We do not sell or share your SMS opt-in data or personal information with third parties for marketing purposes. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with or sold to any third parties.
1. Introduction & Scope
Turn Financial, Inc. ("Turn Financial", "Turn", "we", "us", or "our") respects your personal privacy. This Privacy Policy describes how we collect, use, store, protect, and handle your personal data when you visit our website (turn.financial / turnfinancial.com), register for our waitlist, utilize our applications, or interact with our conversational concierge, Turn Butler, via SMS text messaging or voice telephony.
2. Information We Collect
We collect information you provide directly to us, as well as limited technical information generated automatically:
- Contact Information: Mobile telephone number, full name, and email address provided when you sign up for future updates, early access waitlists, or account onboarding.
- Waitlist & Savings Preferences: Survey answers regarding your savings circle traditions (e.g., Susu, Pardna, Tanda, Sòl), whether you intend to organize or join a circle, and preferred group sizes.
- Communications & Messaging Records: Inbound and outbound SMS/MMS messages, support inquiries, and AI-assisted conversation transcripts when communicating with Turn Butler.
- Voice Call Audio & Transcriptions: If you place an inbound telephone call to or receive a call from our telephony line, the audio is processed, recorded, and transcribed in real time for service execution and quality assurance.
- Device & Usage Data: IP address, browser type, operating system, timestamp, and referral URLs collected automatically through server logs.
3. Strict Mobile Data Protection & Carrier 10DLC Compliance
Mandatory Text Messaging Originator Opt-In Clause
We do not sell or share your SMS opt-in data or personal information with third parties for marketing purposes. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with or sold to any third parties.
In strict accordance with cellular carrier guidelines (including CTIA principles and The Campaign Registry rules):
- Zero Third-Party Marketing: We do not sell, rent, lease, barter, or share your mobile phone number, opt-in records, or messaging history with external telemarketers, lead brokers, or commercial affiliate networks.
- Technical Sub-Processors Only: Your mobile number is only transmitted to licensed telecommunications carriers and our direct messaging infrastructure sub-processors (such as Twilio) solely as necessary to transmit SMS messages and route telephone calls. These sub-processors are bound by strict contractual data processing agreements and are legally barred from utilizing your number for any other purpose.
4. How We Use Your Information
We use personal data strictly for legitimate business and service purposes:
- To send you transactional notifications, launch announcements, early access invitations, and platform updates that you requested;
- To power Turn Butler's automated concierge services across SMS and voice telephone channels;
- To verify member identity and protect against fraud, synthetic identities, and unauthorized access;
- To comply with federal regulations (including anti-money laundering and Regulation E recordkeeping);
- To improve the performance, reliability, and security of our software platform.
5. Opt-Out & Universal Revocation of Consent (STOP)
You have total control over your communication preferences:
- SMS Opt-Out: You may opt out of receiving text messages at any time by replying STOP, CANCEL, END, QUIT, or UNSUBSCRIBE to any message from Turn Financial. You will receive a single confirmation message verifying your opt-out.
- Help & Support: Reply HELP or INFO to any message, or email our privacy and support team at [email protected].
6. Data Security & Storage
Turn Financial implements industry-grade technical, administrative, and physical safeguards. All data transmitted between your device and our servers is encrypted using TLS 1.3. Stored records are encrypted at rest using AES-256 encryption. Access to user communications and personal data is restricted to authorized personnel governed by least-privilege security controls.
7. Your Privacy Rights (CCPA / CPRA & State Protections)
Under applicable state privacy laws (including the California Consumer Privacy Act as amended by the CPRA), you have the right to:
- Know & Access: Request disclosure of the categories and specific pieces of personal data collected about you.
- Correction: Request correction of inaccurate personal data.
- Deletion: Request deletion of your personal data, subject to statutory exceptions (such as financial audit trail retention under federal banking and anti-money laundering mandates).
- Non-Discrimination: We will never discriminate against you, charge different rates, or deny service for exercising your statutory privacy rights.
To exercise any of these rights, contact us at [email protected].
8. Children's Privacy
The Platform is strictly intended for individuals 18 years of age or older. We do not knowingly collect, solicit, or maintain personal information from children under 18.
9. Policy Updates
We may update this Privacy Policy periodically to reflect enhancements to our platform or updates to telecommunications and data privacy laws. When changes occur, we will update the "Last Updated" date at the top of this document. Continued use of our site or messaging services constitutes acceptance of the revised policy.
10. Contact Us
Email: [email protected]
Member Support: [email protected]