Privacy Statement

OUR COMMITMENT TO PRIVACY

Visitors that are residents of California should refer to Turn/River’s California Website Privacy Policy supplement.

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.

This Website Privacy Policy (this “Privacy Policy”) describes how Turn/River gathers and uses data Turn/River obtains from visitors of https://turnriver.waltzwebsite.com (this “Site”). Please read this Privacy Policy carefully. If you do not agree with any of the terms and conditions contained herein, please do not access or otherwise use this Site.

Except where EU laws apply to the processing of your personal information, by providing your personally information to Turn/River, you signify your acceptance of this Privacy Policy and agree that Turn/River may collect, use and disclose your personal information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not provide your personal details to Turn/River.

This Privacy Policy generally does not address Turn/River’s privacy practices concerning any nonpublic personal information Turn/River collects from its investors, potential investors or employees (including prospective employees or contractors) through sources other than the Site; Turn/River practices related to nonpublic personal information Turn/River collects from its investors, potential investors or employees (including prospective employees or contractors) are addressed in separate notices.

In processing data, Turn/River complies with the requirements of privacy legislation. That means, among other things, that:

If you have any questions, or want to know exactly what data Turn/River keeps, please contact Turn/River at privacy@turnriver.com.

This Privacy Policy constitutes a legally binding agreement between Turn/River and you, the user of this Site. By entering and using this Site, you acknowledge your acceptance of, and agree to be bound by, this Privacy Policy stated herein, its Terms and Conditions of Website Use and all additional terms incorporated by reference herein. If you do not agree to this Privacy Policy, please do not access or use this Site.

THE INFORMATION TURN/RIVER COLLECTS AND HOW TURN/RIVER USES IT

Turn/River may collect various types of information from users of this Site. For example, knowing how users use this Site – tracking a person’s movement through this Site (including the browsing history, search history, and information regarding a person’s interaction with an internet web site, application, or advertisement) – helps Turn/River improve this Site’s design and usefulness. As a result, Turn/River’s server collects general data pertaining to users, including the length of time spent on this Site, the pages accessed while visiting this Site and Internet Protocol (IP) addresses. Turn/River also collects certain information through cookies, described below. IP addresses and cookie identifiers may be considered “personal data” in certain jurisdictions and will be treated in accordance with this Privacy Policy. Turn/River generally does not, however, collect any personally identifiable information such as names, home addresses or e-mail addresses from users of this Site, unless a user submits such information to Turn/River via its “Get in Touch” page.  Turn/River may collect personal information about you from third parties including, but not limited to job posting websites.

To the extent that you provide Turn/River with any personally identifiable information through or in connection with this Site, Turn/River may use such information for Turn/River’s business purposes, but will not disclose any personally identifiable information about you to anyone, except as permitted or required by law or by a court order, in response to a law enforcement agency, to the extent permitted under other provisions of law, to provide information, for an investigation on a matter related to public safety and to service providers. In providing personally identifiable information to Turn/River, you consent to Turn/River’s use of such personally identifiable information for the purposes described in this Privacy Policy.  The data you provide on the “Get in Touch” page, including your first and last name, your email address and your telephone number, may be used in connection with the distributions of Turn/River communications.

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

This Privacy Policy does not apply to third party websites connected by links on the Site. Turn/River cannot guarantee that these third parties handle your personal data in a reliable or secure manner. Turn/River recommends that you read the privacy statements of these websites prior to making use of these websites.

CAPACITY

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.

COOKIES

Information regarding how you access this Site (e.g., browser type, access times and IP address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve this Site’s performance and for Turn/River’s business purposes. You may opt-in to accept cookies automatically by changing the settings on your browser.  In addition, when you visit this Site for the first time, the Site shows you a pop-up with an explanation about cookies. You do have the right to opt-out and to object against the further use of non-functional cookies. If you opt-out of certain cookies, you may not be able to access certain parts of this Site. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.  You can learn more about the cookies Turn/River uses on this Site at https://turnriver.waltzwebsite.com/cookie-policy-us/.

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

Analytics Cookies: This Site uses third-party analytics services, including, HubSpot and Google Analytics. These service providers use cookies to help this Site analyze how visitors use the Site. The information generated by the cookie about your use of this Site (including your IP address) are transmitted to and stored by Turn/River’s third-party service providers. Turn/River’s third-party service providers use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Turn/River’s third-party service providers also may transfer this information to third parties where required to do so by law, or where such third parties process the information on behalf of its service providers.

 For more information about cookies, please refer to Turn/River’s Cookie Policy on Turn/River’s Cookie Policy (US) webpage (https://turnriver.waltzwebsite.com/cookie-policy-us/).  

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 privacy@turnriver.com

SEcurity

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.

Turn/River will keep your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law. Turn/River will not keep more information than Turn/River needs for those purposes.

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 privacy@turnriver.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 privacy@turnriver.com

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

Turn/River reserves the right to amend this Privacy Policy from time to time and for any reason, in Turn/River’s sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review this Privacy Policy regularly.  If Turn/River decides to change its Privacy Policy, Turn/River will post those changes to this page so Turn/River’s users are always aware of what information Turn/River collects, how Turn/River uses it and under what circumstances, if any, Turn/River discloses it. If at any point Turn/River decides to collect personal information or use any collected information in a manner different from that stated at the time it was collected, Turn/River will notify users by posting changes on this page. Such updates to the Privacy Policy shall be effective immediately upon posting. Turn/River will use information only in accordance with the Privacy Policy under which the information was collected. Except where California, EU or other laws apply, your continued access or use of this Site following the posting of changes to this Privacy Policy means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing this Site. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you.

MISCELLANEOUS

The provisions in the Terms and Conditions of Website Use are hereby incorporated by reference.

CONTACT TURN/RIVER

If you have any questions, want to know which personal data Turn/River has about you or have any concerns about this Privacy Policy, please contact privacy@turnriver.com.  Please make sure to always clearly state who you are, so that Turn/River can be certain that it does not modify or delete any data of the wrong person. Turn/River shall provide the requested information only upon receipt of a verifiable consumer request. You have the following rights:

CALIFORNIA WEBSITE PRIVACY POLICY

DATE: January 7th, 2021

This California Website Privacy Policy supplements the Website Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA.  This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA.  Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Website Privacy Policy.  To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

What does this Privacy Policy apply to?

This Privacy Policy applies solely to your interactions with Turn/River through the Website (as defined below).  If you provide personal information to use through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.

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[1], 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:

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:

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:

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:

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:

Contact Turn/River

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.waltzwebsite.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.

Our goal is to respond to any verifiable consumer request within 45 days of receipt of such request, but in certain cases, additional time might be required. Please contact Turn/River using the methods outlined above with any questions about this California Website Privacy Policy.