PLEASE READ THIS PRIVACY POLICY (‘Privacy Policy’ or ‘Agreement’) BEFORE USING AND ACCESSING THE WEBSITES AND APPLICATIONS SUBJECT TO THIS AGREEMENT. YOU ARE NOT AUTHORIZED TO ACCESS OR USE THIS WEBSITE OR ANY APPLICATIONS IF YOU DO NOT AGREE WITH THE PRACTICES DESCRIBED IN THIS POLICY.

 

In using and accessing Turul.Network, and/or any affiliate websites, and/or any software offered through the website or available for download, and/or mobile applications available for download or available on the website (‘Website’), the user, including without limitation users who are browsers, vendors, customers, merchants, and/ or contributors of content (‘You’ or ‘User’), agree to abide by and follow the terms and conditions governing access to the Websites by User. Throughout the Website, the terms “we”, “us” and “our” refer to Turul, Turul.Network, and Turullaw Inc (‘Company’).

 

The User agrees to abide by and follow the terms and conditions governing access to the Website by User, and this Privacy Policy addresses how information is collected and used when accessing the Website.  The Website is owned and operated by the Company, and the Privacy Policy governs how all information is collected, used, and shared on the Website by the Company. The User and the Company (each a ‘Party’ and collectively the ‘Parties’) agree to be bound by the terms and conditions set forth herein.

 

By using the Website, the User is accepting the practices of the Company regarding the collection of personal information of the User, and the User acknowledges that any information being provided by the User through the Website is governed by the Company’s Terms of Use, which is incorporated into this Privacy Policy.

 

Information Collected

 

The Company collects non-public personal information from the User in order to create an account and in order to access some of the products and services offered on the Website. This information includes name, registered address, email address, phone number, and payment information.

 

If the User desires to access additional products and services through the Website, the User will be required to fill out an application form requesting specific information as it relates to the specific product or service being requested by the User. This additional information collected will be explicitly requested in the respective application form that requires completion in order to complete the services requested or to deliver any products as required whether by the Company or any third-party service provider.

 

When you visit the Website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Website, and information about how you interact with the Website. We refer to this automatically-collected information as “Device Information”.

 

Other information collected can include IP addresses and cookies when the User is visiting the Website, and information on the User’s transactions and interactions with the Company, and any third-parties through the Website, is also collected. Cookies are also used to authenticate Users, remembering of preferences, and determining the popularity of certain content.

 

We collect Device Information using the following, but not limited to, technologies: “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org; “Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps; “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Website. The Website may also collect information on the location of the User through location-based services that are offered through the Website, such as advertising, search results, and other personalized content. The use of cookies are used to allow for more efficient purchasing, personalized advertisements, and the storage of purchases between visits on the Website. Additionally, when you make a purchase or attempt to make a purchase through the Website, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as “Order Information”. When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information. We use the Order Information that we collect generally to fulfill any orders placed through the Website (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to: Communicate with you; Screen our orders for potential risk or fraud; and, when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services. We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Website (for example, by generating analytics about how our customers browse and interact with the Website, and to assess the success of our marketing and advertising campaigns).

 

Information Shared

 

The Company uses third-party service providers to complete many of the services and deliver the products being offered through the Website. The use of third-party service providers requires the disclosure of certain non-public personal information of the User in order to ensure the third-party service provider is able to complete the services or deliver the products as required and authorized by the User.

 

All third-party service providers are subject to a confidentiality agreement prohibiting the disclosure of any User information to a third-party, and in no instance does the Company disclose any User information to a 3rd party, where such disclosure is exclusively for the third-party to contact you about their own respective products or services.

 

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Wix to power our online store--you can read more about how Wix uses your Personal Information here: https://www.wix.com/about/privacy. We also use Google Analytics to help us understand how our customers use the Website -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here:https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

 

Interest-Based Ads Policy

 

The Website displays interest-based advertising using information the User has made available to the Company when interacting with the Website. These internet-based ads are displayed to the User based on User purchases on the Website and visiting websites that contain Company content or ads, or the User using the Company’s payment services.

 

Cookies, web beacons, action tags, or single pixel gifs are used to learn what ads the User sees, what the User clicks, and other actions that are taken on the Website. In addition, some third parties may provide information on the User to the Company from offline and online sources that may be used to provide the User with more relevant and useful advertising. No User information is provided to advertisers or to any third-party sites that display any Company advertisements.

 

Some advertisers, or their agents, may use technology to display ads that appear on the Website and viewable directly on the User’s browser. In doing so, these advertisers, or respective agents, receive the User’s IP address; these advertisers may also use cookies, web beacons, action tags, or single pixel gifs to measure the effectiveness of any personalized ad content and their respective advertisements. The Privacy Policy does not govern the conduct of advertisers, their respective agents, or other third parties since the Company has no access or control over any technology, cookies, or features that such advertisers, respective agents, or third parties.

 

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Google: https://www.google.com/settings/ads/anonymous
- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

 

Notices

 

If the User has any questions regarding how their information is used, then the Company may be contacted at:

 

            Attention: Privacy Officer

            Turullaw Inc.

            401 Bay Street, Suite 1600

            Toronto, ON  M5H 2Y4

 

Please note that we do not alter our Website’s data collection and use practices when we see a Do Not Track signal from your browser.

 

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information above.

 

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Website), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

 

When you place an order through the Website, we will maintain your Order Information for our records unless and until you ask us to delete this information. We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

 

The Company reserves the right to modify this Privacy Policy at any time, and the notification regarding any changes to the Privacy Policy may be made by posting a notice of such change on the Website.

 

The effective date of this policy is Jan 20, 2021.