Updated September 6th, 2018
The Turn Service is intended for use by an adult general audience. The Turn Service is not directed to children under the age of 13 and Turn does not knowingly solicit personal information from or market to children under the age of 13. If we learn that anyone under the age of 13 has provided any personal information through the Turn Service, we will use commercially reasonable efforts to promptly delete it.
Information We Collect and Usage
Turn collects and uses Customer’s account, information like your name, email address, phone number, and physical address. Turn may also collect, and associate with Customer’s account, information related to your dealership, such as dealer registration number, vehicle purchases and sales, and tax information. Turn may also receive personal information from our business partners and other third parties. The information we collect is used to improve the content and quality of the Turn Service.
Turn uses information that is collected for the following general purposes:
- to process your applications and related documents required to become a contracted dealer and to make a decision regarding the acceptance or rejection of your applications;
- to verify the information that you provide to Turn;
- to verify, evaluate and/or monitor your creditworthiness;
- to assist with the collection of any amounts owing by you to Turn;
- to contact you in response to any transactions, requests, complaints or comments you may have;
- to contact you to provide you with information regarding Turn’ business;
- to provide advertisements to you through our website, email messages, mobile applications or other methods of communication;
- to administer surveys, contests or other promotional activities or events sponsored by us, our vendors or other third party service providers;
- to help us to develop, evaluate and improve our sales and marketing strategies and techniques;
- to operate and improve our web site;
- to provide third parties with information necessary to permit that third party to conduct business with Turn and/or effectively provide you with services.
- to assist Turn and third parties in evaluating the vehicle industry; and
- to respond to legal process and reasonable inquiries from regulatory and/or investigative authorities.
Information is not shared with or sold to others for commercial purposes, except to provide the products or services you’ve requested, when we have your permission, or under the following circumstances:
- It is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service, or as otherwise required by law, regulation or governmental request.
- We may share and/or transfer information in the event of a potential or actual acquisition of Turn or its merger with another company.
- Turn may share information with third party auctions to facilitate a transaction and evaluate vehicles.
When Customers use our Services, we store and process your information and information related to your use of the services (for example, photos, transaction history, feedback, signature, etc.) If Customer gives us access to Customer contacts, Turn will store those contacts on our servers for Customer to use. This will make it easy for the Customer to buy and sell vehicles, send emails, and invite others to use the Services.
Who We Share Information With
Turn may aggregate data collected by the Services and sell that aggregated data to advertisers and other third parties. The aggregate data may or may not be anonymized.
Turn may disclose your information to third parties if we determine that such disclosure is reasonably necessary to (a) comply with the law; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of Turn or our Customers; or (d) protect Turn’ property rights.
Our Services display information like your name, images, and auction history to other reps and dealerships in places like your rep profile and notifications. Certain features let Customers make additional information available to other parties.
Turn for Dealerships
A dealership administrator may have the ability to access and control associated Turn Customer accounts. Please refer to your organization’s internal policies if you have questions about this.
Turn takes commercially reasonable technical, physical and administrative measures to protect the confidentiality, integrity and security of your personally identifiable information. Of course, we cannot guarantee the security of your personally identifiable information on the Internet. The password-protected areas of the Turn Service are secured by industry standard encryption. However, it is your responsibility to maintain the confidentiality of your password(s) and other user credentials. You are also required to log-in to your Turn account after a certain period of time has elapsed to protect you against others accidentally accessing your account.
Retention, Data Storage and Transmission
All personally identifiable information you provide to Turn is secured on servers with restricted access. We reserve the right to use third party agents and service providers, who are bound by strict confidentiality guidelines, to perform storage and processing functions. We will store your personal information for as long as there is a business need for it in accordance with applicable record retention policies and a range of legal and regulatory recordkeeping requirements
To provide you with the Services, we may store, process and transmit information in locations outside the United States. Information may also be stored locally on the devices you use to access the Services.
Change of Control
If we are involved in a reorganization, merger, acquisition or sale of our assets, your information may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.
Opt-Out, Changes and Questions