Turner Duckworth, a division of alpha245 Inc. ("Turner Duckworth", "we", "us", or "our") is a global design agency offering services to some of the world's greatest brands ("Services"). This Privacy Notice sets out how we collect, use, share, and protect any information we collect through this website ("Website"). This Privacy Notice also explains the measures we take to safeguard your information and describes how you may contact us regarding our privacy practices.
For the sake of clarity, throughout this notice we refer to:
"Personal Data" (or "personal information", "personally identifiable information", or other similar terms depending on the applicable data protection law) to be the data that may be collected, automatically or voluntarily, about a "Consumer" (or "Data Subject", "individual", "user", or "you") while navigating this website;
"Controller" (or "business" under applicable data protection law) to be an entity that, alone or jointly with others, determines how Personal Data is processed, including its purpose as well as the manner in which it's collected; and,
"Processor" (or "service provider" under applicable data protection law) to be an entity that, performs any operation or set of operations on Personal Data on behalf of a Controller and in accordance with the Controller's instructions.
Where we can, we have attempted to limit the different terms we apply throughout this Privacy Notice to limit confusion and to make for an easier reading experience.
I. Personal Data We Receive from Clients, and our "Agency" Services
Please note, other than this section, this Privacy Notice does not apply to the advertising services provided by Turner Duckworth on behalf of clients who may direct Turner Duckworth to process the Personal Data of Consumers in support of these services. Consumers who have reached this Privacy Notice looking to learn more about how their Personal Data may be processed for advertising-related purposes are encouraged to review the Privacy Notices of the advertiser and publisher websites they interact with or the third-party technology companies who engage in these activities on their behalf.
As a Processor, we may provide our clients with agency services, which include scheduling and managing advertising campaigns. Our clients determine how to engage with their customers and thus act as the Controller that determines the purposes and means of handling Consumer data. Under these circumstances,Consumers are ultimately subject to the privacy notice(s) of the advertisers controlling their data, and they should read those notice(s) carefully. We are not responsible, as a processor, for the data practices of our clients. We process personal data upon instruction from our respective clients. Accordingly, this Privacy Notice and the rights acknowledged herein do not apply to data that Turner Duckworth handles on behalf of its clients.
While Turner Duckworth strongly encourages its clients to adopt responsible approaches to its marketing practices, Turner Duckworth is not responsible for the data practices of such clients.
II. What Personal Data do we collect?
The following describes the Personal Data we may collect.
Information Voluntarily Provided By You
This includes contact information such as name, email address, telephone number, company you work for, business title, postal address, and other similar types of information. This type of Personal Data is collected for:
Website Functionalities
Such as message boards, profile pages, social media posts or comments, blogs, and other features of our Website for use of our Services, such as our customer access portal where we may also collect and retain your username and password.
Sign-up Opportunities
For example, participation in our surveys, as well as sign-up forms available on our Website.
Events
When you register for our marketing events, trade shows, and webinars.
Correspondence
Usually through an email, where we will also retain the content of your email messages together with the resulting correspondence.
We may also collect this type of Personal Data from publicly available sources such as LinkedIn or receive it from our clients or business partners who have collected it from you.
Automatically Collected
We employ technologies, such as cookies, pixels, and third-party tags, scripts, and other means to automatically collect information about the use of our Website. Cookies are small pieces of text or code sent to your device when you visit our Website. Cookies are used to optimize the viewing experience, count visitors to a webpage, troubleshoot any problems, keep websites secure, and better serve content. Cookies serve as both a method for collecting information on our Website, as well as a form of Personal Data as they can uniquely identify your browser. Further information about our use of cookies can be found in our Cookie Notice.
No Children or Minor Data
Our Services and Website is intended for a business-to-business audience and are not directed at children under the age of 16. We do not knowingly collect children's Personal Data (as defined by the U.S. Children's Privacy Protection Act, or "COPPA"). We do not knowingly "sell", as that term is defined under the CCPA, the Personal Data of minors under 16 years old who are California residents.
The following further describes the categories of Personal Data we collect and the sources of such Personal Data:
1. Category: Identification and contact data
e.g. online identifiers; IP address; first name, last name, postal address, e-mail address, telephone number
Categories of Sources:
We will collect this directly from you when you communicate with us, including by interacting with our user interface or sending us your questions or comments using the query form.
We may collect this from publicly available sources, data brokers, partners (e.g., that offer co-branded services, sell or distribute our products, or engage in joint marketing activities), advertising networks, internet service providers, data analytics providers, operating systems, and social media networks.
2. Category: Commercial or transactions information
e.g. products or services considered, or other purchasing or consuming histories or tendencies
Categories of Sources:
We will collect this directly from you when you communicate with us, including by interacting with our user interface or sending us your questions or comments using the query form.
We may collect this from publicly available sources, data brokers, partners (e.g., that offer co-branded services, sell or distribute our products, or engage in joint marketing activities), advertising networks, internet services providers, data analytics providers, operating systems, and social media networks.
We may also collect this from internet service providers, data analytics providers, operating systems, and social networks.
3. Category: Internet or other electronic network activity information (Technical data)
e.g. browsing history; search history; online interests; such as information about categories of Consumer interests derived from online usage; and information on a Consumer's interaction with a website, application, or advertisement.
Categories of Sources:
We may collect this from publicly available sources, data brokers, partners (e.g., that offer co-branded services, sell or distribute our products, or engage in joint marketing activities), advertising networks, internet services providers, data analytics providers, operating systems, and social media networks.
We may also collect this from internet service providers, data analytics providers, operating systems, and social networks.
4. Category: Geolocation data
Categories of Sources:
We may collect this from publicly available sources, data brokers, partners (e.g., that offer co-branded services, sell or distribute our products, or engage in joint marketing activities), advertising networks, internet services providers, data analytics providers, operating systems, and social media networks.
We may also collect this from internet service providers, data analytics providers, operating systems, and social networks.
III. How Personal Data is used and lawful basis?
We use Personal Data for the following purposes:
Administer and operate our Services and Website, including sending you marketing and other business-to-business communications.
Direct marketing in accordance with your preferences via email, phone, or other channels, including features of our Services. Such marketing could include newsletters, white papers, market research opportunities, and similar.
To fulfill requests you have made to us, including communicating with you, responding to your inquiries, and providing updates on our products and Services,
To analyze and report on trends and activities related to our Services and our other marketing efforts, such as understanding the parts of our Services visited most often.
To improve our Services, the Website and marketing communications, which includes improving the user experience of such.
We process some of your Personal Data to deliver a contractual service to you, or to do something as part of our contract with you (for example provide you with a quote).
Other internal purposes such as internal research, internal operations, auditing, detecting security incidents, debugging, sort-term and transient use, quality control, improving our Services, and legal compliance.
We rely on legitimate interests or performance of a contract for most of the above processing activities, which include providing and operating our Services, operating our business, obtaining new clients and business partners, retaining existing clients and business partners, and responding to questions and inquiries. We also rely on consent where provided.
IV. Third Party Links
Our Services may include links to other websites, including survey providers or social media platforms that we are not affiliated with. We do not endorse or make any representations about any such third-party websites (or any information, software, or other products or materials found there), and this Privacy Notice does not apply to the data protection practices of such.
This Privacy Notice only covers our Services and Website and does not apply to the data practices of third parties. When you interact with other websites or services, including when you leave the Services, those third parties may independently collect information about you and solicit information from you. The information collected and stored by those third parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services, and whether they store information in the U.S. or elsewhere. We encourage you to review the privacy policies of such unaffiliated third-party websites to understand their data protection practices.
V. Content and social media sharing features
Our Website includes social media sharing features such as LinkedIn, Facebook, and Twitter buttons. A Cookie might be set to enable such features to function properly. These features may collect information about your browser and your device, including your IP address as well as which part of our Website you are visiting.
We also have other content-sharing features embedded on our Website, such as YouTube, which lets us share content with you directly (e.g. videos, podcasts, tracks, and playlists). The providers of these content-sharing features might collect information about you (including Personal Data), such as what part of our Website you visited. They do this to be able to recognize you, and in some cases show you personalized content. We are not responsible for the data practices of these providers and recommend that you read their own privacy policies.
Some features might allow you to email useful information from our Website to a friend or colleague. If you choose to do so, we may ask you to provide your full name and email address, as well as your friend's complete email address. We will send your friend a one-time email inviting them to visit our Website, except where prohibited by law.
VI. Who do we share Personal Data with?
We may share Personal Data with third parties for the following purposes:
Additional support for Services
We work with our affiliates or our processors either to receive additional support (technical or otherwise), or to provide you with Services you have requested from us; as well as with our processors or service providers such as hosting companies, email service providers, customer database providers, or analytics providers. Any processing of Personal Data by such processors or service providers or by personnel of Turner Duckworth or its affiliates is in accordance with our instructions and will be accessed by our processors or service providers only to the extent necessary.
Social media integration
We work with various social media platforms or providers to share content and other features.
Client Services
We may share information with clients in order to facilitate their orders, maintain or administer accounts, respond to questions, comply with requests, or otherwise comply with the law. Our clients and other business partners are independent entities and their processing of information is subject to their own privacy policies.
Corporate restructuring
We may share Personal Data in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stocks (including in connection with any bankruptcy or similar proceedings).
Compliance with law
As we believe necessary and appropriate, we may share Personal Data under applicable law to: (a) comply with legal processes and obligations; (b) respond to requests from public and governmental authorities including public and government authorities outside your country of residence; (c) enforce our terms and conditions; (d) protect our operations; (e) protect our rights, privacy, safety or property; or (f) allow us to pursue available remedies or limit the damages that we may sustain.
VII. How long do we keep Personal Data?
Personal Data will be stored in accordance with our applicable data retention requirements and corporate policies which abide by applicable law. The retention period for Personal Data varies depending on the type of Personal Data and the purposes of processing it. Afterwards, we may aggregate or de-identify the data so it is no longer linked to you or your device. We may use aggregate/de-identified information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any other party, including advertisers, promotional partners, and sponsors, in our discretion, unless otherwise prohibited by applicable law.
VIII. Your Personal Data Rights
1. Generally
1a. Email marketing
All direct marketing messages will include an opportunity to unsubscribe or opt out of future messages. For example, via an unsubscribe link at the bottom of an email. You can change your preferences at any time by clicking on that link. Please note that you cannot opt out of non-promotional emails such as those about transactions, servicing, or our ongoing business relations.
1b. Cookies
In situations when we rely on consent to process your Personal Data, you have the right to withdraw your consent at any time in accordance with this Privacy Notice and applicable law. To withdraw your consent to Cookies used on our Website please click on the "Review Consent Preferences" in the footer of the Website and make your choices.
1c. Analytics
We use Google Analytics, a web analytics service provided by Google, Inc.,1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can learn about Google's privacy practices by going to www.google.com/policies/privacy/partners. Google provides tools to allow you to opt out of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout. Please note that your opt-out will only apply to the specific browser or device from which you opt-out. We are not responsible for the effectiveness of, or the compliance with, any opt-out options or programs, or the accuracy of any other entities' statements regarding their options or programs.
2. By territory
Depending on your country of residence (or as applicable state or other legal territories), you may have certain rights with respect to our processing of your Personal Data. However, please note that some of these rights may differ depending on what laws apply or the nature of the Personal Data. For instance, our Website is intended to provide Services to business clients and so the information we collect about you is intended to be within this context. It is important to be aware that different rules may apply to certain business-to-business personal information or employee personal information depending on what laws apply.
You can exercise your rights by contacting us at privacyinquiries@turnerduckworth.com. Subject to legal and other permissible considerations, we will respond within the timeframe required by applicable laws. This timeframe can be extended to take the complexity of the request or the number of requests received into account. We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way. If we cannot fully address your request, we will contact you to let you know and explain the reason why your request was denied.
2a. Where you are a resident of the EU
If you are a data subject in Europe, you may exercise the following legal rights regarding personal data that we hold about you. If you wish to exercise these rights, please contact us using the contact details below.
The right of access
The right to rectification
The right to erasure
The right to object
The right to restrict processing
The right to data portability
The right to withdraw your consent to the processing of your personal data at any time
2b. Your California Rights and Choices
Without being discriminated against for exercising these rights, California residents, under the California Consumer Protection Act of 2018 ("CCPA"), may have the right to request that we disclose what Personal Data we collect from you, to delete that information, and to opt-out of the sale of your Personal Data, subject to certain restrictions. You also may have the right to designate an agent to exercise these rights on your behalf. To the extent applicable, this section describes how to exercise those rights and our process for handling those requests.
To understand the categories of Personal Data we collected in the last 12 months please review the "What Personal Data do we collect?" section above. To understand the purposes for collecting those categories of Personal Data in the last 12 months please see the "How Personal Data is used and lawful basis?" section above. To understand the categories of parties with whom we have shared the categories of Personal Data within the past 12 months, please see the "Who do we share Personal Data with?" section above.
We do not "sell" (as the term is defined by the CCPA) the Personal Data we collect in accordance with this Privacy Notice.
I. Right to request your Personal Data
California residents have the right to request that we disclose what categories of Personal Data that we collect, use, disclose, or sell about them. In particular, you may request:
The specific pieces of Personal Data that we have collected about you;
The categories of Personal Data we have collected about you;
The categories of sources from which the Personal Data was collected;
The categories of Personal Data about you we disclosed for a business purpose or sold;
The categories of third parties to whom the Personal Data was disclosed for a business purpose or sold; and
The business or commercial purpose for collecting or selling the Personal Data.
III. Right to request deletion of your Personal Data
You may also request that we delete any Personal Data that we collected from you, such as if you have been a customer of ours. However, we may retain Personal Data for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of information so that we can provide our Website and Services to you.
III. How to exercise your access and deletion rights
California residents may exercise their California privacy rights by sending an email to the contact listed below or by calling us toll-free at 1.833.983.0087.
For security purposes (and as required by California law), we will verify your identity - in part by requesting certain information from you - when you request to exercise your California privacy rights. For instance, if you request categories or specific pieces of Personal Data, we have collected about you, you may need to confirm your possession of an identifier (such as an email address) or to provide a piece of identification that confirms you are the person you claim to be.
If we are unable to complete your request fully for any reason, we will provide you with additional information about the reasons why we could not comply with your request.
IV. Right to nondiscrimination
We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these CCPA rights.
V. Shine the Light
Customers who are residents of California may request (i) a list of the categories of Personal Data disclosed by us to third parties during the immediately preceding calendar year for those third parties' own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in the "Contact Us" section below and specify that you are making a "California Shine the Light Request." We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during a calendar year.
VI. Authorized Agents
You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps to both verify the identity of the person seeking to exercise their rights as listed above and to verify that your agent has been authorized to make a request on your behalf by providing us with a signed written authorization or copy of a power of attorney.
IX. Data Security
We have implemented appropriate technical and organizational security measures to protect the Personal Data in our care, both during transmission and once we receive it. This includes physical and technical security measures to protect Personal Data from accidental or unlawful destruction, loss, or alteration, and from unauthorized disclosure or access.
X. International Transfers
Due to the international nature of our business, in order to provide our Services and make our Website available, we may transfer Personal Data to, and Process Personal Data in, countries around the world, including outside the European Union (EU), the European Economic Area (EEA), and the United Kingdom. We have taken appropriate and suitable safeguards to ensure that your Personal Data will remain protected when transferred outside a territory with specific requirements for such transfers, including the EU/EEA and the United Kingdom. This includes implementing Standard Contractual Clauses for transfers of Personal Data adopted by the European Commission and/or the United Kingdom. Further information about our international transfers as well as the safeguards in place can be provided upon request.
XI. Notification of Changes
Any changes to this Privacy Notice will be promptly communicated on this page and you should check back to see whether there are any changes.
XII. Contact Us
Turner Duckworth is the controller of the Personal Data that we process as described in this Privacy Notice. If you have any questions about the processing, please email us at privacyinquiries@turnerduckworth.com. This Privacy Notice has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please email us at privacyinquiries@turnerduckworth.com.
If you are unsatisfied with the way we process your Personal Data or if your request has been rejected, as subject to applicable law individuals in certain territories may also lodge a formal complaint with your local competent data protection authority. However, we respectfully request that you contact us first so that we can assist you.
Our Data Protection Officer is tasked with informing and advising us on the obligations that apply to us under Data Protection Laws, as well as monitoring our compliance with the same. If you need to contact our Data Protection Officer, please email privacyofficer@publicisgroupe.com. However, we respectfully ask that you only contact our Data Protection Officer regarding urgent matters relating to data protection only after contacting us first at privacyinquiries@turnerduckworth.com.
Updated: December 21, 2021