is managed.

By staying informed and engaged with updates to our Privacy Policy, you can help
us maintain a transparent and trustworthy relationship while using Turn App's
Services.
13. Dispute Resolution

At Turn App, we prioritize your privacy and strive to address any concerns you may
have regarding the handling of your Personal Data. We are committed to resolving
disputes promptly and transparently. Here’s how we manage dispute resolution:
13.1 Resolution Process

If you have any concerns or complaints about our handling of your Personal Data,
please contact us directly at [email protected]. We will review your request and
respond as quickly as possible, aiming to resolve any issues to your satisfaction.
13.2 Escalation to Data Protection Authorities

If you are not satisfied with our response or resolution to your request, you have the
right to escalate the matter to your local data protection authority. Each jurisdiction
has a data protection authority that oversees and enforces privacy regulations. You
can contact them for further assistance and to file a formal complaint.
13.3 Commitment to Collaboration

We are committed to working with you and the relevant authorities to resolve any
concerns about our handling of your Personal Data. Our goal is to ensure that your
privacy rights are upheld, and we will cooperate fully with data protection
authorities in their investigations and resolutions.
13.4 Your Rights

By empowering you to access, update, correct, and delete your Personal Data, we
aim to provide you with transparency and control over your information. We believe
that your active participation in managing your Personal Data is essential to
maintaining your privacy and trust in Turn App.
13.5 Contact Information

If you have any questions, concerns, or need assistance with your Personal Data,
please do not hesitate to contact us at [email protected]. Our dedicated privacy
team is here to help you and ensure that your experience with Turn App is secure
and satisfactory.
13.6 Our Commitment

We are dedicated to protecting your privacy and ensuring that any disputes are
resolved fairly and efficiently. By maintaining open lines of communication and
adhering to privacy best practices, we aim to foster a trustworthy relationship with
you as a valued user of Turn App.

By using Turn App, you acknowledge that you have read, understood, and agreed
to this Privacy Policy.
Effective Date: June 12, 2024