Last modified: October 24, 2022

Introduction

TurnSignl Inc (“Company” or “We“) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

• The types of information we may collect or that you may provide when you purchase, download, register with, access, or use the TurnSignl App (the “App“).

• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect in this App, and in email, text, and other electronic communications sent through or in connection with this App.

This policy DOES NOT apply to information that:

• We collect offline or on any other Company apps or websites, including websites you may access through this App.

• You provide to or is collected by any third party

Our websites and apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this privacy policy, and the terms and conditions contained herein, and constitutes your acceptance of the privacy policy and your consent to the practices it describes. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App after we revise this policy means constitutes your acceptance of those changes and further consent to the practices contained therein, so please check the policy periodically for updates.

Children Under the Age of 18

Your use of the App constitutes your verification that you are 18 years of age or older. The App is not intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect and How We Collect It

We collect information from and about users of our App:

• Directly from you when you provide it to us.

• Automatically when you use the App.

Information You Provide to Us

When you download, register with, or use this App, we may ask that you provide information:

• By which you may be personally identified, such as name, postal address, email address, telephone number, birthdate, and any other identifier by which you may be contacted online or offline (“personal information“).

• That is about you but individually does not identify you, such as your, race, gender, vehicle Make/Model/Color/Year, employment status, hours worked a week, pay per hour, age, number of dependents, state of residence, and zip code.

This information includes:

• Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App, and subscribing to our service, and requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App.

• Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes.

• Details of usage you carry out through the App including information regarding video calls with attorneys through the App. You may be required to provide financial information before placing an order through the App.

• Information contained within your call log, excluding the actual video file.

You may also provide information for publication or display (“Posted“) on public areas of the app or websites you access through the App/website (collectively, “User Contributions“). Your User Contributions are Posted and transmitted to others at your own risk. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic Information Collection and Tracking

When you download, access, and use the App, it may use technology to automatically collect:

• Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.

• Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.

• Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

• Location Information. This App collects real-time information about the location of your device, when allowed by the user. You must allow us this location access in order for the App to properly work.

If you do not want us to collect this information do not download the App or delete it from your device. Note, however, that opting out of the App’s collection of location information will disable its location-based features.

We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking). Click here for information on how you can opt out of behavioral tracking on or through this app and how we respond to browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

• Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App or use it as it is intended to be used.

• Web Beacons. Pages of the App may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

Third-Party Information Collection

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

• Your mobile device manufacturer.

• Your mobile service provider.

They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

• Provide you with the App and its contents, and any other information, products or services that you request from us.

• Fulfill any other purpose for which you provide it.

• Give you notices about your account/subscription, including expiration and renewal notices.

• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• Notify you when App updates are available, and of changes to any products or services we offer or provide though it.

• Create aggregate sets of data to be used to understand policing and accident trends.

The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our App according to your individual interests.

• Recognize you when you use the App.

We use location information we collect to determine which set of attorneys to connect you with based upon your real time jurisdictional location.

We may use the information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

In addition, we may disclose personal information that we collect or you provide:

• To our subsidiaries and affiliates.

• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TurnSignl Inc’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by TurnSignl Inc about our App users is among the assets transferred.

• To third parties to market their products or services to you if you have these disclosures.

• To fulfill the purpose for which you provide it.

• For any other purpose disclosed by us when you provide the information.

• With your consent.

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• To enforce our rights arising from any contracts entered into between you and us, including the App EULA, and for billing and collection.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TurnSignl Inc, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.

• Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the App may become inaccessible or not function properly.

• Promotion by the Company. If you do not want us to use your email address to promote our own or third parties’ products or services, you can opt-out by emailing us at [email protected].

• Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by emailing us at [email protected].

• Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by emailing us at [email protected].

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the App and visiting your edit profile page.

You may also send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Data Security

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the App like message boards. The information you share in public areas may be viewed by any user of the App.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Changes to Our Privacy Policy

We may update our privacy policy from time to time at our sole discretion. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page by email to the email address specified in your account, or by an in-App alert the first time you use the App after we make the change.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at [email protected]

Your Nevada Privacy Rights

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us at [email protected].

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit this link.

California’s Shine the Light Law

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or write us at 34 13th Ave NE, Suite 104A | Minneapolis, MN 55413.

Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:

• Identifiers, including name, email address, phone number account name, IP address, and an ID or number assigned to your account.

• Customer records, billing and delivery address, and credit or debit card information.

• Commercial information, including purchases and engagement with our Web Sites and Applications.

• Video and Audio Files, including actual footage of your videos while utilizing our App.

• Internet activity, including your interactions with our Web Sites and Applications.

• Geolocation data, including location enabled services such as WiFi and GPS.

• Inferences, including information about your interests, preferences and favorites.

For more information on information we collect, including the sources we receive information from, review the “Information we Collect and How We Collect It” section above. We collect and use these categories of personal information for the business purposes described in the “How We Use Your Information” section, including to provide and manage our Web Sites and App.

To the extent any of our conduct constitutes a “sale” under the CCPA, we will comply with applicable law as to such activity. We disclose certain information, including personal information for commercial purposes, including certain identifiers, commercial information, internet activity, geolocation data and inferences. We use and partner with different types of entities to assist with our daily operations and manage our Web Sites and App. Please review the “How We Use Your Information,” “Disclosure of Your Information,” and “You Choices About Our Collection, Use, and Disclosure of Your Information” sections for more detail about the parties we have shared information with.

We do not knowingly “sell” the personal information of minors under 16 years old who are California residents without their affirmative authorization.

Right to Know and Delete

If you are a California resident, you have the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

• The categories of personal information we have collected about you;

• The categories of sources from which the personal information was collected;

• The categories of personal information about you we disclosed for a business purpose or sold;

• The categories of third parties to whom the personal information was disclosed for a business purpose or sold; and

• The business or commercial purpose for collecting or selling the personal information

You also have the right to request the specific pieces of personal information we have collected about you.

In addition, you have the right to delete the personal information we have collected from you.

To exercise any of these rights, please submit a request to the following email address [email protected] or call us at (612) 812-0085. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

Right to Opt Out of Sale

To the extent we sell your personal information as the term “sell” is defined under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by emailing us at [email protected].

Authorized Agent

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly. Please provide written proof via email to [email protected]

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.