1. Privacy Policy


Each of our website turnkeycle.com and any related URLs (each and collectively, as appropriate, the “Site”) is brought to you by Turn-Key CLE (“turnkey,” “we,” “us,” or “our”). This Privacy Policy provides information about our policies and procedures regarding the collection, use, and disclosure of personal information received through the Site from visitors and registered users of the Site (the “Privacy Policy”). This Privacy Policy is incorporated into, and is part of, our Terms of Use which govern your access to the Site and/or your use of the Site and of the Content (as defined in the Terms of Use) and the services made available on or through the Site (collectively, the “Services”). Unless otherwise defined herein, capitalized terms shall have the meaning assigned to such terms in the Terms of Use. If you have comments, suggestions, questions, or concerns about our Privacy Policy, please contact us at info@turnkeycle.com.

This Privacy Policy governs the manner in which the website collects, uses, maintains and discloses information collected from users (each, a 'User') of the website ('Site'). This privacy policy applies to the Site and all services offered by Turn-Key CLE.

  1. What information is collected

A.Information You Provide To Us

We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site, subscribe, and in connection with other activities, services, features or resources we make available on our Site. When you visit our Site or otherwise engage with us or our representatives, we may collect your e-mail address if you provide it to us voluntarily in order to contact you about the Services, register for our events or other offerings. While some items are optional, most are required for legal and security purposes. To sign up on our Site as a registered user of our Services (“Registered User”) and access any User Restricted Areas (as defined in the Terms of Use), you have to create a user account and provide the following personal information to us during the registration process: your name, your e-mail address and your phone number. You may also voluntarily provide to us information about your investment profile, such as, income level, return expectations, net worth, investment experience, desired investment term, and areas of investment interest. If you contact us by email, we may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to us in your message, to respond to you. Users may be asked for, as appropriate, email address, phone numbers, and other identifying information. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.

B.Financial Data

Registered Users who use our Services to make an investment in our offerings/assets will be asked to provide certain financial data, such as your bank account number and bank routing number. This information is required to enable us or a third party (see third-party privacy policy for more information on how that data may be used) and our banking partners, to utilize your bank account to originate funds transfers and make subsequent investment disbursements to you. Because our banking partners will perform services related to the offering, transaction and processing of payments, your personal information may be shared and will be subject to the their Privacy Policy. For purposes of satisfying “Know Your Customer” requirements, we may ask for your address, date of birth, social security number (or other relevant tax identification number) and, in certain circumstances, a copy of valid government-issued identification. We also use the Google Maps API for the purpose of verifying your address (see the Google Privacy Policy for more information on how that data may be used). Depending on the circumstances, additional documentation or personal information may be requested in order to satisfy “Know Your Customer” and/or anti-money laundering requirements. If you choose to use our referral service to invite a friend to the Service, we will ask you for that person’s email address or import your existing contacts, and automatically send an email invitation. Turn-Key CLE stores this information to send this email, to register your friend if your invitation is accepted and to track the success of our invitation service.

C. information We Collect About Your Interaction With Us.

We collect additional information about your interaction with the Site without identifying you as an individual (“Anonymous Information”), by using cookies on our Site. For example, we receive certain standard information that your browser sends to every website you visit, such as your IP address, browser type and language, access times and referring website addresses. We may use Anonymous Information for any purpose in our discretion. For clarity, Anonymous Information means information that is not associated with or linked to your personal information and does not permit the identification of individual persons. We also collect additional information about your interactions with us or our representatives at online or in-person events.

D. Information We Collect from Third Parties.

We may obtain any category of information about you (including personal information and financial data) from a third party in a business transaction such as a merger, acquisition, or asset purchase in which your personal data is transferred to us as a business asset in the transaction. We may obtain any category of information about you (including demographic and lifestyle information, personal information and financial data) from third parties such as consumer data compilers and other providers of consumer data products and from publicly available sources such as open government databases or other personal information in the public domain.

We may receive some information that you submit to any third party website or application that you access through the Service. Both Turn-Key CLE and the owner or operator of that third party website will be the data controller in respect of any such information and you should check the privacy policy of that website to find out how they will use your personal information.

We will only use any information that we collect from you in accordance with this Privacy Policy.



  1. How information collected is used and shared

A. How We May Use Your Information.

We may use the information we collect about you from you and the sources described above (collectively, “Information”) for any of the following purposes: (i) to operate the Site and provide the Services; (ii) to respond to your requests and inquiries; (iii) to contact you and to communicate with you about your use of the Services and your Registered User account; (iv) to notify you about important changes to our Services, such as updates or revisions to this Privacy Policy or our Terms of Use, security announcements or other similar messages; (v) to review Site usage and operations and to improve the content and functionality of the Site and our Services; (vi) to provide you with information and materials about our products and services; (vii) to address problems with the Services; (viii) to protect the security or integrity of our Services, our Registered Users and our business, (ix) to communicate with you regarding any investments which you have made in products offered on the Site; (x) to better understand our users and customers, to provide improved customer service and products and to facilitate personalized marketing; and/or (xi) to tailor the Site to our clients’ needs. We may communicate with you via phone, email, text messages and push notifications to your mobile device. Standard call, message and data rates charged by your mobile carrier may apply to text messages or other communications received on your mobile device. Your consent to receiving SMS text messages or similar wireless messages is not required to open an account or use our Site. However, by opting-out of receiving any text messages, certain functionality of the Site and/or the Services may not be available to you.

We may use your information in the following ways: to ensure that our Service is delivered in the most effective manner for you and your computer; to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes; to carry out our obligations arising from any contracts entered into between you and us; to provide customer service to you in relation to your use of the Service, to deal with inquiries and complaints relating to the use of the Service and - - to notify you about any changes to our service; to administer, support, improve, optimize and develop our Service; to produce reports which may be used, sold or published by us at our sole discretion provided that any data or reports will be anonymized and not refer to any individual user of the Services; for internal marketing and demographic studies to improve the products and services that we provide; and for security purposes.

We may also use your information to provide you with our email notifications, newsletters and other marketing communications that either you request from us or which you consent to by opting in when completing a registration form on the Service.

You may opt out from receiving such marketing communications from us at any time by notifying us in writing, contacting us at info@turnkeycle.com or, alternatively, by following the procedure to 'unsubscribe' that is specified in the email that you receive. Please allow adequate time to process the change.


B. How We May Share Your Information.

We will not sell or lease your Information to any third party for marketing purposes. Except as otherwise expressly provided in this Privacy Policy, Turn-Key CLE will only share your Information: (i) as required by law or regulation or as we believe in good faith that disclosure of such personal information is reasonably necessary to: (1) satisfy any applicable law or regulation, (2) to respond to claims and/or to comply with a judicial proceeding, court order, or legal process served on us, (3) to protect and defend our rights or property, and/or the rights or property of our Registered Users, or third parties, as permitted by law, (4) to detect, prevent, or otherwise address fraud, security or technical issues; or (5) to enforce our Terms of Use; (ii) with our service providers that provide certain services to maintain and operate the Services and certain features on the Services and to conduct certain compliance services related to “Know Your Customer” and compliance with anti-money laundering and sanctions laws (e.g., we may use third parties to host the Site or operate various features available on the Site, sending and managing email, analyzing data, and providing search results) and those service providers will be permitted to obtain only the Information they need to deliver the service; and/or (iv) to any third party service provider or service that is integrated on the Site, in the form of aggregated information or blind data about users of our Services or the Site, which may be collected by us or by the third party, and which will not include disclosure of any personally identifiable information about you or other users of the Services or the Site. Other than as expressly set out in this Privacy Policy or as otherwise required or permitted by law, we will not share, sell or distribute any of the information you provide to us without your consent. You should note that information posted on the public elements of the Service may be visible by users of the Service throughout the world. You should, therefore, be careful when submitting information about yourself to the Service. We may disclose your personal information: (i) to any third party to whom disclosure is necessary to enable us to fulfill your services and provide you with any service to which you have subscribed via the Service; (ii) where required to do so by law or court order; and (iii) to any person to whom disclosure is necessary to enable us to enforce our rights under this Privacy Policy or under our Terms and Conditions. We may disclose your personal information to Facebook Inc in order to fulfill the Services. You can review Facebook's Terms of Service here https://www.facebook.com/ads/manage/customaudiences/tos.php


C. Corporate business transactions

As with any other business, it is possible that in the future we may disclose or transfer personal data about you as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which case the personal data could be transferred to third parties as a business asset in the transaction – subject to the terms of this Privacy Policy unless and until it is amended.


  1. Accessing, changing or removing personal information

If you are a Registered User, we urge you to review your personal information regularly to ensure that it is correct and complete. We provide an easy way via your online account profile for you to access, correct, update or remove personal information that has previously been provided to us. You can review your personal information and make any necessary changes at any time, by logging in to your Registered User account. If you are unable to edit your personal information by logging into your Registered User account, please contact us for assistance at info@turnkeycle.com.



For the purpose of the Data Protection Act 1998, the data controller in respect of any personal data that you submit to us on our site is Turn-Key CLE, a company incorporated under Ohio law and whose registered office is at 6200 Rockside Woods Blvd. N Suite 100, Independence OH 44131.

If you want to know what information we hold about you or if you have any other queries in relation to this privacy policy, please contact us using the following contact information:

6200 Rockside Woods Blvd. N Suite 100, Independence OH 44131



  1. Security of your personal information

We have implemented reasonable technical and organizational measures designed to deter unauthorized access to and use, destruction of, modification of, or disclosure of personally identifiable information we collect via the Site. Regardless of the precautions taken by us or by you, no data transmitted over the Internet or any other public network can be guaranteed to be 100% secure. We cannot ensure or warrant the security of any information you transmit to us and you provide all personally identifiable information via the Site at your own risk. You are responsible for maintaining the security of your Registered User profile information, including your password and for any and all activities that occur under your account. Do not share this information with anyone. We will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information on the Site. If you are sharing a computer with anyone you should always log out before leaving a site or service to protect access to your personally identifiable information from subsequent users.


     6.Notice to users in the event of a security breach

If a Registered User’s personal information is compromised as the result of a breach of security, we will use commercially reasonable efforts to attempt to notify affected Users directly, or via the Site, of the breach if we determine that the information is sensitive, in accordance with this Privacy Policy and the Terms of Use, or as otherwise required by applicable law.



The Service can use cookies to ensure that you get the most out of the Service. Cookies are small amounts of information in the form of text files which we store on your computer. Cookies allow us to monitor usage of the service, improve the Service's usability and to personalize the content for you. If you do not wish us to install cookies on your computer for these purposes, you may change the settings on your internet browser to reject cookies. For more information about how to do this please consult the "Help" section of your browser. Please note that if you do set your browser to reject cookies, you may not be able to use all of the features of the Service. If you prevent us from placing cookies, you may not be able to use the Service to place an order. This is because we use cookies to enable you to log in to your account. We may use an analytics service provider for service usage analysis and reporting. Analytics service providers generate statistical and other information about usage by means of cookies, which are stored on users' computers. The information generated relating to the Service may be used to create reports about the use of the Service and the analytics service provider will store this information. In addition, advertisers whose advertisements appear on the Service may use and place cookies on your computer and we have no control over this. Please consult the terms and conditions and privacy policy of such third-party advertisers to find out how they collect and use your personal data and to establish whether they use cookies and what they may use them for.


  1. Links to other sites

Our Site contains links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit. Please be aware that the terms of our Privacy Policy do not apply to these third-party websites.


  1. Children’s privacy

This Site is not intended for, or designed to attract, children under the age of 13 and as such, we do not intentionally gather information from individuals who are under the age of 13. Upon notification that a child under 13 has provided us with personally identifiable information, we will delete the child’s personally identifiable information from our records.


  1. Privacy rights of California residents

Under California law, we must provide California residents with a summary of their privacy rights. California law requires us to inform you, at your request, (a) the categories of personal information we collect and the third parties we share that information with; (b) the names and addresses of such third parties; and (c) examples of the products marketed by such companies. Additionally, the Act requires us to allow you to control who you do not want us to share that information with. To obtain this information, please send us your request by email at info@turnkeycle.com or standard mail to: Turn-Key CLE 6200 rockside woods blvd. N, Suite 100 Independence, OH 44131, Attention: Privacy. When contacting us, please indicate your name, address, email address, and what personal information you do not want us to share. Your request should be labeled “California Customer Choice Notice,” and 30 days should be allowed for a response. There is no charge for controlling how your personal information is shared. If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit the CCPA Privacy Notice.

  1. Other privacy rights

Depending on the products you invest in on our platform, you may be entitled to additional privacy rights. Please refer to the offering documents of the relevant investment for more information.

  1. International visitors

Turn-Key CLE and its servers are located in the United States and our services are directed towards the United States market, and our Privacy Policy has been prepared to comply with applicable United States law. If you are an international visitor, you should note that by providing your personal information on or through the Site, you are: (i) consenting to the transfer of your personal information from regions outside the United States to the United States which may not have the same data collection and protection laws as the country in which you reside; and (ii) consenting to the use of your personal information in accordance with this Privacy Policy.

  1. Changes to this privacy policy

We reserve the right at any time to make changes to this Privacy Policy simply by posting such changes or updates on the Site and without any other notice to you. If we do this, we will indicate at the top of the page the date the Privacy Policy was last updated. Any such changes or updates will be effective immediately upon posting on the Site. Each time you use the Site, the current version of this Privacy Policy will apply. You understand and agree that your continued use of the Site after we have made any such changes constitutes your acceptance of the most current Privacy Policy, as amended. You can always refuse to accept the changes to our Privacy Policy by terminating your use of the Services.


By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes. BY USING THE SERVICES, YOU ARE AGREEING TO THIS PRIVACY POLICY AND CONSENTING TO THE USE OF TRACKING TECHNOLOGIES AS SET FORTH IN THIS PRIVACY POLICY.