Privacy Policy — Turn Zero Sim Racing

Turn Zero Sim Racing
Version 1
Effective Date: May 1, 2026

1. Introduction

This Privacy Policy describes how Turn Zero Motorsports LLC, doing business as Turn Zero Sim Racing ("we," "us," "our," or the "Company"), collects, uses, discloses, and retains personal information about visitors, drivers, parents and guardians of minor participants, and other individuals who interact with us, our facility located at 687 S Coast Hwy 101, Suite 151, Encinitas, California 92024, our website at turnzerosimracing.com, our driver portal, our marshalls portal and check-in kiosk, our email and SMS communications, and any related products and services (collectively, the "Services").

This Privacy Policy is intended to satisfy our disclosure obligations under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the "CCPA"), and other applicable privacy laws.

2. Information We Collect

We collect the following categories of personal information:

Identifiers. Name, email address, telephone number, postal address, account username, and Internet Protocol (IP) address.
Customer records. Date of birth, electronic signature, and payment information. Payment card numbers are processed and held by our payment processor; we receive transaction metadata, the last four digits of the card, and the brand of the card, but we do not store full card numbers.
Commercial information. Records of products and services purchased, considered, or used, including session bookings, memberships, gift card purchases and redemptions, credit pack purchases and redemptions, refunds, and event participation.
Internet and electronic network activity. Browser type, device information, pages viewed, referring URL, and information about your interactions with our website, driver portal, and check-in kiosk.
Geolocation data. General geographic location inferred from IP address. We do not collect precise GPS-level location.
Sensitive personal information. Date of birth (used to determine age, including whether a participant is a minor); information about medical conditions, physical limitations, or other safety-relevant health information you voluntarily disclose to us in connection with simulator participation. We use sensitive personal information only for the purposes for which it was collected and related purposes permitted under California law, and we do not use sensitive personal information to infer characteristics about you.
Audit and signing metadata. When you sign a waiver electronically, we collect the IP address and browser/device information of the device used to sign, the timestamp of signing, the version of the waiver and the electronic-records consent disclosure shown to you, and the kiosk device identifier (when applicable). When state-mutating operations are performed in our system, we retain a record of the actor, action, target, timestamp, and (where applicable) before-and-after values for auditing and legal-claims purposes.
Communications content. Records of your communications with us, including email correspondence and SMS messages, and records of marketing-communication preferences.

We do not knowingly collect personal information from children under thirteen (13) years of age. For minor participants between the ages of thirteen (13) and seventeen (17), we collect information about the minor solely from the minor's parent or legal guardian, who signs the waiver on the minor's behalf and is the data subject for our Services.

3. Sources of Personal Information

We collect personal information from the following sources:

Directly from you when you book a session, become a member, sign a waiver, purchase a gift card or credit pack, check in at our facility, contact us, sign up for marketing communications, or otherwise interact with the Services.
Automatically from your device when you use our website, driver portal, marshalls portal, or check-in kiosk (cookies, web logs, and similar technologies).
From our payment processor when you make a purchase (transaction confirmations and metadata).
From parents and legal guardians who sign waivers on behalf of minor participants.

4. How We Use Personal Information

We use personal information for the following purposes:

To provide the Services, including processing bookings, memberships, payments, refunds, gift card sales and redemptions, credit pack activity, and waiver signing.
To verify identity, including age, and to enforce the terms of our waiver, terms of service, and other agreements.
To communicate with you about your bookings, account, payments, waiver expiration, and operational matters.
To send you marketing or promotional communications, where you have consented to receive them. You may opt out of marketing communications at any time using the unsubscribe link in any email or by replying STOP to any SMS.
To operate, maintain, secure, and improve the Services, including for fraud prevention, security monitoring, debugging, error reporting, and analytics.
To comply with our legal obligations, including financial recordkeeping, tax reporting, and responses to lawful requests from government authorities.
To establish, exercise, and defend legal claims, including by maintaining records of signed waivers and audit logs of state-mutating operations.

We process sensitive personal information only for the limited purposes described above and for additional purposes permitted under California Civil Code § 1798.121(d) without separate notice or consent.

5. How We Disclose Personal Information

We disclose personal information to the following categories of recipients:

Service providers and processors acting on our behalf, under written agreements that limit their use of personal information to providing services to us. Current categories include payment processing (Square), SMS messaging (Twilio), transactional and marketing email delivery (Mailchimp and our transactional email provider), error monitoring and observability (Sentry), and cloud storage of waiver records (Amazon Web Services or a comparable provider).
Analytics and advertising partners. We use Google Analytics to understand how visitors use our website and Meta Pixel (provided by Meta Platforms, Inc.) to measure the effectiveness of advertising and to deliver advertising on Meta-operated platforms (including Facebook and Instagram). These technologies receive identifiers, device information, IP address, page-view information, and information about your interactions with our Services, and they may combine that information with information they hold from other sources. See Section 9 for more on cookies and tracking technologies, and Section 7 for your right to opt out of this sharing.
Legal and government authorities in response to subpoenas, court orders, or other legal process, or when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, or to comply with applicable law.
Successors in interest in the event of a merger, acquisition, financing, reorganization, sale of all or part of our business or assets, or similar transaction. Any successor will be required to honor the commitments made in this Privacy Policy with respect to information collected before the transaction.
Professional advisors and insurers in connection with the establishment, exercise, or defense of legal claims, audits, accounting, and similar professional purposes.

No sale; sharing for cross-context behavioral advertising disclosed. We do not sell personal information for monetary or other valuable consideration. However, our use of Meta Pixel, and certain configurations of Google Analytics, may constitute "sharing" of personal information for cross-context behavioral advertising as that term is defined under the CCPA. You have the right to opt out of this sharing at any time. See Section 7 ("Right to Opt Out of Sharing") for the methods available to you, including our "Do Not Sell or Share My Personal Information" link and our recognition of Global Privacy Control browser signals.

6. Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, and to establish, exercise, or defend legal claims. Specific retention periods include:

Customer account records: retained for the duration of your relationship with us and for a reasonable period thereafter consistent with applicable statutes of limitation and our legitimate business interests.
Signed waivers and electronic-records consent disclosures: retained for a minimum of seven (7) years from the date of signing. For waivers signed by a parent or legal guardian on behalf of a minor, retention extends through the participant's twenty-first (21st) birthday plus three (3) additional years.
Financial transaction records: retained for at least seven (7) years to satisfy tax, accounting, and recordkeeping obligations.
Audit log records of state-mutating operations: retained indefinitely while the Company operates, in support of legal-claims defense, financial reporting, and compliance. For audit log entries older than seven (7) years, we apply data-minimization processing to remove personally identifying portions of the entry while preserving structural information (the actor, action, target, and timestamp of the operation).

7. Your Rights

If you are a California resident, you have the following rights under the CCPA, subject to certain exceptions:

Right to know. You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the purposes for which we use the information, and the categories of third parties to whom we disclose the information.
Right to delete. You may request that we delete personal information we have collected from you. This right is subject to legal exceptions, including where information is necessary to complete a transaction, comply with a legal obligation, defend legal claims, or for other internal uses reasonably aligned with the context in which you provided the information. Records we are required or permitted to retain — including signed waivers, audit logs, and financial records — may not be deletable on this basis.
Right to correct. You may request that we correct inaccurate personal information we maintain about you.
Right to limit use of sensitive personal information. You may request that we limit our use of sensitive personal information to what is necessary to perform the Services. We currently use sensitive personal information only for that purpose and for related purposes permitted by law without separate consent.
Right to opt out of sharing. We do not sell personal information for monetary or other valuable consideration. We do, however, use the Meta Pixel and certain configurations of Google Analytics that may constitute "sharing" personal information for cross-context behavioral advertising under the CCPA. You may exercise your right to opt out of this sharing in any of the following ways:
- "Do Not Sell or Share My Personal Information" link. Click the link by that name in the footer of our website to opt out. The opt-out preference is recorded for your browser and, if you are signed in to your account, on your account record.
- Global Privacy Control (GPC). We honor the GPC signal sent by some browsers and browser extensions. When we detect a GPC signal in your browser, we treat it as a request to opt out of sharing for cross-context behavioral advertising for that browser session.
- Email request. Send a request to the email address in Section 11 and we will record the opt-out for the account associated with the requesting email address.
  Opting out applies prospectively and may not affect data already disclosed before the opt-out took effect.
Right to non-discrimination. We will not discriminate against you for exercising any of your rights under the CCPA.

To exercise any of these rights, contact us using the information in Section 11. We will verify your identity before responding to a request, typically by confirming information we already hold about you. We will respond to verifiable requests within forty-five (45) days as required by law, with one additional forty-five (45) day extension available for complex requests where notice of the extension is provided.

You may designate an authorized agent to make a request on your behalf in accordance with California regulations. We may require you to verify your own identity directly with us before acting on the agent's request.

8. Children's Privacy

The Services are not directed to children under thirteen (13) years of age. We do not knowingly collect personal information from children under thirteen. If you believe we have inadvertently collected personal information from a child under thirteen, please contact us using the information in Section 11 and we will delete the information.

For minor participants between the ages of thirteen (13) and seventeen (17), we rely on the minor's parent or legal guardian to provide and consent to the use of the minor's information for purposes of the Services.

9. Cookies and Similar Technologies

Our website, driver portal, marshalls portal, and check-in kiosk use cookies and similar technologies (including pixels, tags, local storage, and software development kits) for several purposes. We classify cookies and similar technologies into the following categories:

Strictly necessary. Required for the Services to function — for example, authentication, session management, security, fraud prevention, and load balancing. These cannot be disabled without making the Services unusable.
Preferences. Remember choices you make (such as language or display settings) to provide a consistent experience.
Analytics. Help us understand how visitors use our website and where we can improve. We use Google Analytics for this purpose. Google Analytics uses cookies and collects information including your IP address, device and browser information, pages viewed, and interactions with our website. Information collected is processed by Google in accordance with Google's privacy practices. For more information, see https://policies.google.com/privacy. You can opt out of Google Analytics tracking by installing the Google Analytics Opt-Out Browser Add-on (https://tools.google.com/dlpage/gaoptout) or by using our cookie preference center as described below.
Advertising. Used to measure the effectiveness of our advertising and, where applicable, to deliver advertising to you on third-party platforms. We use the Meta Pixel (provided by Meta Platforms, Inc.) for this purpose. The Meta Pixel collects information about your use of our website (including IP address, browser and device information, pages viewed, and interactions with our content) and reports it to Meta, which may combine that information with information Meta holds about you from other sources to deliver advertising on Facebook, Instagram, and other Meta-operated platforms. You can manage your Meta advertising preferences through your Facebook account settings (https://www.facebook.com/settings/?tab=ads), and you can opt out of advertising-cookie tracking via our cookie preference center as described below.

Cookie preference center. When you first visit our website, we will present a banner allowing you to consent to or decline non-essential cookies (analytics and advertising). You may change your preferences at any time by clicking "Cookie Preferences" in the footer of our website.

Browser-based controls. You can control cookies through your browser settings, including blocking, deleting, or alerting you to cookies. Some browsers and browser extensions can also send a Global Privacy Control (GPC) signal — when we detect a GPC signal we treat it as a request to opt out of cross-context behavioral advertising sharing as described in Section 7. Disabling strictly-necessary cookies may affect the functionality of the Services.

Do Not Track. Our website does not respond to the legacy "Do Not Track" header, which is no longer a standardized control. We do honor the Global Privacy Control signal as described above.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Effective Date" at the top of this policy and post the updated version on our website. For material changes, we will provide additional notice — for example, by email to your account email address or by a prominent banner on our website — consistent with applicable law. Your continued use of the Services after the Effective Date of an updated Privacy Policy constitutes your acceptance of the updated terms.

A history of prior versions of this Privacy Policy is available on request.

11. Contact Us

If you have questions about this Privacy Policy or our privacy practices, or if you wish to exercise any of your rights, contact us:

Turn Zero Motorsports LLC dba Turn Zero Sim Racing
687 S Coast Hwy 101, Suite 151
Encinitas, CA 92024
Email: privacy@turnzerosimracing.com