Privacy Policy

Last updated: 7/29/2025

1. Introduction

TurnRock ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI services platform.

2. Information We Collect

Personal Information

We collect information you provide directly to us, such as:

• Name and email address
• Username and password
• Invitation code used during registration
• Profile information you choose to provide
• Communications between you and TurnRock

Usage Information

We automatically collect certain information when you use our services:

• Log data (IP address, browser type, operating system)
• Device information
• Usage patterns and preferences
• AI interaction history and generated content
• Performance metrics and error reports

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our services
• Process transactions and send related information
• Send technical notices, updates, security alerts, and support messages
• Respond to your comments, questions, and requests
• Monitor and analyze trends, usage, and activities
• Detect, investigate, and prevent fraudulent transactions and other illegal activities
• Personalize and improve your experience
• Train and improve our AI models (with anonymized data)

4. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information. We may share your information in the following situations:

• With your consent: We may share your information with your explicit consent
• Service providers: We may share information with third-party vendors who perform services on our behalf
• Legal requirements: We may disclose information if required by law or in response to valid legal requests
• Protection of rights: We may disclose information when we believe it necessary to protect our rights, privacy, safety, or property
• Business transfers: We may share information in connection with a merger, acquisition, or sale of assets

5. Data Security

We implement appropriate technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and audits
• Access controls and authentication mechanisms
• Employee training on data protection
• Incident response procedures

6. AI-Generated Content

When you use our AI services:

• Your inputs and the AI's outputs may be stored to improve our services
• We may use anonymized interaction data to train and improve our models
• You retain ownership of your inputs, subject to our license to provide services
• AI-generated content may be subject to additional terms of use

7. Data Retention

We retain your information for as long as necessary to provide our services and fulfill the purposes outlined in this policy. When determining retention periods, we consider:

• The nature and sensitivity of the information
• Legal and regulatory requirements
• Business and operational needs
• User expectations and requirements

8. Your Rights and Choices

You have certain rights regarding your information:

• Access: Request access to your personal information
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your information, subject to certain exceptions
• Portability: Request a copy of your information in a portable format
• Opt-out: Opt out of certain communications and data uses

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Maintain your session and authentication status
• Remember your preferences and settings
• Analyze usage patterns and improve our services
• Provide security features

You can manage cookie preferences through your browser settings.

10. Children's Privacy

Our services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we learn we have collected such information, we will promptly delete it.

11. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place to protect your information in accordance with this privacy policy.

12. California Privacy Rights

California residents have additional rights under the California Consumer Privacy Act (CCPA), including:

• Right to know what personal information is collected
• Right to know whether personal information is sold or disclosed
• Right to opt-out of the sale of personal information
• Right to non-discrimination for exercising privacy rights

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically.

14. Contact Us

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact us at:

15. Additional Disclosures for EU Residents

If you are a resident of the European Union, you have additional rights under the General Data Protection Regulation (GDPR):

• Legal basis for processing your information
• Right to withdraw consent at any time
• Right to lodge a complaint with a supervisory authority
• Information about automated decision-making and profiling