Turnkey Training Terms of Use

This User Agreement (the "Agreement") is a binding agreement between Turnkey Training, LLC ("Turnkey Training," "us" or "we") and each of its users ("Users" or "you") who click the applicable box or link or otherwise acknowledge their acceptance of this Agreement, whether through any website(s), application(s), or any other medium through which Turnkey Training makes this Agreement available (the "Site") and whether or not such user is issued or maintains an account with Turnkey Training. Turnkey Training’s Site, and Turnkey Training’s technology, features, content, and services (collectively with the Site, the "Platform") are provided subject to the terms and conditions set forth in this Agreement and your access to and use of the Platform is subject to this Agreement. It is your responsibility to review this Agreement before using or accessing the Platform.

You should not be able to access the Platform without affirmatively acknowledging your acceptance of this Agreement, and you should not employ any technology or other means that allows you to do so, but, if you do access the Platform, or portions thereof without affirmatively acknowledging your acceptance of this Agreement, then you will nonetheless be considered a User and your use of the Platform constitutes acceptance of this Agreement. Users who are bound by this Agreement may include, without limitation, traders, brokers, compliance professionals, investors, and other financial industry professionals. Users are bound by this Agreement regardless of whether they make any payment to Turnkey Training.

Turnkey Training reserves the right to make changes, modifications, updates, and amendments ("Modifications"), at any time to the Platform or this Agreement. Any Modifications to this Agreement will be effective upon posting of an updated Agreement. Your continued access or use of the Platform after the posting of any Modifications to the Agreement will constitute your acceptance of the Modifications.

You should not use or access the Platform if you do not agree to the terms of this Agreement and/or do not wish to be bound by this Agreement. To the extent permitted under applicable law, this Agreement requires Arbitration in the event of disputes between users and Turnkey Training or any of its affiliates and limits the availability to Users of class action lawsuits and other remedies.

Description Of the Platform

Turnkey Training, via the Platform, delivers required and custom bespoke training solutions to financial service industry professionals and others. This training may be required by the Commodity Futures Trading Commission (“CFTC”), Securities Exchange Commission (“SEC”), National Futures Association (“NFA”), Financial Industry Regulatory Authority (“FINRA”), and the various commodity or securities exchanges such as those owned by the CME Group and NYSE; or the Platform may also deliver bespoke training solutions related to financial service industry best practices, compliance matters, business consulting, or other general topics as may be requested or made available from time to time (collectively the “Services”).  Users will be able to access the platform to take educational training via an online portal. They will have a course login and access to the content that they have purchased.

No Investment Recommendations or Financial Advice Provided

Turnkey Training does not directly, indirectly, implicitly or in any other manner whatsoever provide any brokerage services or investment advice. Turnkey Training is not registered with any regulatory body within the United States of America or any other jurisdiction. You acknowledge and agree that no aspect of the Platform is intended to provide, or should be construed as providing, any investment, financial, tax, compliance, regulatory, legal or other advice of any kind. You should not consider any content on the Platform to be a substitute for investment, financial, tax, compliance, regulatory, legal or other professional advice. 

Limitations Of Platform Information

Turnkey Training’s Platform is offered as an educational technology solution only.  In certain circumstances, or in the future, Users may provide comments, opinions, other information or advice to other Users. Any such information or advice provided by Users is solely the opinion of the party providing the information or advice, and parties, including other Users, who rely on such information or advice do so entirely at their own risk.

You acknowledge and agree that no information, opinion or advice provided by any User or third party will be construed as the information, opinion or advice of Turnkey Training or any Turnkey Training affiliate, or any of their respective owners or agents (each individually a "Related Party" and collectively the "Related Parties"). Turnkey Training does not generate, verify, approve, endorse, exercise editorial control over, or guaranty the accuracy or completeness of content generated by or received from Users or third parties, whether made available on the Platform or otherwise, and makes no representations or warrantees of any kind with respect to any such content or any other information generated by or received from any User or third party.

You acknowledge and agree that Turnkey Training and the Related Parties are not liable for content or information provided by Users or other third parties, including any User or third party generated content that is accessible through the Platform. You acknowledge and agree that you will not bring, file, or assert any claim, proceeding, cause of action, or suit against Turnkey Training or the Related Parties relating to any such content or information, and you waive any right that you may possess to do so.

You also acknowledge and agree that Turnkey Training and the Related Parties are not obligated to (i) detect or remedy any fraudulent, misleading, or otherwise wrongful or improper post, (ii) monitor any User’s activities on any other sites, or (iii) remedy any misuse of information originally posted to Turnkey Training on another site, and you further acknowledge and agree that you will not bring, file, or assert any claim, suit, proceeding, or cause of action relating to, or seek damages arising from, any failure on the part of Turnkey Training or any Related Party to do so, and you waive any right that you may possess in connection with the same.

Pricing and Refund Policy

Generally, prices and fees for any offered Services available on the Platform will be published and charged as advertised.  Please be advised that pricing or fees charged by Turnkey Training to access the Platform and any of the included Services available through the Platform are subject to change from time to time.  Turnkey Training maintains the right to adjust such prices as it deems appropriate in its sole discretion with or without notice to you as a user. 

Turnkey Training’s products may be sold on a one-off or subscription basis. If Services purchased from Turnkey Training are purchased as part of a subscription plan, your subscription will automatically renew when the current subscription period ends.  Please be sure to cancel your subscription at least thirty (30) days prior to its expiration date to avoid any potential inaccurate billing actions. To cancel services please send an email to [email protected] with your full name, phone number, and the firm that you are associated with. Turnkey Training will respond to you accordingly and work to resolve your request. 

Please be advised that as a user of the Platform you acknowledge and agree that Turnkey Training and the Related Parties offer no refunds of any kind. This means that you will not be able to get a refund for any payments which have already been made. Once Services have been initiated you will have access to those Services purchased for a period of up to twelve (12) months or the period of any subscription whichever is longer. Turnkey Training subscription plans are generally based on an annual renewal system. If you do not want to subscribe to the Services any longer, again please cancel your subscription before the next annual renewal date. Once Services have been cancelled you will still have access to the content until the period you have paid for ends.

Taxes

As and where applicable sales, use, excise, service, and other such taxes which Turnkey Training is required or permitted to collect by law from users will be collected on a good faith basis.  Tax amounts Turnkey Training is required to collect will generally be added to the cost of any purchase of the Services at the time of sale and added to the total fees charged.

Use In Other Countries

Turnkey Training makes no representation or warranty that any content or Services are appropriate for use in locations outside the United States. Those who choose to access the Platform from outside of the United States are solely responsible for compliance with local laws. Turnkey Training may, but is under no obligation to, limit the availability and accessibility of its content and Services in certain jurisdictions of its choosing. With respect to Turnkey Training’s compliance with privacy laws, please refer to Turnkey Training’s Privacy Policy which is incorporated into and is made a part of this Agreement.

Electronic System And Technological Failure

It is possible that Turnkey Training may encounter hardware, electronic, technological and system failures, delays or other issues from time to time, including failures relating to internet connectivity, electrical power, third party service providers, and computer crashes. 

You acknowledge and agree that you will not bring, file, or assert any claim, suit, proceeding, or cause of action relating to, and that you will not seek damages arising from, any such failures, delays or other issues, and you waive any right that you may possess to do so.

Use Of The Platform

The Platform contains and provides educational and other creative content developed by Turnkey Training or its Related Parties. All such materials available through the Platform are proprietary to Turnkey Training, as well as links to third party websites. You may download, view, copy and print information, materials and any other aspect of the Site to which Turnkey Training grants you access (i) solely for your own personal informational purposes; and (ii) provided that you do not distribute, modify or alter the materials, including any notices or disclaimers therein. You agree that you are solely responsible for any and all regulatory obligations within your specific jurisdiction or otherwise relating to you that may apply to your use of any Turnkey Training content or Services.

You agree not to upload, transmit, or distribute via the Site or any other aspect of the Platform any information which:

You further agree:

  1. Not to reverse engineer, publish, distribute, transmit, transfer, or sell any content accessible through the Platform that was created by someone other than you;

  2. Not to interfere, in any way, with others’ use of or access to the Platform and to not attempt to gain unauthorized access to the account(s) or computer system(s) of any other User;

  3. To fully comply with all applicable treaties, laws, rules and regulations in connection with your use of the Platform, regardless of your jurisdiction;

  4. Not to promote any commercial enterprise, through which you receive direct or indirect compensation, or other consideration, through the Platform;

  5. Not to use any robot, spider or other automatic device, manual process or application or data mining or extraction tool to access, monitor, copy or use the Site or any other aspect of the Platform;

  6. Not to take any other action that imposes an unreasonable or disproportionately large load on the Site or is likely to slow or burden the Site’s performance;

  7. Not to link to any page of the Site other than the home page or any other publicly available pages without Turnkey Training’s prior express written consent to do so.

Access Methods

You acknowledge and agree that you are fully responsible for maintaining the privacy of any password, user identification or other method to access the Site or any other aspect of the Platform (each, an "Access Method") which you may be granted as a User. You agree not to disclose or share your Access Methods with any other person or entity. You agree not to access or attempt to access any password-protected portions of the Site or any other aspect of the Platform without an authorized Access Method or through any means other than your authorized Access Method. You acknowledge and agree that it is solely your responsibility to monitor and control use of your Access Methods, to ensure the security of your Access Methods and to ensure that your Access Methods are not compromised or used without authorization.

In the event you determine your Access Method to have been compromised for any reason you agree to immediately notify Turnkey Training and provide a detailed explanation regarding the circumstances by which your Access Method was compromised. Turnkey Training will make a determination, in its sole discretion, as to what course of action will be taken to resolve the situation.

While Turnkey Training will endeavor to ensure the security of your Access Methods and personal information, Turnkey Training cannot guarantee that security breaches will not occur and cannot warrant the security of your information. Turnkey Training’s Privacy Policy, which is incorporated into and is made a part of this Agreement.

You acknowledge and agree that Turnkey Training and the Related Parties will not be liable for any losses or damages that you may sustain, and that you will not bring, file, or assert any claim, cause of action, proceeding, or suit against Turnkey Training or the Related Parties arising from or relating to, any unauthorized or improper use of your Access Methods, or any security or privacy breach relating to your Access Methods, and you waive any right that you may possess in connection with the same.

Unauthorized Use Of The Platform

Turnkey Training may but shall not be obligated to investigate and take legal action against those responsible for any illegal and/or unauthorized use of the Site or any other aspect of the Platform including: unauthorized access to the Platform through a third party application, robot, spider, automated device, or data mining or extraction tool or other unauthorized means; interference with the Platform; any action that imposes an unreasonable load on the Site; or any link to any page of the Site other than the home page. Turnkey Training’s decision not to pursue legal action for any such violation or any breach of this Agreement shall not be construed as a waiver of any provision of the Agreement or of any of Turnkey Training’s legal rights.

Denial Of Access

Turnkey Training may prohibit you from using or accessing the Site or any other aspect of the Platform for any or no reason, at any time, in its sole discretion, without notice to you. Turnkey Training may remove any User information on any grounds, including in the event that Turnkey Training believes the information violates applicable law, this Agreement or the rights of Turnkey Training, or any User or third party.

Trademarks And Copyrights

You acknowledge and agree that (i) the trade names and logos of Turnkey Training and the Related Parties, (ii) the design, graphical elements, and appearance of the Site, (iii) the content of the Platform (except to the extent otherwise expressly stated in this Agreement), and (iv) any intellectual property, trade secret, or otherwise protectable information contained in the foregoing (collectively, "Turnkey Training IP") may not be copied, modified, reproduced, republished, posted, transmitted, sold, offered for sale, or redistributed in any way without Turnkey Training’s prior written permission. You acknowledge and agree that Turnkey Training IP is the sole property of Turnkey Training, or a Related Party, or its licensors. You agree to abide by all copyright notices, information, or restrictions with respect to Turnkey Training IP and acknowledge that, other than as expressly provided herein, you do not have a license to use Turnkey Training IP. Turnkey Training names, logos, and other materials displayed on Turnkey Training’s Sites or any other aspect of the Platform, together with the goodwill associated with them, constitute trademarks, trade names, service marks or logos ("Marks") owned exclusively by Turnkey Training or a Related Party. You agree not to use any Marks in any manner whatsoever without Turnkey Training’s prior written consent.

Submissions And Data Transmission

Turnkey Training’s Platform is offered as an educational technology solution only.  In certain circumstances, or in the future, Users may provide comments, opinions, other information or advice to other Users.  When you post or submit content to the Platform you will retain your ownership of such content. You represent that you exclusively own all content that you post or submit to the Site, together with any and all rights thereto, and that your posting or submitting such content to the Site does not infringe on any intellectual property rights or other rights of any other person or entity.

Turnkey Training shall have no responsibility or liability for the deletion of, or failure to store, any content you may post or submit to the Site and Turnkey Training may delete such content from the Site at its discretion. You acknowledge that Turnkey Training may delete accounts that are inactive or that belong to Users who have violated this Agreement. Although you acknowledge that Turnkey Training is under no contractual or legal obligation to do so, Turnkey Training will endeavor to undertake commercially reasonable efforts to protect Users’ confidential information from unauthorized disclosure to third parties.

By posting to the Site or otherwise submitting content to Turnkey Training or any Related Party, you grant Turnkey Training, as well as its parent, subsidiary and affiliated companies, a non-exclusive, transferrable, sub-licensable, worldwide, fully paid-up, royalty-free, perpetual and irrevocable license to use, reproduce, distribute, create derivative works of, display, import or otherwise exploit such content in any form, media, or technology, whether now known or hereafter developed. You represent that you have the right to grant such license with respect to all content you post or submit to the Site, or otherwise provide to Turnkey Training or any Related Party, and that your grant of such license does not infringe on any rights belonging to any other person or entity.

Third Party Advertisements And Links To Third Party Sites

Turnkey Training may at any time and at its sole discretion provide links to the websites of third parties. Additionally, the Site may display advertisements from third parties, such as banner advertisements and pop-up texts, and links to the sites of such advertisers. Turnkey Training is not responsible for the content of such advertisements or any links, or any products, services or other materials relating to such advertisements or provided by the advertisers, any linked site, or any link contained in a linked site. The display of any advertisement or link does not imply endorsement by Turnkey Training of the advertisement or linked site or any content therein.

In no event will Turnkey Training or any Related Party be liable, directly or indirectly, for any damage or loss that you may sustain, and you acknowledge and agree that you will not bring, file, or assert any claim, cause of action, proceeding, or suit against Turnkey Training or the Related Parties, arising from or relating to any use, continued use or reliance on any advertisement displayed on the Site, or any products, services or other materials relating to any such advertisement, any linked third party site, or any link contained in a linked site, and you waive any right that you may possess to bring, file, or assert any such claim, cause of action, proceeding, or suit.

Disclaimer Of Warranties And Limitation Of Liability

Turnkey Training makes no warranties of any kind, either express, implied or statutory, including warranties of title, non-infringement, system integration, availability, integrity, reliability, transmission or response time, data accuracy, completeness, timeliness, suitability of content or services, merchantability or fitness for a particular purpose, including with respect to its Platform.

Your use of the Platform is entirely at your own risk. Neither Turnkey Training nor any of the Related Parties are responsible or liable to you or anyone else for any loss or injury or any direct, indirect, incidental, consequential, special, exemplary, punitive or other damages under any contract, negligence, strict liability or other theory arising out of or relating in any way to your use of, or inability to use, the Platform, or for content accessible through the Platform. The foregoing is applicable whether or not the loss or injury is caused by events beyond the control of Turnkey Training or any Related Party.

In no event shall Turnkey Training’s total liability to you for any and all damages, losses, and causes of action (whether in contract, tort, statutory, or otherwise) exceed the total amount paid by you to Turnkey Training in the twelve (12) months prior to the date on which you first assert a claim. To the extent that Turnkey Training may not, as a matter of applicable law in any particular jurisdiction, disclaim any implied warranty or limit liabilities, the scope and duration such warranty and the extent of Turnkey Training’s liability will be the minimum permitted under such applicable law in such jurisdiction.

Indemnification And Release

You agree to indemnify and hold Turnkey Training and the Related Parties harmless from and against any and all damages, liabilities, actions, causes of action, suits, claims, demands, losses, costs and expenses (including reasonable attorneys’ fees, expert fees, disbursements and court costs) arising from, relating to, or in connection with (i) your or anyone using your account’s use of the Platform or any content, information, or materials contained, displayed or available therein; (ii) your violation of this Agreement; (iii) any postings or submissions submitted by you or someone using your account to Turnkey Training, including any allegation that a posting or submission violates the copyright, trade secret, trademark, or intellectual property rights of any person or entity; (iv) your or anyone using your account’s violation of any applicable law or regulation or any rights of any third party; (v) access or use of the Platform by you or anyone using your Turnkey Training account.

To the maximum extent permitted under applicable laws, you hereby release Turnkey Training and the Related Parties from any liability related to: (a) any incorrect or inaccurate content accessible through Turnkey Training, the Site or any other aspect of the Platform; (b) the conduct, whether online or offline, of any User; and (c) any error or omission, interruption or deletion, defect, delay in operation or transmission, communications line failure, theft or destruction or unauthorized access, or alteration, of, to or in connection with Turnkey Training, the Site or any other aspect of the Platform. If you are a California resident, you hereby waive California Civil Code Section 1542, which states: "A general release does not extend to claims which the creditor does not know or suspect to exist in his favor at the time of executing the release, which, if known by him must have materially affected his settlement with the debtor."

This section shall survive the termination of this Agreement for any reason.

Dispute Resolution

(a) All controversies, disputes, demands, counts, claims and causes of action, including the arbitration of the same, between you and Turnkey Training or any Related Party arising out of, under, or relating in any way to this Agreement or the subject matter hereof, including your use of the Platform, shall be settled exclusively through binding arbitration. Unless arbitration before another body is required by applicable law, or unless otherwise agreed by all parties in writing, the arbitration shall be conducted before a panel of three (3) commercial arbitrators with substantial experience in resolving commercial contract disputes in accordance with the JAMS rules as then in effect (the "Rules"). The arbitration shall be held in a place designated by agreement of the parties or, in the absence of such agreement, at a place in Fort Lauderdale, Florida, designated by the arbitration panel, and, except to the extent inconsistent with this Agreement, shall be conducted in accordance with the Rules in effect at the time of the arbitration.

(b) Notwithstanding the foregoing, the arbitrators shall be empowered only to interpret and apply the terms of this Agreement, and shall not be empowered to revise or amend any provision in this Agreement, or to make a decision based on any such revision or amendment. The arbitral award shall be in writing, state the reasons for the award and relief granted and shall be final and binding on the parties to the arbitration. Any award rendered shall be subject to appeal pursuant to the JAMS optional appeals procedure and, if not so appealed or following affirmance if appealed, may be confirmed, judgment upon any award rendered may be entered, and such award of the judgment thereon may be enforced, in any court of any state or country having jurisdiction over the parties and/or their assets.

(c) You are aware and acknowledge that by entering into this Agreement you are waiving your right to use any federal, state or municipal court system to assert or defend your rights under this contract and that any claims will be determined by arbitrators and not by a judge or jury. Arbitration decisions are fully legally enforceable and are subject to very limited appellate review as compared to court orders. The arbitration proceedings, all documents and all testimony, whether written or oral, produced in connection therewith, and the arbitration award shall be confidential unless otherwise required to be disclosed by law or by any administrative body.

(d) Any claims brought by either you or Turnkey Training must be brought in the parties’ individual capacity, and not as a plaintiff or class member in any purported class, collective, or representative proceeding. The arbitrator may not consolidate more than one person’s claims, and may not otherwise preside over any form of a representative, collective or class proceeding.

If any part of this dispute resolution section is deemed to be invalid, unenforceable or illegal, then the remainder of this dispute resolution section shall remain in effect. In the event this dispute resolution section is held unenforceable by a court of competent jurisdiction, or in the event JAMS refuses to arbitrate the dispute, all controversies, disputes, demands, counts, claims, or causes of action shall be brought exclusively in the courts located in Fort Lauderdale, Florida, and you hereby submit to the jurisdiction of such courts over your person and the subject matter of this Agreement.

Notwithstanding the foregoing, certain laws (such as the European General Data Protection Regulation ("GDPR") and the Canadian Personal Information Protection and Electronic Documents Act ("PIPEDA") and other similar laws) provide users with the right to complain to a Data Protection Authority, Privacy Commissioner or other similar government authority regarding violations of those laws. This dispute resolution mechanism does not replace or supplant such rights unless permitted by those laws. 

Termination

You are free to discontinue your use of the Platform at any time in your sole discretion, with or without cause. Similarly, at any time, with or without notice to you, and with or without cause, Turnkey Training may modify or discontinue its Services and the availability and use of the Site, or any other aspect of the Platform, or terminate your password or other Access Method, account, use, and access to the Platform. Turnkey Training shall in no way be held liable for any consequence which results from Turnkey Training’s decision to modify or discontinue providing the Platform or providing you with access thereto. Any such termination, including any termination of this Agreement shall not terminate any obligations of the parties which, by their terms, are intended to survive the termination of this this Agreement, including the indemnification and the dispute resolution sections of this Agreement. If you object to any change to Turnkey Training’s Site or any other aspect of the Platform, or deletion of content therefrom, your sole remedy is to terminate this Agreement and no longer use the Platform.

Email Communications

You agree to receive all legal and business notifications through email delivered to the email address for you which Turnkey Training has on record and acknowledge that all notifications provided to you electronically satisfy any legal requirement that such communications would satisfy if they were in writing. You are responsible for ensuring that the email address that Turnkey Training has on record is current and accessible. If you do not consent to receive notifications electronically, or if you withdraw your consent, then from that time forward you agree to and shall discontinue using the Platform.

Miscellaneous

All discussions, correspondence, understandings, and agreements heretofore had or made between the parties are superseded by and merged into this Agreement, which alone fully and completely expresses the agreement between the parties concerning the subject matter hereof, and the same is entered into with no party relying upon any statement or representation made by or on behalf of any party not embodied in this Agreement.

This Agreement and the relationship between you and Turnkey Training shall be governed by and construed in accordance with the laws of the State of Florida, without regard to its conflict of law provisions. This Agreement is not assignable, transferable or sub-licensable by you except with the prior written consent of Turnkey Training. Notwithstanding the foregoing, Turnkey Training may freely assign this Agreement, without your consent, to any Related Party or to any other person or entity who acquires substantially all of the assets of Turnkey Training. No waiver by Turnkey Training of any breach or default hereunder shall be deemed a waiver of any preceding or subsequent breach or default.

The headings of sections and subsections contained in this Agreement are merely for convenience of reference and shall not affect the interpretation of any of the provisions of this Agreement. Whenever the context so requires, the singular shall include the plural and vice versa. All words and phrases shall be construed as masculine, feminine or neuter gender, according to the context. Whenever the term "include," "including," or "included" is used in this Agreement, it shall mean "including without limiting the generality of the foregoing". Whenever possible, each provision of this Agreement shall be construed and interpreted in such a manner as to be effective and valid under applicable law, but if any provision of this Agreement or the application thereof to any party or circumstance shall be prohibited by or invalid under applicable law, then such provision shall be ineffective to the extent of such prohibition without invalidating the remainder of such provision or any other provision of this Agreement or the application of such provision to other parties or circumstances.

The parties represent and warrant to each other that they have read this Agreement in its entirety, that they understand the terms of this Agreement and understand that the terms of this Agreement are legally enforceable, that they have entered into this Agreement freely and voluntarily, that they intend to and shall be legally bound by this Agreement, and that they have full power, right, authority, and competence to enter into and execute this Agreement.

Privacy Policy

This policy outlines the types of information Turnkey Training, LLC ("Turnkey Training"), collects about you and how that information is used. This policy may be revised from time to time, with or without notice to you as a user so please revisit this page often to remain fully informed of our policies.

Turnkey Training endeavors to ensure the information we collect about you is protected and is accessed only by authorized individuals and organizations. Specifically, we attempt to protect the personally identifiable information submitted to us, both during transmission and once we receive it. Please be reminded, however, that no method of transmission over the Internet, or method of electronic storage, is ever 100% secure. While we strive to use commercially acceptable means to protect your personally identifiable information, we cannot guarantee its absolute security. 

What Information We Collect

Website Use: When you browse the non-password protected portions of our website, you do so anonymously; no personally identifiable information is collected.

Platform Use: When you sign up to become a registered user of Turnkey Training’s Platform, we request that you provide to us your name, certain address information, phone number, and email address. Once you register with Turnkey Training and sign in to our Platform, you are not anonymous to us. We use your information to provide services under the User Agreement.  We may also use the information you provide to us to contact you or to provide additional Services that we believe may be useful to you. Our collection of this information is pursuant to our User Agreement and this Privacy Policy. 

You should also be aware that while you are accessing the Services via your Access Method, we gather information about what pages are visited, how long each page is viewed, certain responses to quizzes, course completion status, and other similar information. This data is utilized to ensure that any educational or training courses offered by Turnkey Training are being completed in a timely, accurate, and satisfactory manner.  The data collected while you are accessing the Services may be shared with third-parties. Generally, this will only be done as required by law or as permitted and intended via your registration within the financial services industry. In other words, Turnkey Training may transmit to the firm you are registered with, whether or not you have successfully completed any training or educational materials offered, in a timely, and competent fashion.  Your personally identifiable information will not be shared with anyone other than Turnkey Training, the Related Parties, or any third party firms or individuals which may be required to collect this information for regulatory or compliance purposes.  

How We Use the Information We Collect

We intend to use your personally identifiable information to provide our Services to you. You may also use this information to send you Service-related announcements when it is necessary to do so. For instance, if our website is temporarily suspended for maintenance, we might send you an email. Similarly, if a required educational or training course is due for completion we may notify you of this.  Generally, you may not opt-out of communications which are not promotional in nature but are required for Service-related purposes.

Your Rights with Respect to Your Information

Turnkey Training recognizes privacy and data retention laws are complex and ever evolving. As a general matter the following rights are afforded Platform users: 

Right of Access - This includes your right to access the personally identifiable information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.

Right to Correction - This is your right to request correction of your personally identifiable information.

Right to Erasure - This is your right to request, subject to certain limitations under applicable law, that your personally identifiable information be erased from our possession (also known as the "Right to be forgotten"). However, if applicable law requires us to comply with your request to delete such information, fulfillment of your request may prevent you from accessing and taking advantage of certain services offered by Turnkey Training. This may potentially include educational or training course completion certificates which may be required under regulatory obligation.

Right to Complain - You have the right to make a complaint regarding our handling of your personally identifiable information with the appropriate supervisory authority.

Right to Restrict Processing - This is your right to request restriction of how and why your personally identifiable information is used or processed.

Right to Object - This is your right, in certain situations, to object to how or why your personally identifiable information is processed.

Right to Portability - This is your right to receive the personally identifiable information we have about you and the right to transmit it to another party.

Right to not be subject to Automated Decision-Making - This is your right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.

Many of these rights can be exercised by signing in and directly updating your account information, or by making a request to Turnkey Training by contacting us. Upon receiving a verifiable request – verified either by password authentication, two-factor authentication or other similar method – by a user to exercise these rights, Turnkey Training intends to comply within a reasonable time, but in no event more than 30 days, unless we notify you otherwise in writing. If the request is uniquely burdensome or otherwise causes Turnkey Training to incur significant costs, we reserve the right to request reimbursement, to the extent allowed by applicable law or regulation.

Turnkey Training does not discriminate against users, in terms of price, service, or otherwise, for exercising these rights. However, as noted above, the exercise of certain rights may prevent or limit your access to certain services as your personally identifiable information is necessary to provide those services.

For European users or others where it may apply Turnkey Training does not require or seek any "special categories" of information under GDPR including racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, sexual orientation or health information.

Retention of Your Information

We retain your personally identifiable information only as long as necessary for the purpose for which it was collected or as required for necessary business purposes.

Third Party Processors we use

As part of the services we provide, and only to the extent necessary, we may use certain third-party processors to process some or all of your personally identifiable information. For identification of these processors, all of which are located in the United States and whom we have agreements in place contact us directly using the contact information request form at our webpage.

Information Sharing and Disclosure

We will not, without your permission, publicly publish any personally identifiable information (e.g. name, email address or contact information etc.).

We Do Not Sell, Rent or Share Any Personally Identifiable Information

Turnkey Training and its Related Parties do not sell, rent or share any personally identifiable information with third parties that are not our agents or service providers, except as described in this privacy policy or User Agreement or without your permission. Please be advised that certain training and educational course work information may be transmitted to the financial services firm you are registered with if required by compliance or other regulatory obligation.

We May Provide Your Information If Legally Required

Turnkey Training may be required to provide your information under the following circumstances: in response to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against actual or threatened legal claims. In addition Turnkey Training may share your information when we believe it is necessary to do so in order to investigate, prevent, or take action regarding potentially illegal activities, or activities which we believe may give rise to legal liability to us, our users or third parties, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Turnkey Training’s User Agreement, or as otherwise required by law. Further, in the event that Turnkey Training is acquired by or merged with another company, we may transfer information about you to the successor entity.

Changes to This Privacy Policy

Turnkey Training may update this policy at any time for any reason. We intend to notify you of significant changes in the way we treat personally identifiable information by sending a notice to your email address and/or by placing a prominent notice on this section of our website but we are under no obligation to do so. In the event Turnkey Training should be acquired by or merged with another company, your personally identifiable information and/or technical information we obtain from you via this website may be disclosed to any potential or actual third-party purchasers or may be among those assets transferred.

Results of Not Providing Information

You may choose not to provide us with your personally identifiable information, or opt-out of its collection and use, or request deletion of your personally identifiable information. However, choosing not to provide certain requested personally identifiable information may prevent you from accessing and taking advantage of certain services offered by Turnkey Training. This may potentially include educational or training course completion certificates which may be required under regulatory obligation.

Location of Website and Data

This website, the Platform, and Turnkey Training are operating in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our website, participating in any of our services and/or providing us with your information, you consent to this transfer.

Acceptance of These Terms

If you do not agree to the terms of this privacy policy, please do not provide us with any information or utilize our Services. By using this website and voluntarily providing your personally identifiable information to us, you consent to the collection and use of such personally identifiable information as set forth in policy.