Effective Date / Last Revised: November 1, 2022
Turing Medical, Inc. (“Turing Medical,” “our,” “we,” or “us”) respects your right to privacy. This Privacy Notice is intended to inform you of what data is collected through Turing Medical’s www.turingmedical.com website (the “Website”) and our patient onboarding application (the “Application”) (collectively, the “Services”). This Privacy Notice outlines how your information is used, and what measures we take to protect the privacy of your information rights. If you have any questions or concerns about how we might use, share, or protect your personal data or information about your privacy rights, you may contact us using the contact details provided at the bottom of this Privacy Notice.
We recommend that you read this Privacy Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant link below to jump to that section.
In this Privacy Notice, “personal data” or “personal information” means any information relating to an identified or identifiable natural personal. Those terms may also have definitions under applicable data privacy laws. Examples include your name, email address, mailing address, and phone number, as well as certain online identifiers which may be collected by tracking mechanisms (e.g., cookies) on the Services. This definition does not include information that is publicly available.
“Processing” is a term defined under certain privacy laws, but generally means the collection, use, storage, disclosure, transmission, destruction, or alteration of personal data.
In the chart below, we identify the categories of personal data that we collect, the types of data, the purpose for which we collect and use such data, and our legal basis for Processing your personal data.
We generally collect personal data from the following three categories of sources: (1) you provide personal data directly to us, (2) we automatically collect personal data from you when you use our Services (e.g. cookies) or when we provide Services, and (3) we receive personal data about you from third-party sources (e.g. from public sources).
We collect personal data that you provide directly to us. Personal data is required to use certain features of the Services, for example, to download resources, submit job applications, send us questions through our Services, receive or request data from us, and respond to communications from us. We also collect information you provide which may not be considered personal data, such as information about your organization, the team you work on, and what brought you to Turing Medical or its Services.
Online Forms. We collect personal data when you fill out online forms or send other communications through our Services, such as our “contact us” form or when you download resources.
Marketing Communications. We may use your email and mailing address to send you promotional and other electronic and hardcopy communications. We may use third-parties or service providers to deliver these communications to you. You may opt-out of such emails by using the unsubscribe link in the email or contacting us at contact@turingmedical.com with “Unsubscribe” in the subject line. To opt-out of other communications (e.g., postal marketing), please contact us as set forth in the “Contact Us” section below. Opting out of marketing communications does not opt you out of other, non-marketing communications from us.
Feedback. When you provide comments or feedback about our Services, the content on the Services, or our products or Services (“Feedback”), we will not treat that Feedback as confidential. We may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.
If you choose to submit information pursuant to our #HowToSucceed campaign, you understand that we may use your picture, a video of you and your statements about Turing Medical publicly, including posted on our Site, without compensation owed to you. We may shorten or modify any statements you make or videos you provide in order to fit within a certain word count or time length for posting on our Site.
Business Contracts. If you enter into a business relationship with us, we may use information collected about you in accordance with any contract agreed to between you and us. If your employer purchased access to our products or services, the personal data we received directly from that employer is used pursuant to our contract with that employer; however, any information we collect from users of the Services (including employees of such employers) is used in accordance with this Privacy Notice.
If any part of the Site links you to other websites, those websites DO NOT operate under this Privacy Notice, but are linked for your convenience only. We recommend you read the privacy notices posted on those websites to understand their procedures for collecting, using, and sharing personal data.
When you visit the Services, we automatically collect certain information from you through use of cookies and other online tracking mechanisms.
Usage data is collected automatically when using the Service, such as your device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access the Services by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address or device ID of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.
We use cookies and similar tracking technologies to track the activity on Our Service and store certain information. Cookies and other tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. The technologies we use may include:
Cookies can be “Persistent” or “Session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while Session cookies are deleted as soon as you close your web browser. Learn more about cookies: What Are Cookies?.
We use both Session and Persistent cookies for the purposes set out below:
Google Analytics
We also may utilize Google Analytics, a web analysis service provided by Google, to better understand your use of the Services. Google Analytics collects information such as how often users visit the Services, what pages they visit and what other websites they used prior to visiting. Google uses the data collected to track and examine the use of our websites, to prepare reports on its activities and share them with other Google services. Google may use the data collected on our website to contextualize and personalize the ads of its own advertising network. Google’s ability to use and share information collected by Google Analytics about your visits to our website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download and install the Google Analytics Opt-out Browser Add-on for each web browser you use. Using the Google Analytics Opt-out Browser Add-on does not prevent the use of other analytics tools. To learn more about Google Analytics Cookies, visit Google Analytics Cookie Usage on Sites.
Opting Out of Certain Cookies
Additional information on opting out of certain online cookies is as follows:
Your mobile device may give you the ability to opt out of the use of information about the apps You use in order to serve you ads that are targeted to your interests:
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
Non-essential Cookies
We may use other non-essential cookies to display advertising or analyze your use of the Services. Browser-specific guidance on how to manage non-essential cookies, including steps to disable or delete, may be found here for: (i) Google Chrome; (ii) Microsoft Edge; (iii) Mozilla Firefox; and (iv) Safari.
We obtain data about individuals from our strategic partners, referral sources, various third-party companies, and public sources. We may combine that data with personal data or other data we collect from you. This enhances our existing data about our customers and Services users, improves our ability to contact you, and enhances our marketing capabilities. If you sign-up for a Turing Medical event through a third-party website, that third party may share certain personal data about you with us. We also receive contact information of prospective new customers from current Turing Medical customers if someone refers a contact to us.
In addition to the uses described throughout this Privacy Notice, we use personal data for the following purposes:
As Stated or Agreed to at the Point of Collection. We may use personal data for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use personal data to respond to your questions, comments, or complaints. We may also use personal data as requested or consented to by you.
Administration. We use personal data for administrative purposes, such as to manage our Services, inform our business strategies, to understand the demographics of our Services and user preferences, for evaluating applications, to live chat with you, and to provide you materials or resources that you requested or that we think may interest you.
Management of Services and Services Improvement. We use personal data to manage the Services, such as troubleshooting problems, improving the content and functionality of the Services, statistical and other analyses of the Services, and to customize the Services to you and our users. We may also use your personal data to improve our Services and customer service efforts, and to develop new products or Services.
Advertising and Notice. We may use personal data to send you newsletters, promotions or to perform targeted advertising, to notify you of new Services, products or programs, to notify you of new features of our Services, to notify you of changes to our Terms [hyperlink] or this Privacy Notice, and for other similar communications. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email we send or by contacting Us.
To Protect Our Rights. We may use personal data to protect our legal rights or interests, or those of third parties, including to bring a legal action against you or anyone who may be causing harm to us, our Services, or to other users of the Services. We may also use personal data to address any claims or counterclaims, to seek business, financial or legal advice, and to respond to other legal requests.
We may share your personal data with the following categories of third parties and/or service providers:
Employees, Affiliates and Subsidiaries. We may share your personal data with our employees, affiliates and subsidiaries who have a need to know the information for our business purposes. If you are a Turing Medical employee or independent contractor, other employees can see certain information about you, such as contact information and employment information, through Turing Medical’s HR platform.
Service Providers and Third Parties. We may share personal data with service providers that provide services for us. For example, we may share personal data with service providers that help us host and manage the Services; maintain physical storage for paper files and documents; provide targeted advertising and other marketing; improve the content and functionality of the Services; perform data analysis and statistical analysis; troubleshoot problems with the Services; provide public relations; provide email services; support delivery of our Services and products, provide data processing; and support or provide the security of the Services. We may also share personal data with third parties such as event sponsors, referral partners and other strategic partners of Turing Medical.
Specifically, use an email marketing sending service provided by The Rocket Science Group LLC. For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/.
Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose personal data: (i) if we believe in good faith we are legally required to disclose that personal data, (ii) if we are advised to disclose personal data by our legal counsel, or (iii) when necessary to identify, contact, respond to or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Turing Medical or any other party.
Professional Advisors. We may share personal data with certain professional advisors, such as our attorneys, accountants, financial advisors, and business advisors, in their capacity as advisors to Turing Medical.
Business Transactions. We may use your personal data in connection with certain business transactions, including the purchase, sale, merger, rental, combination or any other type of business acquisition, transfer, disposition, and securitization of financing as well as in connection with any bankruptcy or similar insolvency proceeding, including as part of any related due diligence process.
Other. We may share personal data with third parties or service providers when explicitly requested by or consented to by you, or for the purposes for which you disclosed the personal data to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
Special Categories of personal data. “Special Categories of personal data” is any data that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of identifying a person, data concerning health or a person’s sex life and/or sexual orientation, and any other data that is considered “sensitive data” under applicable law. Except as described above when you apply to work with Turing Medical, we do not knowingly collect Special Categories of personal data from you. Your provision of Special Categories of personal data, or other sensitive data, is not mandatory; however, we may not be able to consider you for employment with Turing Medical if you do not provide certain, requested information. Please refrain from sending Special Categories of personal data to us unless requested during your job application process.
Information from Minors. We do not knowingly collect personal data from persons under the age of majority in their place of residence (typically 18 years old) via these Services. Do not send us personal data if you are under the age of majority. If you are a parent or guardian and you believe your child provided us with their personal data, you may contact us as described in the “Contact Us” section below and we will make good faith efforts to delete that data if and as required by applicable law.
Various jurisdictions have different privacy laws giving their residents certain rights. These rights may include any of the following. We will comply with applicable data laws to provide you any rights that you may have under the laws of the country or state in which you reside that are applicable. We may require you to prove your identity before we respond to your request. If there are any country or state specific sections that apply to you at the end of this Privacy Notice, those sections shall control in the event they conflict with or are inconsistent with this section.
How to Exercise Your Rights. To exercise any rights you have under privacy laws that apply to you, please contact us. We will respond to your request within a reasonable period of time. Requests may be denied pursuant to applicable law or if certain exceptions under applicable law apply. Ways to contact us include:
Toll Free: 844-668-7464
Email: contact@turingmedical.com
Turing Medical will not be able to provide some Services or provide you with access to certain parts of the Services without processing certain personal data. For example, we need to collect contact information from you when you request additional information from Turing Medical regarding our Services.
Turing Medical will only keep your personal data for so long as it has a reasonable business purpose for doing so or where we are required to keep it by applicable law.
Turing Medical may collect, use, share, transfer, create and otherwise Process de-identified and aggregated information for any purpose in compliance with applicable laws. Turing Medical is the sole and exclusive owner of such de-identified and aggregated information, including if Turing Medical de-identifies personal data so that it is no longer considered personal data under applicable laws
We are active on social media. The Services may allow you to connect and share data with social media platforms. These features may require us to use cookies, plug-ins, and APIs provided by such social media platforms to facilitate those communications and features. The Services may also use advertising networks and services offered by social media platforms to deliver advertising content. Use of these services requires the applicable social media platforms to implement cookies or pixel tags to deliver ads to you while you access Services.
Anything you post on social media is public information and will not be treated confidentially. We may post (or re-post) on the Services and our social media pages any comments or content that you post on our social media pages. Your use of social media is governed by the privacy policies and terms of the third parties that own and operate those websites and not by this Privacy Notice. We encourage you to review those policies and terms before using any social media features provided through our Services or third-party websites.
We make many efforts to protect your personal data by implementing technical and organizational security measures designed to protect your personal data. These technical and organizational measures are designed to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration of your personal data appropriate to the type of personal data processed. If a breach of your personal data occurs, we will notify you of the breach if and as required under applicable law.
HOWEVER, NO DATA TRANSMISSION OVER THE INTERNET OR A DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL DATA, WE DO NOT GUARANTEE THE SECURITY OF ANY PERSONAL DATA AND YOU PROVIDE PERSONAL DATA AT YOUR OWN RISK.
If you access the Services from outside the United States, please be aware that personal data may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of personal data in the United States to be equivalent to that required in other jurisdictions.
The European Union (EU) and the United Kingdom (UK) specifically have determined that the United States does not have an adequate level of protection for personal data. Further, certain countries require that personal data transferred to other countries can only occur if the recipient resides in a country with materially similar data protection laws. Given that the U.S. does not have data protection laws in every state that provide a materially similar level of protection of personal data as certain other countries, Turing Medical uses (1) the Standard Contractual Clauses in transferring personal data of EU or UK citizens across international borders or other approved methods by the EU, and (2) other data transfer agreements that may be required by other jurisdictions to transfer personal data across country or state borders. You may request a summary of the appropriate safeguards or seek inquiries regarding such safeguards by contacting us at contact@turingmedical.com. We will respond to your request or inquiry within a reasonable time period.
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The CCPA and Personal Information. If you are a California resident, you may have additional rights (or different rights than described above) under the California Consumer Privacy Act, as amended, and its implementing regulations (the “CCPA”). Although the terms “personal information” and “personal data” can often be used interchangeably, in this section when referring to “personal information”, we are referring to how that term is defined under the CCPA.
Collection, Source, Purpose and Sharing of Personal Information. To view the [hyperlink: categories of personal information we collect], the [hyperlink: sources from which personal information is collected], the [hyperlink: purposes for which we collect personal information], and the [hyperlink: categories of third parties and/or service providers with whom we share personal information], please click on the applicable hyperlink in this paragraph, or see the applicable section in this Privacy Notice above. We do not collect Sensitive Personal Information as contemplated by CCPA.
Selling or Disclosing Personal Information for a Business Purpose.
In the last 12 months we sold, or disclosed your personal information for a business purpose, if indicated below. See the section above titled “Personal Data We Collect” [hyperlink] for more detail on the type of personal information in each category.
Data Retention. For information on our data retention practices, see the section above titled “Data Retention”
Your Rights to Opt-Out of the Sale of Personal Information.
We do not sell your Personal Information to other companies for money. We do share personal information with certain companies to help us and them advertise to you, and as part of our strategic partner and referral relationships. Under California law, this sharing of personal information is considered the sale of Personal Information.
California residents may direct us not to “sell” or “share” their Personal Information at any time (this is your right to “opt-out”). However, Turing Medical does not “sell” or “share” Personal Information.
To opt-out online, please use the following web-form: [insert link]. Other ways you may opt-out include:
Your Rights to Access and Deletion. California residents have the right to request certain information or request deletion of their personal information. Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, California residents may exercise the following rights with regard to their personal information:
Right to Access. You have the right to access any of the following which occurred in the prior 12-month period: (a) the categories of personal information we collected from you, (b) the categories of sources from which the personal information was collected, (c) the business or commercial purpose for collecting or selling your personal information, (d) the categories of third parties with whom we shared your personal information, (e) the specific pieces of personal information we collected from you (i.e. “data portability”), and (f) a list of categories of personal information we sold or disclosed for a business purpose in the last 12 months.
Right to Request Deletion. You have a right to request that we delete personal information we collected from you. We will comply with such requests, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.
How to Exercise Your Rights of Access and to Request Deletion. To exercise your California rights described in this Section, you may submit your request to us by contacting us at any of the following:
Verifiable Consumer Request. In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information.
When we receive your request, we may ask you to provide additional information to verify your identity, including personal information. We will only use personal information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we may decline to comply with your request, and will let you know why.
When We Will Respond. We will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select the format to provide such personal information. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.
Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under the CCPA. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this section.
Who May Exercise Your Rights? You may only make a request to exercise your rights on behalf of yourself. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. If you choose to use an authorized agent, you must (a) provide signed permission to that authorized agent to submit requests on your behalf, (b) verify your identity directly with Turing Medical, and (c) directly confirm with Turing Medical that you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent. We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf. Furthermore, a parent or legal guardian may make a request on behalf of their child. CALIFORNIA’S “DO NOT TRACK” REQUIREMENT. WE DO NOT REACT TO “DO NOT TRACK” OR “DNT” BROWSER SIGNALS AT THIS TIME.
Canada. This Section provides additional terms and conditions that apply to residents of Canada under the Personal Information Protection and Electronic Documents Act (PIPEDA). The term “Personal Information” as used below has the meaning give that term under PIPEDA.
Your Rights. Under Canadian privacy laws you have the right:
We may require that you provide information verifying your identity before we provide this requested information to you. To obtain such information, please email your request to contact@turingmedical.com.
Legal Disclosures and Lawful Requests. We and our Canadian, U.S. and other foreign service providers and affiliates may disclose your Personal Information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your Personal Information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Mexico. This Section provides additional terms and information that apply to residents of Mexico pursuant to the Federal Law on Protection of Personal Data in the Possession of Private Parties (Ley Federal de Protección de Datos Personales en Posesión de Particulares) (“LPPD”). Subject to the LPPD, you have a right to access, rectify, cancel, and object to the processing of your personal data, which are called your “ARCO Rights.” See the main body of this Privacy Notice for a more detailed description of these rights and how to exercise them. If you believe that your right to protection of your personal data is improperly used in violation of the LPPD, you may reach out to Mexico’s INAI with an official complaint. For more information, please visit their website at www.inai.org.mx.
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on the Site. We will conspicuously provide notice if we make any material changes to this Privacy Notice or otherwise communicate such updates to you.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
Translations to this Privacy Notice may be provided; however, in the event of conflict between the English version and any other version of this Privacy Notice, the English version shall control unless the laws of your country of residence require otherwise.
If you have any questions or concerns about our use of your personal data, please contact the Vice President of Legal, using the following details: contact@turingmedical.com; 844-668-7464.
Data Controller:
Turing Medical, Inc.393 N. Euclid Ave, Suite 310Saint Louis, MO 63108
contact@turingmedical.com
