myTurn Logo with Turn emphasized

Privacy Policy

Effective date: September 1st, 2023

myTurn.com, pbc (“us”, “we”, or “our”) operates the https://myturn.com/ website and related *.myTurn.com sites (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you, and your users, use our Service and the choices you have associated with that data for yourself, on behalf of the data you store about your users, and about the data your users store on the Service directly.

We use your, and your users’, data to provide and improve the Service. By using the Service, you–and any organization you represent for use of the Service–agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our End User License Agreement, accessible at: https://myturn.com/about/terms-and-conditions/

Definitions

Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession). This includes you and your users (if applicable).

Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies: Cookies are small pieces of data stored on a User’s device.

Data Controller: Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processor (or Service Providers): Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject: Data Subject is any living individual who is the subject of Personal Data.

User: The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data: While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you.

Usage Data: We also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your and your users’ computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, other diagnostic data, data on items tracked, types of items, reservations, and usage of items.

Tracking & Cookies Data: We use cookies and similar tracking technologies (e.g. browser local storage) to track the activity on our Service and hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security and authentication purposes.

Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Service from certain geographic regions.

Information We Collect from Other Sources: We may also get information about you and your users from other sources. For example, if a myTurn account is created or logged into via single-sign-on, we may receive personal profile data from their third party service.

Use of Data

myTurn.com, pbc uses the collected data for various purposes:

  • To provide, maintain, and improve our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To calculate how many people visit our Service from certain geographic regions
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
  • Part of our mission is to make products more accessible and reusable to more people and companies. To further this mission, we will use and may share de-identified and aggregate product usage information with third parties.

Retention of Data

myTurn.com, pbc will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

myTurn.com, pbc will also retain de-identified and aggregate Usage Data for internal analysis purposes. Usage Data is also used to strengthen the security or to improve the functionality of our Service, and when we are legally obligated to retain this data for longer time periods.

Choices Regarding Your Data

At myTurn.com, pbc, we value your privacy and are committed to using your personal data responsibly and in accordance with applicable laws. We do not sell your personal data to third parties. The information we collect is used exclusively for the purposes listed in our “Use of Data” section.

  • If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details provided under the “ Contact us” heading at the bottom of this notice.
  • In addition, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact us” heading at the bottom of this notice.
  • You may opt-out of marketing communications we send you at any time. If you wish to opt-out of receiving news, special offers, and general information about goods, services, and resources similar to those you have purchased or inquired about, you may do so by following the unsubscribe link or instructions provided in any email we send. You may also contact us using the contact details provided under the “Contact us” heading at the bottom of this notice.
  • Similarly, if we have collected and processed your personal data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

Transfer Of Data

Your, and your customer’s information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

If you are located outside the United States and choose to provide your information, and your users’ information, to us, please note that we may transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

myTurn.com, pbc will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Transfer to the U.S. or Other Countries

We use facilities in the United States. Your information will be stored and processed in the United States or other countries where we maintain facilities. By using the Site and/or the Service, you consent to the transfer of information outside of your country, even if your country has more rigorous data protection standards. For any information that may be transferred from the European Economic Area and the United Kingdom (UK), please see below regarding our participation in the EU-US, Swiss-US and UK Extension to the EU-US Data Privacy Frameworks.

EU-US Data Privacy Framework (EU-U.S. DPF), Swiss-US Data Privacy Framework (Swiss-US DPF) and UK Extension to the EU-U.S. DPF

As described in our Data Privacy Framework (for more information see: https://www.dataprivacyframework.gov/s/)  certification available at https://www.dataprivacyframework.gov/s/participant-search (search for “myTurn”), myTurn.com, pbc complies with the EU-U.S. DPF, Swiss-US DPF and UK Extension to the EU-U.S. DPF as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries, Switzerland and the UK, respectively. myTurn remains responsible for any of your personal information that it shares under the Onward Transfer Principle with third parties for external processing on our behalf (as described above in the “Disclosure of Information” section of this Privacy Policy). In certain situations, myTurn may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

With respect to personal data received or transferred pursuant to the Data Privacy Framework, myTurn is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. Please contact us with any questions or concerns regarding our privacy practices in relation to our Data Privacy Framework certification. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://www.jamsadr.com/eu-us-data-privacy-framework. Under certain conditions more fully described on the Data Privacy Framework website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Disclosure Of Data

Information you Consent to Share: We may share and disclose information at your direction. For example, we may share your information with third parties with which you authorize us to do so, such as for single sign-on services.

Aggregated and De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, including to the public.

Third-Party Service Providers: We use third-party service providers to assist us in making the Site available. Such third-party service providers may obtain access to the information you provide, including Personal Information.

Business Transaction: If myTurn.com, pbc is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement: Under certain circumstances, myTurn.com, pbc may be required to disclose your Personal Data if absolutely required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Information Shared Publicly: Information that you choose to make public is disclosed publicly. This may include information about your inventory, organization, or users. Please consider public information may be indexed by search engines or scraped from the service by third parties.

Legal Requirements

myTurn.com, pbc. may disclose your or your users Personal Data, in the good faith belief that such action is absolutely necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of myTurn.com, pbc
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security Of Data

The security of your and your users data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your and your users’ Personal Data, we cannot guarantee its absolute security. We expressly disclaim any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing or otherwise offering any definitive promise of security in connection with your personal information or usage information.

“Do Not Track” Signals

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Rights

myTurn.com, pbc. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your and your users’ Personal Data. Whenever made possible, you or your users can update your Personal Data directly within the account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the right:

  • To access and receive a copy of the Personal Data we hold about you
  • To rectify any Personal Data held about you that is inaccurate
  • To request the deletion of Personal Data held about you

You have the right to data portability for the information you provide to myTurn.com, pbc. Via your myTurn site and myTurn account, you can download all personal data we store about you and your users. Your product usage data, transaction history, and other reports can also be exported from your myTurn site at any time. You can also request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it if the downloads are not sufficient.

Please note that we will ask you to verify your identity before responding to such requests.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

All Services

We use third party cloud infrastructure services from the following providers.

  • Amazon Web Services (AWS): AWS is our primary third party sub-processor, cloud infrastructure and storage provider.
    • Compliance Programs: https://aws.amazon.com/compliance/programs/
    • GDPR Center: https://aws.amazon.com/compliance/gdpr-center/
    • Supplementary Measures Addendum: https://d1.awsstatic.com/Supplementary_Addendum_to_the_AWS_GDPR_DPA.pdf
  • Twilio Sendgrid: Sendgrid is used for some outgoing email. Privacy policy: https://www.twilio.com/en-us/legal/privacy

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

  • Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 13 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

myTurn.com, pbc.
16 Cavendish Ct Suite 424F
Lebanon, NH 03766, USA
privacy@myturn.com