Privacy Policy

This Privacy Policy agreement was last updated on October 25th, 2020

Turnip Media Private Limited ("TMPL") values your privacy. In this Privacy Policy ("Policy"), we describe the information that we collect about you when you visit TMPL’s mobile application (and website, if any) (“Turnip”), and use the services available on Turnip ("Services"), and how we use and disclose that information.

If you have any questions or comments about the Privacy Policy, please contact us at [email protected] This Policy is incorporated into and is subject to the TMPL’s Terms of Use, which can be accessed at https://turnip.gg/terms. Your use of Turnip and/or Services and any personal information you provide on Turnip remains subject to the terms of the Policy and TMPL's Terms of Use.

In terms of the Information Technology (Intermediaries Guidelines) Rules, 2011 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, any grievance or complaint may be intimated to Pooja Dubey, Grievance Officer, who may be reached at [email protected] The complaint shall be redressed within a period of 1 (one) month.

A. Collection of Your Personal Information

1. COLLECTION OF PERSONAL INFORMATION

“Personal information” is defined to include information that whether on its own or in combination with other information may be used to readily identify or contact you such as: name, address, email address, phone number etc.

We collect personal information from users who are desirous of posting Submitted Content on Turnip. This information is partially or completely accessible to all visitors using Turnip. Streamers and Viewers are required to link their YouTube, Facebook and/or both accounts with Turnip in order to log in and to be able to access certain portions of Turnip. 

You may log into Turnip through your YouTube and /or Facebook account. If you do so, you must enter the email address and password that you use for your YouTube and/or Facebook account. We will ask that you grant us permission to access and collect your YouTube and/or Facebook basic information (this includes your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other information you have set to public on your YouTube and/or Facebook account). If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public. We store the information that we receive from YouTube and/or Facebook with other information that we collect from you or receive about you.

YouTube and/or Facebook controls the information it collects from you. For information about how YouTube and/or Facebook may use and disclose your information, including any information you make public, please consult YouTube and/or Facebook's privacy policy. We have no control over how any third party site uses or discloses the personal information it collects about you.

At the time of such linking, user data such as name, email ID, profile picture etc., and information related to the YouTube channel/account and Facebook page/ account such as channel / page ID, channel / page name, channel / page description, thumbnail, statistics such as video count, subscriber count, total views etc. shall be collected and the user grants requisite permission for the same. The Streamer specifically grants permission to TMPL to manage the YouTube and Facebook account, and store chats in relation to the same, in order to provide the Services. Such information gathered shall be utilized to ensure greater customer satisfaction and help a customer satiate its needs. The type of personal information that we collect from you varies based on your particular interaction with Turnip.

We may also collect personal information that you post in your Submitted Content such as profile, feedback, and any comments or discussions you post in any blog, chat room, or other correspondence site on Turnip. TMPL reserves the right to record the conversations between Streamers and Viewers through the messaging/chat mechanism on the platform. All the chat/messaging logs can be used for but not limited to monitor and prohibit abuse, safeguard the rights of Streamers and Viewers, resolve disputes etc.

2. COLLECTION OF AUTOMATIC INFORMATION, USE OF COOKIES AND OTHER TRACKING DEVICES

We and our third party service providers, which include ad networks, use cookies, web beacons, and other tracking technologies to collect information about your use of Turnip and Services, such as your browser type, your ISP or operating system, your domain name, your access time, the URL of the previous website you visited, your page views, your IP address, and the type of device that you use. We also track how frequently you visit Turnip and use our Services. We use this information (including the information collected by our third party service providers) for website / application analytics (including to determine which portions of Turnip are used most frequently, what our users like/do not like), to assist us in determining relevant advertising (both on and off Turnip), to evaluate the success of our advertising campaigns, and as otherwise described in this policy. Currently, we do not honour browser requests not to be tracked.

We may obtain your device ID, which is sent to TMPL's servers and used in fraud prevention efforts.

Cookies. We and our third party service providers collect information from you by using cookies. A cookie is a small file stored on user's computer hard drive containing information about the user. The cookie helps us analyze web traffic or informs you about your use of a particular website. Cookies allow web applications to respond to you as an individual, tailoring its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. When you visit Turnip, we may send one or more cookies (i.e., a small text file containing a string of alphanumeric characters) to your computer that identifies your browser.

Some of these cookies may be connected to third-party companies or websites. The terms of use of such cookies are governed by this Policy and the privacy policy of the relevant third party company or website. For example, Google measures the performance of advertisements by placing cookies on your computer when you click on ads. If you visit Turnip when you have such cookies on your computer, we and Google will be able to tell that you saw the ad delivered by Google. The terms of use of these cookies are governed by this Policy and Google's Privacy Policy.

Disabling Cookies. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you disable cookies you may be prevented from taking full advantage of Turnip because it may not function properly if the ability to accept cookies is disabled.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with Turnip to, among other things, track the activities of Turnip visitors, help us manage content, and compile statistics about Turnip usage. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

B. How TMPL Uses the Information Collected

1. HOW PERSONAL INFORMATION IS USED

We collect your personal information and aggregate information about the use of Turnip and Services to better understand your needs and to provide you with a better Turnip experience. Specifically, we may use your personal information for any of the following reasons:

From time to time, TMPL may use personal information for new and unanticipated uses not previously disclosed in our Privacy Policy. If our information practices change regarding information previously collected, TMPL shall make reasonable efforts to provide notice and obtain consent of any such uses as may be required by law.

C. Electronic Newsletters, Invitations, Polls and Surveys

At our sole discretion, TMPL may offer any of the following free services on Turnip, which you may select to use or receive at your option. Certain of the following services may require you to provide additional personal information as detailed below:

1. ELECTRONIC NEWSLETTERS

We may offer a free electronic newsletter to users. We will gather the email addresses of users who sign up for Turnip for the newsletter mailing list. Users may remove themselves from this mailing list by opting out of receiving newsletters during the registration process, by following the link provided in each newsletter that points users to a subscription management page where the user can unsubscribe from receiving newsletters or by changing their preferences in their settings page.

2. "SEND TO A FRIEND"

Turnip users can voluntarily choose to electronically forward a link, page, or document to someone else by clicking "send to a friend." To do so, the user must provide his or her email address, as well as the email address of the recipient. The user's email address is used only in the case of transmission errors and, of course, to let the recipient know who sent the email. The information is not used for any other purpose.

3. POLLING

We may offer interactive polls to users so they can easily share their opinions with other users and see what our audience thinks about important issues, Services, and/or Turnip. Opinions or other responses to polls are aggregated and are not identifiable to any particular user. We may use a system to "tag" users after they have voted, so they can vote only once on a particular question. This tag is not correlated with information about individual users.

4. SURVEYS

We may conduct user surveys from time to time to better target our content to Turnip users. We will not share individual responses from these surveys with any third party. We will share aggregate data with third party service providers, partners, and other third parties. We also will post aggregate data containing survey responses on Turnip; that data may be viewed and downloaded by other users of Turnip.

D. Security

We employ procedural and technological security measures, which are reasonably designed to help protect your personal information from unauthorized access or disclosure. TMPL may use encryption, passwords, and physical security measures to help protect your personal information against unauthorized access and disclosure. No security measures, however, are 100% complete. Therefore, we do not promise and cannot guarantee, and thus you should not expect, that your personal information or private communications will not be collected and used by others. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. TMPL is not responsible for the unauthorized use of your information or for any lost, stolen, compromised passwords, or for any activity on your Account via unauthorized password activity.

Your password is the key to your Account. When creating your password you should use unique numbers, letters, special characters, and combinations thereof. In addition, DO NOT disclose your password to anyone. If you do share your password or your personal information with others, you are solely responsible for all actions taken via your Account. If you lose control of your password, you may lose substantial control over your personal information and be subject to legally binding actions taken on your behalf. Thus, IF YOUR PASSWORD HAS BEEN COMPROMISED FOR ANY REASON, YOU MUST IMMEDIATELY NOTIFY TMPL TO CHANGE YOUR PASSWORD.

E. Disclosure

We may share the information that we collect about you, including your personal information, as follows:

1. INFORMATION DISCLOSED TO PROTECT US AND OTHERS

We may disclose your information including Personal Information if: (i) TMPL reasonably believes that disclosure is necessary in order to comply with a legal process (such as a court order, search warrant, etc.) or other legal requirement of any governmental authority, (ii) disclosure would potentially mitigate our liability in an actual or potential lawsuit, (iii) reasonably necessary to enforce this Privacy Policy, our Terms of Use etc. (iv) disclosure is intended to help investigate or prevent unauthorized transactions or other illegal activities, or (v) necessary or appropriate to protect our rights or property, or the rights or property of any person or entity.

2. INFORMATION DISCLOSED TO THIRD PARTY SERVICE PROVIDERS AND BUSINESS PARTNERS

We may contract with various third parties for the provision and maintenance of Turnip, Services and our business operations, and TMPL may need to share your personal information and data generated by cookies and aggregate information (collectively, "information") with these vendors and service agencies. For example, we may provide your information to a credit card processing company to process your payment. The vendors and service agencies will not receive any right to use your personal information beyond what is necessary to perform its obligations to provide the Services to you. If you complete a survey, we also may share your information with the survey provider; if we offer a survey in conjunction with another entity, we also will disclose the results to that entity.

3. DISCLOSURE TO NON-AFFILIATED THIRD PARTIES IN FURTHERANCE OF YOUR REQUEST

Your request for services may be shared with third party websites with whom we have a contractual relationship in order to provide your request with maximum exposure. The post on the third party website will include the details of your request, including your location, and other contact details. Interested bidders, however, will be able to click on your request on such third party site, and will be directed to Turnip where they will have access to your contact details (Partial or complete), as would any other service provider on Turnip interested in bidding on your request.

4. DISCLOSURE TO OTHER USERS OF TURNIP

If you are a Streamer, the information that you post (other than your payment information) is available to other users of Turnip and our Services. Comments that users post to Turnip also will be available to other visitors to Turnip (see our discussion of User Generated Content below). In addition, we will post the results (in aggregate form) of surveys to Turnip. If you are a Viewer, certain information and any Submitted Content shall be available to all other visitors to Turnip. 

5. INFORMATION DISCLOSED TO LAW ENFORCEMENT OR GOVERNMENT OFFICIALS

We will disclose your information, including, without limitation, your name, city, state, telephone number, email address, user ID history, quoting and listing history, and fraud complaints, to law enforcement or other government officials if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an investigation of a governmental authority.

6. IN THE EVENT OF A CHANGE OF CONTROL OR BANKRUPTCY

In the event that TMPL undergoes a change in control, including, without limitation, a merger or sale of all or substantially all of TMPL’s assets to which Turnip relates or other corporate reorganization in which TMPL participates, and is thus merged with or acquired by a third party entity (a "Successor"), TMPL hereby reserves the right to transfer the information we have collected from the users of Turnip and/or Services to such Successor.

In addition, in the event of TMPL’s bankruptcy, reorganization, receivership, or assignment for the benefit of creditors, or the application or laws or equitable principles affecting creditors' rights generally, TMPL may not be able to control how your information is transferred, used, or treated and reserves the right to transfer the information we have collected from the users of Turnip and/or Services to non-affiliated third parties in such event.

7. INFORMATION DISCLOSED AT YOUR REQUEST

We may share your personal information with other Users to whom you explicitly ask us to send your information or if you explicitly consent to such disclosure upon receipt of a specific Service. 

F. Links to External Websites

Turnip may contain links to other websites or resources over which TMPL does not have any control. Such links do not constitute an endorsement by TMPL of those external websites. You acknowledge that TMPL is providing these links to you only as a convenience, and further agree that TMPL is not responsible for the content of such external websites. We are not responsible for the protection and privacy of any information which you provide while visiting such external websites and such sites are not governed by this Policy. Your use of any external website is subject to the terms of use and privacy policy located on the linked to external website.

Information we receive from third-party sites you connect to our Service: 

We may receive personal information about you from third parties and combine that with the information we collect through Turnip. For example, we may obtain information when you log in through a third-party social network or authentication service, such as YouTube, or Facebook, among others. We may obtain information, including personal information, from third parties and other sources, such as information from Facebook through the Facebook API and YouTube through the YouTube API and other secure third party information sharing practices. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, address book and contacts, or other information. Similarly, when you interact with us through a social media site or third-party service, such as when you like, follow, or share Turnip content on Facebook, Twitter, Instagram, or other sites, we may receive information from the social network, including your profile information, picture, user ID associated with your social media account, and any other information you permit the social network to share with third parties. The data we receive from these third-party sites is dependent upon that third party’s policies and your privacy settings on that third-party site. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to Turnip. You can find more information on YouTube and Google’s privacy at https://policies.google.com/, and Facebook Privacy Policy at https://www.facebook.com/privacy/explanation

G. Updating, Deleting and Correcting Your Personal Information

You may choose to restrict the collection or use of your personal information in the following ways:

You can review, correct and delete your personal information by logging into Turnip and navigating to your preferences page in "Edit Profile." You must promptly update your personal information if it changes or is inaccurate. Typically, we will not manually alter your personal information because it is very difficult to verify your identity remotely. Nonetheless, upon your request we will close your Account and remove your personal information from view as soon as reasonably possible based on your Account activity and in accordance with applicable law. We do retain information from closed Accounts in order to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations of any User, enforce our Terms of Use, and take any other actions otherwise permitted by law that we deem necessary in our sole and absolute discretion. You should understand, however, that once you publicly post Submitted Content or any other information onto Turnip, you may not be able to change or remove it. Once we have deleted or removed your Account, you agree that TMPL shall not be responsible for any personal information that was not included within your deleted and/or removed Account that remains on the Website. 

H. What Choices Do I Have Regarding Use of My Personal Information?

We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your Account or any Services you have requested or received from us.

I. Third-Party Ad Networks

We participate in third party ad networks that may display advertisements on other websites based on your visits to Turnip as well as other websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. Third party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third party cookies and other technologies are governed by each third party's specific privacy policy, and not by TMPL’s Policy. We may provide these third-party advertisers with information about your usage of Turnip and our services, as well as aggregate or non-personally identifiable information about visitors to Turnip and users of our service.

J. User Generated Content

We invite you to post content on our Website, including your comments, feedback, pictures, and any other information that you would like to be available on Turnip. If you post content to Turnip, all of the information that you post will be available to all visitors to Turnip. If you post your own content on Turnip, your posting may become public and TMPL cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.

L. Privacy Policy Updates

THIS POLICY IS CURRENT AS OF THE EFFECTIVE DATE SET FORTH ABOVE. TMPL MAY, IN ITS SOLE AND ABSOLUTE DISCRETION, CHANGE THIS POLICY FROM TIME TO TIME BY UPDATING THIS DOCUMENT. TMPL WILL POST ITS UPDATED POLICY ON TURNIP ON THIS PAGE. TMPL ENCOURAGES YOU TO REVIEW THIS POLICY REGULARLY FOR ANY CHANGES. YOUR CONTINUED USE OF TURNIP AND/OR CONTINUED PROVISION OF PERSONAL INFORMATION TO US WILL BE SUBJECT TO THE TERMS OF THE THEN-CURRENT POLICY.

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