Turning Pages Now™ · Legal

Last updated: July 24, 2026

About This Policy. Turning Pages Now™ (“we,” “us,” “our,” or “the Company”) is operated under the Employer Identification Number (EIN) of its owner and is headquartered in the Commonwealth of Massachusetts, United States. We provide a digital subscription service that includes access to content through our website at www.turningpagesnow.org (the “Site”), member group video meetings conducted via Zoom, a members-only online group, and one-on-one calls (collectively, the “Services”). This Privacy Policy explains what information we collect, how we use and disclose it, the technologies we use, your rights, and the limits of our responsibility. By accessing the Site or any of the Services, you acknowledge that you have read, understood, and agree to these practices. If you do not agree, you should not use the Site or the Services.

Disclaimer. This is a general disclosure document, not legal advice tailored to your situation, and is provided “as is” without warranties of any kind. For questions about how the law applies to you, consult a qualified attorney licensed in the Commonwealth of Massachusetts.

1 · Information We Collect

1.1 Categories of Information

Personal data: name, email address, username, password, billing address, phone number, and similar identifiers you provide.
Financial data: payment method details, billing information, transaction history, and refund records. Full card numbers are handled by our third-party payment processor; we do not store them.
Social networking data: information you provide when interacting with us via social media platforms, including handles, profile information, and the content of messages or posts directed to us.
Mobile device data: device identifiers, device type, operating system, browser type, IP address, location information derived from your device, and similar technical data.
Other data: any additional information you provide to enter a contest or giveaway, to participate in a survey, or to otherwise engage with the Site and Services.

1.2 Information Collected Automatically

When you visit and use the Site we automatically collect device and usage data (IP address, browser type and version, time zone, operating system, device identifiers), activity data (pages viewed, click patterns, time spent, referring URLs, subscription status, Zoom attendance records), and approximate location derived from your IP address. We do not collect precise GPS location unless you separately grant permission.

1.3 Information From Third Parties

We may receive information about you from our service providers (payment processor, Zoom, analytics vendors, the member group platform), from social media or single sign-on providers if you use them to sign in, and from others when permitted by law.

2 · How We Use Your Information

We use the information we collect to:

Provide, operate, and maintain the Site and the Services, including processing subscriptions and delivering access to content, member group meetings, the online group, and one-on-one calls.
Register and authenticate your account, manage subscriptions and renewals, and process payments and refunds.
Communicate with you about your account, the Services, updates, security alerts, and administrative notices.
Send newsletters and marketing communications where you have opted in (see Section 8).
Respond to your requests, provide customer support, and conduct one-on-one calls.
Analyze and improve the Site, the Services, and our content, and to monitor and prevent fraud, abuse, and violations of our terms.
Comply with our legal, accounting, and tax obligations under federal and Massachusetts law.

Legal Bases. Where applicable law requires a legal basis for processing, we rely on your consent, the performance of a contract with you, our legitimate business interests, and compliance with legal obligations.

3 · How We Disclose Your Information

We do not sell your personal information for monetary consideration. We may share or disclose your information:

To create and administer Your account, deliver products or services purchased by You, correspond with You, process payments or refunds, and contact You about new offerings We think You will be interested in.
To interact with You via social media, send You a newsletter or other updates about Our company or website, deliver targeted advertising, and request feedback from You.
To notify You of updates to Our product and service offerings, resolve disputes and troubleshoot problems, administer contests or giveaways, and generate a personalized profile so future interactions with Our website will be more personal.
To compile anonymous statistical data for Our own use or for a third party’s use, assist law enforcement as necessary, prevent fraudulent activity on Our website or mobile app, and analyze trends to improve Our website.
With service providers that perform services on our behalf — payment processing, video conferencing (Zoom), the member group platform, email and newsletter delivery, website analytics, and hosting — each bound by contract to handle data only as needed to perform their services.

Member Group and Online Group Context. Information you share in member group Zoom meetings and in the members-only online group may be visible to other members. You are solely responsible for what you choose to disclose in those settings, and the Company is not responsible for how other members use, share, or store information they obtain from you.

We may also disclose information when we believe in good faith that disclosure is required by law, court order, or government request; to protect the rights, property, or safety of the Company, our users, or others; in connection with a merger, acquisition, reorganization, sale of assets, financing, or bankruptcy; or with your consent or at your direction.

4 · Zoom Meetings, Online Group, and One-on-One Calls

Recording. Member group Zoom meetings may be recorded for the benefit of members who cannot attend live and for the Company’s internal use. Members will be notified at the start when a session is being recorded. By participating, you consent to being recorded, including your name, video image, voice, and any chat content you submit.

Member-Provided Content. Posts, files, messages, and other content you share in the members-only online group are visible to other members. The Company does not control and is not responsible for how members use, screenshot, download, or redistribute content shared within the group, or for any consequences of sharing your personal information with other members.

One-on-One Calls. Information you choose to share during one-on-one calls is treated as confidential to the extent described in this Policy, but the Company cannot guarantee that information shared verbally over a third-party video or phone platform will not be observed, recorded, or intercepted by third parties, including the platform provider or others in your environment.

No Responsibility for Member Interactions. The Company facilitates access to member group meetings and the online group but does not monitor, vet, endorse, or guarantee the conduct of any member. The Company is not responsible or liable for any interactions, statements, advice, or outcomes arising from member-to-member contact within these forums.

5 · Tracking Technologies

We and our service providers use cookies, web beacons, pixels, local storage, and similar technologies on the Site to recognize your browser, remember your preferences, measure traffic, and serve and measure advertising where applicable. Categories include essential, functionality, analytics, and advertising technologies. Most browsers let you control or delete cookies through their settings; disabling cookies may affect how the Site functions. We are not responsible for the consequences of your choices regarding tracking technologies.

6 · Website Analytics

We use third-party analytics tools to collect and analyze usage data about the Site. These tools may set cookies and similar technologies and may collect information about your device, browser, and interactions with the Site. The data is used in aggregate to understand traffic patterns and improve the Site. We do not use analytics data to identify individual users except where required to investigate fraud or abuse. The third-party analytics providers have their own privacy policies, and the Company is not responsible for their independent data practices.

7 · Processing, Security, and Retention

Where We Process. Your information is processed primarily in the United States. Because our service providers may operate servers in other countries, your information may be transferred to and processed in countries outside your own. By using the Site and Services, you consent to such transfers.

Security. We use reasonable administrative, technical, and physical safeguards designed to protect personal information, consistent with 201 CMR 17.00 (the Massachusetts Standards for the Protection of Personal Information). We maintain a Written Information Security Program (WISP) documenting these safeguards. No method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. We are not responsible for losses resulting from circumstances beyond our reasonable control, or for the data practices, security failures, or policies of independent third parties.

Retention. We retain personal information for as long as your account is active and for additional periods as needed to fulfill the purposes described in this Policy, comply with legal obligations (including tax and accounting recordkeeping), resolve disputes, and enforce our agreements. Account and subscription data is retained for the life of your account and for a reasonable period after closure (typically up to seven (7) years for tax records). Zoom recordings are retained for length of Company's discretion. Members-only online group content may be deleted or archived after you leave the group at the Company’s discretion. Marketing data is retained until you unsubscribe or request deletion, subject to legal retention requirements. When information is no longer needed, we delete it or de-identify it.

8 · Newsletter and Marketing Communications

We may send you newsletters and marketing emails about our Services, content, and offerings if you have opted in. You can opt out at any time by clicking the unsubscribe link in any marketing email, by replying with an unsubscribe request, or by contacting us at [email protected]. Opting out of marketing does not affect transactional messages such as account, billing, and security notices, which you cannot opt out of while your account is active.

9 · Your Privacy Rights

Depending on your location and the applicable law, you may have the right to access, correct, delete, restrict or object to processing of, port, withdraw consent for, and opt out of sale or sharing of your personal information, and to exercise these rights without being denied service (except where the law permits differentiated service where necessary). To exercise any right, contact us at [email protected] with the subject line “Privacy Rights Request.” We will respond within the time frame required by applicable law (generally 30 to 45 days), may need to verify your identity, and may decline or limit requests that are excessive, repetitive, fraudulent, or that would infringe on the rights of others. You may exercise your rights through an authorized agent; we may require proof of authorization and may still need to verify your identity directly.

Massachusetts Residents. Massachusetts law (including M.G.L. c. 93H and the Data Breach Notification law, M.G.L. c. 93H, § 3) gives residents certain rights with respect to personal information. We comply with these requirements, including the obligation to notify affected residents in the event of a breach of security as described in Section 10.

10 · Data Breach Procedures

In the event of a security breach affecting personal information, we will:

Investigate the incident promptly to determine the scope and nature of the breach.
Take steps to contain and remediate the breach, including securing affected systems.
Notify affected individuals and relevant authorities as required by applicable law, including the notice required under Massachusetts law (M.G.L. c. 93H, § 3) and any other applicable federal or state breach notification requirements.
Provide notice that includes, to the extent required by law, the nature of the breach, the types of information involved, steps you can take to protect yourself, and what we are doing in response.

Limitation of Responsibility. While we will take reasonable steps in response to a breach, the Company is not liable for any indirect, incidental, consequential, or special damages arising from a security breach, except to the extent such limitation is prohibited by applicable law. Our responsibility in the event of a breach is limited to what is expressly required by law.

11 · Limitation of Liability and No Responsibility for User Interactions

As-Is Use. The Site and the Services are provided “as is” and “as available.” We make no warranties, express or implied, about the accuracy, completeness, reliability, or availability of the Site or the Services, or about the content shared by members during group meetings, in the online group, or during one-on-one calls.

Not Responsible for Member or Participant Conduct. You acknowledge that the Company does not control, monitor, or vet the conduct of members or other participants in member group Zoom meetings, the members-only online group, or one-on-one calls. The Company is not responsible for any information that other members collect, use, share, or disclose about you, and is not liable for any harm, loss, or damage resulting from interactions between members, statements made by members, or advice given by members in any of these settings.

Not Responsible for Third-Party Platforms. Zoom and any platform hosting the members-only online group are independent third-party services with their own terms and privacy policies. The Company is not responsible for their data practices, security, recording, or actions, or for any data they collect, retain, or disclose.

Not Responsible for Information You Choose to Share. You are solely responsible for the information you choose to disclose in group settings, on calls, or through the Site. Share only information you are comfortable having other members observe.

Indirect and Consequential Damages. To the maximum extent permitted by applicable law, in no event will the Company be liable for any indirect, incidental, special, consequential, or punitive damages, or for any loss of profits, data, or goodwill, arising out of or related to your use of the Site or Services, the conduct of other members, third-party platform practices, or any breach of security, even if we have been advised of the possibility of such damages.

Aggregate Liability. Our total liability arising out of or related to this Privacy Policy or your use of the Site or Services will not exceed the amount you paid us for the Services in the twelve (12) months preceding the event giving rise to the claim, or, if you have not paid us, one hundred U.S. dollars ($100).

12 · Children’s Privacy

The Site and Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children under 18. If you believe a child has provided us with personal information, please contact us at [email protected] and we will take steps to delete that information.

13 · Notice to California Residents

This section applies to California residents under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). In the preceding 12 months, we have collected the following categories of personal information: identifiers (name, postal address, email address, IP address, account name); commercial information (records of products or services purchased and subscription history); internet or other electronic network activity information; geolocation data derived from your IP address or device; inferences drawn from the above to create a profile about you; and sensitive personal information, if any (such as account login credentials). We collect this information directly from you, automatically through the Site and Services, and from third-party service providers. We use and disclose it for the business and commercial purposes described in Sections 2 and 3. We do not sell your personal information for monetary consideration, and we do not knowingly share it for cross-context behavioral advertising.

California residents have the right to: know the categories and specific pieces of personal information we collect; know whether we sell or share their personal information and to whom; delete their personal information (subject to legal exceptions); correct inaccurate personal information; opt out of the sale or sharing of their personal information; limit the use of their sensitive personal information; and not be discriminated against for exercising their rights. To exercise these rights, contact us at [email protected] with the subject line “California Privacy Rights Request.” We will verify your identity before responding and will respond within the time frame required by California law (generally 45 days, extendable by 45 additional days where reasonably necessary). This Privacy Policy serves as our notice at collection under California law.

14 · International Privacy and GDPR Disclaimer

The Site and Services are operated from the United States and are intended for users located in the United States. If you access the Site or Services from outside the United States, you do so at your own risk and are responsible for complying with the laws of your jurisdiction. Because our service providers may operate servers in other countries, your information may be transferred to and processed in countries outside your own. By using the Site and Services, you consent to such transfers.

GDPR Disclaimer. This Privacy Policy is intended to address United States privacy law and may not satisfy all requirements of the European Union’s General Data Protection Regulation (GDPR), the UK GDPR, or the privacy laws of other non-U.S. jurisdictions. The Site and Services are not directed to individuals in the European Union, the European Economic Area, or the United Kingdom, and we do not intentionally collect personal data from individuals located in those regions. We are not a controller or processor established in those regions, have not appointed a representative or Data Protection Officer there, do not knowingly offer goods or services to individuals there, and do not intentionally monitor their behavior. If you are located in those regions and choose to use the Site or Services despite this disclaimer, you acknowledge that any personal data you provide will be processed in the United States in accordance with this Policy, that you may not have the same rights or remedies available to you under the GDPR or the privacy laws of your jurisdiction, and that the Company makes no representation or warranty that this Policy or its data practices comply with the GDPR, the UK GDPR, the EU-U.S. Data Privacy Framework, or any other non-U.S. privacy law. European users who choose to use the Site or Services do so at their own risk and are solely responsible for any consequences of providing personal data to a U.S.-based company that does not specifically comply with the GDPR.

15 · Links to Third-Party Sites

The Site may contain links to third-party websites or services that we do not control. We are not responsible for the privacy practices or content of those third-party sites. This Privacy Policy does not apply to information you provide to third parties through those links. We encourage you to review the privacy policies of any third-party sites you visit.

16 · Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top of this document. We will notify you of material changes by posting the updated Policy on the Site and, where appropriate, by sending a notice to the email address associated with your account. Your continued use of the Site or Services after the effective date of any change constitutes acceptance of the updated Policy.

17 · Governing Law and Disputes

This Privacy Policy is governed by the laws of the Commonwealth of Massachusetts and the United States, without regard to conflict-of-law principles. Any dispute arising out of or related to this Policy or your use of the Site or Services will be resolved in the state or federal courts located in the Commonwealth of Massachusetts, and you consent to the exclusive jurisdiction and venue of those courts, except where prohibited by law.

18 · Contact Us

If you have questions, requests, or concerns about this Privacy Policy or our handling of your personal information, please contact us:

Turning Pages Now™
Attn: Privacy / Data Protection
Mailing address: P. O. Box 918, East Falmouth, MA 02536
Email: [email protected]
EIN available upon verified request where required by law.

We will make every reasonable effort to respond to your inquiry within the time frame required by applicable law.