Echo360 PolicIES



Echo360 respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available our website and platform at (“Site”) and tell you about your privacy rights and how the law protects you.

By accessing and/or using the Site you consent to the collection, use and disclosure of your information, including your personally identifiable information as described in this document. Please note that this Privacy Policy does not govern our collection or use of the Personal Data we Process via our other Echo360 solutions.

With that in mind, this Privacy Policy is designed to describe:

  • Who we are and how to contact us.
  • Your rights relating to your Personal Data.
  • Marketing communications preferences.
  • What Personal Data we collect.
  • How we use your Personal Data and why.
  • What happens when you do not provide necessary Personal Data?
  • How we use cookies and other tracking or profiling technologies.
  • Who we share your Personal Data with.
  • How we keep your Personal Data secure.
  • How long we store your Personal Data.
  • End Users’ Personal Data.
  • Our policy on children.
  • California residents.
  • Third party links.

This Privacy Policy aims to give you information on how Echo360 collects and processes your Personal Data through your use of this Site, including any data you may provide through this Site.


You may have rights under the General Data Protection Regulation 2016/679 of the European Parliament, including as implemented under the laws of the United Kingdom (GDPR), as applicable to the processing of your Personal Data provided through this Site.  The Privacy Policy is intended to meet our duties of transparency under the GDPR. 

We will post any modifications or changes to this Privacy Policy on this page.



Turning Tech Intermediate, Inc., dba Echo360, is the Data Controller (for the purposes of the GDPR) of your Personal Data (referred to as either “Echo360”, “we”, “us” or “our” in this Privacy Policy).

Our address is: 255 West Federal Street, Youngstown, OH  44503, USA‏.

How to contact us.

  • email:; or
  • write to: Turning Tech Intermediate, Inc., dba Echo360, Attn: Privacy Officer/Customer Information, 255 West Federal Street, Youngstown, OH  44503, USA.


Our Data Protection Officer

The GDPR requires us to appoint a “Data Protection Officer”, this is a person who is responsible for overseeing and advising us in relation to our compliance with the GDPR (including compliance with the practices described in this Privacy Policy). If you want to contact our Data Protection Officer directly, you can email:

When you contact us, please describe in as much detail as possible the nature of your inquiry. We will investigate your inquiry promptly.

As Echo360 does not have an establishment in the European Union, we have appointed a representative based in the United Kingdom, who you may address to raise any issues or queries you may have relating to our processing of your Personal Data and/or this Privacy Policy more generally.

Our EU representative is: Blended Learning Consultancy Ltd. Our EU representative can be contacted directly by emailing them at the following address:  



Under certain circumstances, by law you have the right to:

  • Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
  • Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.


How to exercise your rights

If you want to exercise any of the rights described above, please contact us at

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.



If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority.

Marketing communications preferences.

You can ask us to stop sending you marketing messages at any time by following the update email preferences or unsubscribe links on any marketing message sent to you. Please note that we may still find it necessary to communicate with you regarding your use of the Site.



All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.


Category of Personal Data collected

What this means

Identity Data

First name, surname, title

Contact Data

Your email address, physical address and telephone numbers.

Marketing and Communications Data

Your preferences in receiving marketing from us and your communication preferences.

Behavioral Data

Site access, page access, time spent on page, feature use and other patterns related to website flow and usage.

Technical Data

Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site or use our services.

HR Data

Identity Data, government issued identification, work entitlement data (for purposes of verifying you are entitled to work in the country), your resume, education and career development data, performance appraisals, compensation elements, including, pay grade, salary, and pension fund contributions, bank account details, background records, and other relevant information necessary in the context of our current or potential employment relationship with you.

Attendance Data

Snapshot of geolocation when used for GPS attendance and related data.

Additional Personal Data We May Collect:

  • Payment Data. If you sign up for Paid Services, we receive a portion of your payment information from our payment processor (such as the last four digits, the country of issuance and the expiration date of the payment card) and we ask you to select your jurisdiction.
  • Communications Data. The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. Please be aware that information on public parts of our sites is available to others. We may also collect information you share with us in connection with surveys, contests or promotions.
  • Sub-Domain Data. Information from your use of the Echo360 services or users’ sub-domains. This may include: IP addresses, preferences, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services and our Users’ sub-domains (such as timestamps, clicks, scrolling, browsing times, searches, transactions, load times, and problems you may encounter, such as loading errors).
  • Partner Information. Information we get from our partners to support our marketing initiatives, improve our services and better monitor, manage and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.
  • Third-Party Services. Other information you submit to us directly or through third-party services if you use a third-party service to create an Account (based on your privacy settings with such third-party service).


Aggregated Data

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Behavioral Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

No Special Categories of Personal Data

 We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses. 


We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

We use the Personal Data we obtain about you to:

  • Provision of the services. Create and manage your account, provide and personalize our services, process payments and respond to your inquiries.
  • Communicating with you. To respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your Personal Data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Echo360, you may not opt out of receiving these important notices.
  • Surveys and contests. Administer surveys, contests and other promotions.
  • Customizing the services. Provide you with customized services. For example, we use your location information to determine your language preferences or display accurate date and time information. We also use cookies and similar technologies for this purpose.
  • Improving our Services. Analyze and learn about how the services are accessed and used, evaluate and improve our services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually. For example, if we learn that most users of paid services use a particular integration or feature, we might wish to expand on that integration or feature.
  • Security and Fraud Protection. To protect individuals, employees, and Echo360 and for loss prevention and to prevent fraud, including to protect individuals, employees, and Turning for the benefit of all our users, and prescreening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.
  • Third-party relationships. Manage our vendor and partner relationships.
  • Enforcement. Enforce our end user subscription agreement and other legal terms and policies.
  • Protection. Protect our and others’ interests, rights and property (e.g., to protect our users from abuse).
  • Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.

If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.

What is our “legal basis” for processing your Personal Data? 

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

  • Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

Generally, we do not rely on your Consent as a legal basis for using your Personal Data.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.


Category(ies) of Personal Data involved

Why do we do this

Our legal basis for this use of data


Technical Data

To track issues that might be occurring on our systems.

Legitimate Interests.

It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services. 


·       Identity Data

·       Contact Data

·       Technical Data

·       HR Data

To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you. 

Legitimate Interests.

We have a legitimate interest in providing you with updates on our Sites and related offers or information where you have purchased or shown interest in similar services from us.

Human Resource Programs

HR Data

o manage and administer our human resources programs, including employee communications, employee benefit programs, and other working relationships or arrangements, recruiting and hiring job applicants, assessing qualifications and performance, determining employee compensation and pay, performing background checks and references, managing terminations and transitions, employee training, employee health and security, and other general human resource purposes.

Legitimate interests.

We have a legitimate interest in administering our human resources programs, recruiting new applicants, and managing current employees for effective business operations.


What happens when you do not provide necessary Personal Data?

Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site).

In this case, we may have to stop you using our Site have with us but we will notify you if this is the case at the time.

Personal Data from Third Party Sources

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.  Our appointed data processors include: (i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at:


 We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies:

  • first party cookies, served directly by us to your computer or mobile device; and
  • third party cookies, which are served by our partners or service providers on our Site.


Our Site uses the following types of cookies for the purposes set out below:

Type of cookie


Essential Cookies

These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request to load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site.  The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here:

You can find out more about how Google protects your data here:

Targeted and advertising cookies

These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, if applicable, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.

Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

Disabling cookies


You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility).  Many browsers are set to accept cookies until you change your settings. 

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit and

In particular, you can disable cookies which remember your browsing habits and target advertising at you by visiting If you choose to remove targeted or advertising cookies, you will still see adverts, but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.

You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link:]


The table below describes who we share your Personal Data with, what we share and why we share it.


Category(ies) of Personal Data we share.

Why we share it


Service Providers and Business Partners

·       Identity Data

·       Contact Data 

·       Technical Data

·       HR Data

Our service providers provide us with IT and system administration services and help us manage our customer relationships (including providing customer support, customer liaison etc).

To the extent third party service providers assist us in managing our human resources programs, we may provide them with HR Data as necessary for them to perform the services.

·       Within Europe

·       The United States

Regulators and other authorities

·       Identity Data

·       Contact Data

·       HR Data

Authorities may require reporting of processing activities in certain circumstances. We may disclose Personal Data if such disclosure is required by a valid and lawful order to a court or other governmental or public body.

·       Within Europe

·       The United States

Process payments

·       Identity Data

·       Payment Data

We transmit your Personal Data via an encrypted connection to our payment processor.

·       The United States

Affiliates and Business Transfers

·       Identity Data

·       Contact Data 

·       Technical Data

·       HR Data

With affiliates within the Echo360 corporate group.

If we are involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal.

·       Within Europe

·       The United States


International Data transfers

Echo360 is a global organization headquartered in the United States and has legal entities, business functions, and systems in countries around the world. We share your Personal Data both with our affiliated companies within the Echo360 group and certain external third parties who are based outside the European Economic Area (“Europe”). Any processing of your Personal Data by these parties will involve the processing of your Personal Data outside of Europe.   Other countries have privacy laws that are different from privacy laws in your country. Regardless of location, Echo360 handles Personal Data as described here, and we take care to ensure that our employees, agents and strategic partners in other countries act in a manner consistent with this Policy.  Where Personal Data is collected in the European Economic Area (“EEA”) and such Personal Data is transferred to a jurisdiction that is deemed to have inadequate protections, we have taken measures to ensure that such Personal Data is transferred and processed securely in accordance with this Policy. We rely on the European Commission-approved Standard Contractual Clauses (“SCCs”), which we enter into with our customers and partners, as a legal mechanism for transfers of Personal Data from the EEA. The SCCs are contractual commitments made between companies transferring Personal Data with respect to the privacy and security of such Personal Data. For more information about the SCCs, click here. We are also certified under the Privacy Shield Framework. For more information on our Privacy Shield compliance, please reference the section below. 


We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

Personal Data you provide to us resides on a secure server and is only accessible to selected employees and staff via password. We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.


We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above, unless a longer retention period is required by law (for example for regulatory purposes).

The table below shows our standard retention practices:

Category of Personal Data

Retention period

Identity Data

For so long as retention is necessary to comply with our legal and contractual obligations, enforce our agreements, and enable us to investigate events and resolve disputes.

Contact Data

For so long as retention is necessary to comply with our legal and contractual obligations, enforce our agreements, and enable us to investigate events and resolve disputes.

Marketing and Communications Data

For so long as retention is necessary to comply with our legal and contractual obligations, enforce our agreements, and enable us to investigate events and resolve disputes.

Behavioural Data

For so long as retention is necessary to comply with our legal and contractual obligations, enforce our agreements, and enable us to investigate events and resolve disputes.

Technical Data

For so long as retention is necessary to comply with our legal and contractual obligations, enforce our agreements, and enable us to investigate events and resolve disputes.

End Users’ Personal Data

 Our customers may establish a sub-domain using services and are responsible for what they do with the Personal Data they collect about their End Users.  This section is directed to such customers.

If you are one of our Users, you may collect personal information about your End Users. For example, you may ask your End Users to provide their name, and email address in order to establish an account for them. You are solely responsible for complying with any laws and regulations that apply to your collection and use of your End Users’ information, including Personal Data you collect about them.  

You may choose to publish your own privacy policy and comply with them.

We are not liable for your relationship with your End Users or how you collect and use Personal Data about them (even if you collect it through the use of Echo360 functionality) and we will not provide you with any legal advice regarding such matters nor will we defend or represent you in any way with regard to any disputes with your End Users.

Our policy on children.

This Site is not intended for children below 16 and we do not knowingly collect data relating to such children. Echo360 does not market or sell products directly to children under the age of 13.  Echo360 also does not knowingly collect information about children under 13 without appropriate parental/guardian consent.  Products and services may be provided to organizations who use those products and services with children under the age of 13.  It is the responsibility of the organization to meet parental/guardian consent requirements under Children’s Online Privacy Protection Act (“COPPA”).  Regardless of the source, data is maintained according to the descriptions in this Privacy Policy.

California Residents.

California residents have certain rights spelled out in the California Consumer Privacy Act or “CCPA”. Echo360 does not sell the Personal Data we collect.  The types of Personal Data we collect in order to set up an account are described above.  The purposes for sharing any information we collect are also described above.  Echo360 does use third-party cookies as described here.

California consumers may make a request regarding the types of data disclosed and information about the third-party to whom data was disclosed under the CCPA by contacting us at:  We will verify your request using the information associated with your account.  Additional identification may be required.

Third party links.

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every site you visit.

Particular Products.

By using the following Echo360 products or services, you confirm you have agreed to the and read and understood this Privacy Policy and our Cookie Policy, and our End User Subscription Agreement (EUSA)

Echo360, Inc., 2022


Modern slavery is a crime and a violation of fundamental human rights; it includes slavery, servitude, forced labour, forced marriage, child labour violations, debt bondage, deceptive recruiting for labour or services, and human trafficking.

Echo360 is committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing systems and controls to ensure modern slavery is not present or permitted in our own business practices or across any of our controllable supply chains. Our practices and policies in this regard are guided by the United Kingdom’s Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018.

This policy applies to all persons working for Echo360 or on our behalf in any capacity, including employees, directors, officers, volunteers, interns, agents, contractors, consultants, third-party representatives, and business partners. The policy is applied to and enforced for all Echo360 business activities in all Echo360 markets.

Responsibility for the policy

Echo360 has responsibility for ensuring this policy complies with our legal and ethical obligations, and that those under our direct or indirect management comply with it.

Compliance with the policy

All persons working for Echo360 must comply with this policy. The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of those working for us or under our control.

All persons are required to avoid any activity that might lead to or suggest a breach of this policy and must notify their line manager OR a company Director as soon as soon as they believe or suspect that a conflict with this policy has occurred or may occur in the future.

If any person working for Echo360 is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of Echo360’s supply chains constitute any of the various forms of modern slavery, they must raise it with Human Resources via email @

Communication & awareness of this policy

Internal employees will be trained on and indicate acceptance of Echo360’s policy at time of hire, with updates provided using established methods of communication between Echo360 management and employees.

External suppliers, contractors, consultants, and partners will be advised and encouraged to accept Echo360’s policy at the outset of our business relationship with them, and reinforced as appropriate thereafter.

Breaches of this policy

Any employee or external entity who breaches Echo360’s policy will face commensurate disciplinary action, which could result in dismissal or termination.

Last updated: 2022-07