Turnberry Solutions, Inc.

Last updated: March 4, 2026

Turnberry Solutions, Inc. (“Turnberry,” “we,” “us,” or “our”) is committed to protecting and respecting your privacy.

This Privacy Notice explains how we collect, use, disclose, and protect Personal Information in connection with:

• Our websites, online content, and digital properties that link to this Notice.
• Our marketing, sales, and business development activities (including events, webinars, and newsletters).
• Our recruiting, staffing, and talent-related activities.
• Our delivery of consulting and professional services to customers (collectively, the “Services”).

This Notice does not apply to third-party websites, products, or services that have their own privacy statements.

1. Definitions

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) to an individual.

“Customer Data” means information (which may include Personal Information) that we process on behalf of a customer in connection with providing the Services under an applicable contract.

2. Information we collect

A. Information you provide to us

Depending on how you interact with Turnberry, we may collect:

• Contact and professional information (such as name, email address, phone number, employer, job title, and business address).
• Inquiry and communications information (such as the content of emails, form submissions, chat communications, call notes, and support requests).
• Event and marketing information (such as registrations, attendance, preferences, interests, and feedback).
• Recruiting and talent information (such as resume/CV, work history, education, certifications, references, and interview notes; and where permitted by law, eligibility or background-check related information).
• Limited billing or transaction information, if applicable (such as billing contact details and invoicing-related information).

You may choose not to provide certain information, but doing so may limit our ability to respond to you or provide Services.

B. Information we collect automatically

When you visit our websites or interact with our systems, we may collect:

• Device and network information (such as IP address, browser type, operating system, device identifiers, and approximate location derived from IP address).
• Usage information (such as pages viewed, links clicked, referring/exit pages, and date/time of activity).
• Log and security data (such as access logs, audit logs, and error reports).
• Cookies and similar technologies (see Section 6).

C. Information we obtain from other sources

We may obtain Personal Information from:

• Your employer, colleagues, or representatives (for example, when they refer you or engage us).
• Business partners, event co-sponsors, or referral sources.
• Public sources (such as professional networking sites), consistent with your privacy settings.
• Service providers (such as recruiting platforms or background check providers), where permitted by law.

3. How we use information

We use Personal Information to:

• Provide and operate our websites and Services, including responding to inquiries and providing support.
• Deliver consulting and professional services, manage projects, and administer customer relationships.
• Recruit, evaluate, and onboard employees and consultants, and provide talent services.
• Communicate with you, including administrative, operational, and service-related notices.
• Send marketing communications where permitted by law, and measure the effectiveness of our outreach (you may opt out at any time).
• Maintain safety and security, including identity management, access control, auditing, monitoring, and fraud prevention.
• Comply with legal obligations and enforce our agreements.
• Improve our operations, websites, and Services, including through analytics and quality assurance.

4. Customer Data and our role as a processor/service provider

When we process Customer Data as part of providing Services to a customer:

• We act as a “processor” or “service provider” (as those terms are commonly used in privacy laws) and process Customer Data only on the customer’s instructions and as permitted by the applicable contract.
• The customer is responsible for deciding what Customer Data to provide to Turnberry and for providing any required notices and obtaining any required consents from individuals.
• If you have questions about Customer Data processed for a customer (for example, data in a customer’s systems or environment), please contact that customer directly. We support our customers with requests as required by contract and applicable law.

Use of AI-enabled tools

We may use AI-enabled tools to support internal operations and the delivery of Services. We do not input Customer Data or other client-sensitive information into AI applications or services without customer authorization, and we use approved tools and controls designed to protect confidentiality and security.

5. Identity, access, and enterprise systems (including Microsoft Entra ID)

Turnberry uses enterprise identity, access management, and security tooling (which may include Microsoft Entra ID) to administer accounts and help secure access to Turnberry systems and, where applicable, customer environments.

In connection with these tools, we may process:

• User identifiers and profile information (such as name, username, email address, role, and organization).
• Authentication and access information (such as sign-in events, multi-factor authentication status, device information, and IP address).
• Audit and security logs used for monitoring, investigations, access reviews, and compliance.

We use this information to authenticate users, enforce access controls, monitor for suspicious activity, and meet compliance obligations.

6. Cookies and similar technologies

We use cookies and similar technologies to operate our websites, remember preferences, and understand website usage.

You can control cookies through your browser settings and, where available, through any cookie preference tools presented on our websites. Disabling certain cookies may affect site functionality.

7. How we share information

We may share Personal Information with:

• Service providers and vendors that perform services on our behalf (such as website hosting, analytics, CRM platforms, email delivery, customer support tools, recruiting tools, background checks, travel support, and professional services). These parties are permitted to use Personal Information only to provide services to Turnberry under applicable contractual protections.
• Customers, partners, and project stakeholders as needed to provide Services, manage projects, or as directed by the customer.
• Professional advisors (such as auditors, attorneys, and insurers).
• Government authorities, regulators, or law enforcement where required by law or to protect rights, safety, and security.
• Parties to a corporate transaction (such as a merger, acquisition, financing, or sale of assets), subject to appropriate protections.

We do not sell Personal Information.

8. Data security

We maintain administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, loss, misuse, alteration, or disclosure. Safeguards may include least-privilege access controls, encryption in transit and at rest, monitoring and logging, vendor and contract controls, and data minimization.

We also apply controls designed to reduce the risk of accidental exposure of sensitive data (for example, through data masking and restrictions on the use of real sensitive data in non-production environments, subject to appropriate approvals and safeguards).

If we become aware of a security incident that affects Personal Information, we will take steps to investigate and, where required by applicable law or contract, provide notifications to relevant parties.

9. Data retention

We retain Personal Information for as long as reasonably necessary for the purposes described in this Notice, including to provide Services, maintain business records, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary depending on the type of information and the context in which it was collected.

Customer Data is retained and deleted according to the applicable customer contract and our customer’s instructions.

10. Your choices and rights

Depending on where you live and the nature of your relationship with Turnberry, you may have rights to:

• Access, correct, or delete your Personal Information.
• Object to or restrict certain processing.
• Receive a copy of your Personal Information (data portability).
• Withdraw consent where we rely on consent.
• Opt out of marketing communications at any time (by using the unsubscribe link in our emails or contacting us).

We respond to requests consistent with applicable law. If your request relates to Customer Data processed on behalf of a customer, please contact that customer directly (see Section 4).

11. International transfers

Turnberry is based in the United States and may process Personal Information in the United States and, where permitted and consistent with applicable law and contractual requirements, in other locations where we or our service providers operate. Where required, we use appropriate safeguards for cross-border transfers.

12. Changes to this Privacy Notice

We may update this Privacy Notice from time to time. When we do, we will post the updated Notice and revise the “Last updated” date above.

13. Contact us

Questions, comments, or requests regarding this Privacy Notice are welcomed and should be addressed to:

Email: info@turnberrysolutions.com

Mail: Turnberry Solutions, Inc.
      100 South Fifth Street, Suite 300
      Minneapolis, Minnesota 55402