Introduction
Turner Construction Company (“Turner”) operates turnerconstruction.com and may operate other websites. It is Turner’s policy to respect your privacy regarding any information we may collect. This Privacy Policy sets out the principles governing Turner’s use and protection of personal data.

This policy is effective as of August 13, 2024.

Privacy Notice Changes
This privacy policy will be reviewed and updated, if required at a minimum of every 12 months. 

Turner encourages visitors to frequently check this page for any changes to its Privacy Notice. If we make changes, we will revise the “Effective” date at the top of this statement, and we may provide additional notice such as on the Turner website homepage, or via the email address we have on file for you.

What We Collect and How We Use the Personal Information
Turner may collect Personal Data in the course of our normal business activities, as detailed below.

Turner collects, uses, stores and process Personal Data, which is data that identifies, relates to, describes, or can reasonably be associated with a particular person.  For all data subjects, this can include:

• Identifiers:  Identifying information including name, postal or e-mail address, and phone or fax number, social security numbers, driver’s license numbers, biometric information.
• Personal Information:  Names, signatures, Social Security Numbers, addresses, government identification documents, financial information such as bank account, credit or debit card information, health insurance information, education information.
• Business contact information including as job title, department and name of organization, business address, e-mail address, mobile telephone number.
• Usernames and passwords used to access internal Turner network resources such as our Partner Logon on web page or Turner University.
• Website visitor activity including IP address, the identity of the Internet service provider, the name and version of the operating system, the name and version of the browser, the date and time of the visit, the pages visited. This data may be aggregated such that the individual identities have been removed.
• Biometric information:  Genetic, physiological, behavioral, biological characteristics, activity patterns, fingerprints, eye scans, health or exercise data.
• Geolocation information:  Physical location, movements, and mobile device unique identifier.
• Images via video surveillance.
• Financial information including as financial account information used for payment purposes and/or information that may be contained in a consumer report, bank account information.
• Contact information for referrals.
• Employment information:  employment history, employee number, performance appraisals, salary and benefits, healthcare information, emergency contact information.
• Protected class information:  Age, race, color, national origin, citizenship, religion or creed, marital status, disability information, sex, genetic information, military or veteran status.

Children
Turner’s services are not directed to persons under 13 years of age. We do not knowingly collect personal information from children under 13. If a parent or guardian becomes aware that their child has provided us with personal information without the parent’s consent, they should contact us at privacy@tcco.com. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete the information from our records.

How We Collect Information
When you visit our website, we may collect information about your visit.
Directly from clients, contractors, sub-contractors, vendors, employees, and job applicants.
From third parties including contractors, sub-contractors, government agencies.

Why We Collect It
We collect personal information to conduct our business activities. Turner collects only the minimum amount of personal data required to fulfill these activities.  These activities include:

• Executing business activities, including completing our services.
• Conducting marketing and promotional activities, including responding to inquiries about Turner products or services, providing offers and information (as permitted by law) about products, services, or events offered by Turner.
• Improving the functionality, security, and usability of Turner’s website.
• Security, including monitoring log-in portals for access, validating identity, and preventing fraud.
• Fulfilling a legal or contractual obligation.
• Managing employee relationships, including the administration of benefits.
• Processing job applications, including background investigations.
• Validating identity for security to allow access to Turner premises and job sites.
• For health and safety reasons.
• Complying with applicable laws or regulations.

Turner will not use the personal data it collects for purposes other than those described above without notifying data subjects identified by the data.

How We Share the Information
We use the information you have given us in order to conduct business activities.

Information Sharing
Turner may share this information with:

• Other entities controlled by or under common control with Turner, including all affiliated entities using the TURNER® mark 
• Vendors
• Service providers
• Contractors or sub-contractors
• Federal, state, and local governments

For the purposes of:

• Fulfilling Turner’s commercial, contractual, legal, and regulatory obligations.
• Responding to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements.
• Investigating illegal activities, suspected fraud, or as otherwise required by law or regulation. Centralizing Turner’s administrative, IT maintenance, and IT security practices.
• Providing information about Turner products, services, or events.

Any third-party that receives personal information from Turner may only process the information in accordance with applicable data processing agreements or contracts terms which require the third-party to protect the data and process it in a manner consistent with applicable privacy laws, regulations and Turner’s policies and practices.

Third-Party Links
Turner’s websites may provide links to other third-party websites that are outside of Turner’s control and not covered by this Privacy Policy. Turner is not responsible for the availability, content, or accuracy of third-party policies, nor is it responsible for the privacy practices of other websites, products, services, or goods that may be linked to Turner’s websites. Turner encourages all users of its websites to review the privacy policies posted on these (and all) sites.

How We Store Your Information
Turner takes the responsibility of keeping your information secure.

Storage
The security measures Turner uses vary based on the sensitivity of the personal information we collect, process, and store, and the current state of technology. We also take measures to ensure service providers that process personal data on our behalf also have appropriate security measures.

Retention
Turner retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law.

If you have consented to the processing of your Personal Data, Turner will retain and process your Personal Data until you withdraw your consent (“opt-out”), unless the Personal Data must be kept for administrative, legal, or regulatory purposes.

If Turner has not received your opt-in, Turner will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed.

Disposal
Data is securely destroyed or disposed once it is no longer necessary to retain the data.

Security
Turner has in place security policies that are intended to ensure the security and integrity of all Personal Data. Turner has appropriate technical and organizational measures in place to protect against unauthorized or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Turner. If Turner forwards Personal Data to any third party, Turner requires that those third parties have appropriate technical and organizational measures in place to comply with this Privacy Policy and applicable laws.

Your Data Protection Rights
You have certain rights for the collection, use, or dissemination of your Personal Data to the extent required by law as applicable to Turner and your data.

Your Individual Data Subject Rights

Right to request access to data
You have the right to ask for copies of your Personal Data.

Right to correction
You have the right to request correction of your Personal Data.

Right to deletion
You have the right to request that we delete your Personal Data.

Right to opt-out of communications
You have the right to opt-out from marketing communications.  We provide an unsubscribe link in certain marketing communications.  You may also request to opt-out of marketing communications via the data subject rights request process.

Californian Consumers Data Subject Rights Under the California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act of 2018 provides California consumers (California residents) with specific rights regarding their personal information. If you are a California resident, you have the rights under data protection law which are explained here.

How to Submit a Data Subject Rights Request:
You may exercise your data subject rights using any of the following methods:

Emailing privacy@tcco.com.

Calling our toll-free number at 855-214-7480.

Mailing the request to the Privacy Officer at Turner Construction, 66 Hudson Boulevard East, New York, New York 10001.

We will verify your identity prior to completing these requests. Please provide sufficient information in your request for us to be able to reasonably locate our records about you and what actions you are requesting we take with regards to your data.


How we will respond to your data subject rights request

Turner will respond as described below:

Turner will deliver the required information within 30 days of a verifiable request, and you will receive notification if Turner will need an additional 30 days to respond.

Turner will provide response to requests for access to data in a written, readily usable format for data portability and free of charge to the consumer after Turner receives a valid request.

You will receive your requested information either by your account, electronically, or via mail.

Turner will not provide you with specific pieces of personal information if the disclosure would create a substantial, articulable, and reasonable risk to the security of the personal information, your account with the business, or the security of Turner’s systems or networks.

Turner will notify you when data has been deleted.

There may be circumstances where Turner must deny your verified request because of a conflict with state law, federal law, or an exception to applicable privacy laws. If Turner must deny a request accordingly, you will be informed and given the basis for the denial. If the request is denied only in part, Turner will disclose the other information sought by you.

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EU-U.S. and Swiss-U.S. Data Privacy Frameworks

Turner complies with legal frameworks for transferring data from the EU, UK, and Switzerland.  

Turner (including SourceBlue) complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. Turner has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  Turner has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles (collectively, “DPF Principles”), the applicable DPF Principles shall govern. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit Data Privacy Framework website.

The Federal Trade Commission has jurisdiction over Turner’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

Data Transfers to Third Parties
We are responsible for the processing of personal information we receive under the DPF Principles and subsequently transfer to a third party acting as an agent on our behalf.  We shall remain liable under the DPF Principles if our agent processes such personal information in a manner inconsistent with the DPF Principles, unless we can provide that we are not responsible for the event giving rise to the damage.

Be advised that we may be required to disclose personal information in response to lawful requests by public authorities in the United States, including to meet national security or law enforcement requirements.

Your DPF Privacy Rights
You may have the right, under the DPF Principles, to access the personal information that we hold about you, and correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the DPF Principles, subject to certain exceptions. You may also have the right to opt-out of having your personal information: (i) disclosed to a third party (other than parties that are acting as our agents to perform tasks on our behalf and under our instructions); or (ii) used for a purpose that is materially different from the purposes for which it was originally collected or which you subsequently authorized.

For more information about your DPF rights and/or to exercise such rights, please contact us at privacy@tcco.com.

Resolution of DPF Complaints
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Turner commits to resolve DPF Principles-related complaints about our collection and use of your personal information.  EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact us at privacy@tcco.com.

Resolution by regulatory authorities
Turner commits to cooperate and comply with the advice of the panel established by the EU data protection authorities, the UK Information Commissioner’s Office and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner, respectively and as applicable, with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

Binding arbitration
Under certain conditions, you have the option to invoke binding arbitration for complaints regarding DPF compliance that remain fully or partially unresolved. For more information about the terms under which we are obligated to arbitrate claims, please see Annex I to the DPF. 

How to Contact Us
If you have any concerns or questions about anything in this Privacy Notice, please get in touch with us.

This website is owned and operated by Turner Construction Company.

We are registered in the State of New York.

Our principal place of business
Turner Construction
66 Hudson Boulevard East
New York, New York 10001


Chief Privacy Officer contact information:
privacy@tcco.com

You can also contact us:

By mail: 
Privacy Office
Turner Construction Company
66 Hudson Boulevard East
New York, New York 10001

By telephone toll-free, at 855-214-7480