PRIVACY POLICY

This Privacy Notice sets forth the information gathering, use, and dissemination practices of Turnstile Capital Management, LLC. (“LLC”) in connection with the website located at  www.turnstilecapital.com (the “Site”). This Privacy Notice addresses TCM’s practices regarding information collected only directly through or from its Site – it does not address or govern any information gathering, use, or dissemination practices related to information collected other than directly through or from its Site, including, without limitation, from or via telephone, facsimile, postal mail, personal delivery, or other or additional offline means or media.

This Privacy Policy is incorporated into TCM’s Terms and Conditions for the Site, which must be reviewed and accepted by you.

The Site is not intended for children under the age of 18. It does not knowingly collect personal information online from visitors in this age group.

IMPORTANT DISCLOSURE ABOUT THE FDCPA: Nothing in this Site Privacy Notice is intended to contradict your rights under the Fair Debt Collection Practices Act. TCM will not disclose any information to third parties that is otherwise prohibited by the FDCPA.

TCM collects, uses, and stores information on the domain you use to access its Site, the Internet address of the site from which you linked directly to its Site, and the date and time of your visit to its Site. This information may be used to measure the number of visitors to the various pages on the TCM Site, to help make improvements to the information contained on the site, and to better serve site visitors through special marketing and service programs, among others. TCM also collects, uses, and stores the e-mail addresses of users that communicate with TCM via e-mail, information knowingly provided by Site users, and information regarding which Site pages users’ access. TCM may also use Internet cookies and other identifiers or methods of web analysis to gather, store, and track certain information related to your visit to and activity on the Site. If you are uncomfortable with the idea of your information being used in this way, most computer systems and web browsers offer privacy settings and options, such as disabling cookies or opting for “Do Not Track” features. TCM does not override these settings or options, and encourages you to use them to enhance your choices and personalize your experiences. However, in order to access certain content, features, services, products or benefits on the Site, you may be required to provide TCM with certain information, including some types of personally identifying information such as your email, your address, and your phone number. If you do not wish to provide such information through the Site or if you opt to utilize the aforementioned privacy features of your computer system or web browser, you may be unable to obtain certain content, features, services, products or benefits of the Site.

Personal information contained in e-mail sent by individuals may be used by TCM to answer questions, follow-up on suggestions or complaints, process requests or transactions, or improve the level of service TCM provides.

TCM will protect your information, and will not release your name, email address or other personal information to any advertiser, merchant, or other third parties not related to  www.turnstilecapital.com without your permission.

TCM will not give, sell, share, rent, or trade information to others in ways different from what is disclosed in this statement. www.turnstilecapital.com stores its records in the United States www.turnstilecapital.com is the owner of the information collected on this website.

The Site may also contain links to third-party websites, for the convenience of users in locating information, products, or services that may be of interest. If you access a third-party website from a link on this Site, any information you disclose on that website is not subject to this Privacy Policy. It is possible that these links may be used by third parties or others to collect personal or other information about you. TCM is not responsible for the privacy practices of such websites, advertisers, or third parties or the content of such websites and it is your sole obligation to review and understand the privacy practices and policies of these other websites. TCM does not control these third parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other websites, advertisers and any third parties.

E-mail posted or sent through this Site may not be secure against interception by unauthorized individuals. To protect against interception by unauthorized individuals, we will not respond to e-mail requests concerning accounts placed for collection. Therefore, if you are communicating with TCM regarding a debt that has been placed for collection with Transworld Systems Inc., all correspondence regarding that account should be sent by U.S. Postal Service. Be sure to include your name, your mailing address, the TCM account number, creditor name, and creditor account number so that we may process your inquiry and respond promptly. Without complete information, we will be unable to respond to your request.

The address for mailing inquiries is:
402 West Broadway, 20th Floor, San Diego CA 92101

TCM has implemented physical, electronic, and procedural security safeguards to protect against the unauthorized release of or access to personal information. Accordingly, TCM is not responsible for the security of information transmitted via the Internet.

The  www.turnstilecapital.com privacy policy may be updated to increase our users’ privacy protection or to improve our information practices. If there are changes made in the future, the changes will not affect information already collected. Any changes to www.turnstilecapital.com privacy policy will be available on this page for users to review.

 

CALIFORNIA RESIDENTS: PRIVACY POLICY NOTICE

This Privacy Policy Notice is intended for California residents pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), and supplements the information contained in the above Privacy Policy.  Any terms defined in the CCPA and applicable California Attorney General regulations have the same meaning as used in this Privacy Policy Notice.

  1. Information We Collect About You

We may collect and use personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be directly or indirectly linked, with a consumer, device, or household (“personal information”).

Personal Information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, such as (but not limited to) information governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the California Confidentiality of Medical Information Act (“CMIA”), the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”).

We regularly collect (and have collected in the past 12 months)  several types of personal information about individuals offline regarding accounts we service for other entities, including: name, DOB, address, gender, account number, payment and other financial information, email address, insurance information, Social Security Number, employment information, telephone number, IP address, military or veteran status, audio information, username, commercial information (such as records of property, products, or services purchased, or other purchasing or consuming histories or tendencies), internet activity such as interaction with our website(s) or application(s), inferences drawn from any personal information categories to create a profile about a consumer reflecting the consumer’s preferences, characteristics, aptitudes, or behavior, publicly available information, and information collected or shared pursuant to HIPAA, CMIA, FIPA, GLBA, FCRA, DPPA, and/or other applicable privacy laws.  We also may collect additional categories of personal information users provide directly to us, our clients, or our vendors.

2. How Your Personal Information is Collected

We collect most of this personal information from our creditor clients or from you or your authorized representative if you provide it to us.  However, we may also collect information:

  • From publicly accessible sources (e.g., property or other government records);
  • From our vendors (e.g., call analytics, information source, skip-tracing, payment processing, mailing, and other vendors)

3. Why We Use or Disclose Your Personal Information

We regularly use or disclose personal information for one or more of the following business purposes:

  • Fulfill the reason you provided the information. For example, if you share your personal information to make a payment, we will use that information to process your payment.
  • Perform services on behalf of a business or service provider, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, providing analytic services, or providing similar services on behalf of the business or service provider
  • Provide you with information or services that you request from us
  • Auditing related to consumer interactions
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  • Debugging to identify and repair errors that impair existing intended functionality
  • Short-term, transient use, where the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction
  • Undertaking activities to verify or maintain the quality of a service or device that is owned, made by or for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, made by or for, or controlled by us
  • Respond to law enforcement requests and as required by applicable law or court order
  • As appropriate to protect the rights, property, or safety of us, our clients, or others
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different purposes without providing you notice.

We regularly disclose (and have disclosed in the past 12 months) several types of personal information about individuals for one or more business purposes, including: name, DOB, address, gender, account number, previous payment and other financial information, email address, insurance information, Social Security Number, employment information, telephone number, IP address, military or veteran status, audio information, username, commercial information (such as records of property, products, or services purchased, or other purchasing or consuming histories or tendencies), internet activity such as interaction with our website(s) or application(s), inferences drawn from any personal information categories to create a profile about a consumer reflecting the consumer’s preferences, characteristics, aptitudes, or behavior, publicly available information, and information collected or shared pursuant to HIPAA, CMIA, FIPA, GLBA, FCRA, DPPA, and/or other applicable privacy laws.

We have not sold your personal information over the last 12 months and will not sell your personal information under the CCPA.

4. Verifiable Consumer Requests for Information

Upon verification of identity, California residents may in some cases request that a business:

  • Disclose the categories of personal information the business collected about the consumer;
  • Disclose the categories of sources from which the personal information is collected
  • Disclose the categories of personal information that the business sold about the consumer;
  • Disclose the categories of personal information that the business disclosed about the consumer for a business purpose;
  • Disclose the categories of third parties with whom the business shares personal information
  • Disclose specific pieces of personal information the business has collected about the consumer
  • Disclose any financial incentives offered by the business for collection, sale, or deletion of personal information

Businesses that provide information requested pursuant to the CCPA must provide such information in a readily useable format and allow consumers to transmit the information from one entity to another without hindrance.

A business may charge a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to you by your personal information.

Please note that we are not required to:

  • Carry out information access requests we receive from you if acting as a service provider to another entity regarding such information
  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
  • Provide requested information if a CCPA or applicable exception applies.

5. Right to Request Deletion of Personal Information

Upon verification of identity, California residents may in some cases request that a business delete personal information collected from them, subject to certain exceptions.

We may deny your deletion request if we are acting in the role of a service provider to another business regarding the applicable personal information.  If we deny your request on that basis, we will generally refer you to the relevant business.  In addition, we may deny your deletion request if retaining the information is necessary for us or our client to:

  • Complete the transaction for which the personal information was collected, provide a good or service requested by you, as reasonably anticipated within the context of your relationship with the relevant business, or otherwise perform a contract between you and the business.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  • Debug to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act.
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent.
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the relevant business.
  • Comply with a legal obligation.
  • Otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided the information; or
  • If another CCPA or applicable exception applies.

6. Verifying Your Identity If You Submit CCPA Requests

If you choose to contact us directly via the designated methods described above to exercise your CCPA rights, you will need to:

  • Provide enough information to reasonably identify you [(e.g., your full name, account number if applicable, and potentially other identifying information]; and
  • Describe your request with sufficient detail to allow us to properly process and respond to your request.

In addition to the exceptions described in this Notice, we are not obligated to make an information disclosure or carry out a deletion request pursuant to the CCPA if we cannot sufficiently verify the identity of the requestor.

If seeking to make a verifiable request under the CCPA on behalf of someone else, we require enough information to reasonably identify the subject of the request (including name and other identifying information) and the subject’s written consent to make the CCPA request on his or her behalf, as consistent with applicable law.

Any personal information we collect from you in order to verify your identity in connection with your CCPA request will be used solely for the purposes of verification.