The Turn Lab Inc. (“theturnlab”) respects the privacy of those who provide us with their personal information, whether they provide it to us directly when visiting our website, when engaging our services, or whether they provide it to us by responding to our own marketing initiatives or the marketing initiatives that we perform on behalf of our clients.

The purpose of this privacy policy is to disclose to you the type of personal information we gather, how we gather it, what we use it for, and inform you of the choices that you have in our use of your personal information.

The Personal Information Protection and Electronic Documents Act is legislation enacted by the Canadian government. That Act outlines the way we may legally use your personal information, and we fully adhere to it.

how we collect personal information

theturnlab collects personal information in a number of ways. For example: when you visit our website, when you request to be placed on the email list for the theturnlab electronic newsletter, when we collect it from those who ask us about the professional services we provide and from those who retain us to provide professional services.

We also collect personal information from those who contact us seeking employment with theturnlab, be it when they telephone us about employment opportunities, when they complete an on-line employment application, or during an employment interview.

We conduct surveys (whether on our own behalf or on behalf of our clients) to gather information about the public and consumers, and in responding to these surveys, respondents will be providing us with personal information.

We also obtain personal information when we conduct consumer promotions (such as contests) on behalf of our clients.

Please note that when we conduct surveys (whether on our own behalf or on behalf of our clients) or when we conduct contests on behalf of our clients, you will know at the time of the survey or contest entry what specific personal information we are requesting and you may decline to provide any information that you would prefer not to disclose. However, by exercising your right to decline may mean that you will no longer be considered as eligible to participate in the matter in question (for example, you may no longer be eligible to receive a gift for having taken the time to complete the survey or be entered into a contest for which a fully completed entry form is an entry requirement).

personal information we collect

The types of personal information that we may collect from you from time to time includes:

• your name
• your address
• your telephone number
• your email address
• when conducting surveys, we may ask for your consumer preferences, or in a broad way your financial or health circumstances

We also collect what can be called “anonymous/aggregated information” when you visit our website or the websites of our clients whose website we manage. We collect such information via the following methods:

Browser Information (i.e., the URL of the web page you were just on, the IP address of the computer you are using, your domain type, and your browser version): Browser information is automatically recorded as part of transmitting information over the Internet. We may use it to help us display information in the best format for you.

Cookies: Website generally use “cookies.” A cookie is a small text file sent to your browser’s files for our reference. No one else can read this file. Cookies allow our server computer to recognize you when you return to the site, so you don’t have to re-register and so we can retain any preferences you may have given us. If you do not wish to receive cookies, most browsers allow you to be alerted when a cookie is sent to your computer, so you can decide whether to accept it.

“Clickstream” Data: During your visit to our site, we may record choices you have made and use this to provide more customized content or advertising. If we do market research studies or polls in any area that will only be reported in aggregate, this will be indicated.

In that the volume of personal information we collect can be quite large (for example, when we conduct surveys or conduct contests on behalf of clients), the personal information we collect may be stored on the servers of third parties who specialize in the storage of data on their servers.

giving your personal information to the party who engages us

As part of administering a consumer promotion that we conduct on behalf of one of our clients, we would record the personal information about you that we received (for example, as part of a contest, we would record personal information contained in a contest entry) and use it for the purpose collected (for example, to award the prize to the winner of the contest) and sometimes to send information about the products and services of the sponsor of that contest.

We would also pass that personal information along to the sponsor of the consumer promotion on whose behalf we have collected it (our client), and once we do so, the privacy policy of the contest sponsor will govern the use of that information once received by them. You may at any time decline to have us pass your personal information on to the contest sponsor, provided that your request to us is in writing. If your request is not received prior to transmission of the information to the promotion sponsor, we will then forward your request to the sponsor of the contest and once we have done so, we bear no liability or responsibility if for any reason the contest sponsor fails to act on the request.

Under no circumstances would we pass personal information received in relation to a consumer promotion to any party other than the sponsor of that specific promotion (unless pursuant to the terms of the promotion, the sponsor has requested and obtained your consent to do so, we do not investigate whether sufficient consent has been requested by the sponsor or given by you; we at all times act on the instructions of the sponsor).

Personal information obtained in relation to any specific consumer promotion we manage on behalf of our clients is delivered to our client who has retained us to conduct the contest and archived by us for one year. The only exception to this is where someone requests information about privacy or has concerns about privacy (such as a request to have their information deleted), and in such cases while the information requested to be deleted will be deleted, the background information contained in these requests (for example, the name and address of the person making the request, and the nature of the request) is stored in our files in perpetuity and disclosed to no one except our internal staff and the sponsor to whom that information request relates.

We may also compile statistics and the like that relates to aspects of consumer promotions, but no such statistics will contain personally identifiable information about individuals (all such statistics will be in an aggregated form).

other relevant matters

We reserve the right to change this privacy policy at any time and the then- current policy (as posted on our Website) will govern. This privacy policy is not intended to, nor does it create any contractual or other relationship between you and us, or provide or create any legal rights in or on behalf of any party (however, this privacy policy does not, and is not intended to, circumvent privacy legislation enacted by the Federal or Provincial legislatures).

how to contact us and have your personal information deleted

If you have any questions about our privacy policy, or the use of any personal information you provided us with, please contact us in writing at either of the addresses below.

To have your personal information removed from the data bank of any sponsor that we provided it to on your behalf, or from our own files (as the case may be), please contact us in writing at either of the addresses below. Only written requests will be acted upon. All such written requests will be acted upon either by removing it from our files, or passing your request to the sponsor (as the case may be) within one week of having received your request. Please note that when your request is to have your personal information removed from the data bank of any client that we provided it to on your behalf, our responsibility in relation to your request ends as soon as we forward the removal request to the party who possesses it.

By email:
privacyofficer@theturnlab.com

By regular mail:
Privacy Officer
The Turn Lab Inc.
2216 Queen Street East
Toronto, ON  M4E 1E9