PRIVACY POLICY
Last updated: February 14, 2024
Turtzed LLC and its affiliates (“Turtzed”, “we”, “our”, or “us”) understands that privacy is important to our users. This Privacy Policy describes our practices regarding the collection, use, sharing, and protection of your personal information for our website, https://www.turtzed.com (the “Website”), our podcast, and any other products or services we offer from time to time (collectively, the “Services”). This Privacy Policy also tells you about the rights and choices you have with respect to your personal information, how you can assert those rights, and how you can contact us to get answers to your questions.
ACCESSIBILITY -- IF YOU ARE HAVING ANY TROUBLE ACCESSING THE OFFERINGS OR ANY ASSOCIATED WEBSITES, PLEASE CONTACT US TOLL FREE AT (305) 504 2200 24 HOURS A DAY, 7 DAYS A WEEK, OR EMAIL US AT INFO@TURTZED.COM.
This Privacy Policy applies to the personal information that we obtain in various contexts, including when you access or use the Services, or communicate with us over email or text message, or otherwise via the Services. BY USING OR ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES OR PRACTICES, YOU SHOULD NOT USE OR ACCESS THE SERVICES OR PROVIDE US WITH ANY PERSONAL INFORMATION.
The following links will take you directly to the corresponding sections of this Privacy Policy:
PERSONAL INFORMATION WE COLLECT FROM YOU
We use the term “personal information” – also called “personal data” or “personally identifiable information” in the laws of some jurisdictions – to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been deidentified or that otherwise cannot reasonably be related back to a specific person is not considered personal information. The precise definition of personal information may vary depending on your place of residence, but we take the same general approach to protecting your privacy, subject to any additional measures that may be required by applicable laws.
The following are the categories and types of personal information that we may collect from or about you, depending on how you interact with the Services:
Identifiers, such as your name, phone number, and email address;
Device and online identifiers and related information, including internet protocol (IP) address, mobile ad identifiers, data collected from cookies, beacons, and pixel tags, and similar unique identifiers;
Internet or other electronic network activity information, including, but not limited to browsing history, search history, and information regarding your interaction with an application, mobile app, or advertisement;
Payment information, if you make a purchase on the Website, or purchase a subscription to the Services.
Any other personal information that you voluntarily provide us.
HOW WE COLLECT YOUR PERSONAL INFORMATION
Personal Information You Provide
We collect personal information that you provide to us directly. This may include, but is not limited to:
Information you provide when you contact us through the Website, via email or text message, or through other Internet-enabled communications;
Information you provide when you subscribe to any of the Services;
Details relating to transactions that you carry out through the Website and any payment or other financial information you provide to us relating to such orders; or
Any other information that you provide us on or through the Website.
Personal Information We Collect Automatically
When you use the Services, open or click on emails we send you, or interact with our advertisements, we or third parties we work with may automatically collect certain information using technologies such as cookies and other tracking technologies described below.
Cookies and Similar Technology: "Cookies" are pieces of information that may be placed on your device for the purpose of collecting data to facilitate and enhance your communication and interaction with a website or app. Such data may include, for example, the address of the websites you visited before and after using the Website, the type of device you are using, your Internet Protocol (IP) address, what pages on the Website you visited and what links you clicked on, the region where your device is located, and geographic information based on your IP data. We may store some information on your device or device hard drive as a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Website. We may also use cookies to customize your visit to the Website and for other purposes to make your visit more convenient or to enable us to enhance the Website and our Services.
Clickstream Data: As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as "clickstream data," can be collected and stored by a website's server. Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the Services. We may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our Website, how visitors navigate throughout the Services, and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our Services.
Analytics: The Website utilizes various third-party vendors who use the technologies described in this section to conduct analytics to help us track and understand how visitors use the Website. One such provider is Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help analyze how users use the Website. The information generated by these cookies about your use (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on activity for its staff, and providing other services relating to web page activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You may refuse the use of cookies by selecting the appropriate settings in your browser. By using the Website and accepting cookies, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Please refer to the currently available opt-outs for Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.
From Other Sources: We may obtain information about you from other sources, such as vendors that provide other services on our behalf, or publicly available sources.
HOW WE USE YOUR PERSONAL INFORMATION
We collect and use personal information for the following purposes:
To communicate with you, which may include:
Contacting you about and providing you and our services;
Responding to your direct inquiries, requests, issues or feedback, and providing customer service;
Adding you to our mailing lists and sending you emails from time to time;
To provide our products and services, which may include:
Operating the Services, and providing you with any specific services that you have requested;
Creating, maintaining, and otherwise managing your account, profile, or subscription;
Delivering content and product and service offerings relevant to your interests;
Completing the transactions you have requested, processing your payments, and providing you receipts and order updates;
Providing a forum for discussion, asking questions, posting photos and reviews, and sharing experiences;
For marketing and promotional purposes, which may include:
Marketing Turtzed goods and services or goods and services of those of our affiliates, business partners, and other third parties;
Providing you advertising for products and services that may be of interest to you;
Administering sweepstakes, contests, and other similar promotions;
For analytics and personalization, which may include:
Identifying trends and making inferences about you and your interactions with us or our affiliates or our business partners;
Conducting research and analytics to improve our services and product offerings or those of our affiliates and business partners;
Understanding how you interact with the Services, advertisements, and communications with you to determine which of our products or services are the most popular, and to improve App and marketing campaigns;
Personalizing your experience to save you time when you visit the Services, and to customize the marketing and advertising that we show you;
Providing personalized recommendations about our products and services;
For security and fraud prevention, which may include:
Helping maintain the safety, security, and integrity of the Services, databases and other technology assets, and business;
Internal research; technological development and demonstration; and improving, upgrading, or enhancing the Services;
Detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity;
Investigating suspected fraud, harassment, or other violations of any law, rule, or regulation, or the policies for the Services;
To comply with legal obligations, which may include:
Compliance with legal or regulatory obligations, establishing or exercising our rights, and to defending against a legal claim;
Responding to law enforcement requests and as required by applicable law, court order, legal process, or governmental regulation;
Acting in connection with a bankruptcy proceeding or the sale, merger, or change of control of the Turtzed or the division responsible for the services with which your information is associated;
To support core business functions, which may include:
Maintaining records related to business process management, loss and fraud prevention, and to collect amounts owing to us;
Providing and maintaining the functionality of the Services, including identifying and repairing errors or problems; and
For any additional purposes that you specifically consent to.
HOW WE DISCLOSE OR SHARE YOUR INFORMATION
In addition to using your personal information ourselves for the reasons stated above (and as otherwise mentioned in this Privacy Policy), we may disclose your personal information to other affiliates and entities in the following instances:
Service Providers: We may share your personal information with third-party service providers who may use your information to provide us with services, including, but not limited to website hosting providers, infrastructure provision, information technology services, email delivery services, and payment processing. These service providers may have access to personal information that is necessary to perform their functions. To the extent provided by law, they are not authorized by us to use the information for their own benefit.
Corporate Affiliates: We may share personal information with our corporate affiliates, divisions, and subsidiaries, who process personal information on our behalf, where necessary to provide a product or service that you have requested, or in other circumstances with your consent or as permitted or required by law.
Business and Advertising Partners: We may share your personal information with third parties who partner with us to promote products and services, provide marketing and advertisements, conduct data analytics, or use the data for other commercial purposes. We do not control how these third parties use and share your personal information once they receive it. You will need to contact such third parties directly for information about their privacy practices or to exercise any rights you may have (including if you would like to opt-out of marketing messages).
Payment Processors: If you make a payment through the Website, your payment card details are provided to SquareSpace. Please see SquareSpace’s privacy policy at https://www.squarespace.com/privacy to learn more about how they use and protect your information. We do not receive your full credit card or other payment information.
Legal Compliance and to Defend Our Rights: We may disclose personal information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms of Service; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Business Transfers: We may share your personal information and other information with third parties in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of the Turtzed, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the assets transferred may include information about the users of our Services.
Non-Personal Information: We may share non-personal information with unaffiliated third parties, such as business and advertising partners, to improve and enhance your experience using the Services, for our own market research activities, and as otherwise permitted by law.
Please note that if you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.
LINKS TO OTHER SITES AND SOCIAL MEDIA SERVICES
We may create links to other websites that we think may be of interest to you, such as providers of various products and services. We may also provide links that allow you to send or forward a post from the Website through or to third-party social media sites, or other means of electronic communication. We do not endorse any other websites, providers, or services by providing such links, and this Privacy Policy applies only to your use of our Services. We are not responsible for the privacy policies of any websites and services we link to on the Website, and you should read the privacy policies of each site you visit to determine what data that site may collect about you.
The Services may also integrate with social media services. We do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Services, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.
You should be aware that any personal information which you voluntarily include and transmit online in a publicly accessible blog, forum, social network, or otherwise may be viewed and used by others. By using such features, you assume the risk that the personal information provided by you may be viewed and used by third parties.
INTEREST BASED ADVERTISING
Targeted Advertising / Behavioral Advertising: We may ourselves, or with third-party vendors, use your information to deliver targeted advertising to you when you visit our App or other websites. Cookies, and other similar technologies described below may be used in this process. For example, if you are searching for information on a particular product, we or our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising, sometimes called “targeted advertising,” “behavioral advertising,” or “cross-context behavioral advertising,” enables us and our vendors to know about your interests in connection with the delivery of a specific ad. We believe that such advertising is helpful because it allows you to see advertisements that are relevant to your interests.
If you would like to opt out of these interest-based advertisements, please follow the opt-out process described in the section titled Your Choices below.
Cross-Device Matching: We may use your information to help us, or our third-party vendors, determine if you have interacted with our Services across multiple devices and to match such devices. To accomplish this, we may rely on information (including demographic, geographic and interest-based data) from third parties such as data vendors, pursuant to their own privacy policies, or we may use information we collect in conjunction with such third-party data. Based on this data, we may then display targeted advertisements across devices that we believe are associated with each other, and may further provide services to our advertisers to better enable cross-device targeting and analysis. To opt-out of or restrict our use of certain cross-device data, please see the section titled Your Choices below.
HOW WE PROTECT YOUR PERSONAL INFORMATION
Personal information is maintained on our servers or those of our vendors, and is accessible by authorized employees, independent contractors, representatives, and agents as necessary for the purposes described in this privacy policy. We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal information. However, no method of safeguarding information is completely secure, and we cannot guarantee that our safeguards will be effective or sufficient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting info@turtzed.com.
DATA RETENTION
We will retain your personal information for as long as needed to provide you with the services, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregate data, or any other data that constitutes non-personal information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.
YOUR CHOICES
Consistent with applicable law, you may exercise the choices described in this section regarding your personal information and communications from us. You may also have certain additional rights available depending on laws in your state or country of residence, as may be described further below in the Privacy Policy.
Opting Out of Messages or Services: We may send you marketing messages via email. If you receive a marketing message from us, you may unsubscribe from future messages in accordance with our standard unsubscribe process (such as by using the unsubscribe link included in an email). We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of our services may no longer be available to you.
Cookies and Tracking Technologies: If you would like to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of the App or some of its functionality may be affected.
Note that cookie-based opt-outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. Additionally, if you opt out on one of your devices, that opt out may not be effective on all of your devices. However, please be advised that cookie-based opt-outs are not effective on some mobile services.
Some browsers have a Do Not Track (“DNT”) feature that lets users signal to websites that they do not want to have their online activities tracked. Please note that we do respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Interest-Based Advertising: You may opt out of receiving targeted ads from certain data and advertising partners that participate in certain industry self-regulatory programs. The DAA provides a website at www.aboutads.info/consumers with information about how to opt out of targeted advertising from some or all of the DAA’s participating companies. Additionally, the Network Advertising Initiative (“NAI”) offers a website at http://optout.networkadvertising.org/ where you can opt out of interest-based advertising from some or all of the NAI’s members. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. In the event that we perform cross-device matching (as described above), once you have opted out on one device (“Opted-Out Device”), we will not use any new data from the Opted-Out Device to identify you on another device for interest-based advertising purposes, and we will not use data from another device for interest-based advertising purposes on the Opted-Out Device.
For targeted advertisements delivered through mobile apps, users may opt out of certain ads or reset advertising identifiers via their device settings. To learn how to limit ad tracking or to reset the advertising identifier on your iOS and Android device, visit the following links:
You can also install the DAA’s AppChoices app on your device to opt out of targeted advertising by certain providers, and to select system-level advertising preferences on your device (such as “Limit Ad Tracking” on Apple devices, or “Opt-out of Interest-based ads” on Android devices).
Finally, to learn more from the NAI about how to opt out of targeted advertising on mobile devices, you can also visit the following link: https://thenai.org/opt-out/mobile-opt-out/.
CROSS-BORDER DATA TRANSFERS
If you submit personal information to us, that information may be processed in a jurisdiction where privacy laws may be less stringent than those in your country of residence. By submitting your personal information to us, you agree to the transfer, storage, and processing of such information in foreign jurisdictions including, but not limited to, the United States. Please note that personal information transferred to the United States is subject to access by law enforcement.
CHILDREN'S PRIVACY
We do not knowingly collect personal information from children under the age of 13. When we become aware that personal information (or other information that is protected under applicable law) from a child under 13 has been collected, we will use all reasonable efforts to delete such information from our databases. If you believe we might have any personal information from or about a child under 13, please contact us at info@turtzed.com.
EUROPEAN PRIVACY RIGHTS
If you are situated in the European Economic Area, Switzerland, or the United Kingdom, this section applies to our collection, use, and disclosure of your personal data and additional rights you have under applicable law.
Legal Basis. We will only use your personal data, as that term is defined under the General Data Protection Regulation (“GDPR”), when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where you have consented to a certain use of your personal data.
Where we need to comply with a legal or regulatory obligation.
To the extent permitted under applicable laws, we will also process, transfer, disclose, and preserve personal data when we have a good faith belief that doing so is necessary.
Data Controller. Turtzed is the data controller of all personal data collected through our Services.
If you are situated in the EEA, Switzerland, or the UK and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us in the first instance. If you have a complaint, please contact us at info@turtzed.com.
Provision of personal data and failure to provide personal data. Where we need to collect personal data by law or under 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 our services). In this case, we may not be able to provide certain services to you.
Withdrawing Your Consent. If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at info@turtzed.com.
Data Transfer. We may transfer personal data from the EEA, Switzerland, and the UK to the USA and other countries, some of which have not been determined by the European Commission or the UK Secretary of State to have an adequate level of data protection. Where we use certain vendors, we may use specific contracts approved by the European Commission or the UK Secretary of State which give personal data the same protection it has in Europe. For more information about how we transfer your data, please contact us at info@turtzed.com.
Use of Personal Data for Marketing Purposes. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Promotional offers from us: We may use your personal 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 products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have consented to our use of your personal data for marketing purposes.
Data Subject Rights. If you are situated in the European Union, Switzerland, or the UK, under the GDPR, as a data subject, you have the right to:
Request access to your personal data (commonly known as a "data subject access request"). 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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. 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 at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
To exercise your rights under the GDPR, please contact us at info@turtzed.com. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 (“Shine the Light”), California residents may have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal information, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge. However, we do not disclose personal information protected under Shine the Light to third parties for their own direct marketing purposes.
NEVADA PRIVACY RIGHTS
If you are a resident of Nevada, you have the right to opt out of the sale of certain personal information that we have collected (or may collect) from third parties. You can exercise this right by emailing us at info@turtzed.com with the subject line “Nevada Do Not Sell Request.”
CHANGES TO THIS POLICY
We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time, provided that any such modifications will only be applied prospectively. We encourage you to periodically review the App for the latest information on our privacy practices. Your continued use of the App following the posting of any changes to this Privacy Policy means you accept such changes.
CONTACTING US
If you have any questions about our privacy or security practices, please email info@turtzed.com or call us at (305) 504 2200.