Turnkey Privacy Policy

Last Updated: August 11, 2025

This privacy policy is designed to help you understand how Turnkey Global, Inc. (“Turnkey,” “we,” “us,” or “our”) collects, uses, processes, and shares your personal information, and to help you understand and exercise your privacy rights (“Privacy Policy”). In some cases, we may specifically ask for your consent to collect, use, or share personal information, such as when required by law. For more information on how we use cookies and similar technologies, and how you can control their use, please review our Cookie Policy, which is incorporated by reference into this Privacy Policy.

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 TO USE OUR SERVICE. BY ACCESSING, BROWSING OR OTHERWISE USING THE SERVICE, YOU ARE ACCEPTING AND AGREEING TO BE BOUND BY AND ABIDE BY THE TERMS, AND YOU REPRESENT AND WARRANT THAT YOU HAVE THE RIGHT, AUTHORITY AND CAPACITY TO ENTER INTO AND AGREE TO THE TERMS (ON BEHALF OF YOURSELF OR THE ENTITY THAT YOU REPRESENT).

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1. SCOPE AND UPDATES TO THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed by us when providing our non-custodial key management solution, including on our websites, and other online or offline offerings (the “Services”). By using the Services, you acknowledge the practices outlined in this Privacy Policy. Capitalized terms used but not defined herein shall have the respective meanings given to them in the Turnkey Terms of Service (the “Terms”).

Changes to our Privacy Policy. We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well. We will post any changes we make to our Privacy Policy on this page and, where appropriate or required by law, we will provide you with reasonable notice of any material changes. You understand and agree that you will be deemed to have accepted and consented to the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

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2. PERSONAL INFORMATION THAT WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

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A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us, including but not limited to:

‍Contact Data. We may collect personal information such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.

Account Creation. We may collect personal information when you create an account, such as wallet addresses and profile data such as the username and password that you may set to establish an online account with us including biographical information and any other information that you add to or is associated with your account.

Personal Identification Information

Protocol Payloads, Wallet and other Output Information. In order to utilize some of the Services, you may need to provide us with information about your wallet(s) including the types and amounts of digital assets on the blockchain you possess and details about Protocol payloads into which you have entered. We will never ask you for your private keys, API keys, or authenticators.

Blockchain Activity Data. We may collect other personal information relating to or needed to support your cryptocurrency transactions on or through Services (including wallet address, transaction number, transaction sender and recipient, transaction amount, and transaction history), as well as information relating to other on-chain activity associated with your publicly available wallet address, such as applications you have interacted with on the blockchain.

Payment Data. We may collect personal information relating to payments relating to or for our Services (including payment card information and billing information) and your purchase history.

Your Communications with Us. We may collect personal information, such as names and email addresses, when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.

User-Generated Content. We may collect personal information such as photos, images, music, videos, comments, questions, messages, correspondence, and other content or information that you generate, transmit, or otherwise make available on the Service to us or other persons, as well as associated metadata.

Government-Issued Identification Numbers.

Technical Usage Data. We may collect personal information such as your interactions, use and visits to Services, including but not limited to information about your timezone, internet protocol (IP) address, dates of access and the like via cookies, analytics programs and software, and other tracking technology.

Device Data. We may collect personal information such as the operating system, browser, name of the device you are using to access the Services

‍Interactive Features. We and others who use our Services may collect personal information that you directly submit to us through our interactive features.

Data About Others. Users of the Service may have the opportunity to refer contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.

Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

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B. Third-Party Sources.

We may combine personal information we receive from you with personal information we obtain from other sources, such as:

Public Sources: such as government agencies, public records, social media platforms, public blockchain, and other publicly available sources.
Data Providers: such as information services and data licensors that provide demographic and other information.
Marketing Partners: such as joint marketing partners and event co-sponsors.

Business transaction partners: we may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.
Third-party linked services that you use to log into, or otherwise link to, your Services account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

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C. Personal Information Collected Automatically

We may collect personal information automatically when you use our Services including but not limited to:.

Device and Technical Usage Data. We may collect certain information automatically when you use our Services, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, random access memory (RAM) and disk size, central processing unit (CPU) usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

Performance Data: We may collect personal information such as clickstream data and diagnostic, crash, website, performance logs and reports.

Online Activity Data: We may collect personal information such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.

Location Data: We may collect personal information such as your location when you authorize the Service to access your device’s location.

Analytics. We may use Technologies and other third-party tools to process analytics information on the Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize the Services. Some of our analytics partners include:‍

Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.‍

Personal Information Collected from Other Sources. We may collect personal information from other sources when you use our Services.‍

Blockchain Networks. We may independently collect personal information from blockchain networks that we have access to. This personal information may include public wallet addresses and details about transactions carried out on the applicable blockchain network.

As part of this collection, we may use cookies, pixels, and similar technologies. For more detail on the categories of cookies we use and how to manage them, please see our Cookie Policy.

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3. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services We use your information to fulfill our contract with you and provide you with our Services, such as to:

Determine your eligibility to use the Services;
Create and maintain your account;
Conduct Know Your Customer (KYC) checks, background checks and other screens permitted by law;
Enable peer-to-peer communication or transaction;
Respond to your comments, questions and requests and provide customer service;
Provide and deliver the products and services you request;
Process transactions and provide you related information, including invoices, confirmations and receipts;
Enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
Prevent, identify, investigate and deter fraud, misuse of the Service, or harmful, unauthorized, unethical or illegal activity, criminal activity;
Communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
Fulfill and comply with applicable law or our good faith belief that action is necessary to fulfill and comply with applicable laws, lawful requests, and legal obligations and processes to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties, including without limitation auditing our internal processes for compliance with legal and contractual requirements or our internal policies and enforcing the terms and conditions that govern Services;
Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
Understand your needs and interests, and personalize your experience with the Service and our communications; and
Provide support and assistance for the Services; and
Provide, maintain and improve our Services.

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We use your information where it is in our legitimate business interests to do so, such as to:

Send you technical notices, updates, security alerts and support and administrative messages;
Monitor and analyze trends, usage and activities in connection with our Services
Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Turnkey and others;
Personalize and improve the Services and provide content or features that match user profiles or interests;
Ensure and improve the security of our website and the Services; and
Link or combine with information we get from others to help understand your needs and provide you with better service.

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B. Marketing our Products and Services

As permitted by applicable law — and unless your consent is required — it is in our legitimate business interests to use personal information to tailor and provide you with direct marketing content or Turnkey-related communications (including about our products, services, news and information) via email. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below or by following the unsubscribe link provided in each email.

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C. With Your Consent. We may use personal information for other purposes where you provide your consent.

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D. Interest-Based Advertising. We may engage third-party advertising companies and social media companies to display ads on other online services. These companies may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) over time across Turnkey Service, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the section below.

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E. Other Purposes We also use your personal information for other purposes as requested by you or as permitted by applicable law, including where such purposes are clearly disclosed to you at the time you provide your personal information.

‍De-identified or Aggregated Information. We may use personal information to create de-identified, anonymized and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create (collectively, “Aggregated Data”). We may use this Aggregated Data, publish such Aggregated Data, make such Aggregated Data generally available, or share such Aggregated Data with third parties for our lawful business purposes, including without limitation to analyze and improve Turnkey Service and promote our business.

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4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, 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 our Services The categories of third parties with whom we may share your personal information are described below.‍

‍Notice Regarding Use of Blockchain Networks. Information about transactions you enter into via the Services will be recorded on the blockchain and may be accessible to third parties due to the public nature of the blockchain. Because entries to the blockchain are, by their nature, public, and because it may be possible for someone to identify you through your pseudonymous, public wallet address using external sources of information, any transaction you enter onto the blockchain could possibly be used to identify you, or information about you.‍

Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services or who otherwise perform business-related functions for Turnkey. This includes:
- Third-party Protocol participants;
- Technology, hosting and telecommunications vendors and IT support;
- Compliance and security risk assessment service providers;
- Support and customer service vendors;
- Payment processing companies, such as Stripe;
- Vendors providing accounting, auditing, tax, legal, and other professional services; and
- Analytics providers.‍

Third-Party Services You Share or Interact With. Certain features and functionalities of the Services may link to or allow you to interface, interact, or share information with, access and/or use third-party websites, services, products, and technology (collectively, “Third-Party Services”). Any information shared with or otherwise collected by a Third-Party Service may be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.‍

Other Users and the Public. Your personal information may be visible to other users of Services and the public (e.g. transactions via blockchain). In situations in which your personal information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines, blockchain transaction explorers), we are not responsible for any such use of information.

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.‍

Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes and in a manner consistent with this Privacy Policy.

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 due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be disclosed, sold or transferred as part of such a transaction, as permitted by law and/or contract.

D. SMS The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

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5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.‍

‍Email and SMS Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails and SMS messages regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services, your account or updates to our Terms or this Privacy Policy).‍

“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 and Personalized Advertising. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage technologies like HTML5 and Flash, and other technologies (“Technologies”) to automatically collect information through your use of the Services. 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. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, IOS, and others. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance and the Digital Advertising Alliance of Canada. Please note you must separately opt out in each browser and on each device.

You may manage your cookie preferences at any time using our Cookie Preferences manager, where you can opt out of non-essential cookies.

Declining to Provide Information. We may need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Third-Party Platforms. If you choose to connect to the Service through a third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Advertising choices. You can limit use of your information for interest-based advertising by:
- Browser settings. Blocking third-party cookies in your browser settings.
- Privacy browsers/plug-ins. By using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies.
- Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising:
- Google: https://adssettings.google.com/
- Facebook: https://www.facebook.com/about/ads
- Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:
- Network Advertising Initiative: www.networkadvertising.org/managing/opt_out.asp
- Digital Advertising Alliance: optout.aboutads.info
- AppChoices mobile app, available at www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.

You will need to apply these opt-out settings on each device from which you wish to opt-out. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked to above.

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Your Privacy Rights. In accordance with applicable law and depending on your location, you may have the right to:

Access to, and Portability of, Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format;

Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update 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.

Other sites and services. Services may contain links to third-party operated services and business offerings such as websites, mobile applications, and other online services. In addition, our content may be integrated into web pages or other online services that are not associated with or controlled by us. The information you share with such third-party services are governed by policies and practices of the third-parties and not governed by this Privacy Policy. These links and integrations are not an endorsement by us of or representation that we are affiliated with or have reviewed any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies and practices of the other websites and mobile applications and online services you use, and please contact such third parties directly for additional information on their privacy policies and practices.

Notwithstanding the above, we cannot edit or delete any information that is stored on a blockchain or other technologies involving immutable records.

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6. SECURITY OF YOUR INFORMATION

We implement many commercially reasonable, technical, administrative organizational and physical safeguards designed to protect the personal information we collect both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or description. However, security risk is inherent in all internet, information, and blockchain technologies and we cannot guarantee the security of your personal information. Therefore, you should take special care in deciding what information you send to us or any third-parties. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Turnkey Service or third party services and business offerings. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information. By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

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7. INTERNATIONAL DATA TRANSFERS

You transfer your personal information directly to us in the United States. All information processed by us may be further 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. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

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8. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. We may also create and use Aggregated Data for research, statistical or other lawful, as described above, in which case we may use this information indefinitely without further notice to you.

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9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

Beginning January 1, 2020, the California Consumer Privacy Act (“CCPA”) gives California residents certain rights with respect to the processing of personal data (known as “personal information” under the CCPA. This supplement provides additional privacy disclosures and details additional rights and should be read in conjunction with our Privacy Policy. Collection of Information Section 2 of our Privacy Policy sets forth the categories of personal information that we collect and process about you, a description of each category, and the sources from which we obtain each category. Section 3 describes how we use your personal information, and Section 4 describes our sharing practices. Your Rights: Right to Know. Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and request that we provide you with the following information:

Categories of and specific pieces of personal information we have collected about you.
Categories of sources from which we collect personal information.
Purposes for collecting personal information.
Categories of third parties with whom we share personal information.
Categories of personal information disclosed about you for a business purpose.
If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold. Right to Delete. You also have a right to request that we delete personal information, subject to certain limitations under applicable law. Right to Opt-out From Sale. You may request to opt-out of any “sale” of your personal information that may take place. We do not rent or sell personal information and take care to not enter into any data sharing arrangements that could constitute a "sale" under the CCPA. Non-discrimination We will not discriminate against you for exercising any of your rights under the CCPA.

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10. CHILDREN'S INFORMATION

The Services are not directed to children under 16 (or other age as required by local law), 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 our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

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11. OTHER PROVISIONINGS

Third-Party Websites/Applications. 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. Payment Processing. Please be advised that your use of our payment processing partner, Stripe, Inc. ("Stripe"), is subject to Stripe’s privacy policy and terms and conditions. By using the Stripe services, you agree to be bound by Stripe’s terms of service and privacy policy, which can be found on its website. Data Protection Regulator. Depending on your location, you may have the right to lodge a complaint with the competent data protection regulator if you believe our processing of your personal information violates applicable law.

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11. SUPPLEMENTAL INFORMATION FOR THE EUROPEAN ECONOMIC AREA, SWITZERLAND AND THE UNITED KINGDOM

These terms supplement our Privacy Policy regarding the processing of personal data from the European Economic Area (EEA), which includes the European Union Member States, Iceland, Liechtenstein, and Norway, as well as Switzerland and the United Kingdom (UK). In the event of any conflict between these terms and other sections of our Privacy Policy, this section will govern with respect to the processing of EEA, Swiss, and UK personal data, where applicable.

Data Controller: the entity responsible for processing your personal data under this Privacy Policy is the Turnkey entity with which you have a primary relationship, which may be the entity that has entered into a service contract with you, the entity that has provided you with marketing communications, the primary entity operating in the region where you access our services. In most cases, the data controller is Turnkey, unless otherwise specified
Legal Basis for Processing: please refer to the above in this Privacy Policy for details on the legal basis upon which we collect, process, and use personal data.
Data Protection Rights: Under applicable data protection laws, you may exercise certain rights regarding your personal data as outlined below. To exercise any of the following rights, please contact us using the contact details in this Privacy Policy. However, requests may be denied in certain cases, such as when they infringe on another individual’s privacy rights or conflict with legal obligations.
- Right to Access: you may request confirmation of whether we process your personal data and obtain a copy of your personal data undergoing processing.
- Right to Data Portability: if processing is based on your consent or a contract and is carried out by automated means, you may request to receive your personal data in a structured, commonly used, and machine-readable format for transfer to another data controller.
- Right to Withdraw Consent: if you have provided consent for data processing, you may withdraw it at any time without affecting prior lawful processing.
- Right to Rectification: you may request correction of inaccurate or incomplete personal data.
- Right to Object: you may object to the processing of your personal data in certain circumstances. Right to Restrict Processing: you may request restrictions on the processing of your personal data in specific situations.
- Right to Erasure: you may request the deletion of your personal data under certain conditions.
- Right to Lodge a Complaint: you have the right to file a complaint with a supervisory authority, such as the EU Data Protection Authorities (DPAs), the U.K. Information Commissioner’s Office (ICO), the Gibraltar Regulatory Authority (GRA), or the Swiss Federal Data Protection and Information Commissioner (FDPIC).
- Right to Avoid Automated Decision-Making: we do not engage in automated decision-making under Article 22(1) and (4) of the EU/UK General Data Protection Regulation (GDPR). If this changes, we will inform you and provide mechanisms for human intervention, expression of viewpoint, and contesting decisions.

As a result of our multinational reach, some data recipients may be located in countries outside the EEA, Switzerland, or the U.K., where data protection laws may not provide the same level of protection. When we transfer data internationally, we will aim to ensure compliance with legal requirements by utilizing approved codes of conduct or certification mechanisms, EU Standard Contractual Clauses and/or the U.K. Addendum, approved binding corporate rules and/or permissible statutory derogations or other legally valid transfer mechanisms.

Some jurisdictions have been deemed to provide adequate data protection by EEA, Swiss, and U.K. authorities, in which case no additional safeguards are required. For more information about data transfers, including copies of relevant transfer mechanisms, please contact our Data Protection Officer as specified below.

Data Protection Officer: The contact details for our data protection officer are as follows: Turnkey, Inc., Attn: Legal, 1209 N. Orange Street, Wilmington DE 19801, United States, privacy@turnkey.com.

12. SUPPLEMENTAL INFORMATION FOR OTHER COUNTRIES AND REGIONS

Australia. Personal data collected, stored, used, and processed by Turnkey is handled in accordance with the Australian Privacy Act 1988 (Commonwealth) and the Australian Privacy Principles (APPs). If you are dissatisfied with our response to a complaint or disagree with our proposed resolution, you may escalate your concern to the Office of the Australian Information Commissioner (OAIC) via the contact methods listed on their website. Alternatively, you may request that we forward the details of your complaint to the OAIC on your behalf.

Brazil. Personal data collected, stored, used, and processed by Turnkey complies with Lei Geral de Proteção de Dados (LGPD). By using or accessing our Services, you explicitly consent to the collection, use, storage, and processing of your personal data for the purposes described in this Privacy Policy.

Canada. Personal data, as defined under the Personal Information Protection and Electronic Documents Act (PIPEDA), is collected, stored, used, and processed by Turnkey in compliance with its obligations under PIPEDA.

Japan. Personal data collected, stored, used, and processed by Turnkey is managed in accordance with Japan’s Act on the Protection of Personal Information (APPI).

New Zealand. Personal data collected, stored, used, and processed by Turnkey is handled in accordance with New Zealand’s Privacy Act 2020 and its 13 Information Privacy Principles (NZ IPPs).

Singapore. Personal data collected, stored, used, and processed by Turnkey complies with the Personal Data Protection Act 2012 (PDPA) and Turnkey’s obligations under this law.

United Kingdom. Personal data collected, stored, used, and processed by Turnkey is managed in accordance with the UK Data Protection Act 2018, as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 and any subsequent amendments, supersessions, or replacements (U.K. GDPR).

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13. CONTACT US

Turnkey is the entity responsible for 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@turnkey.com.

UK General Data Protection Regulation (GDPR) - UK Representative
Pursuant to Article 27 of the UK GDPR, Turnkey Global, Inc. has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/
by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

General Data Protection Regulation (GDPR) – European Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Turnkey Global, Inc. has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium