Privacy Policy

This Privacy Policy describes how Turn.CEO LLC ("Company," "we," "us," or "our") collects, uses, and protects information through our website, services, and platforms, including the Captivate business intelligence platform ("Platform"). By using our services, you consent to the practices described in this policy.

1. Information We Collect

a. Information You Provide

• Account Information: Name, email address, phone number, business name, industry, and company size when you register or submit a contact form.
• Billing Information: Payment method details processed through our third-party payment provider (Stripe). We do not store full credit card numbers on our servers.
• Business Data: Information you enter or upload to the Platform, including business profiles, team member details, files, and notes.
• Communications: Messages sent through the Platform's chat features, support requests, feedback, and SMS/text message conversations.

b. Information from Connected Data Sources

When you connect third-party services (e.g., HubSpot, Stripe, QuickBooks, Xero, Meta, Google), we retrieve data from those services on your behalf to display in your dashboards. This may include:

• CRM data (contacts, deals, pipeline stages)
• Financial data (revenue, invoices, transactions)
• Social media metrics (followers, engagement, reach)
• Website analytics (traffic, sessions, conversions)
• Review and reputation data (ratings, review counts)

We access this data using authorized API connections that you configure. You can disconnect any data source at any time.

c. Automatically Collected Information

• Usage Data: Pages visited, features used, actions taken, timestamps.
• Device Information: Browser type, operating system, screen resolution, IP address.
• Cookies & Similar Technologies: Session cookies for authentication and preferences. We do not use third-party advertising cookies.

2. How We Use Your Information

3. Artificial Intelligence & Data Processing

Captivate uses AI and algorithmic models to generate insights, scores, and recommendations from your connected data. Key details:

• Your data is not used to train general-purpose AI models. Data processing is limited to generating outputs specific to your account.
• AI processing occurs on our servers and through our authorized service providers.
• Aggregated, anonymized usage patterns may be used to improve the Platform's scoring algorithms and feature recommendations. Individual business data is never shared or exposed in this process.
• You may opt out of AI-powered features through your Account settings where applicable. Core functionality (e.g., score calculation) requires data processing to function.

4. How We Share Your Information

We do not sell your personal information or business data.

We may share information with:

• Service Providers: Hosting providers, payment processors (Stripe), email delivery services, SMS delivery services (Twilio), and analytics tools that help us operate our services. These providers are contractually bound to handle data only for specified purposes.
• Third-Party Integrations: When you connect data sources, data flows between our platforms and those services as directed by you.
• Legal Requirements: If required by law, subpoena, court order, or to protect the rights, property, or safety of Turn.CEO, our users, or the public.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

5. SMS/Text Messaging

Turn.CEO LLC may send SMS/text messages to users who have provided their phone number and opted in to receive text communications. By checking the SMS consent checkbox on our contact form or otherwise opting in, you agree to receive text messages from Turn.CEO at the phone number you provided.

a. Types of Messages

Messages may include:

• Appointment confirmations and reminders
• Consultation follow-ups
• Service updates and notifications
• Responses to your inquiries

b. Message Frequency

Message frequency varies based on your interactions with Turn.CEO. You will not receive more than 5 messages per month unless you initiate a conversation.

c. Costs

Message and data rates may apply. Turn.CEO does not charge for SMS messages, but your mobile carrier's standard messaging rates will apply.

d. Opt-Out

You can opt out of SMS messages at any time by replying STOP to any message from us. After opting out, you will receive a single confirmation message and no further texts will be sent unless you re-subscribe.

e. Help

For help with SMS messaging, reply HELP to any message from us, or contact us at [email protected] or (725) 777-5383.

f. Consent and Data Use

Your consent to receive SMS messages is not a condition of purchasing any goods or services from Turn.CEO. Your phone number and SMS consent data will not be shared with third parties or affiliates for their own marketing purposes. We share your phone number only with our SMS service provider (Twilio) for the sole purpose of delivering messages you have consented to receive.

g. Supported Carriers

SMS messaging is supported on all major US mobile carriers. Carriers are not liable for delayed or undelivered messages.

6. Data Security

We implement industry-standard security measures including:

• HTTPS encryption for all data in transit
• Encrypted storage for sensitive credentials and API tokens
• Session-based authentication with secure token handling
• Role-based access controls for multi-user accounts
• Regular security reviews and vulnerability assessments

No method of transmission or storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

7. Data Retention

• Active Accounts: We retain your data for as long as your account is active.
• Cancelled Accounts: Upon cancellation, we retain your data for 30 days to allow for reactivation, after which it is scheduled for deletion.
• SMS Records: SMS opt-in consent records and message logs are retained for the duration of your relationship with Turn.CEO and for a reasonable period after opt-out for compliance purposes.
• Legal Obligations: Certain data may be retained longer as required by law (e.g., billing records, tax compliance).
• Backups: Data in system backups may persist for up to 90 days after deletion from active systems.

8. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access your personal data held by us.
• Correct inaccurate personal data.
• Delete your personal data ("right to be forgotten").
• Export your data in a portable format.
• Restrict or object to certain types of processing.
• Withdraw consent where processing is based on consent, including SMS messaging consent.

To exercise these rights, contact us at [email protected]. We will respond within 30 days.

9. Cookies

We use essential cookies required for our services to function (authentication, session management). We do not use advertising or tracking cookies. No cookie consent banner is currently required as we only use strictly necessary cookies.

10. Children's Privacy

Our services are not directed to individuals under 18. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child under 18, we will delete it promptly.

11. International Data Transfers

Our servers are located in the United States. If you access our services from outside the US, your data will be transferred to and processed in the US. By using our services, you consent to this transfer.

12. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act, including the right to know what personal information we collect, the right to delete it, and the right to opt out of the sale of personal information. We do not sell personal information.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or a notice on our website at least 14 days before they take effect. The "Effective Date" at the top will reflect the most recent revision.

14. Contact Us

For privacy-related questions or to exercise your data rights:

Turn.CEO LLC
Phone: (725) 777-5383
Email: [email protected]