At Turolight Inc. ("us", "we", or "our"), safeguarding your privacy is a top priority. This Privacy Policy ("Policy") outlines our practices regarding the collection, use, and safeguarding of personal data and informs you of your rights and choices regarding your personal information when you interact with our Service, including our website https://turolight.com (the "Service") and the TuroSmart App.

This Policy is governed by the laws of Ontario, Canada, and any disputes arising from it will be subject to the exclusive jurisdiction of Ontario's courts. We encourage you to read this Policy carefully. If you do not agree with it, please refrain from providing your personal information.

Definitions

• Personal Data: Data about a living individual who can be identified from those data or from other information in our possession.
• Usage Data: Data collected automatically during the use of the Service or from the Service infrastructure itself (e.g., the duration of a page visit).
• Cookies: Small pieces of data stored on your device used to enhance the user experience.
• Data Controller: The entity that determines the purposes for which and how personal data is processed. We are the Data Controller for this Privacy Policy.
• Data Processors: Third-party companies that process personal data on our behalf.

What Is Personal Information?

For the purposes of this Policy, "personal information" refers to any data that can be used to identify an individual, directly or indirectly. Examples include name, email address, phone number, date of birth, and communication preferences.

When Does This Privacy Policy Apply?

This Policy applies when you interact with the TuroSmart App, our website, and any associated features and services, including customer support. It does not apply to personal information that is public by law.

Information Collection and Use

We collect different types of information to provide and improve our Service:

1. Personal Data: We may collect personally identifiable information such as your name, email address, phone number, and communication preferences.
2. Usage Data: This includes information on how you interact with the Service, such as IP address, browser type, and device details.
3. Cookies and Tracking Technologies: We use cookies to track activity on the Service and improve your experience. You can disable cookies, but some features may be limited.
4. Third-Party Data: We may receive information from third-party partners integrated with the TuroSmart App or the Service.

We use this data for the following purposes:

• To provide and maintain the Service.
• To notify you about changes to the Service.
• To offer customer support and respond to inquiries.
• To improve the Service and analyze user behavior.
• To comply with legal obligations.

Children's Privacy

The TuroSmart App and our Service are not intended for children under 14 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected personal data from a child without parental consent, we will take steps to delete that information.

How We Use Your Personal Information

We use your personal data for various purposes:

• Communication: To respond to your inquiries and provide customer support.
• Personalization: To customize your experience and offer relevant content.
• Legal Compliance: To fulfill legal and regulatory obligations.
• Improvement: To enhance the Service and develop new technologies.

Sharing Your Personal Information

We do not sell your personal data. However, we may share your information in the following cases:

• With your consent.
• With service providers who help us process data on our behalf.
• As required by law (e.g., for legal compliance or safety).

Cross-Border Transfers

Your personal data may be transferred to jurisdictions outside your country of residence, including Canada. By using the Service, you consent to the transfer of your data.

Security of Your Personal Information

We implement industry-standard security measures to protect your personal information. However, no method of transmission over the internet is completely secure, and we cannot guarantee the absolute security of your data.

Retention of Personal Information

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy or to comply with legal obligations. If you wish to delete your data, you may contact us.

Your Rights Regarding Personal Information

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: You can request to access your personal data.
• Correction: You can request to correct inaccurate data.
• Deletion: In certain cases, you can request deletion of your data.
• Withdraw Consent: You can withdraw consent for data collection at any time.
• Objection: You can object to certain types of data collection.

To exercise these rights, please contact us.

Legal Basis for Processing Personal Data (For EEA Users)

For users in the European Economic Area (EEA), our legal basis for processing your personal data includes:

• Consent: You have given consent for processing your data.
• Contract Performance: Data processing is necessary to fulfill a contract with you.
• Legitimate Interests: Processing is necessary for legitimate interests, and your rights do not override those interests.

Disclosure of Data

We may disclose your personal data under the following circumstances:

• Law Enforcement: If required by law or in response to valid legal requests.
• Legal Requirements: To protect our rights, prevent wrongdoing, or ensure user safety.

Service Providers

We may employ third-party service providers to help with our Service. These service providers are authorized to access your personal data only to perform specific tasks on our behalf and are obligated not to use or disclose it for other purposes.

Analytics

We may use third-party analytics services, such as Google Analytics, to monitor and analyze how our Service is used. You can opt out of Google Analytics by installing the opt-out browser add-on.

Behavioral Remarketing

We may use remarketing services, such as Google AdWords, to display ads to users based on their past behavior on the Service. You can opt-out of such remarketing by adjusting your Google Ads settings.

Links to Other Sites

Our Service may contain links to third-party websites. We are not responsible for the content or privacy practices of these external sites.

Severability and Waiver

If any part of this Policy is deemed unenforceable, the remaining provisions will remain in effect. Waiver of any breach does not constitute waiver of future breaches.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page, and the "Effective Date" will be updated accordingly. We encourage you to review this Policy periodically.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:

• By email: info@turolight.com
• By visiting our website: https://turolight.com