Privacy Policy

Privacy Notice

Last Updated: 13 June 2023

We (“we,” “us,” or “our”) respect your privacy. This Privacy Notice explains how we, and our affiliates, collect, use, disclose, and protect Personal Information (defined below), and your choices about the collection and use of Personal Information.

This Privacy Notice applies to Personal Information collected or processed by or on behalf of Pixlee TurnTo, Inc., and its affiliated companies (including without limitation TurnTo Inc., (collectively, “Pixlee/TurnTo”) via our websites, apps, social media pages, or other platforms that link to this Privacy Notice (collectively, the “Site”).

1. Types of Personal Information We Collect and Use

“Personal Information” is information that identifies or relates to a particular individual.  Examples of Personal Information include, among others, name, email address, phone number, mailing address, and online identifiers.

As described in more detail below, we collect Personal Information from you in two ways – when you voluntarily submit Personal Information through a form on the Site; and through information we automatically collect when you use the Site.

A. Information that You Provide Us

In various places on the Site we may request information from you, for example via forms we ask you to complete. The exact Personal Information we need to collect will depend on the purpose for which we request it.

• ‍Registration and Profile Information. When you register to use our Services or update your profile, we collect various kinds of information about you including, your name and email address; your title, company and other profile information you provide; demographic information; information about your skills and preferences (if you are an influencer); and information you upload like photos, files, and documents. ‍
• Contact Information. We collect the email addresses you provide for contacts you enter or upload into your private contacts page. When you choose to collaborate or share files with others, we also collect email addresses you provide to email invitations to those individuals on your behalf. ‍
• Payment Information. If you choose to use a paid Pixlee/TurnTo account or service, our payment processing vendor collects your credit card information and billing address.‍
• Content Related Information. When uploading pictures, a name and an email address may be required. Generally, the information we collect helps us to communicate with you regarding content that you have submitted through the Site. For instance, we may use your email address to notify you of the status of the content you have submitted. ‍
• Social Media Profile. For certain services (including Pixlee.me), you can connect your social media account to your Pixlee/TurnTo profile. If you do so, we may collect Personal Information relating to your use of the service. For example, to help connect you with brands on Pixlee.me, we collect data such as number of followers, profile description, and your image, depending on the social media service's API and your security settings for that service. If you continue to authorize us to access your social media data, we will periodically retrieve new data to update your profile.

We will indicate whether a particular field of Personal Information we ask you to provide is mandatory or optional. If you choose not to provide certain Personal Information, we may not be able to provide requested services.

B. Information We Automatically Collect from You

We collect the following types of information automatically through your use of the Site:

• Cookies, Device Identifiers, and Similar Technologies

When you use or access the Site, we and our service providers use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect information about how you use the Site.  We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of the Site, to enhance your experience through personalization, and to help us better understand the features of the Site that you and other users are most interested in.

Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Site may not be available or some functionality may be limited or unavailable.  Please review the help pages of your browser or mobile device for assistance with changing your settings.

Some of our service providers or plug-ins may use cookies or other methods to gather information regarding your use of the Site, and may combine the information in these cookies with any Personal Information about you that they may have.  The use of such tracking information by a third party depends on the Privacy Notice of that third party.  We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.

We use YouTube API Services (see https://developers.google.com/youtube/terms/api-services-terms-of-service for more details). When using Google services (e.g. YouTube), you can manage and revoke our access to your data contained in the Google services via the Google Security Settings page at https://myaccount.google.com/permissions.

• Analytics

To assist us with analyzing our website traffic through cookies and similar technologies, we use analytics services, including Google Analytics.  For more information on Google Analytics’s processing of your information, please see the Google Privacy Policy. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

• Log File Information

When you use the Site, our servers may automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g.,the site you visited before coming to our Site), domain names associated with your internet service provider, information on your interaction with the Site, and other such information (collectively, “Log File Information”). We may also collect similar information from emails sent to you which then help us track which emails are opened and which links are clicked by recipients.

We use Log File Information collected from our implementation of the Site to help secure the Site by identifying potential threats and vulnerabilities and in analyzing the effectiveness of our Site to improve the Site’s function and content.  

In addition, we may track the photos you like on the Site to provide you with better service. We use this information for internal system administration, to help diagnose problems with our server, and to administer the Site. Such information may also be used to gather demographic information, such as country of origin and Internet Service Provider. We may link this information with your Personal Information.

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2. How We Use Personal Information

We use Personal Information the following purposes: 

• Responding to your inquiries and customer service requests;
• Making the Site available to you;
• Analyzing, administering, and improving the Site;
• Enabling secure use of the Site and preventing fraud;
• Sending information and personal promotional materials (e.g. newsletters and service updates);
• Protecting our rights or our property;
• Meeting our legal obligations; and
• For other purposes related to the reasons for which you provide Personal Information.

We will retain your Personal Information for at least as long as necessary to fulfill the purposes for which your Personal Information has been collected as outlined in this Privacy Notice or any longer retention period required by law.

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3. Disclosure of Personal Information

We will not disclose Personal Information except as set forth in this Privacy Notice or with your consent. This Section describes to whom we disclose Personal Information and for what purposes.

• Affiliates. We disclose Personal Information to our affiliated businesses. Our affiliated business may use Personal Information in accordance with this Privacy Notice, including for those affiliates' marketing purposes.
• Our Service Providers. We engage service providers to perform tasks on our behalf and to assist us in operating the Site and providing our services. For example, we engage third parties to provide analytics services, send newsletters, and maintain Site functionality. We take commercially reasonable steps to help ensure our service providers provide at least the same level of protection for Personal Information as we do.
• Our Customers. If you are an influencer, you may use our Pixlee.me service to disclose information to brands (our customers) that may hire you to promote their brands and products based on your skills, demographics, and other attributes.
• Companies Involved in Mergers and Acquisitions Transactions.  If we sell or otherwise transfer part or the whole of our business or assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), any information collected through the Site, including Personal Information, may be among the items sold or transferred.
• Law Enforcement, Government Agencies, and Courts. We may disclose Personal Information at the request of law enforcement or government agencies; in response to subpoenas, court orders, or other legal process; to establish, protect, or exercise our rights; to defend against a legal claim; to protect the rights, property, or safety of any other person; or as otherwise required by law.

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4. How We Protect the Confidentiality of Personal Information

We use our commercially reasonable efforts to protect the confidentiality and security of Personal Information we process.

Despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information. We do not represent or warrant that Personal Information about you will be protected against, loss, misuse, or alteration by third parties.

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5. Accessing, Updating, or Deleting Personal Information

If you would like to access, update, or delete Personal Information about you, you may submit a request using the contact information in Section 12, below. We will promptly review all such requests in accordance with applicable law.

If you are a resident of California, please see the information below in Section 13 (California Residents) for more information regarding your rights.

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6. Opting Out of Receiving Electronic Communications

We may send newsletters, notifications, promotions, or other information via email ("Communications"). You may choose to stop receiving Communications by clicking on the unsubscribe link at the bottom of our emails. Please note that certain Site-related Communications are necessary for the proper functioning and use of the Site (e.g. to send you emails following your booking inquiry) and you may not have the ability to opt out of those Communications.

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7. International Use of the Site

If you are using our websites from outside the United States, please be aware that Personal Information will be collected, stored, and processed in the United States. Please be aware that the data protection laws of the United States might not be as comprehensive as those in your country.

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8. Children's Privacy

We do not knowingly collect or solicit any Personal Information from children.  In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information.

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9. Other Websites and Sites, Including Social Media

We are not responsible for the practices employed by any websites or services linked to or from the Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s privacy notice.

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11. Your Rights

Depending on your relationship with us, certain rights may apply with respect to your personal data. Please contact us using the information in Section 12 for more information about your rights, and how to exercise them.

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12. How to Contact Us

If you have any questions about this Privacy Notice or the Site, please submit a request using the following information:

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Email: legal@pixleeturnto.com

Phone: (415) 429-3703

By Mail: 

Pixlee TurnTo, Inc.

2443 Fillmore Street, #380-18365

San Francisco, CA 94115

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Toll-Free Number for California Residents: (855) 474-9533

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13. California Residents

This Section applies to our collection and use of “Personal Information” if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).  When we use the term “Personal Information” in the context of the CCPA, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.

If you would like to receive a copy of this Section in an alternate format (e.g. printable) or language, please contact us using the information provided in Section 12 above.

A. Categories of Personal Information Collected, Used, and Disclosed

In accordance with California law, we collected and disclosed the following categories of Personal Information within the past 12 months:

• Identifiers: A real name, Internet Protocol address, or email address,
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): e.g., a  name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories
• Internet or other similar network activity: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
• Geolocation data: Physical location or movements.
• Inferences drawn from other Personal Information: Profile reflecting a person's preferences, characteristics, psychological trends,  predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.  
• Protected classification characteristics under California or federal law:  Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex(including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
• Professional or employment-related information: Current or past job history or performance evaluations.

We disclose each of these categories of Personal Information to our service providers to the extent necessary for them to facilitate our business purposes (including any purpose specified in Section 2, above).  Additionally, some of our online advertisers may have used and disclosed Usage Information collected automatically from the Service.  Regardless of whether this is a “sale” of Personal Information as defined by California law, we provide you the right to opt out of cookies used for online behavioral advertising as described in Section 1(B), above.

In the last 12 months, we do not have knowledge that we sold any Personal Information of California Consumers, nor actual knowledge that we sold the Personal Information ofCalifornia Consumers under the age of 16 years old. The CCPA defines “sale” as:  selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information to another business or third party for monetary or valuable consideration.  

If we do sell your Personal Information, we will notify you, and if you submit to us a verifiable consumer request using the contact information in Section 12 above, we will disclose to you a list containing the categories of Personal Information that we sold in accordance with the CCPA’s requirements.  

B. Your California Privacy Rights

If you are a resident of California, you have the following rights: 

• Right to Know. You may have the right to request information on the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You also have the right to request information on the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.
• Right to Delete.  You may have a right to request us to delete Personal Information that we collected from you.

If you would like to exercise your rights listed above, please contact (or have your authorized agent contact) us the contact information provided in Section 12, above. When doing so, please tell us which right you are exercising and provide us with contact information to direct our response.

We must verify your identity before fulfilling your requests.  If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.  

We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes (e.g., tax accounting).  You have a right not to receive discriminatory treatment by any business when you exercise your California privacy rights.

The CCPA gives California Consumers the right to lodge a complaint with the California Attorney General’s office. The Attorney General’s office may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or by telephone at: (916) 210-6276.

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14. Individuals in the EU

In this Section, we provide additional information relating to how we processPersonal Information of individuals in the European Union and the United Kingdom, in accordance with the European Union’s General Data Protection Regulation and the UK General Data Protection Regulation (“GDPR”).  If you need more information or would like to exercise your rights under the GDPR, you may contact us at gdpr-requests@pixleeturnto.com or by using one of the methods listed in Section 12 above.

A. Basis for Processing

Our legal basis for collecting and using the Personal Information described in this Privacy Policy will depend on the Personal Information concerned and the context in which we collect it.  We collect Personal Information from you:

• where we need Personal Information to perform a contract with you;
• where the processing is in our legitimate interests;
• where the processing is necessary for us to meet our applicable legal obligations; or
• if we otherwise have your consent.

B. Your Privacy Rights

Depending on applicable law, you may have the right to: 

• Request access to Personal Information about you.
• Request correction of the personal information that we hold about you.
• Request erasure of Personal Information about you. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of Personal Information about you where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom.
• Request restriction of processing of Personal Information about you. You can ask us to suspend the processing of Personal Information in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of Personal Information to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process Personal Information about you.

If you wish to exercise any of these applicable rights, please contact us at privacy@pixleeturnto.com.

Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information. We encourage you to first reach out to us at legal@pixleeturnto.com, so we have the opportunity to address your concerns directly before you do.