OUR COMMITMENT TO PRIVACY
Your privacy is important to Turn/River Management, LP and its affiliates (together, “Turn/River”). Turn/River has a policy of protecting the confidentiality and security of information Turn/River collects about you. To better protect your privacy, Turn/River is providing information explaining Turn/River’s online information practices.
In processing data, Turn/River complies with the requirements of privacy legislation. That means, among other things, that:
- Turn/River aims to limit its collection of personal data to only the personal data required for legitimate purposes;
- Turn/River takes appropriate security measures to protect your personal data and also require this from parties that process personal data on Turn/River’s behalf;
- Turn/River respects your right to access your personal data or have it corrected or deleted, at your request.
If you have any questions, or want to know exactly what data Turn/River keeps, please contact Turn/River at email@example.com.
THE INFORMATION TURN/RIVER COLLECTS AND HOW TURN/RIVER USES IT
Turn/River is committed to the security of personal data. Unfortunately, the transmission of information and data via the Internet is not completely secure. Although Turn/River takes appropriate security measures to limit the abuse of and unauthorized access to personal data, Turn/River cannot guarantee the security of any information or data transmitted to or through this Site; any transmission of information or data by you to or through this Site is at your sole risk. Turn/River’s security measures are regularly reviewed.
HOW TURN/RIVER RESPONDS TO DO NOT TRACK SIGNALS AND GLOBAL PRIVACY CONTROL
The Site responds to and supports the Do Not Track (“DNT”) header request field. If you turn DNT on in your browser, those preferences are communicated to Turn/River in the HTTP request header, and Turn/River will not track your browsing behavior.
THIRD PARTY WEBSITES
You represent to Turn/River that you have the authority to visit this Site according to the Terms and Conditions of Website Use. This Site is only intended for individuals who are at least the age of consent in their state and/or country of residence (the “Age of Consent”). Turn/River does not knowingly encourage or solicit visitors to this Site who are under the Age of Consent or knowingly collect personal information from anyone under the Age of Consent without parental consent. Turn/River therefore requests that individuals under the Age of Consent do not submit any personal data to it. If Turn/River learns it has collected or received personal information from an individual under the age of consent in their country of residence, Turn/River will delete that information.
Technical cookies used by the Site
Technical Cookies: Turn/River uses session cookies to provide you with the services available through this Site and to use some of their features. These cookies are served by Turn/River and are essential for using and navigating the Site. Without these cookies, basic functions of this Site would not work. Because these cookies are strictly necessary to deliver this Site, you cannot refuse them without impacting how this Site functions. For example, when a visitor enters this Site using a mobile device, Turn/River detects the device and presents the visitor with its mobile website (vs. its desktop website) for ease of navigation and content legibility.
Statistics Cookies: We use statistics cookies to optimize the website experience for our users. With these statistics cookies we get insights in the usage of this Site.
These cookies are not essential for using and navigating the Site. However, without these cookies, certain functionality may become unavailable. You can block or delete these cookies by changing the browser settings.
Third-party cookies used by this Site
Turn/River has concluded a data processing agreement with Google. To block or delete cookies, or to withdraw your consent after accepting cookies, change the configuration of your browser to not accept cookies and delete any existing cookies. Please note that if you limit the ability of the Site to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
You may access any personally identifiable information Turn/River has about you by contacting firstname.lastname@example.org.
Turn/River is committed to protecting the personal information you entrust to it. Turn/River endeavors to implement appropriate security measures and technologies to seek to ensure the security of your personal information on its systems and to ensure that it is protected to the extent possible from unauthorized access and improper use. In addition, Turn/River limits access to your personal information to those employees, agents, contractors, and other third parties who have a business need to know. They will process your personal data based on Turn/River’s instructions and they will be subject to a duty of confidentiality. Turn/River has put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where Turn/River legally required to do so.
Notwithstanding Turn/River’s efforts to protect your information, no security system is completely impenetrable or error-free, so Turn/River cannot guarantee the absolute security of its databases, nor can Turn/River guarantee that information you supply to Turn/River will not be intercepted while in transit to us over the Internet. Any transmission of information or data by you to or through this Site is at your sole risk.
Transfers of Personal Information Outside the EEA
Your personal information will be hosted in the U.S. and will therefore be transferred and stored outside of the European Economic Area (“EEA”). For the purpose of applicable EU laws, such third countries (including the U.S.) may not offer the same level of data protection as your country of residence. Such transfers will be made in accordance with applicable EU data privacy laws. For further information about the safeguards used, please contact email@example.com.
Your EU Rights
If you are located in the EEA or Switzerland, subject to applicable law, you may have the following rights in relation to personal information that Turn/River holds about you. To exercise these rights and controls, please contact firstname.lastname@example.org.
- Access: You have the right to ask for a copy of the personal information that Turn/River holds about you free of charge, however Turn/River may charge a reasonable fee, if Turn/River thinks that your request is excessive, to help Turn/River cover the costs of locating the information you have requested.
- Correction: You may notify Turn/River of changes to such your personal information if it is inaccurate or it needs to be updated.
- Deletion: If you think that Turn/River should not be holding or processing your personal information anymore, you may request that Turn/River deletes it. Please note that this may not always be possible due to legal obligations.
- Restrictions on use: You may request that Turn/River stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that Turn/River no longer needs your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and Turn/River is verifying whether Turn/River’s legitimate grounds to process your personal information, override your own rights.
- Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
- Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask Turn/River to do so, and Turn/River will send it directly if Turn/River has the technical means.
- Withdrawal of consent: If you previously gave Turn/River your consent (by a clear affirmative action) to allow Turn/River to process your personal information for a particular purpose, but you no longer wish to consent to Turn/River doing so, you can contact Turn/River to let it know that you withdraw that consent.
Turn/River may need to request specific information from you to help Turn/River confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. Turn/River may also contact you to ask you for further information in relation to your request to speed up Turn/River’s response.
If you believe that Turn/River has processed your personal information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country. You can find details for your relevant EU national data protection authority at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
NOTIFICATION OF CHANGES
The provisions in the Terms and Conditions of Website Use are hereby incorporated by reference.
DATE: January 7th, 2021
What information does Turn/River collect about you?
Turn/River collects limited types of personal information through the Site and Turn/River’s investor reporting portals, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information Turn/River collects about you depends on the nature of your interaction with Turn/River. The categories of personal information Turn/River has collected from individuals on the Website over the last 12 months include the following:
- Identifiers, such as name, contact details and email address;
- Internet or other electronic network activity information, such as information regarding your use of the Website (e.g., cookies, browsing history and/or search history), as well as information you provide to Turn/River when you correspond with Turn/River in relation to inquiries.
Turn/River does not knowingly collect or solicit personal information from anyone under the Age of Consent.
How does Turn/River obtain your personal information?
In connection with forming and operating the Website, Turn/River collects and maintains your personal information from the following sources:
- Information from your communications with Turn/River in connection with the Website, including any update notices provided by you.
- Information captured on the Website, including registration information, information provided through online forms and any information captured via cookies.
Turn/River may combine personal information that you provide to it with information that Turn/River collects from or about you from publicly available sources. This will include information collected in an online or offline context.
If you are an entrepreneur affiliated with a company that Turn/River is evaluating (or may evaluate in the future) in connection with a potential investment or acquisition, Turn/River may also collect and process information about you that Turn/River obtains from third party sources (including such company’s website) in connection with Turn/River’s efforts to build a relationship with you and/or evaluate such company in connection with a potential investment or other acquisition.
How does Turn/River use your personal information?
Turn/River will use your personal information for one or more of the following business purposes:
- To perform services for you.
- To improve the Website and the products and services that Turn/River offers and notify you about changes to Turn/River’s products and services.
- To communicate with you, including responding to requests for information submitted by you through the Website.
- To keep a record of your relationship with Turn/River.
- To further build Turn/River’s relationship with you.
- To provide you with details regarding Turn/River’s potential financing, operational support or other capabilities that Turn/River offers to entrepreneurs and/or prospective portfolio companies.
- Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
- To audit and verify the quality and effectiveness of Turn/River’s services and compliance.
- To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
- To generally comply with U.S., state, local and non-U.S. laws, rules and regulations.
Additionally, Turn/River may use your personal information to keep you informed of Turn/River’s products and services, if you have provided your consent to Turn/River doing so, or where Turn/River has an existing relationship with you and Turn/River wishes to contact you about products and services similar to those which Turn/River provides you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting Turn/River and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all Turn/River’s marketing emails.
Who does Turn/River share your personal information with?
Turn/River does not sell any of the personal information Turn/River collects about you to third parties.
Turn/River does not disclose any personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. Turn/River may disclose your personal information to professional advisors and other third parties who are bound by contractual or professional obligations to keep such personal information confidential and use it only for the purposes for which Turn/River discloses it to them. Such purposes include performing due diligence activities in connection with an actual or potential investment or acquisition transaction, to support Turn/River in operating its business, or to support Turn/River in performing its obligations under Turn/River’s business contracts. Turn/River reserves the right to disclose your personal information to third parties, including, but not limited to, law enforcement or other governmental agencies, in order to comply with law or when Turn/River believes that disclosure is necessary to enforce or protect its rights in or otherwise with respect to, or the safety of, the Site or to protect the safety or rights of other users of this Site and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should Turn/River, or any of its affiliated entities, be the subject of a takeover, divestment or acquisition Turn/River may disclose your personal information to the new owner of the relevant business and their advisors.
Within the last 12 months, Turn/River has not sold consumers’ personal data and has not disclosed consumers’ personal information for a business purpose. Turn/River does not in the future intend to sell any personal information collected for a business purpose.
“What information does Turn/River collect about you?”
Turn/River may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of Turn/River’s business, assets or shares.
How does Turn/River keep your personal information secure?
Turn/River considers the protection of sensitive information to be a sound business practice, and to that end, Turn/River employs appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in Turn/River’s possession or under Turn/River’s control to the extent possible from unauthorized access and improper use.
Your rights under the CCPA
Deletion Rights: You have the right to request that Turn/River delete any of your personal information that Turn/River retains, subject to certain statutory exceptions, including, but not limited to, Turn/River’s compliance with U.S., state, local and non-U.S. laws, rules and regulations. If Turn/River receives a verifiable request to delete the consumer’s personal information, Turn/River shall delete such personal information from its records and direct any service providers to delete the consumer’s personal information from their records. Turn/River will notify you in writing if Turn/River cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that Turn/River discloses to you certain information regarding Turn/River’s collection and use of personal information specific to you over the last 12 months. Be advised that Turn/River is not required to disclose such information more than twice in a 12-month period. Such information includes:
- the categories of personal information Turn/River collected about you;
- the categories of sources from which the personal information is collected;
- our business or commercial purpose for collecting such personal information;
- the categories of third parties with whom Turn/River shares the personal information;
- the specific pieces of personal information Turn/River has collected about you; and
- whether Turn/River disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.
No Discrimination: Turn/River follows the requirements of California Civil Code §1798.125. Turn/River will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact Turn/River section below.
When Turn/River is Not Required to Comply With Your Request: Turn/River or any service provider shall not be required to comply with a your request to delete personal information if it is necessary for Turn/River or the service provider to maintain your personal information in order to:
- complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of a Turn/River’s ongoing business relationship with you, or otherwise perform a contract between Turn/River and you;
- detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- debug to identify and repair errors that impair existing intended functionality;
- exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
- engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when Turn/River’s deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent;
- to enable solely internal uses that are reasonably aligned with the expectations of you based on your relationship with Turn/River;
- comply with a legal obligation; and
- otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
For any requests relating to the exercise of your rights under the CCPA, or questions regarding Turn/River’s processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.
Call Turn/River using the following number: (415) 858-0910.
Submit a request online using the following online form: https://turnriver.com/get-in-touch
Turn/River will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. Turn/River verifies requests by matching information provided in connection with your request to information contained in Turn/River’s records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), Turn/River may request further information in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and Turn/River may verify such authorized person’s identity using the procedures above.