We may update this Privacy Policy from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Policy and/or we may also send other communications. 

We collect personal information that you provide to us, personal information we collect automatically when you use the Services or interact with us, and personal information from third-party sources, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

• Account Information. We may collect personal information in connection with the creation or administration of your account and profile. This personal information may include, but is not limited to, your name, title, email address, telephone number, physical address, social media usernames, and other information you store with your account or otherwise provide to us.
• Transactions with Turing. We may collect personal information and details associated with the transactions that you enter into with Turing, including payment information. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
• Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or our web chat tool. 
• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public.”
• Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities. 
• Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, profile, and the interview process. This personal information may include, but is not limited to, your contact information, CV, and personal information you provide in connection with your participation in a recorded assessment of your professional qualifications and experience.
• Affiliated Person Information. If you are a Turing employee, officer, director, contractor, consultant, contingent worker, freelancer, or agent (each an “Affiliated Person”), we may collect personal information from you. Examples of this personal information may include: 

1. Contact Details and Other Information. We may collect personal information including, but not limited to, Affiliated Person’s name, title, marital status, date of birth, race, gender, email address, telephone number, physical address, copies of government issued identification and background check information.
2. Financial Information. We may collect personal information such as Affiliated Person’s payment or banking information.
3. Assessment Information. We may collect personal information you provide in connection with your participation in a recorded assessment of your professional qualifications and experience.
4. Posting on Intra-Turing Sites. We may offer intra-Turing accessible sites, pages, messaging channels, blogs, or forums for Affiliated Persons to communicate and collaborate with each other, like Slack or Zoom (“Intra-Turing Sites”). We and other individuals who use the Intra-Turing Sites may collect the information you submit or make available through these sites. If you choose to make content available on any generally accessible area of the Intra-Turing Sites, such content will be visible to other Affiliated Persons and may not be subject to the privacy protections set forth in this Privacy Policy.

B. Personal Information Collected Automatically 

We may collect personal information automatically when you use the Services. 

• Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information). 
• Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.
• Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services. 

1. Cookies. Cookies are small text files stored in device browsers.
2. Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

• Audio and/or Visual Information. We may collect audio, video, transcripts, and other recordings. These recordings may include, but are not limited to, training sessions, Turing meetings (e.g., videoconferencing calls), and recordings or screenshots of your use of video games. In addition, during a live coding interview, we may record your name, image, likeness, identification information, voice, screenshares, and how you may have solved specific challenges.
• System Monitoring. If you are an Affiliated Person, we may monitor and review use of technology, equipment, applications, accounts, electronic communication tools, systems, and networks that you use in connection with your work for Turing. Turing may also access and review electronic files, messages, voicemails, and emails sent or stored on technology, equipment, applications, accounts, electronic communication tools, systems, and networks that you use in connection with your work for Turing. 

For clarity, any and all Affiliated Person telephone conversations or transmissions (including text messages), electronic mail or transmissions, or Internet access or usage by an Affiliated Person of any electronic device or system, including but not limited to the use of a computer or telephone may be subject to monitoring at any and all times and by any lawful means.

To the maximum extent permitted by law, Affiliated Persons have no expectation of privacy while at Turing premises or while using Turing approved or compatible technology, equipment, applications, accounts, electronic communication tools, systems, and networks. To underscore this point, Affiliated Persons should know that they may not have access to every file, network, and programs – this is because we need to maintain confidentiality and protect our team members.

C. Personal Information Collected from Third Parties

We may collect personal information about you from third parties. These third parties may include, but are not limited to, the examples listed below. 

• Third-Party Services. If you access the Services using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. 
• Third-Party Providers of Personal Information. We may buy or otherwise obtain personal information about you from third-party providers of personal information. This personal information may include, but is not limited to, images of individuals. 
• Background Check Providers. If you are an Affiliated Person, where permitted by law, we may collect results and outcomes from historic and ongoing background checks (including criminal record checks and credit reports). We may also collect social media information that is publicly available or that we are otherwise able to obtain. 
• Affiliated Persons Providing Personal Information About Others. We may collect personal information from Affiliated Persons regarding Affiliated Person beneficiaries and emergency contacts. This may include, but is not limited to, name, email address, mailing address, phone number, and the individual’s relationship to the Affiliated Person. 

We use personal information we collect for a variety of business purposes, including to provide the Services, to improve the Services, to develop new products and services, to operate our business, to manage our workforce, to provide you with marketing, and for purposes you have consented to, as described below.

A. Provide the Services

We use personal information we collect to provide the Services, such as:

• Communicating with you;
• Answering requests from you; 
• Providing products and Services to Turing customers; 
• Providing access to certain areas, functionalities, and features of the Services;
• Sharing personal information with third parties as needed to provide the Services;
• Processing your financial information and other payment methods; and 
• Ensuring internal quality control and safety.

B. Improve the Services and Develop New Products and Services

We use personal information to improve the Services and our customers’ services. We also use personal information to develop our and our customers’ new products and services, such as:

• Developing, training, fine tuning, and prompting artificial intelligence models, artificial intelligence algorithms, and artificial intelligence systems; and
• Improving, upgrading, or enhancing the Services and our customers’ products and services.

C. Operate Our Business

We use personal information to operate our business, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Carrying out data analytics; 
• Creating de-identified and/or aggregated information; 
• Processing applications if you apply for a job we post on our Services; 
• Analyzing recorded assessments of Affiliated Person and applicant professional qualifications and experience; 
• Interacting with, or marketing to, Turing customers, if you are an Affiliated Person;
• Allowing you to register for events; 
• Monitoring Turing property, technology, systems, and networks; 
• Enforcing our agreements and policies; 
• Defending, enforcing and protecting our rights and interests and those of third parties; and
• Carrying out activities that are required to comply with our legal obligations.

D. Manage Our Workforce

If you are an Affiliated Person, we use personal information to manage our workforce, such as: 

• Onboarding Affiliated Persons;
• Managing our relationship and communicating with Affiliated Persons; 
• Paying Affiliated Persons for services performed; 
• Administering Affiliated Person benefits; and
• Processing Affiliated Person personal information for talent management. 

E. Marketing

We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law. 

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below. 

F. With Your Consent or Direction 

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.

G. Automated Decision Making

We may engage in automated decision making, including profiling. Turing’s processing of your personal information will not result in a decision based solely on automated processing that has a legal or other similarly significant effect on you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. 

If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.

We disclose personal information to third parties for a variety of business purposes, including to provide the Services, operate our business, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. 

A. Disclosures to Provide the Services and Operate our Business

We may disclose any of the personal information we collect to the categories of third parties described below.

• Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.
• Other Individuals You Share or Interact With. The Services may allow individuals to share personal information or interact with other individuals. For example, if you are an Affiliated Person, personal information may be shared with or otherwise made available to other Affiliated Persons when you post content to the Intra-Turing Sites, where other Affiliated Persons may be able to see some information about you, such as your name and/or picture in addition to the content you post.
• Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”).

Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

• Turing Customers. We may share personal information with Turing customers and potential Turing customers. 

For example, if you are an Affiliated Person, we may share personal information with Turing’s current or prospective customers in order to facilitate the development, operation, and maintenance of Turing’s business.

In addition, in some cases, we may sell or otherwise make available personal information to Turing customers in exchange for monetary or other valuable consideration. 

• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services. Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.
• Turing Customers (Authorized Users Only). In cases where you use our Services as an employee, contractor, or other authorized user of a Turing customer, that customer may access information associated with your use of the Services, including usage data and the contents of the communications and files associated with your account. Your personal information may also be subject to the Turing customer’s privacy policy. We are not responsible for the Turing customer’s processing of your personal information.
• Affiliates. We may share your personal information with our corporate affiliates.
• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “personalized advertising,” or “targeted advertising.”
• Building Management and Security. Your personal information may be shared with building management and/or security at Turing properties to facilitate your access to the building.
• Benefits Providers. If you are an Affiliated Person, we may share personal information with benefits providers that administer Affiliated Person benefits. 

Any personal information shared with a benefits provider may also be subject to the benefit provider’s privacy policy. We are not responsible for the processing of personal information by benefit providers.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

Your Privacy Choices. The privacy choices you may have about your personal information are described below. 

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails or as set forth in “Contact Us” below. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Policy).
• Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.
• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly. 

The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance. 

Please note you must separately opt out in each browser and on each device. 

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Confirm Whether We Are Processing Your Personal Information; 
• Confirm Which Third Parties We Have Shared Your Personal Information With;
• Request Access to or Portability of Your Personal Information;
• Request Correction of Your Personal Information;
• Request Deletion of Your Personal Information;
• Request Restriction of or Object to our Processing of Your Personal Information; and
• Withdraw Your Consent to our Processing of Your Personal Information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.

To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.

If your personal information is subject to the applicable data protection laws of the European Economic Area, the United Kingdom, or Brazil, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. These countries may or may not have adequate data protection laws as defined by the data protection authority in your country. 

If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to a country that does not provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses. 

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

We store the personal information we collect as described in this Privacy Policy for as long as you use the Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

This Supplemental Notice for EU/UK GDPR only applies to our processing of personal information that is subject to the EU or UK General Data Protection Regulation.

In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter into a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.

• Turing’s processing of your personal information may be supported by one or more of the following lawful bases:

If we process personal information that is considered a “special category of personal data,” then our processing of this personal information may be supported by one or more of the following conditions: 

• Explicit Consent: You may have provided your explicit consent for our processing of your personal information. 
• Necessary for Employment, Social Security, or Social Protection Law Purposes: Our processing of your personal information may be necessary for the purposes of carrying out obligations and exercising specific rights in the field of employment, social security, and/or social protection law. 
• Necessary to Protect Vital Interests: Our processing of your personal information may be necessary to protect the vital interests of you if you are physically or legally incapable of giving consent. 
• Publicly Available Personal Information: Our processing of your personal information may relate to personal information which has been manifestly made public by you. 
• Necessary for the Establishment, Exercise, or Defense of Legal Claims: Our processing of your personal information may be necessary for the establishment, exercise, or defense of legal claims.

The Services are not directed to children under 16 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below.

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk. 

Turing Enterprises, Inc. and its affiliates are the controllers of the personal information we process under this Privacy Policy. 

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at: privacy@turing.com.

EU Representative:

Osano International Compliance Services Limited
ATTN: BWOZ
3 Dublin Landings
North Wall Quay
Dublin 1
D01C4E0

UK Representative:

Osano UK Compliance LTD
ATTN: BWOZ
42-46 Fountain Street
Belfast
Antrim
BT1 - 5EF

This Supplemental CCPA Privacy Notice supplements our Privacy Policy and only applies to our processing of personal information that is subject to the CCPA.

Notice at Collection

At or before the time of collection, California residents have a right to receive notice of our privacy practices. California residents can find this information below.

• Personal Information Collected. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for a list of personal information which may be collected. If we have previously collected personal information in the past 12 months, we may collect that personal information from you. 
• Uses of Personal Information. See the section above on “HOW WE USE PERSONAL INFORMATION” for a list of the purposes for which we use personal information. 
• Is Personal Information “Sold” or “Shared” for “Cross-Context Behavioral Advertising”? Yes. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for more details. If we have previously “sold” personal information or “shared” personal information for “cross-context behavioral advertising” in the past 12 months, we may “sell” or “share” that personal information if collected from you. See the section of this Supplemental CCPA Privacy Notice titled “Right to Opt Out of ‘Sales’ of Personal Information and/or ‘Sharing’ for ‘Cross-Context Behavioral Advertising’” for instructions on how to opt-out of these activities.
• How Long is Personal Information Retained For? To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
• Additional Information. For more information on our privacy practices, please review this Supplemental CCPA Privacy Notice and our Privacy Policy. Importantly, the section titled “Your Privacy Rights” includes important details about how you can exercise some of the rights which you have under the CCPA. 

Categories of sources from which personal information is collected

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources. 

Overview of personal information collected, disclosed, sold, and/or shared

The CCPA provides California residents with the right to know what categories of personal information Turing has collected about them, whether Turing disclosed that personal information for a business purpose (e.g., to a service provider), whether Turing “sold” that personal information, and whether Turing “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:

Disclosure regarding “sales” of personal information and/or “sharing” for “cross-context behavioral advertising”

We “sell” your personal information or “share” your personal information for “cross-contextual behavioral advertising” to provide you with “cross-context behavioral advertising” and other advertising about Turing’s products and services. 

California residents have the right to opt out of the “sale” of personal information and the “sharing” of personal information for “cross-context behavioral advertising.”

California residents may exercise these rights by emailing us at privacy@turing.com, opting out of our use of advertising cookies via any cookie management tools we may provide, or using the standard cookie management functionality offered by their Internet browser (if any) and opting out of our use of advertising cookies via that tool. 

Disclosure regarding individuals under the age of 16

Turing does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. Turing does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”

Disclosure regarding sensitive personal information

Turing only uses and discloses sensitive personal information for the purposes listed in Section 7027(m) of the CCPA regulations.

Non-Discrimination

California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Notice of financial incentive

This Notice of Financial Incentives aims to inform you about any programs, benefits, and other financial incentive offerings (collectively, “Incentive Offerings”), that we may provide in connection with the collection of your personal information so that you may make an informed decision on whether to participate in our Incentive Offerings. Such Incentive Offerings may be deemed “financial incentives” under the CCPA. 

The material aspects of any Incentive Offering, along with the personal information collected in connection with an Incentive Offering, will be described at the time you are presented with the Incentive Offering. 

Examples of our Incentive Offerings may include offering your compensation in exchange for providing your personal information to Turing, or its client, to use in connection with the training of artificial intelligence. 

You can opt-in to an Incentive Offering by following the instructions that accompany the presentation of the Incentive Offering. If you subsequently wish to withdraw from the Incentive Offering, you may request such withdrawal by contacting us as set forth in “Contact Us” above. Please note that your withdrawal will only apply to future Incentive Offerings. 

Each Incentive Offering may be based upon our reasonable and good-faith determination of the estimated value of such offer to our business, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized.