Turnkey Processing, LLC., (“Turnkey”, “we” or “us”), the owner of this website and application, believes it is important to protect the privacy of our merchants, customers, and guests. We know that you care about how your personal information is collected, updated, used and shared. Furthermore, we want to help you make knowledgeable choices about the information you provide to us. The effective date of this policy is 8/28/18.
Turnkey is a financial technology and merchant services company which provides subscription based apps, and owns and operates various sites on the World Wide Web, including without limitation www.processwithturnkey.com (collectively, the “Services”).
Use of Personal Data
Do Not Track Disclosures
“Do Not Track” (DNT) is a preference that you may enable from your web browser to opt-out of online behavioral tracking. Our site and app does not follow DNT settings, and may collect personally identifiable information about you over time and across third party websites regardless of whether DNT is enabled or disabled in your browser. This Personal Data is used by us to provide targeted advertising to you for the products and services we sell. Please also be aware that some third party sites that we are linked to may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
Passively Collected Information
When you interact with us through the website, we receive and store certain additional non- personally-identifiable information. For example, we automatically receive and record information on our server logs from your browser including your IP address, browser type and language, referring/exit pages and URLs, other browser history, platform type, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time. Except as provided below under “Fraud Prevention,” we only use this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. This type of aggregate data enables us to figure out how often users use parts of the website or Services so that we can make the website appealing to as many users as possible, and improve our Services. As part of this use of information, we may provide aggregate information to our partners about how our users, collectively, use the website. We share this type of statistical data so that our partners also understand how often people use their services and the website, so that they, too, may provide you with an optimal online experience. Again, Turnkey never discloses aggregate information to a partner in a manner that would identify you personally.
As part of our efforts to combat fraud, we may record your IP address when you use the Service, and confirm that the geographic location associated with your IP address matches the banking information you may provide us or a third party App Distributor. This process allows us to detect and prevent certain fraudulent transactions from being processed through the Service (for example, a payment request associated with a U.S. billing address, but a non-U.S. IP address, may be declined).
Aggregated Personal Data
In an ongoing effort to better understand our users, we may analyze the Personal Data that is provided to the website in aggregate form. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents and business partners. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
In operating this website, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our website gives to your computer when you access a website. Our cookies help provide additional functionality to the website and help us analyze website usage more accurately. Company cookies do not collect Personal Data, and we do not combine the general information collected through cookies with other Personal Data to identify you personally.
Sharing Information: We won’t share your Personal Data with anyone except for the situations listed below or unless we specifically inform you and give you an opportunity to opt out of our sharing your Personal Data.
We may share your Personal Data with:
- Authorized service providers.
Our authorized service providers are companies that perform certain services on our behalf. These service providers may have access to your Personal Data to the extent necessary to perform their functions, but we do not allow them to share or use any of your Personal Data for any other purpose.
- Turnkey affiliates.
We may share information we collect, including Personal Data, with Turnkey-owned or affiliated businesses. Sharing information with our affiliates enables us to provide you with information about a variety of products and services that might interest you. All Turnkey companies comply with applicable privacy and security laws and, at a minimum, in any commercial email they send to you, will give you the opportunity to choose not to receive such email messages in the future.
- Protection of Turnkey and others.
We may release Personal Data when we believe in good faith that release is necessary to enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others. This includes, without limitation, exchanging information with other companies and organizations for fraud monitoring, detection, and prevention.
- Other Situations.
We also may disclose your information:
- In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
- In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Special Notice to International Visitors and Customers
Privacy laws differ across the globe. This website is hosted in the United States. If you are visiting from other regions with laws governing data collection and use that may differ from U.S. law, including those whose privacy laws may be stricter than U.S. law, please note that you are transferring your personal data to the United States to Turnkey. By providing your personal data, you consent to that transfer.
Storage and Period of Holding for Personal Information
Unless otherwise requested by you, Turnkey will continue to keep the Personal Data you or a third party App Distributor provided to us. If the reason for collecting your personal information no longer exists, we will delete the personal information at the appropriate required time if legally required by relevant applicable data protection law.
The website and Services are not intended for children under 13, and we do not knowingly collect information from children under the age of 13. Children aged 13 or older should not submit any personal information without the permission of their parents or guardians. By using the website and Services, you are representing that you are at least 18, or that you are at least 13 years old and have your parents’ or guardians’ permission to use website and our related services. In the event that we learn that we have collected personal information from a child under age 13 we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, Turnkey cannot ensure or warrant the security of any information you or a third party App Distributor transmits to us and you assume all risks associated with the Personal Data supplied by you or the third party App Distributor. You should note that in using the website and Services, your information will travel through third party infrastructures which are not under our control. Once we receive a transmission of Personal Data, we make reasonable efforts to ensure security on our systems. We use secure server software (SSL) and firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.
If, at any time after registering, (i) you change your mind about receiving information from us or about the use of information volunteered by you, (ii) you need to update or modify any Personal Data, or (iii) you have any other questions or concerns regarding privacy at the website or associated with the Service, please send us a request specifying your new choice at email@example.com. We will make every effort to resolve your concerns.
816 Broad Street Suite 10, Meriden, CT USA 06450