TuringSense Privacy Policy

This TuringSense Privacy Policy (“Privacy Policy”) describes TuringSense Inc.’s, its affiliates’, and subsidiaries’ (collectively “TuringSense”) practices regarding the collection, use, storage, sharing, and safeguarding of your information collected from any TuringSense-operated website, mobile application, product or service (collectively, the “Service”).

Changes to this Privacy Policy

TuringSense may make changes to this Privacy Policy. The most current version of the Privacy Policy will govern TuringSense’s use of information about you and will be located at www.turingsense.com/policies/privacy.

If TuringSense makes material changes to this Privacy Policy and if you have an account with us, TuringSense will notify you by posting a notice on the Service and sending an email to the address TuringSense has on file for your account. Please ensure this address remains current so you will receive updates.

Categories of Personally Identifiable Information that TuringSense Collects

TuringSense may collect information that you provide to TuringSense in connection with your use of the Service when you:  (A) register your account with TuringSense as a user of the Service (“Customers”); (B) make changes to your user profile information; (C) send email messages, forms, or other information to TuringSense or other users using the Service; (D) install, use or otherwise interact with the Service. This information may include your first and last name, address, email address, telephone number, profile photo, and any additional information you provide to TuringSense during the account registration process or via the Service.

When you use our products, you will be interacting with our fitness tracking sensors.  These sensors will transmit information to your mobile device via our mobile application and will collect information about your physical movements and the positioning of your body.  The Service may use this information to derive additional information, such as the type and frequency of activities that you may be performing while using the Service.

TuringSense may also collect certain technical information about your use of the Service. This technical information may include information about your device(s), browser type and version, geo-location, computer, computer connection, statistics on page views, traffic to and from the Service, Wi-Fi connection, internet protocol (“IP”) address, and standard web log.

Since TuringSense offers products and services related to your physical performance, we require certain information from you in order for you to use the Service.  When you register to use the Service, we require you to provide us with your contact e-mail and your height (“Required Information”).  You must provide this information in order to access and use the Service.  If you do not wish to provide this information, please do not access or use the Service.

In order to facilitate our analysis of your physical performance, you may, but are not required to, provide us information about yourself that will help you enjoy the Service (“Optional Information”).  This information includes your weight, gender, and age.  Although you will not need to provide this information to us in order to access and use the Service, providing us this information will improve your experience with the Service.

Although we use third party service providers to process payments, when purchasing access to the Service, we may require you to provide our payment processing service providers with financial and billing information, such as billing name and address and your credit card number (“Financial Information”). We use Payment Card Industry (“PCI”)-certified third-party payment services and do not store your credit card information on our servers.  For more information, please refer to the section in this Privacy Policy entitled “Categories of Third-Party Persons or Entities With Whom TuringSense May Share Your Personally Identifiable Information.”  Required Contact Information, Financial Information, and Optional Information about Customers are referred to collectively as “Customer Data.”

How TuringSense Collects Your Information; Tracking and Cookies

When you register for an account with TuringSense, we may ask you to provide us with certain information in order to create your account, and to provide you with our services. This information is collected by us when you fill out forms that may be provided to you through the Service.

TuringSense, and third parties we interact with, including our third-party service providers, may use cookies, web beacons, locally shared objects (sometimes called “flash cookies”), and similar technologies in connection with your use of the Service to provide and support the Service (collectively referred to in this policy as “Cookies“). Cookies are small data files that may have unique identifiers, and reside, among other places, on your mobile device, in emails we send to you, and on our applications. Locally shared objects, or “flash cookies,” are data files that can be created on your computer by the websites you visit and are a way for websites to store information for later use. Locally stored objects are different than cookies because they are stored in different parts of your computer than cookies. Web beacons 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.

If Cookies are used, they may be used to collect information about you and your use of the Service, such as your browser type, preferences, data relating to content that has been displayed to you or that you have clicked on, and the date and time of your use. Cookies may also be used in order to further features and processes on the Service, provide authentication and security for your transactions using the Service, store your preferences, facilitate relevant advertising, and help us learn more about how users engage with the Service.

We sometimes use service providers to help us provide certain products and services or to integrate other features. These third-party service providers may collect information when you view or use them, including information about you and your device or browser and about your online activities over time and across different websites. They may do this using Cookies or similar technologies. These third-party service providers also may use Cookies or similar technologies to help share information with us, like how you use their website or application. To learn more about the information they collect or receive, review their privacy policies.

How TuringSense Uses Your Personally Identifiable Information

TuringSense may use information that TuringSense collects about you to: (A) provide access to the Service and to communicate with you; (B) personalize, customize, measure, and improve TuringSense’s services, content, and advertising; (C) prevent, detect, and investigate potentially prohibited or illegal activities or a breach of the applicable agreement(s) between you and TuringSense; (D) analyze the accuracy, effectiveness, usability, or popularity of the Service; (E) generate and review reports and data about TuringSense’s user base and service usage patterns; (F) compile aggregate data for internal and external business purposes; and (G) resolve disputes and troubleshoot problems.

Correcting and Updating your Information

Customers may update or change their account information through their account settings page. Access to your account will require your Service username and password. To update your Financial Information or to delete your account information, please visit your account settings page or email us at support@turingsense.com.  Requests to access, change or delete your information will be addressed within 30 days.

Submitted Data

As part of using our Service, Customers may submit electronic data or information to the Service (“Submitted Data”) that constitutes personal information of other individuals to us. Submitted Data may include an individual’s name, email address, phone number or any other data that the Customer chooses to submit to us. TuringSense generally has no direct relationship with the individuals to whom Submitted Data may pertain.  TuringSense processes Submitted Data on behalf of our Customers and any uses of Customer Data by TuringSense are done pursuant to our Terms of Service or a separate agreement in place between TuringSense and the applicable Customer, which exclusively governs our treatment of Submitted Data and supersedes this Privacy Policy in case of conflict, or as required by law. If your individual personal information has been submitted to us by a Customer as Submitted Data and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with the Customer (or his/her organization) directly.

Categories of Third-Party Persons or Entities With Whom TuringSense May Share Your Personally Identifiable Information

TuringSense may disclose the information we collect from you to the following third parties:

Users of the Service; Public Information.  When you share information via the Service, TuringSense may share your information to fellow users of the Service, in accordance with the privacy settings you have chosen for your account or that are applicable to that information. To the extent you share any information to a public audience or via a publically accessible portion of the Service, that information will be available to anyone.

Credit Card Processing Services.  When you make a payment to TuringSense through our payment page, we may collect credit card information from you in order to properly process your payment. We do not store your credit card information on our servers and no one at TuringSense can access your credit card information. All credit card information that you share with us is maintained by our payment processing merchant. We use industry standard encryption techniques and methods to protect all information sent to our payment processor’s servers. Once your information reaches our payment processor, it resides on the payment processor’s server that is protected administratively, physically and electronically.

Third Party Integration.  When you use third-party products or services that integrate with the Service, we may share information about you with the owners or developers of those third-party products or services.

TuringSense’s Service Providers.  TuringSense may share your information with third-party contractors, agents, collaborators, or service providers who provide certain services to TuringSense or on TuringSense’s behalf, such as operating and supporting the Service.

Companies that Acquire TuringSense’s Business or Assets.  If TuringSense becomes involved in a merger, acquisition, sale of assets, securities offering, bankruptcy, reorganization, or dissolution or if the ownership of all or substantially all of TuringSense’s business relating to the Service otherwise changes, TuringSense may provide your information to a third party or parties in connection with the applicable transaction.

TuringSense’s Affiliates.  TuringSense may share some or all of your information with TuringSense’s parent company, subsidiaries and corporate affiliates, joint venturers or other companies under common control with TuringSense.

Aggregate Information.  TuringSense may share information relating to visitors and users of the Service with affiliated or unaffiliated third parties on an aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this information with other data they have about you, or that they receive from third parties, in a manner that allows them to associate this aggregated data with your personal data.

Legal Requirements.  TuringSense may share your information with law enforcement, governmental agencies, or authorized third parties, in response to a request relating to a criminal investigation or alleged illegal activity or any other activity that may expose TuringSense, you, or any other TuringSense user to legal liability, or to protect TuringSense’s rights or property, or during emergencies when public safety is at risk. TuringSense may also share your information in response to court orders, subpoenas, or other legal or regulatory requests, and may provide TuringSense’s legal counsel and other consultants access to your information in connection with actual or potential litigation.

DMCA Notices. TuringSense may share your information with third parties when we forward Digital Millennium Copyright Act (DCMA) notifications, which will be forwarded as submitted to us without any deletions.

Your information may also be disclosed to third parties in unforeseeable situations or situations that are not preventable even when commercially reasonably protections are employed, such as in the case that TuringSense or the Service is subject to a hacking or other attack.

Do Not Track

You may be able to adjust your browser settings or other settings so that “do not track” requests are sent to the Service’s websites and mobile applications. TuringSense does not use any tracking technology that would respond to any “do not track” requests that are sent to our services. TuringSense does not collect personally identifiable information about your online activities over time and across different websites when you use the Service; however, certain service providers that use Cookies may collect your personally identifiable information over time and across different websites.  For more information about how these third parties collect this personally identifiable information, please see the section entitled “How TuringSense Collects Your Information; Tracking and Cookies.”

Links

TuringSense’s website or mobile application may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  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 these policies. Please check these policies before you submit any personal data to these websites.

Security

TuringSense takes reasonable measures to protect the information you provide to TuringSense or submit through the Service against misuse, loss, theft, unauthorized use, disclosure, or modification. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Accessing, Changing and Managing Your Information.

Changing or Updating Your Information.  You can access or change your personal profile and contact information or delete your account through your TuringSense personal settings page. If you choose to delete or deactivate your account, you can no longer retrieve your content or reactivate your account.

Retention of Your Information.  We retain information as long as it is necessary and relevant for our operations. Information about you that is no longer necessary and relevant for our operations will be disposed of securely. In addition, we may retain information from closed accounts to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, and enforce the Service’s terms and conditions and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

 

Notice of Privacy Rights to California Residents.  Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, information related to the personal information disclosed by TuringSense to third parties for direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by emailing TuringSense at support@turingsense.com or sending a letter to:

 

TuringSense, Inc.

4675 Stevens Creek Blvd. Ste. 101

Santa Clara, CA 95051

 

Contact

If you have questions or complaints regarding TuringSense’s Privacy Policy or practices, please contact TuringSense at support@turingsense.com.

Effective Date: August 17, 2016.