Privacy Policy

Turing collects the following data:

• General data such as your full name, title, marital status, date of birth, race, and gender
• Contact data such as your email address, telephone number and physical address
• Profile data such as your social media usernames and passwords, feedback and survey responses
• Recruitment data such as job applications and recordings of assessments.
• Marketing and communications data including details about your preferences in receiving marketing from us and, where relevant, from our third parties, and your communication preferences.
• Technical data such as your internet protocol (IP) address, cookie ID, login data, browser type and version, time zone and geographic location and online use of our services.
• Other data including any other information you provide visiting our website and any other information provided to us by you or on your behalf by a third party.

We collect your data directly when you:

• Complete and submit online forms we make available to you through our company website or through third parties (e.g., contact forms, job applications).
• Register for access to and use our services.
• Use or view our website via your browser's cookies.
• Participate in recorded assessments of your professional qualifications and experience.

Turing may also receive your data indirectly from the following sources:

• Publicly available data repositories (e.g., GitHub).
• Your employer or third party staffing agency.

Turing collects your data so that we can:

• Manage your services account.
• Respond to enquiries submitted on our website.
• Provide our services.
• Promote the Company and improve its products or services.
• Ensure system security, including monitoring activities and fraud detection and reporting.
• Administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
• Make suggestions and recommendations about services that may be of interest to you.
• Use data analytics to improve our website, products/services, marketing, customer and client relationships and experiences.
• Manage our relationships including notifying about changes to our terms of business or this Policy.
• Invite you to take part in marketing or other promotional events, or customer or client seminars or similar events, and to manage your participation in them.
• Identify services which might interest you, and to send you marketing (including paper and electronic marketing communications) or to contact you by other means to offer you our services products.
• Interact with governmental or regulatory bodies or other authorities in relation to our legal and regulatory requirements.
• Manage our assessments of you to:
• Ensure the integrity of our assessment processes;
• Provide feedback to participants;
• Assist in the fair matching of developers with potential job opportunities.

Turing may share your data with the following parties for the purposes set out above:

• Your data may be shared internally which may include with our affiliates and related companies to locations outside your home country as reasonably necessary for the purposes set out in this Policy.

Your data may be shared with third parties such as:

• Our professional advisors including lawyers, bankers, auditors, accountants and insurers.
• Clients and customers including potential clients and customers.
• Service providers with which we have contracted to provide services on our behalf such as hosting our website, providing application tracking systems, conducting marketing activities, and performing analyses to improve our website and services:
• Greenhouse Software
  18 W 18th Street, 11th Floor
  New York, NY 1001
  Greenhouse is an application tracking system used by Turing to
  recruit, hire and onboard individuals
  
  The above list is subject to updates in future versions of this Policy.

We may also provide your data to legal and regulatory authorities, as required by applicable law, and pursuant to law enforcement warrants and court orders.

We may share your data with persons or entities outside Turing if we reorganize or transfer all or part of our business. If a change happens to our business, the purchaser will be entitled to use your personal data in the same way as set out in this Policy and will assume the rights and obligations regarding your data as set out in this Policy

We may on occasion transfer your data to a country outside your home country where the data privacy laws may not be equivalent to or provide the same level of protection for personal data as the laws in your home country. Whenever we transfer your personal data outside your home country, we implement appropriate measures to ensure it remains protected, as required by applicable data protection laws. This may include contractual obligations as well as technical and organisational measures.

Turing will keep your data only for so long as necessary to fulfill the purposes for which the data was collected, subject to longer retention periods as required by applicable law and for bringing and defending legal action or investigations. For example, the period during which Turing will store the data of independent contractors may differ from the retention period for client data. Once the specified retention time period has expired, we will delete your data. Subject to this section, the maximum time for retention of data is three (3) years.

To ensure we provide marketing materials and content on our website that is of interest we use technology in our emails and on our website that logs whether you click on the links in our emails, and the time and date you access our website as well as the time spent on our website, when you follow a link to our website.

Any marketing communications we send you will include a method to unsubscribe, or opt out, of receiving our communications (e.g., an unsubscribe link). You can choose to not receive our marketing emails at any time. If you are unable to opt out using the provided method, please contact us as provided in the How to contact us section in this Policy. If required by applicable law, we will first seek your consent before sending you marketing communications.

We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed, in accordance with applicable data protection laws. We limit access to your data to personnel and third parties who have a business need to know. They will only process your data on our instructions and they are subject to a duty of confidentiality

After careful selection, we require all our third-party service providers who will process your data to implement appropriate security measures and maintain the confidentiality of your data in accordance with applicable data protection and privacy laws. Our third-party service providers must use your data for specified purposes, only and in accordance with our instructions. We do not allow our third-party service providers to use your data for their own purposes

We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Turing would like to make sure you are fully aware of all your data protection rights. Under certain circumstances, and subject to applicable laws, you may be entitled to the following:

• The right to access - to request Turing for copies of your data. We may charge you a small fee for this service.
• The right to rectification - to request that Turing correct any information you believe is inaccurate. You also have the right to request Turing to complete information you believe is incomplete.
• The right to erasure - to request that Turing erase your data, under certain conditions. Your right may include third parties with whom we have shared your data.
• The right to restrict processing - to request that Turing restrict the processing of your data, under certain conditions.
• The right to object to processing - to object to Turing‘s processing of your data, under certain conditions.
• The right to data portability - to request that Turing transfer the data that we have collected to another organization, or directly to you, under certain conditions.

You may be entitled to additional fights if you reside in the following jurisdictions:

California.

• The right to opt in - to authorize us to sell or share the data of minors under 16 years of age. Turing does not use or disclose the data of individuals under 16.
• The right to opt out - to stop us from selling or sharing your data to third parties for behavior-based advertising, and we will provide you with an online mechanism to opt out. Turing does not sell or share your data.
• The right to know - to request we tell you about your data, specifically: 1) categories of data; 2) sources of data; 3) purpose for which data is used; 4) categories of third parties with whom we share data; and 5) categories of the shared data. Turing responds to all personal data related requests promptly and no longer than thirty (30) days following receipt of the request.
• The right to equal treatment - to not be discriminated against for exercising any of your rights. Turing respects the data rights of all individuals.

If you would like to exercise any of these rights, please contact us using the details in the How to contact us section in this Policy.

We will respond to your request in a timely manner as required by applicable law. Under applicable law, Turing may confirm the identity of the requestor, ask for clarification of the request, or ask for more time to respond.

For California residents: When you provide your data to Turing, the online form or other method by which you enter your data will contain a link to this section of this Policy which will serve as a notice of our collection and use of your data. For purposes of this section, please refer to this Policy and the following sections of this Policy:

• What data do we collect?
• How will we use your data?
• How long do we store your data?
• What are your data protection rights?

Cookies are text files placed on your computer or device when you sign in to our service or visit our website. Cookies collect information about your use of our service and our website. We may collect information from you automatically through cookies or similar technology. The cookies may be ours or those of third parties.

Cookies are useful as they allow a website to recognize your device and store certain information about your preferences to help to improve your online experience.

Turing uses cookies to collect data for the following purposes:

• Sign in to and use of our service.
• Security of our service and of electronic communications between us.
• Understanding your use of our service and website.
• Give you a better browsing experience, personalized to your preferences.
• Analyze the effectiveness of our online content.

Our website uses the following cookies:

Our websites may also contain electronic images known as web beacons – sometimes called web-pixels or clear gifs – that allow us to understand your browsing activity

You can delete cookies from your browsing history and set your browser not to accept cookies. Please use the links below for instructions on how to manage your cookie preferences, including essential or strictly necessary cookies:

• Internet Explorer (IE)
• Google Chrome
• Firefox
• Safari (desktop)
• Safari (mobile)
• Opera

The allaboutcookies.org website tells you how to remove cookies from your browser.

Deletion and blocking of certain cookies may affect your use of the service and website. Some cookies are essential or strictly necessary and identified as such and cannot be turned off.

The Turing website contains links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your data. Turing does not control those websites and is not responsible for the privacy practices of those third parties. Our privacy policy applies only to our website. The practices of those third parties with respect to data collected through their websites, products and services is governed by their own privacy policies, so if you click on a link to another website, you should read the relevant privacy policy.

Turing keeps thisPolicy under regular review. Any changes to this Policy take effect immediately upon this Policy being posted on this web page or otherwise notified to you. The last reviewed date of this Policy will be indicated in the title of this Policy.

If you have any questions about this Policy or Turing's privacy practices, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us as follows:

Email us at:
privacy@turing.com

Or write to us at:
Turing Enterprises, Inc.
Attn: Legal
1900 Embarcadero Road
Palo Alto, CA, 94303

Turing maintains compliance with applicable laws regarding data protection, data privacy and marketing communications. These laws may differ between countries, economic blocs, states and provinces. These laws include the following jurisdictions: European Union (EU) and European Economic Area (EEA); United Kingdom (UK); Canada; India; State of California.

Regardless of your place of residence, these laws do not limit you from providing us with your data via Turing’s website, the websites of our third party partners, or any other publicly available websites (free or subscription). You may apply for jobs posted on these websites and work with us.

Should you wish to report a complaint or if you feel that Turing has not addressed your concerns about our use of your data, you also have the right to file a complaint against us with your local data protection authority.