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Overview Top

Last revised date: February 9th, 2024.

Your privacy and transparency in how your information may be collected, used and shared is important to Turn5, Inc. With that in mind, our privacy policy is written in a way that is easy to understand and navigate.

Please note that our ordering systems do not currently service residents of the United Kingdom or European Union. As such, we cannot offer residents of the United Kingdom or European Union goods or services, and do not intend to monitor any online behavior by residents of the United Kingdom or Union.

Your continued use of our website is considered acceptance of this policy as well as the practices described within it. Please read this policy closely.

Scope Of Policy Top

This policy discusses information we collect on our own behalf, and for which Turn5 is deemed the business or data controller under applicable law. As a business or controller, we will use personal information about you only for the purposes and in the manner set forth below, which describes the steps we take to ensure the processing of personal data is in compliance with applicable data protection law.

Our collection and use of information includes the transmission of information about you and your visit to our website to third parties who act on our behalf for a variety of purposes, including, but not limited to, participation in advertising networks, for analysis of the use of our website, and to obtain content for our website. To learn more about your choices regarding this type of sharing, please see the section titled “Your Privacy Choices,” below.

Please note that use of information we may collect as a service provider or processor to our business clients is limited by the restrictions placed on that information by those clients and their privacy policies. You can learn more about how your information is collected and used by our clients by reviewing the privacy policies of the businesses you engage with.

What Information Is Collected Top

We collect information provided by you (e.g., your name, telephone number, mailing address) when, for example, registering for an account, creating or modifying your profile, setting preferences, entering contests, signing up for promotions, or making purchases.

Additional information collected indirectly includes, for example: geographic location information to personalize shipping delivery estimates, browser information to determine desktop or mobile view, referral URLs, IP address, website navigation data (by session), and Google and Meta campaign information.

If you are a representative of our B2B clients, we may also collect your name, business address, phone number, email address, and billing address. We gather this in order to grant you access to a private log-in where you can access information relevant to you and your relationship with us. B2B representatives who are residents of California are able to exercise the rights described under “Your Privacy Choices,” below, as to the treatment of this data.

Cookies Top

A cookie is a small data file that is stored by your web browser directly on your computer. Cookies may collect information such as:

  • Details of your visits to our website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the website;
  • Information about your computer and Internet connection, including your IP address, operating system, and browser type.

Cookies are used to identify how a person arrived at our website and to store information about their shopping cart, navigational preferences, product interests and account. Cookies enable you to place an order on our website. They also allow us to collect information to enhance and personalize your online shopping experience, so that the information you receive is more relevant to you, and to measure the success of our marketing efforts. Most Internet browsers allow you to block or delete cookies and other similar technologies from your browser. If you do not agree to the use of these cookies or similar technologies, please disable or delete them by following the instructions for your browser or use automated disabling tools where available. Please note that if you reject cookies, you may still use our products and services, but your ability to use some features of our website may be limited.

We also contract with third-party service providers, including Google Analytics. Google Analytics and similar companies use cookies to help us analyze how you use the website. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google and other service providers in aggregate form.  These service providers may use this aggregated information to evaluate use of the website, compile reports on the website’s activity and other services relating to website activity and usage. You can learn more about Google Analytics and how to opt out here: https://tools.google.com/dlpage/gaoptout

Why Your Info Is Collected And How It Is Used Top

Our goal is to provide you with the highest level of service possible. From your first visit to the delivery of your order, we want you to be completely satisfied with your experience with us. Collecting information allows us to offer you features which saves you time during the order process.

We collect information to enable customers and visitors to quickly navigate our website for products of interest, accurately place orders, and improve your experience on our websites, as well as to understand the way the website visitors use our website, and to market our products to you and potential customers.

How We Share The Information Collected Top

Any and all personal information divulged to Turn5 is used solely with the goal of improving and enhancing your personal shopping experience.

We engage third parties to perform services in connection with the operation of our business. Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customization, order fulfillment and shipping, marketing and promotional material distribution, web site evaluation, data analysis, and where applicable, data cleansing. We provide personal information to these third parties, but they are only authorized to use this information with the services they perform.

Our website makes use of session replay analytics tools to help us reconstruct the user experience on the site. These tools collect data on our behalf. We use them to troubleshoot issues with and improve user experience on our site. The tools provide insight into what works and what doesn’t work for users of the site, and it allows us to, for example, identify and repair technical errors such as broken links that impair the site’s functionality. We may also use the tools to authenticate users, enable site features, prevent fraud, and implement security measures. The tools use cookies and similar technologies to collect and analyze information related to user behavior on our site, such as mouse movements, clicks, user inputs, scrolling, access times, visit duration, pages viewed, IP address (including location), operating system, page reloading, crash data, performance data, and other diagnostic data. The tools also collect name, email address, phone number, and physical address.

We engage a third-party vendor to provide live chat support services on our website. To utilize this chat feature you must provide your name, phone number, and email address. Please note that the contents of your chat session may be recorded and your use of the chat functionality constitutes your consent to such recording by us and the third-party vendor. Cookies are also utilized to enable these chats.

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout

Your Privacy Choices Top

If you have selected to receive our emails by supplying your email address on the website, we will send out exclusive deals and discounts and content you may enjoy. At any time, you can click “unsubscribe” at the bottom of our email to unsubscribe.

If you provide express written consent to receive our promotional and marketing text messages we will send you messages using an automatic telephone dialing system. Consent to receive text messages for these purposes is not a condition of any purchase, service, or sweepstakes entry. Your phone number may have been provided.  If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.

Many of our advertising partners will honor consumers’ requests to opt-out of behavior-based online advertising submitted through the websites of the Network Advertising Initiate (NAI) or the Digital Advertising Alliance (DAA). To learn more about your choices regarding this type of data collection or to opt-out of interest-based advertising by members of the NAI or the DAA, please visit http://optout.networkadvertising.org or https://www.aboutads.info.

If you are a resident of California, Colorado, Connecticut, Montana, Oregon, Texas, Utah or Virginia you have the following additional rights.

  • Request to Know: You have the right to know whether we are processing your personal information and request that we disclose a report of your personal information, including the categories and specific pieces of personal information we have about you, the categories of sources from which the personal information has been obtained, the business or commercial purpose for collecting, selling, or sharing personal information, and the categories of third parties to whom we disclose personal information (as well as which categories of information were disclosed). Any such information should be provided in a format easily understandable to the average consumer, and to the extent technically feasible, in a structured, commonly used, machine-readable format. For additional information and to request your report, you may send an email to [email protected], or you may call us at 1-888-706-1096.
  • Request to Delete: You have the right to request that we delete your personal information. Once we receive and verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. For additional information and to request deletion of your personal information, you may send an email to [email protected], or you may call us at 1-888-706-1096.
  • Request to Correct: You have the right to request that we correct, rectify and/or update any of your personal information that is incorrect, incomplete or out of date. If you have created an online account, you may log on and edit your personal information at any time. If you are unable to edit your personal information through your online account, you may send an email to [email protected], or you may call us at 1-888-706-1096.
  • Request to Opt-out: You have the right to direct us not to sell or share your data for purposes of cross-context behavioral marketing, and the right to opt out of the processing of personal information for purposes of targeted advertising. To exercise your right to opt out, you may send an email to [email protected], or you may call us at 1-888-706-1096.

If exercised, the decision to opt-out will be valid for 12 months, at which time we may request that you authorize the sharing of personal information for marketing purposes again.

  • Statement re the Use or Disclosure of Sensitive Personal Information: Turn5 does not use or disclose sensitive personal information or sensitive data, as such is defined in The Connecticut Act Concerning Personal Data Privacy and Online Monitoring, The Utah Consumer Privacy Act, Colorado Privacy Act, Virginia Consumer Data Protection Act, and the California Privacy Rights Act.
How To Exercise Your Privacy Rights Top

When you contact us to exercise your rights to know, delete, or correct your personal information, we will first verify your identity by asking you to confirm a few pieces of information that we have in our records, such as your email address, phone number, or address. With a request to correct, we may require information from you to demonstrate that our information is incorrect. This information shall only be used and/or maintained by the business for the purpose of correcting your personal information and to comply with any record-keeping obligations we may have under the law.

You may use an authorized agent to exercise your opt out rights described above. For avoidance of doubt, parents may make a verifiable request on behalf of their minor child to exercise any consumer rights described in this policy.

You may make a verifiable consumer request up to two times within a 12-month period, without charge. Unfortunately, we cannot respond to your request to delete or correct or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.

We try to respond to a verifiable consumer request within 45 days of its receipt, and an opt-out request will be processed within 15 business days. If we require more time to respond to a verifiable consumer request, we will inform you of the reason and extension time period (up to 90 days). If you have an account with us, we will deliver our response to the email associated with that account. If you do not have an account with us, we will deliver our response by mail or electronically, at your option. The response we provide will also explain any reasons we cannot comply with a request, if applicable.

You have a right to appeal any denial of a consumer right. If your request is denied in whole or in part, you have the right to appeal your decision within 30 days. We will review and respond to your request within 45 days, and if your appeal is denied, we will provide you with an explanation of our reasons and a description of any further rights you may have at that time.

Right To Equal Service Top

We will not discriminate against you for exercising your rights as a consumer under any applicable laws. Unless permitted by law, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We may offer you certain financial incentives permitted by law that can result in different prices, rates, or quality levels. Any legally-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

For California Residents Only Top

Notice at Collection

The Personal Information we collect about you will depend upon how you use our website and interact with us. The below chart describes the categories of Personal Information, as defined under California law, that we may collect about you when you visit our website or interact with us, the Business Purpose for which the data is collected, and how the information may be shared or sold. This chart also describes the manner in which Personal Information collected and used in the past 12 months. 

Categories of Sources from which the Information was collected Business or Commercial Purpose(s) for which Information is Collected Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose Categories of Third Parties to whom this Type of Personal Information is Sold/Shared

Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address or account name (Cal. Civ. Code. §1798.140(v)(1)

  • Directly from you when you place an order, or provide it to us in connection with a service you request
  • Automatically, when you visit our Sites
  • From third party sources, such as data brokers, or third-party social media platforms.
  • To complete your order or service request, or to communicate with you
  • To provide the Sites and their functionality to you
  • To analyze and understand our customers’ preferences and use of our Sites and services
  • To inform our marketing efforts
  • Service providers who facilitate the provision of a requested service, or support our business purposes described in the previous column

 

  • We may share information with third party marketing services as described in the “How we share the information collected” section above.

Categories of Personal Information as defined in Cal. Civ. Code §1798.80, including name, physical characteristics or description, address, telephone number, driver’s license or state identification card number, education, occupation or field, and gift card information

  • Directly from you
  • From third parties, such as data brokers or social media platforms
  • To complete your order or service request, or to communicate with you
  • To better tailor our product and service offerings and to market them to you
  • Service providers who facilitate the provision of a requested service, or support our business purposes described in the previous column
  • We may share information with third party marketing services as described in the “How we share the information collected” section above.

Characteristics of protected classifications under California Law.  Including race, ethnicity, or national origin, marital status, veteran or military status, and sex (including gender)

  • Directly from you
  • From third parties, such as data brokers or social media platforms
  • To better personalize your experience and our marketing efforts
  • Service providers who facilitate the provision of a requested service, or support our business purposes described in the previous column
  • We do not share this data with third party marketing services

Commercial information, including records of products or services purchased

  • Directly from you, when you make a purchase from us
  • To complete your order
  • To comply with legal obligations
  • To analyze our business, inform inventory and product decisions, and inform marketing efforts
  • Service providers who facilitate the provision of a requested service, or support our business purposes described in the previous column
  • We may share information with third party marketing services as described in the “How we share the information” collected section above.

Internet or other electronic network activity information, including but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement

  • Automatically, when you visit our Sites
  • To provide the Sites and their functionality to you
  • To analyze the use of our Sites and performance of our business and marketing efforts, and to improve the functioning of our Sites and the effectiveness of our marketing
  • Service providers who facilitate the provision of a requested service, or support our business purposes described in the previous column
  • We may share information with third party marketing services as described in the “How we share the information” collected section above.

Inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

  • We may draw these inferences ourselves or acquire them from third party data resellers
  • To help us better personalize your experience, our websites, and our marketing efforts
  • Service providers who facilitate the provision of a requested service, or support our business purposes described in the previous column
  • We may share information with third party marketing services as described in the “How we share the information” collected section above.

Sensitive Personal Information

  • When you place an order, we will collect your payment information
  • To process your order
  • Service providers, such as payment processors
  • We do not use or disclose Sensitive Personal Information for any reasons other than the permissible business purposes set out in Cal. Civ. Code Sec. 1798.140(e) (2), (4), (5), and (8), and as authorized by regulations adopted by the California Privacy Protection Agency
Links To Other Sites Top

On our website, we provide links to other sites that we think you will enjoy. These other sites operate independently of Turn5 and have established their own privacy and security policies. We encourage you to review the privacy and security policies of any sites you visit. Once you leave our website or are redirected to a third-party website or application, you are no longer governed by this policy. We are not responsible for the data collection, use practices, policies or cookie use of the third-party sites that you access from our website.

Privacy Of Children Top

This website is not intended for use by children under the age of 18. No one under age 18 may provide any personal information on the website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this website. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information.

Policy Changes Top

We reserve the right to modify this policy at any time. Any updates we may make to our policy will be posted on this page, and we may also provide a notice of any material changes on our website for a reasonable period of time. Whenever we make updates, we will revise the “last revised” date at the top of this policy. Please check back frequently to see any updates or changes to our policy.

How To Contact Us Top

If you have any questions or feedback regarding this privacy policy, we welcome you to contact us at: [email protected]