Introduction Definitions Name and address of the controller Data protection Cookies Personal information we collect How we use personal information Disclosure of personal information Your rights`Children Links to other websites Security and Retention Legal basis for the processing Legitimate Interest by Controller or Third Party International users Changes to the privacy policy How to contact us

Introduction

Last Updated August 31, 2023

We at Tur.ai B.V. (together withour affiliates, “Tur.ai”, “we”, “our” or “us”) respect your privacy and arestrongly committed to protecting and keeping secure any information we obtainfrom you or about you. This Privacy Policy describes our practices with respectto Personal Information we collect from or about you when you use our website,applications, and services (collectively, “Services”). This Privacy Policy doesnot apply to content that we process on behalf of customers of our businessofferings, such as our API. Our use of that data is governed by our customeragreements covering access to and use of those offerings.

The processing of personal data,such as the name, address, e-mail address, or telephone number of a datasubject shall always be in line with the General Data Protection Regulation(GDPR), and in accordance with the country-specific data protection regulationsapplicable to the Tur.ai B.V.. By means of this privacy policy, our enterprisewould like to inform the general public of the nature, scope, and purpose ofthe personal data we collect, use and process. Furthermore, data subjects areinformed, by means of this data protection declaration, of the rights to whichthey are entitled.

As the datacontroller, the Tur.ai B.V. has implemented numerous technical andorganizational measures to ensure the fullest protection of personal dataprocessed through this website. However, Internet-based data transmissions mayin principle have security gaps, so guaranteeing complete protection is not always possible. For this reason, every data subjectis free to transfer personal data to us via alternative means, e.g. bytelephone.

Definitions

The privacy policy of the Tur.aiB.V. is based on the terms used by the European legislator for the adoption ofthe General Data Protection Regulation (GDPR). Our goal is for our privacy policy to be easily readable andunderstandable for the general public, our customers, and business partners. To ensure this, we would like tofirst explain the terminology used.

In this privacy policy, we usethe following terms, among others:

a) Personal data

Personal data means anyinformation relating to an identified or identifiable natural person("data subject"). An identifiable natural person is one who can beidentified, directly or indirectly, in particular by reference to an identifiersuch as a name, an identification number, location data, an online identifieror to one or more factors specific to the physical, physiological, genetic,mental, economic, cultural or social identity of that natural person.

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b) Data subject

Data subject is any identified oridentifiable natural person, whose personal data is processed by the controllerresponsible for the processing.

c) Processing

Processing is any operation or setof operations which is performed on personal data or on sets of personal data,whether or not by automated means, such as collection, recording, organization,structuring, storage, adaptation or alteration, retrieval, consultation, use,disclosure by transmission, dissemination or otherwise making available,alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing is themarking of stored personal data with the aim of limiting their processing inthe future.

e) Profiling

Profiling means any form ofautomated processing of personal data consisting of the use of personal data toevaluate certain personal aspects relating to a natural person, in particularto analyze or predict aspects concerning that natural person's performance atwork, economic situation, health, personal preferences, interests, reliability,behavior, location or movements.

f) Pseudonymization

Pseudonymization is the processingof personal data in such a manner that the personal data can no longer be attributedto a specific data subject without the use of additional information, providedthat such additional information is kept separately and is subject to technicaland organizational measures to ensure that the personal data are not attributedto an identified or identifiable natural person.

g) Controller or controller responsible forthe processing

Controller or controllerresponsible for the processing is the natural or legal person, publicauthority, agency or other body which, alone or jointly with others, determinesthe purposes and means of the processing of personal data; where the purposesand means of such processing are determined by Union or Member State law, thecontroller or the specific criteria for its nomination may be provided for byUnion or Member State law.

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h) Processor

Processor is a natural or legalperson, public authority, agency or other body which processes personal data onbehalf of the controller.

i) Recipient

Recipient is a natural or legalperson, public authority, agency or another body, to which the personal dataare disclosed, whether a third party or not. However, public authorities whichmay receive personal data in the framework of a particular inquiry inaccordance with Union or Member State law shall not be regarded as recipients;the processing of those data by those public authorities shall be in compliancewith the applicable data protection rules according to the purposes of theprocessing.

j) Third party

Third party is a natural or legalperson, public authority, agency or body other than the data subject,controller, processor and persons who, under the direct authority of thecontroller or processor, are authorized to process personal data.

k) Consent

Consent of the data subject is anyfreely given, specific, informed and unambiguous indication of the datasubject's wishes by which he or she, by a statement or by a clear affirmativeaction, signifies agreement to the processing of personal data relating to himor her.

Name and address of thecontroller

Controllerfor the purposes of the General Data Protection Regulation (GDPR), other dataprotection laws applicable in Member states of the European Union and otherprovisions related to data protection is:

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Tur.ai B.V.

KvK72024453, VAT NL858950777B01

Communicatieweg9-1, 3641 SG Mijdrecht, The Netherlands

Email:

hello [at] tur [.] ai

Website: www.tur.ai

Data protection

Data protection officercontact email:

Email:

hello [at] tur [.] ai

Any data subject may, at anytime, contact our Data Protection Officer directly with all questions andsuggestions concerning data protection.

Cookies

The Internet pages of the Tur.ai B.V., use cookies. Cookies aretext files that are stored in a computer system via an Internet browser.

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Many Internet sites and servers use cookies. Many cookies contain aso-called cookie ID. A cookie ID is a unique identifier of the cookie. Itconsists of a character string through which Internet pages and servers can beassigned to the specific Internet browser in which the cookie was stored. Thisallows visited Internet sites and servers to differentiate the individualbrowser of the data subject from other Internet browsers that contain othercookies. A specific Internet browser can be recognized and identified using theunique cookie ID.

Through the use of cookies, the Tur.ai B.V. can provide the usersof this website with more user-friendly services that would not be possiblewithout the cookie setting.

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By means of a cookie, the information and offers on our website canbe optimized with the user in mind. Cookies allow us, as previously mentioned,to recognize our website users. The purpose of this recognition is to make iteasier for users to utilize our website. The website user that uses cookies,e.g. does not have to enter access data each time the website is accessed,because this is taken over by the website, and the cookie is thus stored on theuser's computer system. Another example is the cookie of a shopping cart in anonline shop. The online store remembers the articles that a customer has placedin the virtual shopping cart via a cookie.

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The data subject may, at any time, prevent the setting of cookiesthrough our website by means of a corresponding setting of the Internet browserused, and may thus permanently deny the setting of cookies. Furthermore,already set cookies may be deleted at any time via an Internet browser or othersoftware programs. This is possible in all popular Internet browsers. If the datasubject deactivates the setting of cookies in the Internet browser used, notall functions of our website may be entirely usable.

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For more details on cookies, please visit All About Cookies.

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Personal information we collect

We collectpersonal information relating to you (“Personal Information”) as follows:

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Personal Information You Provide: We collect Personal Informationif you create an account to use our Services or communicate with us as follows:

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Account Information: When you create an account with us, we will collect information associated with your account, including your name, contact information, account credentials, payment card information, and transaction history, (collectively, “Account Information”).
User Content: When you use our Services, we collect Personal Information that is included in the input, file uploads, or feedback that you provide to our Services (“Content”).
Communication Information: If you communicate with us, we collect your name, contact information, and the contents of any messages you send (“Communication Information”).
Social Media Information: We have pages on social media sites like Instagram, Facebook, Medium, Twitter, YouTube and LinkedIn. When you interact with our social media pages, we will collect Personal Information that you elect to provide to us, such as your contact details (collectively, “Social Information”). In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.

Personal Information We Receive Automatically From YourUse of the Services: When youvisit, use, or interact with the Services, we receive the following informationabout your visit, use, or interactions (“Technical Information”):

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Log Data: Information that your browser automatically sends when you use our Services. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interact with our website.
Usage Data: We may automatically collect information about your use of the Services, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and your computer connection.
Device Information: Includes name of the device, operating system, device identifiers, and browser you are using. Information collected may depend on the type of device you use and its settings.
Analytics: We may use a variety of online analytics products that use cookies to help us analyze how users use our Services and enhance your experience when you use the Services.

How we use personal information

We may usePersonal Information for the following purposes:

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To provide, administer, maintain and/or analyze the Services;
To improve our Services and conduct research;
To communicate with you;
To develop new programs and services;
To prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our IT systems, architecture, and networks;
To carry out business transfers; and
To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

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Aggregated or De-Identified Information. We may aggregate or de-identifyPersonal Information so that it may no longer be used to identify you and usesuch information to analyze the effectiveness of our Services, to improve andadd features to our Services, to conduct research and for other similarpurposes. In addition, from time to time, we may analyze the general behaviorand characteristics of users of our Services and share aggregated information likegeneral user statistics with third parties, publish such aggregated informationor make such aggregated information generally available. We may collectaggregated information through the Services, through cookies, and through othermeans described in this Privacy Policy. We will maintain and use de-identifiedinformation in anonymous or de-identified form and we will not attempt toreidentify the information, unless required by law.

As notedabove, we may use Content you provide us to improve our Services, for exampleto train the models that power Tur.ai.

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Disclosure of personal information

In certaincircumstances we may provide your Personal Information to third parties withoutfurther notice to you, unless required by the law:

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Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may provide Personal Information to vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software, and web analytics services, among others. Pursuant to our instructions, these parties will access, process, or store Personal Information only in the course of performing their duties to us.
Business Transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a “Transaction”), your Personal Information and other information may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
Legal Requirements: We may share your Personal Information, including information about your interaction with our Services, with government authorities, industry peers, or other third parties (i) if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, or users, or the public, or (vi) to protect against legal liability.
Affiliates: We may disclose Personal Information to our affiliates, meaning an entity that controls, is controlled by, or is under common control with Tur.ai. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.

Your rights`

Dependingon location, individuals in the EEA, the UK, and across the globe may havecertain statutory rights in relation to their Personal Information. Forexample, you may have the right to:

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Access your Personal Information and information relating to how it is processed.
Delete your Personal Information from our records.
Rectify or update your Personal Information.
Transfer your Personal Information to a third party (right to data portability).
Restrict how we process your Personal Information.
Withdraw your consent—where we rely on consent as the legal basis for processing at any time.
Object to how we process your Personal Information.
Lodge a complaint with your local data protection authority.

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Pleasesend your request to

privacy [at] tur [.] ai

A noteabout accuracy: Services like Tur.ai generate responses by reading a user’srequest and, in response, predicting the words most likely to appear next. Insome cases, the words most likely to appear next may not be the most factuallyaccurate. For this reason, you should not rely on the factual accuracy ofoutput from our models. If you notice that Tur.ai output contains factuallyinaccurate information about you and you would like us to correct theinaccuracy, you may submit a correction request to

privacy [at] tur [.] ai.

Given the technical complexity ofhow our models work, we may not be able to correct the inaccuracy in everyinstance. In that case, you may request that we remove your PersonalInformation from Tur.ai output by filling contacting us as

privacy [at] tur [.] ai.

Security and Retention

Weimplement commercially reasonable technical, administrative, and organizationalmeasures to protect Personal Information both online and offline from loss,misuse, and unauthorized access, disclosure, alteration, or destruction.However, no Internet or email transmission is ever fully secure or error free.In particular, email sent to or from us may not be secure. Therefore, youshould take special care in deciding what information you send to us via theService or email. In addition, we are not responsible for circumvention of anyprivacy settings or security measures contained on the Service, or third-partywebsites.

We’llretain your Personal Information for only as long as we need in order toprovide our Service to you, or for other legitimate business purposes such asresolving disputes, safety and security reasons, or complying with our legalobligations. How long we retain Personal Information will depend on a number offactors, such as the amount, nature, and sensitivity of the information, the potentialrisk of harm from unauthorized use or disclosure, our purpose for processingthe information, and any legal requirements.

Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processingoperations for which we obtain consent for a specific processing purpose. Ifthe processing of personal data is necessary for the performance of a contractto which the data subject is party, as is the case, for example, whenprocessing operations are necessary for the supply of goods or to provide anyother service, the processing is based on Article 6(1) lit. b GDPR. The sameapplies to such processing operations which are necessary for carrying outpre-contractual measures, for example in the case of inquiries concerning ourproducts or services. Is our company subject to a legal obligation by whichprocessing of personal data is required, such as for the fulfillment of taxobligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases,the processing of personal data may be necessary to protect the vital interestsof the data subject or of another natural person. This would be the case, forexample, if a visitor were injured in our company and his name, age, healthinsurance data or other vital information would have to be passed on to adoctor, hospital or other third party. Then the processing would be based onArt. 6(1) lit. d GDPR. Finally, processing operations could be based on Article6(1) lit. f GDPR. This legal basis is used for processing operations which arenot covered by any of the above mentioned legal grounds, if processing isnecessary for the purposes of the legitimate interests pursued by our companyor by a third party, except where such interests are overridden by theinterests or fundamental rights and freedoms of the data subject which requireprotection of personal data. Such processing operations are particularlypermissible because they have been specifically mentioned by the Europeanlegislator. He considered that a legitimate interest could be assumed if thedata subject is a client of the controller (Recital 47 Sentence 2 GDPR).

International users

By usingour Service, you understand and acknowledge that your Personal Information willbe processed and stored in our facilities and servers in the EU and may bedisclosed to our service providers and affiliates in other jurisdictions.

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For EEA,UK or Swiss users:

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Legal Basis for Processing. Our legal bases for processing yourPersonal Information include:

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Performance of a contract with you when we provide and maintain our Services. When we process Account Information, Content, and Technical Information solely to provide our Services to you, this information is necessary to be able to provide our Services. If you do not provide this information, we may not be able to provide our Services to you.
Our legitimate interests in protecting our Services from abuse, fraud, or security risks, or in developing, improving, or promoting our Services, including when we train our models. This may include the processing of Account Information, Content, Social Information, and Technical Information.
Your consent when we ask for your consent to process your Personal Information for a specific purpose that we communicate to you. You have the right to withdraw your consent at any time.
Compliance with our legal obligations when we use your Personal Information to comply with applicable law or when we protect our or our affiliates’, users’, or third parties’ rights, safety, and property.

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Data Transfers. Where required, we will use appropriatesafeguards for transferring Personal Information outside of the EEA,Switzerland, and the UK. We will only transfer Personal Informationpursuant to a legally valid transfer mechanism. For more information on theappropriate safeguards in place and to obtain a copy of these safeguards,please contact our data protection office using the contacts stated above.

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