INTRODUCTION

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY.

This Privacy Statement tells you how we use information that we collect about you

through this website operated by Left Turns LP based in Greece as well as any mobile

sites, applications ( "apps"), widgets, conferences, events, electronic newsletters,

communications or other services (collectively the "Services") that link to this Privacy

Statement. This Privacy Statement does not apply to situations where we have notified

you that an alternative privacy statement applies, nor does it apply to other Left Turns

LP websites.

You should review the privacy statement posted on other Left Turns LP websites when

you visit them. This website and this Privacy Statement are intended for global

audiences.

We intend to deal with your information in a manner that is fair and in line with your

expectations and encourage you to read and consider the information provided in this

Privacy Statement to confirm that this is the case.

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

The information we receive, and how we use it, depends on what you do when visiting

our website or using our Services. We collect and use non-personal information

(information that does not identify you personally) differently from your personal

information.

YOUR PERSONAL INFORMATION

Personal information is information that can specifically identify you, such as your:

 first and last name

 address, telephone number, e-mail address, or other contact information

 date of birth or age

 social media username or profile

 interests and qualifications

 IP (Internet Protocol) address when such address is associated with a specific

user

We collect personal information about our users in two ways:

1.               when you directly provide information to us, e.g. by entering personal

information on certain pages of the website. For example, you may fill out a registration

form for a particular service, participate in a survey, or complete a contact form.

2.               using automated means, specifically through cookies. Cookies are small text

files that are placed on your computer by websites that you visit. They are widely used

in order to make websites work, or work more efficiently, as well as to provide

information to the owners of the website. For more information about the cookie policy,

please read below:

COOKIES AND OTHER TOOLS

Left Turns LP and its Providers collect information about you by using cookies, tracking

pixels, and other technologies (collectively, “Tools”). We use this information to better

understand, customize and improve user experience with our websites, services, and

offerings as well as to manage our advertising. For example, we use web analytics

services that leverage these Tools to help us to understand how visitors engage with

and navigate our Site, e.g., how and when pages in a site are visited and by how many

visitors. We are also able to offer our visitors a more customized, relevant experience

on our sites using these Tools by delivering content and functionality based on your

preferences and interests. If we have collected your personal data, e.g., through a

registration or a request for certain materials, we may associate this personal data with

information gathered through the Tools. This allows us to offer increased

personalization and functionality on the Site.

Your web browser can be set to allow you to control whether you will accept cookies,

reject cookies, or notify you each time a cookie is sent to your browser. If your browser

is set to reject cookies, websites that are cookie-enabled will not recognize you when

you return to the website, and some website functionality may be lost. The Help section

of your browser may tell you how to prevent your browser from accepting cookies. To

find out more about cookies, visit www.aboutcookies.org. Certain information is

collected by most browsers or automatically through your devices, such as your Media

Access Control (MAC) address, computer type (Windows or Macintosh), screen

resolution, operating system name and version, device manufacturer and model,

language, and Internet browser type and version. We use this information to ensure that

the services function properly.

Your IP address is a number that is automatically assigned to the computer that you are

using by your Internet Service Provider. An IP address may be identified and logged

automatically in our server log files whenever a user accesses the Site, along with the

time of the visit and the pages visited. Collecting IP addresses is standard practice and

is done automatically by many websites, applications, and other services. We use IP

addresses for purposes such as calculating usage levels, diagnosing server problems,

and administering the Site. We may also derive your approximate location from your IP

address.

We may use Google Analytics, which uses cookies and similar technologies to collect

and analyze information about the use of the Site and report on activities and trends.

This service may also collect information regarding the use of other websites, apps, and

online resources. You can learn about Google’s practices by going to

www.google.com/policies/privacy/partners/, and opt-out of them by downloading the

Google Analytics opt-out browser add-on, available

at https://tools.google.com/dlpage/gaoptout.

We may use Flash Local Shared Objects (“Flash LSOs”) and other technologies to,

among other things, collect and store information about your use of the Site. If you do

not want Flash LSOs stored on your computer, you can adjust the settings of your Flash

player to block Flash LSO storage using the tools contained in the Website Storage

Settings Panel. You can also control Flash LSOs by going to the Global Storage

Settings Panel and following the instructions (which may include instructions that

explain, for example, how to delete existing Flash LSOs (referred to as “information” on

the Macromedia site), how to prevent Flash LSOs from being placed on your computer

without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs

that are not being delivered by the operator of the page you are on at the time). Please

note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may

reduce or impede the functionality of some Flash applications, including those used in

connection with the Site.

HOW DOES LEFT TURNS LP USE PERSONAL INFORMATION?

We may use the information that you have shared with us through this website and

relevant Services (other than sensitive information, which is discussed separately

below) for the following purposes:

 to respond to your requests

 to provide the services or information you request

 to allow you to register certain products or services, or enhance their functionality

 to resolve and track the status of any consumer and/or product or service issues

 to manage our relationship with you and facilitate any necessary follow-up (e.g.

by storing relevant information and preferences for a reasonable amount of time)

 to enter into, or perform a contract with you (e.g. in case you wish to order

products or services from us)

 to enable you to participate in our online communities, including social media and

blogs

 to enable you to participate in and join online meetings in this website

 to contact you with information that might be of interest to you – see further the

Marketing and Education section below

 In other ways to which you consent

Left Turns LP may also use your personal information to the extent necessary to

achieve the following legitimate interests, so long as compatible with your rights and

expectations of privacy:

 for analytical purposes in order to research, develop and improve programs,

products, services, and content

 to anonymize your information by removing any personal identifiers (your name,

e-mail address, etc.) so that it may be used for other purposes. In this case, the

anonymized information would no longer identify you and may be treated like

other non-personal information. For more details please see the relevant section

below.

 to enforce this Privacy Statement and other rules about your use of this website

 to protect our rights or property

Left Turns LP also has legal grounds to use your personal information:

 as necessary to protect someone;s health, safety, or welfare; and

 in order to comply with a law or regulation, court order, or other legal processes

Where required by law, we will ask you to "opt in" or affirmatively consent to the

processing of your personal data for a particular purpose. For example, where the law

so requires, we will only send you newsletters if you have subscribed to them.

MORE INFORMATION ON OUR PROCESSING ACTIVITIES

Below we outline each website-related processing activity in greater detail and provide

information on the categories of information collected for each activity as well as the

legal basis of processing for each of these activities, if and to the extent the data

processing is subject to GDPR.

 Responding to requests or inquiries

We may use the information that you provide to us to take the steps necessary to

respond to your request, for instance, inquire about a product, or subscribe to one of our

mailing lists. Depending on your request, we may collect your contact information (such

as your name, mailing address, telephone number, job title, your interests and

preferences (such as products or areas of interest), and any other information you

provide to us.

We collect and process your personal data for these purposes based on our legitimate

interest to respond to your request. If you submit sensitive Personal Data as part of your

inquiry, we will also base such processing on your explicit consent. If reporting is

required, we may process your data to comply with our legal obligations.

Article 6(1)(f) GDPR Articles 6(1)(a) and 9(2)(a) of the GDPR Article 6(1)(c) and Article

9(2)(i) GDPR

 Completing transactions

Some parts of our website may collect your Personal Data to fulfill services that you

have requested and to understand your interests and preferences. In these instances,

we may collect your contact information as well as a history of your previous

transactions with us. (such as order history, Customer account information).

We use this information to perform an agreement with you.

Article 6(1)(b)

 Personalizing Your Experience

We may collect certain information about you, your preferences, and how you have

interacted with us in the past in order to understand your interest in our products and

services so that we can best serve you. This may include information about your contact

and product preferences, languages, marketing preferences, and demographic data.

In cases where we collect this information automatically, we collect and process his

information for our legitimate business interests. In other cases, we will collect and

process this information pursuant to your consent.

Article 6(1)(f) GDPR Articles 6(1)(a) of the GDPR

 Website Analytics and Tracking

Where permitted by law, we may combine Personal Data you provide with other

information you’ve provided to Left Turns LP through our websites. Where permitted by

law, we may combine Personal Data collected through our websites and online

resources with Left Turns LP offline records and information provided to us by third

parties. More information about this can be found in the section below and in our Cookie

Policy.

In cases where we collect this information automatically, we collect and process his

information for our legitimate business interests. In other cases, we will collect and

process this information pursuant to your consent.

Article 6(1)(f) GDPR Articles 6(1)(a) of the GDPR

 To Run and Maintain our Website

We use this information to secure our websites, network systems, and other assets.

This may include information concerning your IP Address, geographic location,

resources you have accessed, and similar information.

We collect this information automatically, for our legitimate business interests to run,

maintain, and secure our websites.

Article 6(1)(f)

WHAT IS SENSITIVE INFORMATION?

Some types of personal information are sensitive information. Sensitive information is

personal information revealing or relating to your health (such as your device serial

number, or the date of surgery, implantation, injection), genetic or biometric data, your

racial or ethnic origin, religious or philosophical beliefs, sex life or sexual orientation,

political opinions or trade union membership.

WILL LEFT TURNS LP TREAT SENSITIVE INFORMATION DIFFERENTLY THAN

OTHER PERSONAL INFORMATION?

Left Turns LP will only collect and process your sensitive information:

 in ways for which you have given your explicit consent

 to protect the vital interests of you or another person, in cases where your explicit

consent cannot be given or reasonably requested

 according to applicable laws which include suitable and specific measures to

safeguard your fundamental rights and interests

 to establish, exercise, or defend a legal claim

For example:

 We may collect sensitive information directly from you, when you voluntarily

provide it to us for a particular purpose (e.g. when you contact us with a question

or suggestion about our products and services);

 We may collect sensitive information about participants who have explicitly

consented to participate in clinical trials, studies, and other research initiatives.

NON-PERSONAL INFORMATION

Non-personal information is information that cannot identify you or be tied to you in any

way. Therefore the non-personal information that we collect through this website does

not identify you as an individual person, and will not be linked to you. It may include

information such as the following:

 the type of web browser software you use (for example, Safari or Internet

Explorer)

 the name of the domain from which you access the Internet

 the Internet address of the website from which you linked directly to our website

 the date and time you access our website

 which pages you have visited on our website

 the search terms you use

 the links on which you click

If you visit our website to read or download information, such as information about one

of our products, we may collect certain non-personal information from your computer.

This information is collected from your computer's web browser. If you only read or

simply click to download information on our website, we do not collect or learn your

name, e-mail address, home address, or any other personal information about you.

WHAT DOES LEFT TURNS LP DO WITH NON-PERSONAL INFORMATION?

We are always looking for ways to better serve you and improve our products, services,

and website experience. We will use non-personal information from you to make this

website more useful to visitors. We may also use non-personal information for other

business purposes. For example, we may use non-personal information or aggregate

non-personal information to:

 create reports for internal use to develop programs, products, services, or

content

 adapt or improve the information or services provided

 share or sell information to third parties

 provide information on how our site is used, such as "traffic statistics" and

"response rates" to third parties

DIRECT MARKETING AND EDUCATIONAL MATERIALS

Left Turns LP may wish to provide you with educational materials or other information

about our products and services, that might be of interest to you, based on the

information you have shared with us and that we have collected through cookies or

similar techniques regarding your use of Left Turns LP websites, social media, and

blogs. We will ask you to "opt-in" or affirmatively consent to the use of your personal

information for the purposes of such communications, in accordance with applicable

laws.

If at any time you decide not to receive any educational, commercial, or promotional

information related to our products and services or regarding the products or services of

our affiliates or service providers, please email us at the contact details listed below and

mention “OPT-OUT” in the subject of your email. Alternatively, you may use the opt-out

procedure provided in any relevant message you receive from us.

Please note that if you opt not to receive promotional messages from us, we may still

continue to send you relevant information for other lawful purposes, such as to

administer any account you may have with us, to respond to your requests, to execute

agreements with you, or to provide you with information that Left Turns is required by

law to provide, e.g. regarding product recalls.

SURVEYS

From time to time, we may invite you to participate in a survey to determine customer

satisfaction levels, identify areas of potential improvement, or carry out market research.

We may send you a specific invite to participate in such a survey on the basis of our

legitimate interests in conducting the survey, or on the basis of your prior “opt-in”

consent to receive such communications, in accordance with applicable laws. You may

opt out of receiving any such future communications in the manner detailed in the

section above. The personal data that is collected for the purpose of the survey may

include your email address, phone number, survey results, and any free-text message

you may have written in the survey.

We process your personal information as part of the survey for carefully considered and

specific business purposes which are in our legitimate interests and which we believe

also often benefit you, based on our assessment that our legitimate interests do not

override your freedom and data protection rights.

The business purpose of collecting your data is to reply to survey feedback you may

have provided, specifically:

 Should you have indicated an issue that we need to take action to resolve

 In order to gain further insight into the experience you have described

 To inform you of any action we might take internally to resolve your issue or

enhance your experience

DOES LEFT TURNS EVER SHARE PERSONAL INFORMATION WITH THIRD

PARTIES?

Left Turns will not share your personal information with a third party except as described

in this Privacy Statement.

In the ordinary course of business, we may share some personal information with Left

Turns LP affiliates or third-party companies that we hire to perform services or functions

on our behalf. For example, we may:

 use a service provider to administer certain newsletters or informational mailings

that you have signed up for, and provide access to your email address for this

purpose.

 use a third-party application or platform to allow us to manage and keep track of

our communications with you.

 use a third-party application or platform like Zoom or Microsoft Teams or any

custom live streaming platform to conduct live video training events (webcast) to

manage and keep track of our communications with you.

 use our company affiliates to provide services relating to your personal

information e.g. we may store your information on a secure server based at our

affiliate’s site in Europe or the United States. For more information on the

circumstances in which we may transfer your information to other countries,

please see the relevant section below.

 use a third-party application or platform to conduct surveys, which can include

storage of the survey feedback.

In all cases, we will not share more information than is necessary, and we will not

authorize any third parties to keep, disclose or use your information except to provide

the requested services in line with the purposes set out above.

Please note that subject to applicable laws, we may disclose your personal information

if we believe we are required to do so to comply with any law, regulation, court order,

legal or government request. In the unlikely event that all or part of our business is

acquired by a third party, your information may be transferred to the new corporate

owner insofar as relevant to the business in question and subject to appropriate

safeguards being in place.

In addition, we may use and disclose your personal information to third parties if

necessary to:

 enforce this Privacy Statement and the other rules about your use of this website

 protect our rights or property

 protect someone;s health, safety, or welfare

 comply with a law or regulation, court order, or other legal processes

 investigate or take action in cases of suspected fraud or illegal activities

In addition, please keep in mind that certain areas of our website may be interactive in

nature, and allow you to post information that other users can see. If you do not wish to

have information viewed publicly, please do not use those sections of the website.

DO WE TRANSFER PERSONAL INFORMATION TO OTHER COUNTRIES?

In certain cases, Left Turns may transmit personal information collected on this website

to our affiliates or third-party service providers in other countries, but only in furtherance

of the purposes set out in this Privacy Statement. In cases where personal information

is transmitted from Europe to other countries, we will ensure that safeguards equivalent

to those provided by European data protection laws are in place. For more information

please contact hello@leftturns.gr. 

HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION FOR?

We will only keep your personal information for as long as necessary to fulfill the

purposes for which we are allowed to use them, as set out in this Privacy Statement.

For example, if you tell us that you no longer wish to receive a newsletter from us, we

will immediately delete your email address from our mailing list. In case you participate

in a program via our website we will delete the personal information provided as part of

that program within a reasonable time after its completion (e.g. six months after

completion will normally be considered reasonable unless we have lawful grounds to

retain some of the information for longer (e.g. if necessary for validation or to comply

with recordkeeping obligations)).

WHAT HAPPENS IF THE PRIVACY STATEMENT CHANGES?

This Privacy Statement was created in November 2022. We may change this Privacy

Statement at any time and for any reason. If we decide to make a significant change to

our Privacy Statement, we will post a notice on the homepage of our website for a

period of time after the change is made. We encourage you to review this Privacy

Statement each time you visit the website.

WHAT ABOUT PRIVACY ON OTHER WEBSITES?

This website may contain links to other websites. Some of those websites may be

operated by Left Turns LP and its affiliates, and some may be operated by third parties.

This Privacy Statement does not apply to other websites, even other Left Turns LP

websites. Therefore whenever you leave this website we recommend that you review

the privacy practices that apply to the information you provide on other websites. We

provide the links for your convenience, but we do not review, control, or monitor the

privacy practices of websites operated by others. Neither are we responsible for

websites operated by third parties or your business dealings with them.

ARE THERE SPECIAL RULES ABOUT CHILDREN;S PRIVACY?

We care about protecting the online privacy of children. We will not intentionally collect

any personal information (such as a child;s name or e-mail address) from children under

the age of 16 without the consent of someone holding parental responsibility. If you

think that we have otherwise collected personal information from someone under the

age of 16, please contact us.

WHAT ABOUT WEBSITE SECURITY?

Security is very important to us. We also understand that security is important to you.

We use industry-standard measures to protect your personal information from loss,

misuse, and unauthorized access, disclosure, alteration, or destruction. However no

website or email transmission is 100% secure and we encourage you to therefore take

special care in deciding what information you send or request via email, and take

appropriate precautions such as keeping any usernames and passwords you use

confidential.

YOUR RIGHTS

At any time, you may exercise your right to access, rectify and, as the case may be,

erase, any personal information relating to you, or restrict the processing of your

personal information, in compliance with applicable laws. You also have the right at any

time to object, based on your particular situation, to any use or processing of your

personal information which we have based on our legitimate interests.

In case we are processing your personal information in an automated manner as part of

a service to you or based on your consent then you also have the right to request a

copy of your information in a structured, commonly used, and machine-readable format

(known as the right to “data portability”).

Such requests can be sent to hello@leftturns.gr.

Please note that we may ask you to provide proof of identity (such as a copy of your ID

card or passport) before we can comply with your request.

If we have based our collection or use of your personal information on your consent

then you also have the right to withdraw your consent at any time in the same way as it

was given, or by sending a request in the above manner.

You may also at any time, free of charge and without having to provide any justification,

opt-out of any direct marketing campaigns and request to no longer receive any

promotional material as described above.

In case you are not satisfied with our handling of your request you may contact the

applicable Data Protection Authority. See further: http://ec.europa.eu/justice/data-

protection/bodies/authorities/index_en.htm