TURNSOCIAL.COM PRIVACY POLICY

Welcome to TurnSocial.com, a website owned and controlled by TurnSocial, Inc. ("TurnSocial", "we", "us", or "our"). We operate the TurnSocial platform, which enables websites to integrate applications and web toolbars into their websites, thus providing certain functionalities to such website's users. We are aware of the trust you place in us and our responsibility to protect your privacy. As part of this responsibility, we provide this privacy policy to let you know what information we collect, how we use it, share it and protect it.

1. Scope

This Privacy Policy applies to the website located at www.turnsocial.com (the "Site"), the tools and interactive forums made available through the Site and the TurnSocial application and web toolbar platform, as well as a number of related services (collectively the "Services").

By accessing the Site or using the Services, you agree to the policies and practices set forth in this Privacy Policy, including to the collection and processing of your Personal Information (as defined below). If you disagree to any term provided herein, you may not use the Site.

To be clear about the terminology we are using, when we use the term "Personal Information" in this Privacy Policy, we mean information that can be used to identify you like your name, address, e-mail address, or phone number, as well as other non-public information that is associated with this Personal Information. When we use the term "Anonymous Information" in this Privacy Policy, we mean information that cannot be used to identify you and is not associated with or linked to your Personal Information.

As a general rule there are two categories of users of the Site and Services: "Publishers" who are operators or publishers of websites that make the TurnSocial application and web toolbar platform available on their website, and "End Users" who are individual visitors of a website and use the TurnSocial application and web toolbar platform for different use cases (collectively, "you").

The Site and Services are hosted in the United States. If you access the Site or Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the Site or Services, you are transferring your Personal Information to the United States and you consent to that transfer. Additionally, you understand that your Personal Information may be processed in countries (including the United States) where laws regarding processing Personal Information may be less stringent than in your country.

2. Our Site and Services

(a) The Information We Gather and How We Use it:

When you access the Site or Services, we may collect the following information:

• Personal Information - We collect Personal Information when you voluntarily provide it, including when you register for the Site, provide feedback, or request information. We use your Personal Information to administer your account and provide you services of your choice, to send communications and administrative emails, to respond to your inquiries, to market to you, and to improve the quality of the Site and Services. Additionally, we may strip your Personal Information of any information that specifically identifies you to effectively create Anonymous Information and we will use this Anonymous Information as provided in this Privacy Policy.
• Anonymous Information - When you access our Site or use our Services, we use Cookies and log files to automatically record information that your browser sends. This includes your Internet Protocol address, browser type, browser language, the date and time of your request, and the web pages you have visited. We use Cookies and log files to improve the quality of our Site and Services, to keep track of your login name, passwords, and pages you have visited; and to tailor content to your interests and to personalize the Services on your behalf.
• "Cookies" are small pieces of information that a website sends to your computer's web browser while you are viewing a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience. Persistent Cookies can be removed or blocked by following the help file directions in your Internet browser. If you elect to block Cookies, you may not be able to access certain personalized sections of our Services such as Publisher reports.

(b) Information Sharing:

We share Personal Information and Anonymous Information with other companies or individuals only in the following cases:

• When they help us operate our business, such as with vendors that assist us in sending email, marketing and customer service.
• With third parties if we have a good faith belief that access, use, or disclosure of such information is reasonably necessary to (a) satisfy applicable law, regulation, legal process or an enforceable governmental request, (b) enforce the applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of TurnSocial, its users or the public as required or permitted by law.
• With any of our subsidiaries, joint ventures, or other companies under common control with us, in which case we will require them to honor this policy. Additionally, in the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred.
• With third parties to whom you ask us to send Personal Information, whether explicitly or by using our Services (e.g. through the use of a chat application or a forum);
• In addition, we may aggregate your Anonymous Information with the Anonymous Information of others and share that aggregated information with third parties without restriction.

(c) Forums:

We may make interactive forums available on the Site and as part of the Services. Any information that you post to these interactive forums or otherwise choose to make publicly available, including your Personal Information, may be disclosed and available to all users who have access to any interactive forum and is no longer private. Please be thoughtful about what you post and make publicly available through our interactive forums.

(d) Choice:

If you have provided Personal Information such as your email address when registering for our Site, you may modify that information at any time by visiting your account settings. As we use your user name as the account identifier, you cannot change your user name. While we would be sorry to see you go, you can cancel your account at any time by sending us an email to info@turnsocial.com. Keep in mind, however, that even if you delete your account, we may retain your Personal Information in conformance with our data retention policy, under which we may reasonably retain such information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and take other actions otherwise permitted by law. There may be residual Personal Information that remains within our databases, access logs, and other records. In addition, we are not responsible for updating or removing your Personal Information already disclosed to third parties who have been provided information as permitted by this Policy. You can opt out of receiving certain email communications from the Site by clicking the "Unsubscribe" link at the bottom of certain emails or by replying to the email with the subject "UNSUBSCRIBE". Please note that even if you unsubscribe or opt-out, we may still send you Site and Service related communications.

3. Additional Information about the TurnSocial application and web toolbar platform

We operate the TurnSocial application and web toolbar platform (the "TurnSocial Platform"), which adds functionality to Publishers. If you are reading this policy, you are probably familiar with our web toolbar (collectively, the "TurnSocial bar") that Publishers place on their websites.

The previous Sections also apply to the use of the TurnSocial Platform. However, this Section is intended to clarify certain aspects with regard to the collection, usage and sharing of your information as part of the TurnSocial platform.

(a) The Information We Gather and How We Use It:

• Personal Information - If you are accessing the Site or Services as a Publisher, you may provide your email address when you register the Publisher on the Site and create a user name and password. Any choices you make, information you voluntarily provide us or data we gather and provide to you in analytics reports about the use of the TurnSocial Platform on the Publisher's website is the Publisher's Personal Information. In addition, we include a unique user identifier number in the TurnSocial code the Publisher places on its website, which enables us to associate analytics data with the Publisher's account.
• Anonymous Information - When you, an End User, download a page that uses the TurnSocial Platform, our server logs collect your Internet Protocol address, browser type, browser language, and the date and time of your request. We use this information to improve our internal operations and software. In addition to log files, when a page containing the TurnSocial Platform is downloaded, we may also set Cookies. Without knowing who you are, our Cookies may record information about how you use the web, for example, the websites and webpages you have visited, web searches that landed you on a page of interest, categories of interest, and if and how often you share content with others using the TurnSocial platform. We may use this information to customize different types of functionality of the TurnSocial bar or application. If you elect to block or delete Cookies, you may not be able to enjoy certain personalized features of our Service.

(b) Information Sharing

We share the information we collect through the TurnSocial platform in the same way described in "Our Site and Services" Section above. In addition, we may assist our advertising partners in setting cookies so that we can share all or some of the Anonymous Information with them. Our advertising partners use the Anonymous Information to deliver targeted advertising. Please see the section below on Choice if you do not want us to share information with our advertising partners. To be clear the Anonymous Information provided to our advertising partners does not contain any Personal Information of End Users or any information that can be associated with any Publisher or Publisher domain.

(c) Choice

As noted above, we may have helped our advertising partners set Cookies. In order to ensure that no additional information is collected by these Cookies for the purpose of delivering targeted advertising, you can clear all of your Cookies as provided in your browser's instructions. You can also opt-out from other network advertising from the opt-out page of the Network Advertising Initiative.

Finally, we allow Publishers to prohibit us from collecting information about their End Users.

4. Information security

We take reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to Personal Information to TurnSocial employees, contractors and agents who need to know that information in order to operate, develop or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, if they fail to meet these obligations. Despite these measures, you should know that we cannot fully eliminate security risks associated with Personal Information and mistakes may happen.

5. Children

We do not knowingly collect or maintain Personal Information from individuals who are under 13 years of age, and no part of our Site or Services are designed to attract people under the age of 13. Protecting the privacy of children is very important to us. If we obtain knowledge that a user is under the age of 13, we will take steps to remove that user's Personal Information from our databases.

6. Links to Other Sites

Our Site and Services contain applications from and to third party websites and services. The fact that we link to a website or service or allow you to use the application is not an endorsement, authorization or representation that we are affiliated with that third party, nor is it an endorsement of their privacy or information security policies or practices. This privacy policy applies only as provided in the scope section above. Other websites and services follow different rules regarding the use or disclosure of the personal information.

7. Questions or Comments?

TurnSocial regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy by contacting us through this Site, by emailing us at info@turnsocial.com or writing to us at:

TurnSocial, Inc.
191 Russ St.
San Francisco, CA 94103

8. Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us any time through this Site or by writing to us at the address set forth above.