Privacy Policy

TURNKEY ANALYST, LLC (“TURNKEY”) takes your privacy seriously.

This policy covers how TURNKEY (or the “Firm”) treats personal information that the company collects and receives, including user submissions, personal information, and information related to your past use of our products and services. In the course of its client relationships, the Firm may also gather and maintain personal, non-public information regarding its clients’ financial circumstances and investment objectives. Personal information is information about you that is personally identifiable like your name, address, email address, or phone number, and that is not otherwise publicly available.  TURNKEY is committed to maintaining the privacy and confidentiality of this client information.  Accordingly, TURNKEY has adopted a privacy policy.

The Privacy Policy relates to all products and services provided by TURNKEY to our users through client interactions, applications and services that run on a variety of sites, including but not limited to Facebook and other third-party sites (collectively, the ‘Products’), and on the TURNKEY website (the ‘TURNKEY Website’), located at and all subdomains. The Products and Website comprise, collectively, the ‘Site’.

Information We Collect

Non-Personally Identifiable Information. Non-personally identifiable information is information that, by itself, cannot be tracked to a specific individual. TURNKEY may collect non-personally identifiable information while you are visiting the Site. While providing services and features, TURNKEY may collect web surfing data such as your IP address, web pages on the Site that have you visited, time and date, and whether or not you clicked on advertisements (“Web Surfing Data”). We use different types of technologies to collect this information, including cookies.

If your browser is configured to accept the cookies, these cookies will be used to recognize your computer when you revisit the Site to provide you with a superior user experience — for example, making it so you do not have to enter your login credentials on every visit. However, if you wish, you can configure your browser to block cookies.

Advertisements of third-party advertisers may be displayed on the Site (Website or Products). If you choose to click on an advertisement or link, TURNKEY may provide non-personally identifiable information to the advertiser and/or web publisher. Also, the advertiser or web publisher may use cookies or other technologies to collect information when you are visiting their websites. The information advertisers or other third parties collect is governed by their individual privacy policies, not by TURNKEY’s privacy policy.

TURNKEY’s partners or affiliates may provide the Product through their website, including by framing the Product. To the extent the partner or affiliate collects information, the treatment of that information is governed by the privacy policy of the partner or affiliate, not by TURNKEY’s privacy policy.

Personally Identifiable Information. While providing various services or features, we may ask you to provide personal information. For example, if you choose to register at the Site, you will be asked to provide your email address and a Screen Name. If you choose to create a profile at the Site, you may elect to provide information, such as your name, telephone number, street address, email address, age, gender, stocks of interest, and income range.

Another service provided through the Site Product allows you to invite a friend to Sign Up for membership. If you use this service, we will ask you to provide your email address along with your friend’s email address. We will send one email message to your friend inviting the friend to Sign Up. We will not use this information for any other purpose.

The Firm may also collect personally identifiable information about TURNKEY’s clients and potential clients from the following sources:

  • Information received from account applications, questionnaires, interviews, information forms, and other client interactions;
  • Information about transactions with TURNKEY, TURNKEY’s affiliates, or others;
  • Information TURNKEY obtains or receives from a consumer reporting agency.

Use of the Information We Collect

Use of Non-Personally Identifiable Information. TURNKEY may use non-personally identifiable information collected to improve the quality of TURNKEY’s services — for example, by diagnosing service or technology problems, by assessing and maintaining security, by presenting you with ads that we think you would be interested in seeing, or by allowing you to remain logged into TURNKEY on your computer. We may also use the information to count and recognize returning users.

TURNKEY may use user submissions, such as screens and searches, to conduct studies and develop forecasts, price forecasts, and stock ratings and reports, which it may display on the Site or otherwise provide to Site users. TURNKEY may use user submissions to make trades. By using the Site and providing User Submissions and, specifically predictions, you agree to allow us to use the information to make forecasts, trade on the forecasts, and to provide statistics to others.

TURNKEY may conduct research on the Web Surfing Data to determine user demographics, interests, and behavior and may market the Site by sharing Web Surfing Data with potential advertisers or partners. If it does so, TURNKEY will share the Web Surfing Data in such a way that users are not identified. For example, we may provide demographic or usage information to an advertiser so they may see how many registered users are from a specific geographic area or clicked on a certain ad in the previous month. TURNKEY also may provide your non-personally identifiable information to contractors so that they can perform services for us.

Use of Personally Identifiable Information. TURNKEY may share contact information with carefully pre-screened third parties for marketing or promotional purposes. TURNKEY may also provide personally identifiable information as part of an inquiry about products or services provided by one of the advertisers or partners: we will provide that information to that advertiser or partner so that they may attempt to provide you with information regarding the products or services about which you inquired.

TURNKEY may use the personally identifiable information provided by users or advertisers for internal purposes, such as sales, human resources, marketing, and administration.

Other Sharing of Information

TURNKEY may release information when necessary to comply with the law or a court order or an investigation. TURNKEY also may release information to law enforcement to protect its rights, property, or other interests, including those of its customers or users or to prevent illegal activities or violations of TURNKEY’s Terms of Service Agreement.

Because the Site may make available certain financial market data, quotes, price forecasts, other forecasts, news, research, predictions, recommendations, and opinions or other financial information (collectively “Information”), which has been independently obtained by certain financial market information services, financial publishers, various securities markets, including stock exchanges and their affiliates, investment bankers, and other providers (collectively the “Information Providers”), TURNKEY reserves the right to share limited information of users, including, for example, name and address, to the Information Providers if the user is violating TURNKEY’s Terms of Service Agreement or an Information Provider’s terms of use.

In the event that TURNKEY, in whole or in part, establishes a partnership with another company, or is acquired by or merged with another company, collected information may be transferred to the partner or the acquiring or merging company.


You can delete your account by emailing  [email protected] . TURNKEY also allows users who choose to provide personally identifiable information on their profile to edit their profile to ensure that it is correct and up-to-date.

Child Protection

TURNKEY does not offer services to, or target, persons under the age of 13. In compliance with the Children’s Online Privacy Protection Act, any information we receive from people we believe to be children under 13 will be purged from our database.


TURNKEY makes significant efforts to protect against the loss, misuse, and alteration of the collected information. These measures may include the use of secure server technology. Be aware, however, that the Internet is not 100% secure. Therefore, we cannot ensure the security of any information transmitted to us over the Internet, and we accept no liability for any unintentional disclosure.

Some areas of the Site are password-protected. To increase security, please do not share your passwords with anyone.

Links to Advertisers and Other Websites

TURNKEY’s services are combined with content from web publishers and advertisers. The Site may contain links to other websites, including advertisers. In addition, User Submissions may contain links to other websites. TURNKEY is not responsible for the privacy practices or the content of web publishers, advertisers, or other websites that may be linked to the Site.

Acceptance of Privacy Policy


Effective Date

We reserve the right to modify this privacy policy at any time by posting the changes on our website. Please check the effective date at the bottom of this page to determine if the privacy policy has been modified since you last reviewed it. We also will notify you about significant changes to the privacy policy by sending you a notice to the primary email address specified in your account or by placing a prominent notice on the Site. Your continued use of our Site following posting of the updated privacy policy will constitute your acceptance of the changes.

Privacy Policy Notification

TURNKEY will provide clients with a privacy notice (the “Privacy Notice”) when the client engages TURNKEY for advisory or other services.  The Privacy Notice shall detail the types of nonpublic client information TURNKEY collects, the information TURNKEY shares with third parties or with affiliates, the kinds of third parties with which TURNKEY shares information, the policies and practices TURNKEY has in place to protect the confidentiality and security of nonpublic client information; and the procedures TURNKEY has in place to permit clients or potential clients to opt-out of information-sharing arrangements with third parties (inapplicable to TURNKEY so long as TURNKEY only shares information with third parties for purposes of servicing client accounts).

TURNKEY shall distribute an updated Privacy Notice to all of its clients on or before July 1 of each year, even if the policy has not changed since the previous year.  Privacy Notices shall be sent by electronic mail unless otherwise requested by the client, and may be included in a quarterly report, newsletter or other client mailing. The Privacy Notice will also be available via our Site.

The Compliance Officer is responsible for evaluating TURNKEY’s compliance with this privacy policy.  Compliance deficiencies must be addressed by the Compliance Officer and brought to the immediate attention of TURNKEY’s management.

Disclaimer: is not an investment adviser, brokerage firm, or investment company. The use of any information on this site does not guarantee performance. Past results are not necessarily indicative of future performance. Empiritrage and are both owned in part by Wesley R. Gray, Ph.D.