Privacy Policy

Turning Hearts takes your privacy seriously and is committed to protecting your privacy rights. We want you to know why we collect your personal information, what we collect, how we use it, and for how long we store it. We also want you to know how you can access, amend, correct, and in some cases delete your information.
This is a high-level overview of our privacy policy. Please scroll down read the full privacy policy.

Who we are

When we speak of Turning Hearts, we mean the Turning Hearts group of companies which currently comprises the following legal entities:

-Turning Hearts LLC (“Turning Hearts”).

Why we collect information

  • We collect personal information when you request an account or our content assets, in order to provide useful content and follow up on its effectiveness for business purposes.
  • We collect information when you contact us to respond to your request, question, or issue, and to follow up on the resolution.
  • We collect information when you buy and/or use our software or services. We do this to be able to deliver our services, to send you important operational information, for contractual reasons, to process financial transactions, and for legal and regulatory reasons.

What we collect

  • We collect name, email, phone, address, job title, company, and if you use Turning Hearts products or services and what those are.
  • We may collect other data you have provided while contacting us or creating an account, especially using the contact, download, or signup forms on our website.
  • We collect data that you have sent to us through account postings, an online survey, support ticket, or job application.
  • We collect anonymous information sent by your browser when you visit our websites, including IP address, operating system, and browser version. If you identify yourself by filling out a form, some data (such as what pages you view on our websites) will be connected to your personal information.

How we use information

  • We never sell or rent your personal information to third parties. If you have given us your express permission, we may share your personal information to select partners that you decide. (Non-EU: We may share your personal information to select partners. We always make clear when we share that information.)
  • If you have requested an account or have participated viewing an account or posting, we use your personal information to follow up on the effectiveness of the Turning Hearts products.
  • If you are an individual based in the EU and you have requested to be added to one of our newsletters, we may use your address to send you marketing communications. If you are a non-EU individual and have registered to access one of our content marketing assets or a webinar, me may use your address to send you marketing communications.
  • If you are a customer, we may use your contact information to send you product or services updates and information that is relevant to your use of the products and services.
  • We may share information with vendors that act on our behalf, such as services we use to maintain our contact records. These vendors act on our instructions and adhere to the policies described in this document.
  • Turning Hearts has employees and offices globally. This means that we may transfer information globally. Outside of the EU, we have offices in for example United States, but Turning Hearts employees or sub-processors may access the information from other countries.

Information we and partners collect when you browse our website

  • Google Analytics – see below
  • Load balancer tagging – we have multiple web servers, and this identifier make sure that you are served by the same web server between page views. 
  • On our websites, we include a number of scripts from third-party vendors. These scripts may gather data for web statistics, they may be used for interest-based advertising on other services (such as Google, Facebook, or LinkedIn), and they may offer additional functionality to the web sites (such as chat).
  • The websites and third-party scripts may use cookies or local storage. Cookies and local storage can be used to identify a returning visitor. Cookies and local storage in themselves to not identify you as an individual – but if you for instance are using Facebook, and subsequently visit our websites, Facebook may learn about your visit.
  • On our websites, we are tracking data for analytical purposes into our data stores and prediction models powered by Turning Hearts. 
  • We cannot tell who you are unless you willingly identify yourself on our websites.
  • If you at some point have identified yourself by filling out a form on our websites, pages you view on our websites may be connected to your personal information. We do this to understand the effectiveness of our website.
  • For certain parts of our websites, for instance pages that require a login, cookies are required for the website to work properly. Otherwise, cookies are generally not required for the operation of the website.
  • We set a cookie and use local storage in your browser that contains information that we use to identify you between visits. In particular, we set an identifier that identifies you for the functional site features described below:

Required site features – vendors that may collect Personal Data on our behalf:

Functional site features – vendors that may collect anonymous data on our behalf:

  • Google Analytics: We use Google Analytics to analyze the performance of our websites and follow up on the effectiveness of ou marketing efforts. Google Analytics allow us to analyze data in aggregate, we do not collect or store any personal information in Google Analytics. Read Google’s privacy policy here.
  • Optinmonster (Vendor anonymous data): Optinmonster is a conversion optimization tool that we use to create pop-ups to guide users through our website. It collects anonymised visitor behaviour information such as new and returning visitor data, number of pages visited during a session and how did the visitor interact with the Optinmonster popups. This data is stored in local cookies. For specific marketing campaigns the anonymous data is aggregated and used to evaluate the success of a campaign. The cookies are not used externally with third parties for any purpose. No personally identifiable information is stored but visitors can delete the cookies in their own browser to stop them being used. The cookies are:

    _omappvp: used for determining new vs. returning visitors
    _omappvs: used to determine when a new visitor becomes a returning visitor
    om-global-cookie / omGlobalSuccessCookie: used to prevent any future OptinMonster campaigns from showing on your site
    om-interaction-cookie / omGlobalInteractionCookie: used to determine if a visitor has interacted with any campaign on your site
    om-{id} / om-{campaignSlug}: ;used to determine if a visitor has interacted with a campaign ID of {id} / {campaignSlug} on your site
    omSeen-{campaignSlug}: used to determine if a visitor has been shown a campaign by the slug
    om-success-{id} / omSuccess-{campaignSlug}: used to determine if a visitor has successfully opted into a campaign with the ID of {id} / {campaignSlug} on your site
    om-success-cookie / omSuccessCookie: used to determine if a visitor has successfully opted into any campaign on your site
    om-{id}-closed / omSlideClosed-{campaignSlug}: used specifically with slide-in campaigns {id} / {campaignSlug} to determine if it has been closed or not by a visitor
    omCountdown-{campaignSlug}-{elementId}: used for countdown elements {elementId} in campaigns {campaignSlug} to determine when it should complete
    omSessionStart: used to determine the current session time of the visitor on your site
    omSessionPageviews: used to determine the number of pages seen by a visitor during their browsing session on your site.

Information we collect when you fill out a form on our websites

  • When you submit a form on our websites, we collect the information that is listed in the form – typically your name, email address, phone number, and information about individuals who you create an account for. If you are based in a country within the European Union, you also get the option to opt in to our email newsletter. If you are a non-EU individual, you may receive our newsletter if you sign up for an account, demo, or webinar.
  • By submitting a form on our websites, you confirm that you have you have read and accept this privacy policy, and that you understand that data will be collected and processed for the purposes outlined in this policy.
  • If you have filled out a form on our websites, we may collect the URLs of any pages viewed or links clicked on our websites and connect them to your profile. This may include pages that you have visited prior to filling out a form on our website. We do this to better understand your needs.
  • If you open or click a link in an email we have sent you in response to you filling out a form, including email newsletter, that information will be connected to your profile. We may do this to either verify your email address to prevent spam and misuse, or to follow up on the usefulness of our email marketing.
  • If you use any of our discussion forums (such as the one on Turning Hearts World), the information you enter will be stored for the purpose of publishing it to the discussion forum.
  • As a way to prevent spam and fraudulent input, we make use of the reCAPTCHA service from Google to protect forms. This service captures data about the visitor in order to figure out if it is a real person or a bot. We do not send any personal data to Google, but they may see information that your browser sends, such as your hardware and software configuration or your IP address.

How long we keep information

  • We keep your information only for as long as it is warranted from to fulfill our commitments to you, or to adhere to legal or regulatory requirements.
  • If you are a customer or partner, we keep the information for the duration of our relationship. Certain information may be kept for longer though, for instance contracts will be archived even when terminated.
  • If you have requested to receive marketing communications, we will keep your personal information only for as long as you interact with us.
  • In most cases, we keep your personal information for no more than 12 months after the last contact or when your contract has expired, with the exception of information we have to keep for legal reasons, such as signed contracts. A more full description follows below. 

If you are an Turning Hearts customer or partner

  • If you are an Turning Hearts customer or partner, we may keep your personal information for the duration of our contract between your organization and us. If not required by law or regulation to keep your information beyond that term, we will remove it within 12 months of the contract ending.
  • If you have signed or entered into a contract with us, we typically archive and store that contract for an extended period of time, typically seven years or longer, depending on jurisdiction. Other items such as invoices may also be kept for longer than 12 months.
  • If you have asked to receive one of our newsletters or other marketing communications from us, we will keep your personal information to maintain your subscription, even if you would no longer be a customer or partner of ours.
  • If you have signed up to take part in our developer community or discussion forums, your personal information will remain unless you explicitly tell us to remove it.

If you are not an Turning Hearts customer or partner

  • If you have opted into any of our content marketing initiatives or have opted in to our newsletters, your personal information will be kept for us long as you seem to be an active subscriber.
  • If we haven’t seen any activity on your part for 12 months, we will remove your personal information or anonymize it.
  • If you have been in touch with us with a question, demo request, asked for a quote, or have engaged with a sales representative, your information will be stored for up to 12 months after the last recorded activity, and will then be removed or anonymized.
  • If you have signed up to take part in our developer community or discussion forums, your personal information will remain unless you explicitly tell us to remove it.
  • If you have submitted a valid GDPR data subject access request to exercise your right to be forgotten we will delete your data within 30 days of the request.

Products and Services

  • We provide software services to our customers. This software service allows our customers to build websites portfolios of individuals and it may be used to collect personal information.
  • In these cases, it is our customers that control the processing of personal information, and we act on their behalf as a processor.
  • If you have a question about how your information is processed, please contact the owner of the website or sender of the communication.

Security 

  • Protection of your information
    • We take care to protect your personal data against abuse or loss. As an example, we store it in secure environments. We also provide training to our employees on data protection best practices and require them to enter into a confidentiality agreement.
    • We cannot guarantee absolute security though. If you would like to learn more about what we do to protect your data, please contact us at [email protected].
  • Information shared with vendors and service providers
    • In order to deliver our services, we rely on a number of different vendors. This covers everything from the software we use in our finance department to the infrastructure we use to run the services. These vendors act as data processors on our behalf.
    • We hold our vendors and service providers to the same high privacy standards as we hold ourselves to. In all cases where we share your information with anyone outside of the Turning Hearts group of companies, we explicitly require them to acknowledge and adhere to privacy and customer data handling policies through a data processing agreement.
    • Some vendors and service providers are based outside the European Union, including the United States.

Your choices and rights

  • You can choose to opt out of marketing communications at any time, regardless if you are a customer, partner, or none of the above.
  • If you are an individual based in the EU you can request a copy of your personal information and you can update any incorrect information.
  • If you are an individual based in the EU, you can ask to have your personal information removed, or in some cases limit our processing of personal information. This does not apply when we need to keep your information for legal reasons.

How you can opt out of marketing

  • If you don’t want to receive marketing communications from us, you can at any time use the “Unsubscribe” link present in all marketing emails from us, or go to our unsubscribe page.
  • Please note that opting out of email marketing typically doesn’t mean that you won’t see ads from us – please see the section below on how you can opt out of web tracking, although it doesn’t mean that you will opt out of ads altogether.

How you can opt out of web tracking

  • Most browsers allow you to block third-party cookies or prevent cross-domain tracking. This will limit the cookies that can be set by third-party scripts. This will not completely eliminate tracking by some third-party services though as they may use first-party cookies.
  • Most browsers also allow you ask not to be tracked (it sends the “Do Not Track” request header). If you have enabled this feature, we will not track the pages you visit in a way that enables us to connect them to your personal information. Your page views may still be collected anonymously though. Many of the third-party services we use for collecting anonymous data also respect the Do Not Track setting.
  • You can opt out of interest-based advertising on these two pages: NAI consumer opt-out page and DAA opt-out page. This will not remove ads, but will for example remove the possibility for us to display ads to people that have visited our website. Note that these services in themselves requires cookies.
  • You can also opt out from the individual services we use:
  • AdRoll: You can turn off interest-based ads on AdRoll’s opt-out page.
  • Facebook: You can turn off interest-based ads in your Facebook settings – please see this page: https://www.facebook.com/help/568137493302217
  • Google ads, including Google AdWords and Doubleclick: You can turn of personalization for Google’s display and search ads – please see this page: You can edit your settings for ad personalization here. There is more information on ad personalization on Google and through their ad networks here.
  • Google Analytics: You can use Google’s opt-out browser add-on to prevent tracking in Google Analytics, see https://tools.google.com/dlpage/gaoptout.
  • Hotjar: You can turn off Hotjar recording by following the steps on this page: https://www.hotjar.com/opt-out
  • Microsoft (including Bing): You can turn off interest-based ads here: https://choice.microsoft.com/
  • Optimizely: If you want to opt out of Optimizely experiments (such as A/B-testing), please follow the instructions on this page.
  • There are several ways to opt out of web tracking

Your rights as an individual based in the EU

  • Access to your information: You have the right to request a copy of the personal information we hold about you.
  • Correcting your information: We want to have accurate data. Please contact us if you think the data we hold is not up to date or correct.
  • Deletion of your information: You have the right to ask us to delete Personal Data about you if it no longer is required for the purpose it was collected, you have withdrawn your consent, you have a valid objection to us using your Personal Data, or our use of your Personal Data is contrary to law or our other legal obligations.
  • Objecting to how we may use your information: You have the right at any time to require us to stop using your Personal Data for direct marketing purposes.  In addition, where we use your Personal Data to perform tasks carried out in the public interest then, if you ask us to, we will stop using that Personal Data unless there are overriding legitimate grounds to continue.
  • Restricting how we may use your information: In some cases, you may ask us to restrict how we use your Personal Data.  This right might apply, for example, where we are checking the accuracy of Personal Data about you that we hold or assessing the validity of any objection you have made to our use of your information.  The right might also apply where this is no longer a basis for using your Personal Data but you don’t want us to delete the data.  Where this right to validly exercised, we may only use the relevant Personal Data with your consent, for legal claims or where there are other public interest grounds to do so.
  • Automated processing: If we use your Personal Data on an automated basis to make decisions which significantly affect you, you have the right to ask that the decision be reviewed by an individual to whom you may make representations and contest the decision.  This right only applies where we use your information with your consent or as part of a contractual relationship with you
  • Withdrawing consent using your information: Where we use your Personal Data with your consent you may withdraw that consent at any time and we will stop using your Personal Data for the purpose(s) for which consent was given.
  • Please contact if you wish to exercise any of these rights. You can find the contact details below.

If you want to submit a complaint

  • We have appointed a Data Protection Officer. If you are a European Union (“EU”) resident who requires assistance in exercising your privacy rights, please write to Data Protection Officer at [email protected],.
  • We always want to resolve directly all complaints about how we handle Personal Data. If you are a EU resident, you also have the right to lodge a complaint with the Swedish Data Protection Authority (Datainspektionen).

How to contact us:

Address (EU):
Pesätie 34 F 120,
90420 Oulu, Kaakkuri,
Finland

  • Generally, the same terms apply for you as for individuals based in the European Union.
  • Some provisions regarding your rights to access, delete, or limit the processing of data may be different.
  • If you download one of our content marketing assets by filling out a form on our website, we may send you marketing communications. You may unsubscribe at any time.
  • For residents in California, special privacy rights apply.

How to contact us (Email)

If you are outside the EU:

Turning Hearts
9707 N. Royal Red Road
Cedar Hills, UT, 84062

[email protected]