Privacy Policy

Last updated: August 19th, 2024

Thank you for visiting the Turnover website. The site turnover.biz and its associated pages and services (herein, the “Website”) are provided by Turnover Global, Inc,, doing business as Turnover (“Turnover”, “we”, “us”). By accessing or using the Turnover Website, however accessed, or by purchasing any products through the Website, you manifest your intent and agree to be bound by this privacy policy (“Privacy Policy”), together with all other terms and conditions. 

When you browse our Website or purchase something from our platform, we collect the personal information you give us such as your name, address, phone number, and email address. We also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system. 

This Privacy Policy is intended to provide you with specific details about how we collect and process your personal and personally identifiable information through your use of the Website. Except for when we process payments, we are the data processor and data controller of all information collected through the Website. With regard to payment processing, please refer to the respective privacy policies of our payment processor service providers. 

You understand and agree that Turnover may store and process your personal information on computers located outside of the European Union, including, but not limited to, in the United States. By using the Website, you agree to the collection and processing of your personal or personally identifiable information outside of the European Union.

Before using the Website or providing information to us, please carefully review this Privacy Policy. By using or accessing the Website, you agree that we may collect and use your personal and personally identifiable information in accordance with this Privacy Policy, as revised from time to time. Turnover may modify, amend, replace, or suspend this Privacy Policy at any time. If you have any questions or suggestions regarding our Privacy Policy, or if your personal information is not accurate or complete, please contact us at support@turnover.biz 

By providing Turnover with your personal or personally identifiable data and using the Website, you warrant that you are over the age of eighteen (18) or otherwise above the age of majority within your jurisdiction. If you are younger than eighteen (18) or the age of majority within your jurisdiction, please do not use the Turnover Website and please do not provide personal information to us. 

You further acknowledge and agree that Turnover may utilize third parties to provide services to the Company and you consent to the transfer of the data we collect should the third party require such data to provide the services. 

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  1. Implied Consent; Personal Information Collected.

When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only. If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

When you use the Website, we may collect personal or personally identifiable information from you (“PII”). PII may include any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. It does not include anonymized data. You understand and agree that we can share this data with our affiliates and partners (for example, we will need to share your information to our delivery partners so that they can deliver the products when you make an order on the site); we will not sell your information without your consent. You further acknowledge and consent that we may use anonymized group data to provide offers, deals and other promotions to you and other users of the Website.

We may collect and process the following categories of PII about you:

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  • Communication Data. Communication data includes any communication that you may send to us through the website, email, SMS or social media. We process this data to communicate with you, to provide you with customer support, to record logs of our communication, and to store information to respond to legal claims. Turnover’s lawful ground for processing this communication data is to respond to communications sent by you to us, to keep records of our communication, and to pursue or defend against legal claims.

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  • User Data. User data includes data about how you use the Website and any data that you post to or authorize through the Website. This includes data stored in persistent cookies when you login to the Website and analytics data that is collected when you use the Website. We collect and process this data to operate the Website, to authenticate you as a user of the Website, to ensure that timely and relevant content is provided to you, to secure the Website, to ensure that the Website operates in a fast and efficient manner, and to maintain backups of the Website. Turnover’s lawful ground for processing this user data is its legitimate business interests in administering and offering the Website.

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  • Technical Data. Technical data includes data about your use of the Website, such as your IP address, your mobile device model, your operating system, your geolocation, and your time zone. Turnover may collect this data from your use of the Website and from advertising IDs. Turnover processes this data to analyze your use of the Website, to route Website traffic, to administer and secure the Website, to provide location-relevant content, and to troubleshoot problems with the Website. Turnover’s lawful ground for collecting and processing this technical data is its legitimate interests in administering and offering the Website and to grow its business and marketing strategy.

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  • Marketing Data. Marketing data includes data about your preferences in receiving and interacting with Turnover’s advertisements or content on the Website. Turnover collects this data from your use of the Website and from advertising IDs created through advertising programs, such as Google Advertising IDs, Facebook Advertising IDs, Pinterest Conversion Tracking, and TikTok Conversion Tracking. Turnover does not connect advertising identifiers to persistent device identifiers, such as MAC addresses or mobile device IDs. Turnover’s lawful ground for collecting and processing this marketing data is its legitimate interests in administering and offering the Website and to grow its business and marketing strategy by providing advertisements, including remarketing advertisements, to you.

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  • Personally Sensitive Data. Personally sensitive data includes data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, union membership, or information about your health. Turnover does not collect or use personally sensitive data through the Website.

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Turnover will only use your PII for the purpose for which it was collected. In the event that Turnover needs to use your PII for an unrelated new purpose, Turnover will provide you with notice of this new use and will explain the lawful ground for such processing. Turnover may process your PII without your knowledge or consent where required or permitted by law.

Turnover does not use your PII to automatically make any decisions or to create an automated profile about you.

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  1. Collection of Data From Third Parties; Payments.

Turnover may collect data about you through cookies and other technologies. This helps Turnover understand how you use the Website and to understand any patterns that may be associated with your use of the Website. This aids Turnover in developing or improving its Website in response to your needs or wants.

Turnover may use session or persistent cookies. Session cookies are only stored on your computer or mobile device during your use of the Website and are automatically deleted when you close your web browser. Session cookies may be used to direct internet traffic to a server that is closer to you or to allow us to identify you as you move between pages of the Website. Persistent cookies are stored as a file on your computer or mobile device that remains on your computer or mobile device even after you close your web browser. Persistent cookies can be read by the website that created the cookie when you revisit it again. Turnover may use persistent cookies to authenticate you when you return to the Website so that you do not have to login again or when it utilizes Google Analytics or other analytics providers, which is intended to track the origin and behavior of traffic to the Website. Turnover may use the following analytics providers, and you are directed to review their cookie policies, current as of the date of this policy:

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  • Google Analytics
  • MoEngage
  • Posthog 

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Turnover may also receive data from third parties including analytics providers or advertising networks such as Google, Facebook, TikTok, or Apple. These third parties may be based outside of the European Union.

Our payments processing is provided by Stripe. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through the Payment Processor’s data storage, databases and the general application. They store your data on a secure server behind a firewall.

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If you choose a direct payment gateway to complete your purchase, then [Payment Processors store your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.

All direct payment gateways 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 credit card information by our store and its service providers.

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  1. Marketing Communications.

As stated above, Turnover’s lawful ground for sending you marketing communications is either consent or its legitimate business interests, such as to grow its business by advertising products to you. Turnover may send you marketing communications if you have asked for information concerning its goods or services or if you have agreed to, and have not opted out from, receiving marketing communications. You may ask Turnover to stop sending you marketing messages at any time by logging into the Website to adjust your marketing preferences within your User Account or by following the opt-out link in any marketing message sent to you. If you opt out of receiving marketing communications, your opt-out does not extend to PII provided for other purposes.

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  1. Disclosure of Personal Information.

Turnover may share your PII with the following parties:

  • Service providers that provide Turnover with information technology or other administrative services;
  • Turnover’s accountants, auditors, insurers, or attorneys; 
  • Law enforcement agencies upon the receipt of a subpoena or court order or where necessary to protect Turnover’s personnel or property; and
  • Government bodies that require Turnover to report its processing activities.

Turnover may also transfer PII to third parties when it sells, transfers, or merges any part of its business or assets. 

Turnover requires all third parties that receive a transfer of PII from Turnover to maintain the same level of respect for the protection of PII as Turnover and Turnover only allows third parties to process your personal data for the specific purposes listed in this Privacy Policy. Under no circumstances will Turnover ever sell your information to third parties. 

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  1. Data Security.

Turnover has put into place data security measures to protect your PII. Turnover allows access to your PII only by employees and service providers who have a need to know or on Turnover’s instructions. Turnover abides by a confidentiality policy and requires the same or similar restrictions of its partners and affiliates. However, no security measures are impenetrable and there are always security risks. Turnover will notify you and any regulatory body of any breach of your PII or Turnover’s security measures if it is legally required to do so.

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  1. Retention of Data.

Turnover will only retain your PII for so long as necessary to fulfill the purposes for which it is collected under this Privacy Policy or for the purposes of satisfying any legal, accounting, or reporting requirements. We will also retain and use your PII 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, such as the California Consumer Privacy Act), resolve disputes, and enforce our legal agreements and policies.

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  1. Right to Access, Rectification, Correction, Erasure, Transfer, and Withdrawal.

Under the law, you may have a right to request access to your PII for rectification, correction, erasure, transfer, or restriction, or to object to its processing or withdraw your consent. If you wish to exercise any of these rights, please contact Turnover’s Privacy Officer as disclosed in this Privacy Policy. The Privacy Officer can reached at support@turnover.biz 

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You do not need to pay a fee to access your PII or to exercise your rights. However, Turnover may charge a reasonable fee if your request is unreasonable or excessive.

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To confirm your request, Turnover may need to request specific information from you as a security measure to ensure that PII is not disclosed to an unauthorized third party. Turnover will attempt to respond to all legitimate requests within thirty (30) days.

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  1. California Privacy Rights.

While inclusion of the below does not mean we are explicitly availing ourselves of the California Consumer Privacy Act, out of an abundance of caution we are electing to provide the the following rules that apply solely to visitors, users, and others who are residents of the State of California. California residents have the right to be notified which categories of PII are being collected and the purposes for which the PII is being used. In particular, we collected the following categories of PII (A, B, D, and F) as defined in the California Consumer Privacy Act within the last twelve months. Our uses of this PII are detailed above in this Privacy Policy:

A. Identifiers: Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.: YES

B. Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e)): Name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.: YES

D. Commercial: Records of products purchased: YES

F. Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement: YES

We obtain these categories of PII directly from California residents when they complete forms through our website or provide it to us as a part of a transaction or inquiry concerning our products. We also obtain these categories of PII indirectly from California residents while observing their actions on our Website and from third parties or service providers that they have authorized to receive and share PII.

California residents have a right to request that we disclose what PII we collect from you and whether, and how, we disclose or sell that PII. California residents may also request that we delete any personal information collected or maintained by us from you. 

California residents may also have the right to opt out of the sale of their personal information by contacting us or, where available, by clicking a link or icon associated with an advertisement. While we do not sell your information, you may still see interest-based advertisements. To learn more about interest-based advertising across websites and additional opt-out choices, you can visit http://optout.aboutads.info. If you opt-out of the sale of your personal information but do not opt out of interest-based advertising more generally, you may still receive ads tailored to your interests based on PII that was not sold by us, personal information that was sold to downstream participants at least 90 days before you opted out, or personal information that was sold by other sources from which you have not opted out.

To submit a request for a list of the categories of personal information collected from you or to request that Turnover delete your personal information, please contact us at support@turnover.biz 

To verify your request, we may request certain information from you to confirm that you are a Turnover user, such as your phone number, username, email address, city, state, or geographic location. You may also designate an authorized agent to make a request to Turnover to disclose or delete your personal information. To do so, you must provide Turnover with proof that the individual or business has been appointed as your agent, such by providing a signed power of attorney form, and provide accurate responses to any information requested by Turnover that may be necessary to confirm that you are a Turnover user, such as your phone number, username, email address, city, state, or geographic location. California residents have a right not to receive discriminatory treatment by Turnover for their exercise of these rights conferred under California law.

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  1. Third Party Links.

Turnover’ Website may include links to third-party websites and applications. By clicking on third-party links, you may allow third parties to collect or share data about you. Turnover does not control these third-party links and you are advised to review their respective privacy policies. For the avoidance of doubt, you understand and acknowledge that Turnover shall not be liable for any breaches associated with third party websites and applications. 

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  1. Responding to Do Not Track Signals.

You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website. Our website is not currently set up to respond to browser do-not-track signals because there is no consensus within the advertising industry as to what “do not track” means in this context, but you can configure your browser settings to reject all cookies or prompt you before a cookie is set.

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  1. Nevada Residents.

If you are a resident of Nevada, you may provide notice to us to limit the sale of your PII to third parties for resale or licensing purposes. However, we do not sell your PII for such use. To notify us that you wish to limit the sale of your PII to third parties for resale or licensing purposes, you may send us an email to support@turnover.biz with the subject line, “Nevada Do Not Sell Request,” along with your name, address, and user account information.

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  1. Children’s Privacy.

We do not direct the Website to anyone under the age of 13 and we do not knowingly collect PII from anyone under the age of 13. If you are a parent or guardian of an individual under the age of 13 and believe that we may have collected PII from your child, please contact us at[TBD .

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  1. Notification of Changes.

Whenever Turnover changes its Privacy Policy, we will post those changes to this Privacy Policy on the Website and other places that we deem appropriate. Your use of the Turnover Website following these changes indicates your consent to the practices described in the revised Privacy Policy.

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  1. Contact Us.

If you have any questions about this Privacy Policy or the manner by which we collect or use Personal Information about you, email us at support@turnover.biz 

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