The Neutral Privacy Policy

Last modified: May 26, 2020

Introduction

Turbine Corporate Holdings, Inc., doing business as “Turbine Labs” (the “Company”, “Turbine Labs”, “we”, or “us”), respects your privacy and is committed to protecting it through our compliance with this Privacy Policy.

If you choose to use certain Turbine Labs digital products displaying or otherwise governed by this Privacy Policy, including theneutral.com (the “Website”), our mobile sites and applications, and any of the features of the Website, including but not limited to our content, RSS feeds and APIs, and other downloads (collectively, the “Services”), you will be agreeing to abide by this Privacy Policy. Furthermore, you agree to be bound by our Terms of Use, found at https://theneutral.com/terms-and-conditions/, incorporated herein by reference. If you do not want to agree to this Privacy Policy or the Terms of Use, you must not access or use the Services.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you access the Services, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy applies to information we collect:

  • On the Services.
  • In email, text, and other electronic messages between you and the Services, including our email newsletters.
  • Through mobile and desktop applications you download provided by the Company, which provide dedicated non-browser-based interaction between you and the Services.
  • When you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this Privacy Policy.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using the Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

Privacy and Children

This Services are intended for a general audience, and are not directed at children. We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act (“COPPA”)) in a manner not permitted by COPPA.  If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at info@theneutral.com. We will remove the data to the extent required by applicable laws.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Services, including information:

  • By which you may be personally identified, such as name, e-mail address, and telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
  • That is about you but individually does not identify you; and/or
  • About your internet connection, the equipment you use to access our Services and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the Services. Information collected automatically may include usage details, IP addresses, browser type and language, prior websites visited, pages viewed, access times, location data, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties, for example, our business partners.

Information You Provide to Us 

The information we collect on or through our Services may include:

  • Information that you provide by filling in forms through the Services. This includes information provided at the time of registering to use our Services, subscribing to our service, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Services.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Services and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Services.
  • Your search queries on the Services.


Information We Collect Through Automatic Data Collection Technologies
.

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Services.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically does include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Services according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Services.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.
  • Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of our Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).


How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Services and its contents to you.
  • To operate, maintain, and improve our sites, products, and Services.
  • To provide you with information, products, or services that you request from us.
  • To respond to comments and questions and provide customer service.
  • To send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
  • To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
  • For direct marketing of our goods and Services.
  • To process and deliver contest entries and rewards.
  • To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.


Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Turbine Corporate Holdings, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Turbine Corporate Holdings, Inc. about our Services users is among the assets transferred.
  • To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Services, we will transmit the contents of that email and your email address to the recipients.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Turbine Corporate Holdings, Inc., our users, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by checking the relevant box located on the form on which we collect your data (the order form). You can also always opt out by checking or unchecking the relevant boxes or by sending us an email stating your request to info@theneutral.com.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Services and visiting your account profile page. You may also check boxes to opt in or out of the ways in which your personal information is used through your account profile page and through checking or unchecking the appropriate boxes on our account registration form and order form. Emails received from the Company will include a link for unsubscribing, which directs the recipient to the Company’s unsubscribe landing page and questionnaire.

You may also send us an email at info@theneutral.com to request access to, correct, or delete any personal information that you have provided to us. We may only be able to delete your personal information by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

You can opt out of text alerts at any time by replying “STOP” or any alternative keyword we have shared with you.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. The date the Privacy Policy was last modified is identified at the top of the page. You are responsible for periodically visiting our Services and this Privacy Policy to check for any changes.

Third Parties

The Services may contain links to other websites, mobile applications, and other online services operated by third parties, and other websites, mobile applications, and online services operated by third parties may contain links to our Services. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions of their privacy policies. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information.  We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

We rely on third parties to provide many features of our Services using data about your use of our Services and of other websites. These third parties may use cookies, web beacons, or other technologies to collect and process your personal data for the purposes of information storage and access; personalization of our Services; measurement of and analytics regarding the use of our Services; content selection, delivery, and reporting; and advertising selection, targeting, delivery, and reporting.

For instance, third party analytics services use cookies, web beacons, and other tracking technologies to collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website, in order to help us analyze how users interact with and use the Services, compile reports on the Services’ activity, and provide other data and insights related to the Services’ usage.

In general, the information collected and generated by third parties is processed and stored by the third parties and will be subject to their respective privacy policies (which we do not control and for which we are not responsible).  We do not control these third parties’ tracking technologies or the information they may collect.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transaction will be encrypted using SSL technology by our third party payment processor.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

Data Retention

We only keep your information for so long as it is reasonably necessary. When setting our data retention periods, we consider the amount, nature, and sensitivity of the information we hold, the potential risk of harm from unauthorized use or disclosure of the information and the purposes for which we process the information (including whether we can achieve those purposes by other means). We also take into account our other legal obligations to keep or securely dispose of personal information.

Data Transfer

Turbine Labs is headquartered in the United States. If you are located outside the United States, your information is collected in your country and then transferred to the United States.

If we transfer your data out of the European Economic Area (the “EEA”), we implement at least one of the three following safeguards:

  • We transfer your information to countries that have been recognized by the European Commission as providing an adequate level of data protection according to E.E.A. standards (see the full list of these countries).
  • We use a service provider in the United States that is Privacy Shield certified.
  • We take steps to ensure that the recipient is bound by E.U. Standard Contractual Clauses to protect your personal data. You can see a copy of these clauses.

In certain situations, the courts, law enforcement agencies, regulatory agencies or security authorities in those countries might be entitled to access your personal information.

Information for European Union Residents: Your EU Privacy Rights

If you are located in certain countries, including Switzerland or those countries that fall under the scope of the European Union’s General Data Protection Regulation (“GDPR”), data protection laws give you rights with respect to your personal information, subject to any exemptions provided by the law, including the rights to:

  • Request access to your personal information;
  • Request correction or deletion of your personal information;
  • Object to our use and processing of your personal information;
  • Request that we limit our use and processing of your personal information; and
  • Request portability of your personal information.

You can access, correct, or delete your personal information using your account profile, but if you aren’t able to do so, or you would like to contact us about one of the other rights, please refer to Contact Information below. European Union and Swiss individuals also have the right to make a complaint to a government supervisory authority.

Personal information collected on or about users located in the European Union and the EEA is collected on the following legal bases of processing:

  • Necessary for Performance of a Contract: If we or our affiliates have entered into a contract with you, partners, suppliers or other third parties, we may need to process your personal information.
  • Consent: Where you have provided your consent for us to engage in marketing activities with you or otherwise process your data, we may need to process your personal information.
  • Legitimate Interest: We may need to process your personal information where we have a legitimate interest in doing so, such as (1) to communicate with you in response to your requests, questions, inquiries and submissions; (2) to conduct advertising, marketing and promotional activities in connection with operating our business; (3) for research and development, security and optimization of our Services; and (4) preventing fraud.
  • Comply with Legal Obligations: Where we are required to comply with laws or legal obligations, such as to comply with a subpoena or other legal process, or to process an opt-out request.

Information for California Residents: Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (“CCPA“) requires us to disclose the following information with respect to our collection, use and disclosure of personal information.

  • Categories of Personal Information Collected: In the preceding 12 months, we have collected the following categories of personal information: identifiers, personal information categories listed in the California Customer Records statutes, commercial information, and internet or other similar network activity. For examples of the personal information we collect, please see Information We Collect About You and How We Collect It and Information You Provide To Us above.
  • Business or Commercial Purpose for Collecting and Using Personal Information: We collect personal information for the business purposes described in How We Use Your Information above.
  • Categories of Sources of Personal Information: We collect personal information directly from you, automatically, and from other sources, each of which is more particularly described in Information You Provide To Us and Information We Collect Through Automatic Data Collection Technologies above.
  • Categories of Personal Information Disclosed: In the preceding 12 months, we have disclosed the following categories of personal information for business or commercial purposes: identifiers, personal information categories listed in the California Customer Records statutes, commercial information, and internet or other similar network activity.
  • Categories of Third Parties with whom We Share Personal Information: We may share your personal information with the third parties as described in Disclosure of Your Information above.
  • Sale of Personal Information: Turbine Labs does not sell your personal information.

Your Consumer Rights

California consumers have the right to request access to their personal information, additional details about our information practices and deletion of their personal information (subject to certain exceptions). We describe how California consumers can exercise their rights under the CCPA below. Please note that you may designate an authorized agent to exercise these rights on your behalf by providing written materials demonstrating that you have granted the authorized agent power of attorney. Please note that if an authorized agent submits a request on your behalf, we may need to contact you to verify your identity and protect the security of your personal information.

  • Right to Know: You may request access to the specific pieces of personal information we have collected about you in the prior 12 months. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the sources of such collection, the categories of personal information we share for a business or commercial purpose, the categories of third parties with whom we share your personal information, and the specific pieces of personal information we collected about you (also called a data portability request). We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.
  • Deletion: You may request that we delete the personal information we have collected about you. Please note that we may retain certain information as required or permitted by applicable law, and we may deny your deletion request if retaining the personal information is necessary for us or our service providers under one of the nine statutory exceptions listed in Cal. Civ. Code § 1798.105, as amended by AB 1146. We are required by law to verify your identity prior to deleting your information in order to protect your privacy and security. If you request to delete your personal information, certain of our products and services may no longer be available to you.
  • To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us in writing or via email as set forth in Contact Information below. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
  • “Shine the Light” Disclosure: In accordance with the California Shine the Light law, California residents may request certain information regarding our disclosure (if any) of personal information to third parties for their direct marketing purposes. Other than to third party recipients as set forth in Disclosure of Your Information above, or unless you request us to or consent to it, we do not share your personal information with third parties for their own direct marketing purposes. For any questions on these practices, please contact us as set forth in Contact Information below.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; and/or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

6465 Greenwood Plaza Blvd., Suite 575
Greenwood Village, CO 80111

info@theneutral.com

To register a complaint or concern, please email us at info@theneutral.com.