TurnTo Networks, Inc. Privacy Policy

Effective July 1, 2008

The TurnTo System enables you to share with people you specify information about your activities, transactions, and profile at TurnTo partners ("Activities"), ratings and comments you create through the TurnTo System regarding TurnTo partners and your Activities ("Comments"), your TurnTo account profile ("Profile"), and data regarding your usage of the TurnTo System ("Usage Data"), collectively your "Personal Information". For each TurnTo partner, the TurnTo System enables you to specify the people with whom you share your Activities and related Comments or to prevent sharing entirely (e.g., I'll share information about my partner X transactions with all my friends, but I'll share my partner Y activities with no one). It also enables you to prevent sharing entirely of any individual Activity and related Comments regardless of your general sharing settings for the partner where the Activity takes place (e.g., I don't want to share information about my purchase of a particular book at partner X even though I do want to share other purchases at partner X).

Activity information is generally provided to TurnTo by our partners, while Comments and Profile information is submitted directly by you through one of the TurnTo interfaces. Usage Data is collected automatically by the TurnTo System or third-party systems employed by TurnTo.

TurnTo makes your Personal Information available to those with whom you have authorized sharing through an interface on partner sites, through a feed provided to other 3rd party sites, and on TurnTo.com. Regardless of the means through which TurnTo makes your Personal Information available to others, TurnTo always enforces your settings as to which people may access each item of your Personal Information.

Other than the above, TurnTo will not disclose personally-identifiable information about you to others except when we have your consent to do so or if we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on TurnTo. We reserve the right to use and disclose in a non-personally-identifiably manner any information that we collect, subject to restrictions specified in the Partner Terms of Use.

If you choose to use our invitation service to tell someone about TurnTo or if you choose to authorize sharing with someone who has not yet joined TurnTo in anticipation of their joining, we will ask you for and store information needed to send the invitation or to identify that person once they join, such as their email address.

You may delete your TurnTo account at any time and we will remove from the System all Personal Information submitted by you, allowing for the time needed for propagation of removal instructions throughout the System. TurnTo may maintain copies of Personal Information in back-up and archive systems.

We use reasonable security measures in an effort to prevent loss, misuse and alteration of information under our control. However, you post information to the TurnTo System and authorize the sharing of Personal Information through the TurnTo System at your own risk. Although we allow you to control how your Personal Information is shared, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you may choose to share your Personal Information. Therefore, we cannot and do not guarantee that your Personal Information will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures. You understand and acknowledge that, even after removal, copies of Personal Information may remain viewable in cached and archived pages or if other users have copied or stored your Personal Information.

TurnTo provides you with several options for receiving e-mail notifications related to the routine operation of the TurnTo System; we will communicate with you by e-mail in accordance with the preferences you express. From time-to-time, we may send you by e-mail a strictly service-related announcement which is not promotional in nature; you may not opt-out of these communications.

The TurnTo System uses cookies to recognize you. If you set your browser not to accept cookies, you will not be able to use the TurnTo System.

We may use third party service providers to assist us with the administration of the TurnTo System or to perform other services for us, including transaction processing and sending email. These third parties may be given or may have access to your Personal Information, but agree to receive and use such information solely to provide services to us or on our behalf, and subject to all the terms and restrictions in this Privacy Policy.

We reserve the right to change our Privacy Policy at any time. If we make changes, we will post the revised Policy and will indicate at the top of the page the Policy's new effective date. Non-material changes and clarifications will take effect immediately, and material changes will take effect within 14 days of their posting. If we make material changes to this Policy, we will notify you through a message posted to your TurnTo homepage and through e-mail according to the preferences you have set for receiving notifications from TurnTo. We encourage you to refer to this policy on an ongoing basis so that you understand our current Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.

In the event TurnTo goes through a business transition, such as a merger, acquisition or the sale of all or substantially all of its assets, in which your Personal Information is transferred to a new owner, your Personal Information will remain subject to all the terms and restrictions of the Privacy Policy in effect at the time of the transition.

The TurnTo System is not intended for and may not be used by children under the age of 13. TurnTo does not knowingly collect Personal Information from children under the age of 13. If you are under 13 years old, you should not register with or otherwise provide Personal Information to the TurnTo System.