Last Revised August 23, 2017

THE INTURN WEBSITE, APPLICATION AND SERVICE (COLLECTIVELY, THE “SERVICE”) ARE OWNED, OPERATED AND DISTRIBUTED BY SMART SKUS INC., D/B/A INTURN, A DELAWARE CORPORATION (“INTURN,” “WE,” “US” OR WORDS OF SIMILAR MEANING). BY ACCESSING ANY PART OF THE SERVICE, YOU ARE AGREEING TO THE TERMS AND CONDITIONS DESCRIBED BELOW (THIS "PRIVACY POLICY") AND YOU HEREBY CONSENT THAT WE WILL COLLECT, USE, AND SHARE YOUR INFORMATION IN THE FOLLOWING WAYS. YOUR USE OF THE SERVICE IS AT ALL TIMES SUBJECT TO THE TERMS AND CONDITIONS OF THE INTURN TERMS OF SERVICE (THE “TERMS OF SERVICE”). IF YOU DO NOT AGREE TO ANY OF THESE TERMS, YOU SHOULD NOT USE THE SERVICE. THIS PRIVACY POLICY APPLIES TO ALL USERS, INCLUDING BOTH USERS WHO ARE SIMPLY VIEWING THE SERVICE AND USERS WHO ARE PURCHASING OR SELLING (OR PROMOTING THE PURCHASE AND SALE OF) GOODS OR SERVICES THROUGH THE SERVICE.

IF YOU ARE ACTING ON BEHALF OF A COMPANY OR OTHER LEGAL ENTITY, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND SUCH ENTITY AND ITS AFFILIATES TO THIS PRIVACY POLICY, IN WHICH CASE THE TERMS "YOU" OR "YOUR" SHALL REFER TO SUCH ENTITY AND ITS AFFILIATES.

Any terms that we use in this Policy without defining them have the definitions given to them in the Terms of Service.

General

The disclosure of personal information is always a sensitive issue and INTURN takes it very seriously. We consider it our highest priority to protect the privacy of our members. To that end, this Privacy Policy outlines the types of information INTURN collects and how that information is used in the operation of the Service. This Privacy Policy covers our treatment of personally identifiable information ("Personal Information") that we gather when you are accessing or using our Service, but not to the practices of companies we don’t own or control, or people that we don’t manage. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Service, including to personalize, provide, and improve our services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Service. We may also share some Personal Information with third parties, but only as described below. All information that INTURN collects will adhere to this Privacy Policy.

1. What Information We Collect and How We Use It

Most of the benefits of INTURN can only be made available to you if we have certain information about you. To access these services, you will, from time to time, be asked to submit information about yourself and/or your company. You may view and make adjustments to your user information at any time by logging into INTURN and selecting "My Profile".

Registration and Purchase. In order to provide you with an account at INTURN that allows you to sell or purchase products, through you registration and/or your account settings, we may need to collect Personal Information from you such as your first name, last name, email address, username, company name, and password. Certain information may be required to register with us to take advantage of some of our features. In addition, when you view products, place offers on products via the Service we need to collect purchase information, including the price, quantity and types of products that you are interested to purchase. When you register, you will be automatically opted in to receive in-system and email notices, which may include notification if someone sends you a message or sends you a new connection requests, INTURN announcements, notification of new activity, and notices about INTURN. You may opt not to receive commercial emails from us by clicking unsubscribe, but you may not be able to enjoy some of the features of the Service. In addition, you may not opt out of receiving non-commercial notices, such as emails that we deem important for security or administrative purposes.

Service Providers. Information may sometimes be collected by third party service providers with whom INTURN contracts to help provide the Service. INTURN asks such service providers to make the Personal Information available only to INTURN for INTURN to use in accordance with the terms of this policy and not to use the information for any other purpose. INTURN uses this information to allow you to enjoy the functionality of the Service, to troubleshoot and to provide customer support. We also utilize third party service providers to provide products, services or functions on our behalf (such as sending emails or producing analytics), and ask these service providers to agree to maintain the confidentiality of your Personally Information and not to use your Personally Information for any reason except to carry out the purpose(s) for which we hired them.

Personalized Services. Whenever you interact with our Service, we automatically receive and record information on our server logs from your browser or device, which may include your messages, IP addresses, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Service, browsing patterns, and the page or feature you requested. We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Service – for example, this data can tell us how often users use a particular feature of the Service, and we can use that knowledge to make the Service interesting to as many users as possible. We also may use this data to monitor your compliance with the Terms of Service and/or your other agreements with us.

Cookies and Log Files. Like most web sites and interactive services, INTURN collects information using cookies and web log files to track site usage. A cookie is a tiny data file that resides on your computer and allows INTURN to recognize you when you return to our site using the same computer and web browser. Our web log files may contain additional information such as your IP address, the type of browser and version you are using and other information that is not, by itself, personally identifiable.

Cookies are text files that identify your computer to our server. Cookies generally identify a computer used and not a specific individual, recording areas of the site or pages and features in our Service that have been visited by a computer and, how, when, and for how long. Users have the opportunity to set their computers to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. You can, should you chose, disable the cookies from your browser and delete all cookies currently stored on your computer. This may, however, prevent you from taking full advantage of all the Service has to offer.

One type of cookie, known as a "persistent" cookie, is set when you log in to your INTURN account. The next time you use the INTURN Service, the persistent cookie will allow us to recognize you as an existing member so you will not need to log in before using the Service. In order to change your e-mail address or password, however, you will need to re-enter your password even if your computer contains your persistent cookie. Additionally, if you log out of the INTURN site you will need to re-enter your password the next time you visit in order to log in to your account. Another type of cookie, called a "session" cookie, is used to identify a particular visit to the INTURN site. Session cookies expire after a short time or when you close your web browser.

If you click on a link to a third party website or service, a third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Service, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.

Due to the communications standards on the Internet, when you use the INTURN Service we automatically receive the URL of the site from which you came and the site to which you are going when you leave INTURN. We also receive the Internet protocol (IP) address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, as well as the name of your ISP.

Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Service. Just like any other usage information we collect, this information allows us to improve the Service and customize your online experience, and otherwise as described in this Privacy Policy. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites.

2. Disclosure of Your Information

Third Parties. INTURN will not sell, rent, or lease your Personal Information in personally identifiable form to third parties without your explicit consent, unless required by law. We may share your information with third parties under certain circumstances:

  • If sharing your information is necessary to execute a specific request by you. For example, if you engage in any transaction arranged via the Service, or offer to engage in a transaction (e.g., an offer), the other party to that transaction will receive all necessary information. The other party’s use of your information is subject to its own privacy policy, so you should be sure to review the other party’s privacy policy prior to engaging in any transaction with it.
  • If sharing your information is required by law or, in our judgement, is necessary to respond to a subpoena, warrant or court order, to promote public safety, to protect the rights, property, or safety of INTURN, its employees, users, contractual partners, or others, or to enforce or apply our Terms of Service and other agreements.
  • If you request that we share your information which may result in an introduction with a buyer or seller.
  • If you give us explicit permission to share your information for any reason not stated in this Privacy Policy.
  • If your Personal Information has been de-identified. We may de-identify your Personal Information so that you are not identified as an individual or company, and provide that information to our partners. We may also provide anonymized aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Service, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person or a company.

We use Google Analytics to grow our business, to improve or develop our products, to monitor and analyze use of our Services, for our technical administration, to increase the functionality and user-friendliness of our Services, and to verify that users have the authorization needed for us to process their requests. To learn more about the privacy policy of Google Analytics, visit http://www.google.com/intl/en/analytics/privacyoverview.html. You can opt out of the Google Analytics by visiting http://tools.google.com/dlpage/gaoptout.

Other Members. Occasionally you may invite a non-user of INTURN to register with the Service and join your network or group. You also may invite existing INTURN users to join a group or become your direct contact. Upon your invitation request (which will be deemed as your explicit consent for INTURN to contact your invitees), INTURN generates an e-mail message to your invitee that may list information such as your e-mail address, your full name and your headshot photo (if you have provided one). The rest of your contact information will only be shared with the person you invite if both of you have indicated that you would like to establish each other as contacts.

Links to Other Web Sites. If you transfer to a site outside of the INTURN Service, your activity will be conducted on that site, and in accordance with that web site owner’s privacy policy and terms of service. INTURN has no control over those policies, so you should carefully review them before you conduct any business on a third party site. INTURN shall have no liability for any commercial transactions you conduct on a third party's site, and you hereby release INTURN for any claims, liabilities or damages of any nature as a result of such activities.

Your Content. Certain user profile information, including your name, email address, and other information about you or your company, and Your Content may be displayed to other users to facilitate user interaction within the Service or address your request for our services. You may limit the other users who can see the Personal Information in your user profile and/or what information in your user profile is visible to others.

In the Event of Merger, Sale, or Bankruptcy. We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. In the event that INTURN is acquired by or merged with a third party entity, it reserves the right to transfer or assign the information it has collected from users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of INTURN’s bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, INTURN may not be able to control how your Personal Information is treated, transferred, or used, and Personal Information could be one of the assets transferred to or acquired by a third party.

3. Security

INTURN endeavors to protect the privacy of your account and other Personal Information we hold in our records and has implemented security measures to protect member information from loss, misuse and alteration. We use industry-standard practices such as encrypted storage, firewalls and password protection systems to safeguard the confidentiality of your Personal Information. Each of our employees is aware of our security policies, and your information is only available to those employees who need it to perform their jobs. We cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. In the event that you believe your personal or INTURN account information has been compromised, you must notify us as soon as possible.

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

4. Control Over Your Personal Information

The success of INTURN is directly related to your trust in our privacy practices. You can change any of your Personal Information stored on the INTURN that you supplied at any time. You may view and make adjustments to your user information at any time by logging into INTURN and selecting the "My Profile" link. When you update information, however, we may maintain a copy of the unrevised information in our records. In addition, you may cancel your INTURN account by sending us an e-mail support@inturn.co via our Contact page. Some information may remain in our records after your deletion of such information from your account or cancellation of your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

The information you can view, update, and delete may change as the Service change.

5. Users Under Age 18

If you are under the age of 18, you are not permitted to register as a user of the INTURN Service.

We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If 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 a child under 13 may have provided us personal information, please contact us at support@inturn.co.

6. Changes to This Privacy Policy

INTURN may update our privacy policy and reserves the right to do so at any time. The latest version of the privacy policy will always be available at https://www.inturn.co/inturn-privacy-policy so please check this page regularly to make sure you are aware of any updates. Please note that if you’ve opted not to receive notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Service, and you are still responsible for reading and understanding them. By using the Service at any time after a change has been made to our privacy policy, you are agreeing to such changes.

7. Contact Information

If you have questions regarding this Privacy Policy, please contact our privacy staff by email to privacy@inturn.co and we will try to resolve your concerns.

8. Special Note to International Users

The Service is hosted in the United States and is intended for and directed to users in the United States. If you are accessing the Service from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from United States laws, please be advised that through your continued use of the Service, which is governed by U.S. law, this Privacy Policy, and our Terms of Service, you are transferring your Personal Information to the United States and you consent to that transfer.

9. California Privacy Rights

California Civil Code Section 1798.83 permits users of the Service who are California residents to request certain information regarding its disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail with "California Privacy Rights" in the heading to privacy@inturn.co.