Privacy Policy

In order to receive information about your Personal Data, the purposes and the parties the Data is shared with, contact the Owner.
For more information and to understand your rights, you can also view the complete version of this privacy policy, by clicking
the link at the bottom right of this page.

Owner and Data Controller
Unit 4 53 Carrer de Nicolau de Montsariu Valencia 64011
Owner contact email: hello@turnerand.co

Types of Data collected

The owner does not provide a list of Personal Data types collected.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by
specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it
impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not
mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the
Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this
Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the
present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized
destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes
strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of
persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration)
or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies,
communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be
requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are
located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To
find out more about the place of processing of such transferred Data, Users can check the section containing details about the
processing of Personal Data.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose
they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Cookie Policy
This Application uses Trackers. To learn more, Users may consult the Cookie Policy.

Further Information for Users

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations
thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the
Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether
the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose
they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be
retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill
such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the
relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing,
as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period
whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to
rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their
consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is
carried out on a legal basis other than consent.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding
certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or
corrected.
Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner
will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the
Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a
structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another
controller without any hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed
by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the
Owner to safeguard their Data.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for
the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground
related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to
that processing at any time, free of charge and without providing any justification. Where the User objects to processing
for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the
Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this
document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such
requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users
with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be
communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves
impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action
arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and
contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction
with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see
the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly
within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information
available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at
the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent
from the User, where required.

Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number —
allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can
include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses
(Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file
received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country
of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time
spent on each page within the Application) and the details about the path followed within the Application with special reference
to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as
described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes
and means of the processing of Personal Data, including the security measures concerning the operation and use of this
Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to
the European Union and the European Economic Area.
Legal information
This privacy policy relates solely to this Application, if not stated otherwise within this document.
Latest update: November 07, 2024

Cookie Policy of www.turnerand.co
This document informs Users about the technologies that help this Application to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with this Application.

For simplicity, all such technologies are defined as "Trackers" within this document – unless there is a reason to differentiate.
For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.

Some of the purposes for which Trackers are used may also require the User's consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.

This Application only uses Trackers managed directly by the Owner (so-called “first-party” Trackers).
The validity and expiration periods of first-party Cookies and other similar Trackers may vary depending on the lifetime set by the Owner. Some of them expire upon termination of the User’s browsing session.

How this Application uses Trackers
Necessary
This Application uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.

Owner and Data Controller
Unit 4 53 Carrer de Nicolau de Montsariu Valencia 60411

Owner contact email: hello@turnerand.co

Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by this Application.