Privacy Policy

Last Updated: March 2022

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‍Thank you for choosing to be part of our community at Turtle Technologies, Inc. ("Company", "we", "us", "our"). The Company understands and appreciates that users are concerned about their privacy and about the confidentiality and security of information we may obtain about them online. We want you to understand the steps we have taken to safeguard the information we receive when you visit our website https://www.turtleos.com/ (the "Website"), use our mobile application (the "App") and/or use any of our services (collectively, with the Website and App, the "Services").

We are committed to protecting your personal information and your right to privacy. Please read the following privacy policy (the “Privacy Policy”), carefully as we seek to explain to you what information we collect, how we use it and what rights you have in relation to it. Your use of the Services is subject to your acceptance of this Privacy Policy and the Terms of Use. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Services immediately.

If you have any questions or concerns about this Privacy Policy, or our practices with regards to your personal information, please contact us at support@turtleos.com.
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‍1. What information do we collect?

We collect personal information that you voluntarily provide to us in several ways from different parts of the Services, including when you (i) register to use the Services, (ii) participate in and use the Services and (iii) otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following:

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(1) Personal Information Provided by You

Personal Information. We collect names; email addresses; debit/credit card numbers; contact or authentication data; and other similar information.
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy.
Google Login Data. We provide you with the option to register with us using your existing Google account details, so we may collect the login data of your Google account if you choose to register with such account.

Please be advised that all personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

(2) Information automatically collected

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. The information that is automatically collected includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information that our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity when using our Services, such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take (including which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings.
Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Please note, however, if you choose to opt out, you may not be able to use certain aspects of the Services.

(3) Information collected through our App

If you use our App, we also collect the following information:

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, files, photos, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Data. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID and information about the features of our App you accessed.
Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

The information collected through our App is primarily for the maintenance of the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.

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2. How do we use your information?

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. It is important to stress that we do not sell your data.

We use the information we collect or receive:

To facilitate account creation and logon process. If you link your account with us to a third-party account (i.e., your Google account), we will use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
To post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at support@turtleos.com and be sure to include your name, testimonial location, and contact information.
To request feedback. We may use your information to request feedback and to contact you about your use of our Services.
To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.
To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or other obligations that arise in connection with our contract. We may use your personal information to enforce the contractual terms, policies or purposes legitimately associated with our rendering of the Services, or to facilitate our compliance with legal, regulatory or contractual requirements.
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.
To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time.‍
To deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

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‍3. Will your information be shared with anyone?

We may process or share your data that we hold based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests, including operating and maintaining the security of our Services and protecting our rights and properties.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).‍
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data on our behalf about how you interact with our Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

Specifically, we only share and disclose your information with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact support@turtleos.com.

- Cloud Computing Services: Amazon Web Services (AWS) and Google Cloud Platform
- Functionality and Infrastructure Optimization: Heroku
- Functionality and Infrastructure Optimization: Heroku
- Invoice and Billing: Stripe
- User Account Registration and Authentication: Google Sign-In
- Web and Mobile Analytics: Google Analytics, Mixpanel
- Website Performance Monitoring: Sentry
- Website Testing: Optimizely
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Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as your Google account), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

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‍‍4. Do we use cookies and other tracking technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice as provided below.

‍Cookie Notice

This Cookie Notice applies to our Services and explains how we use cookies and similar technologies to recognize you when you use or access our Services.

What Are Cookies?

Cookies are small files that are placed on your device when you visit a website. They are widely used for maintaining a website or to improve the efficiency of a website. Website owner also use cookies to provide reporting information.

In addition, cookies may also be used for supplementary purposes, meaning that when we use certain cookies, such cookies are not used in a way that is necessary for the functioning of our Services. We will seek your consent to place such cookies on your device whenever using such cookies are required by laws. Where required by applicable law, we will obtain your consent before we place any cookies on your device that are not strictly necessary for the functioning of our Services.

How First Party Cookies Are Different from Third Party Cookies?

First party cookies means the cookies that we set and place on your device for using or accessing our Services. As to third party cookies, those are the cookies that enable third party features or functionality to be provided on or through our Services, such as advertising.

Why Cookies are Used for Our Services?

We use first party cookies to ensure the operation, efficiency and availability of our Services. We thus deem such first party cookies as the necessary component for our rendering of Services. On the other hand, other first and third party cookies allow us to understand the interests of the users and help us improve the Services. Below you can find details of the cookies that we use in connection with our Services:

“Strictly necessary” cookies are the cookies that are required for our Services. In most cases such cookies are set in response to your actions. For example, when you perform any one of the following actions, the cookies will respond: (a) account log-in, (b) subscription for Services and (c) billing or payment.
“Performance” cookies are first party cookies that help us to collect information about how visitors use our Services and allow us to improve. While performance cookies will remain on your device after you close your browser, we only use the information collected by these cookies in aggregated form, meaning that information relating to you or your device will NOT be identified or used separately or independently. Where permitted by applicable law, we will deploy first party performance cookies automatically when you use our Services.
“Targeting” cookies means the third party cookies that are used to make advertising messages more relevant to you. The targeting cookies do not store personal information, but they are capable of identifying your browser and internet device. Please note that advertisement would still be displayed in the event you denied the targeting cookies to be placed.
“Functionality” cookies means the cookies that help our App or Website to recognize and “remember” your information. Examples of the use of such cookies are automatic fill-ins for online forms. The functionality cookies do not track your activity when you are using other websites, and, if you do not allow these cookies to be placed, some features or functions of the App or Website might not work properly.

What About Other Tracking Technologies, Like Web Beacons?

In general, tools other than cookies might also be used to recognize or track visitors to a website. Certain technologies like web beacons (also called "tracking pixels" or "clear gifs") are often used for tracking purposes. Such technologies are tiny graphics files that contain a unique identifier, by which a website can ascertain its visitors when the visitors use the website or open an e-mail sent by the website. The tracking technologies are mostly used for following purposes: (i) to monitor the traffic patterns of users, (ii) to ascertain whether the user comes from an online advertisement which is shown on a third-party website, (iii) to deliver or communicate with cookies, (iv) to assess e-mail marketing activities, or (v) to improve website performance. These technologies generally require cookies in order to function properly, so any rejection or blocking of cookies might impair the functionality of such technologies.

How do We Use Google Analytics for Our Services?

We use Google Analytics to assess how our Website and App are used by our users. In general, Google Analytics would place first party performance and targeting cookies through our Website or App so that it could recognize such cookies when you visit or access other websites or applications. Google Analytics’ first party performance and targeting cookies will generate your activities or personal information (such as your IP address), and such information, once generated, will be transmitted to and stored by Google on its servers located in the United States. Google will compile the information collected through those cookies and provide a report to us describing your use of our Website or App or other activities associated with such use.

How Can I Control Cookies?

You can decide whether to accept or reject certain or all cookies by changing your web browser settings. In general, you can find out what cookies are placed on your device and delete or block them with the control features provided by browsers. If you choose to delete or block some or all of the cookies placed on your device, you may still use our Website or App, but our Services might be restricted due to such rejection or blocking. Additionally, your preference will be lost when cookies are deleted or rejected, and such loss of saved preference would include your preference to opt-out from cookies because opting out would require an opt-out cookies to function properly. For more information on how to delete or block cookies, please visit your browser’s help menu.

How Often Will You Update This Cookie Notice?

We may update this Cookie Notice from time to time so long as we deem such update adequate or necessary. We may also update this Cookie Notice for changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore revisit this Cookie Notice regularly to stay informed about our use of cookies and related technologies. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. The date shown at the top of this Privacy Policy is the date on which this Cookie Notice and the Privacy Policy were last updated.

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‍5. How do we handle your social logins?

Our Services offers you the ability to register and login using your third-party social media account details (e.g., your Google or Apple account). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platform

We will use the information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

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‍‍6. Is your information transferred internationally?

We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information in other countries.

If you are a resident in the European Economic Area, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.

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‍7. How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

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‍‍8. How do we keep your information safe?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

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‍9. Do we collect information from minors?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@turtleos.com.

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‍10. Your privacy rights and GDPR notice

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(1) General Rights

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can email us at support@turtleos.com. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you can email us at support@turtleos.com.

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(2) GDPR Notice

This section is for people who are located in the European Economic Area (“EEA”). Our processing of personal data of people who are in the EEA is governed by the General Data Protection Regulation (the “GDPR”), and GDPR requires us to provide certain information to you about your personal data.

Data Controller

We are the data controller for the Services, including our App and Website.

Purpose of Processing Your Information

We collect and process your personal information in accordance with the purposes that we enumerated in Section 2 of this Privacy Policy.
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Legal Basis for Processing Your Information

We process your personal information on the basis of consent, which you may withdraw anytime by contacting us at support@turtleos.com. We may also process personal information on other bases permitted by the GDPR and applicable laws, such as when the processing is necessary for complying with certain legal or regulatory obligations.

Categories of Personal Information

We will process the information that you voluntarily provide with us. The information may include, without limitations, your name, business title, name of employer, email address, country, and telephone number. We will also collect and process information through cookies, but we will seek your consent when placing cookies that are not strictly necessary for our Services, and you can revoke your consent at any time by contacting us at support@turtleos.com.

Who Might Receive Your Personal Information

We work with third party service providers to operate, maintain or manage our Services. We have entered into contracts with the third party service provider to covenant that what they can do with your personal information should be compliant with applicable laws. If you would like specific information about the third party service provider with whom we share your information, please contact us at support@turtleos.com and we will provide that information to you.

Transfers of Personal Information Outside of EEA

We are based in the United States of America. When you provide personal information to us, we request your consent to transfer that personal information to the USA. We will safeguard your personal information by treating it in accordance with this GDPR privacy notice. We will take adequate steps to protect your privacy and implement reasonable security measures to protect your personal information in storage.

How Long We Retain Your Personal Information

As stated in Section 7 of this Privacy Policy, we will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

What Are Your Rights

You have the rights (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. Your rights may be subject to certain limitations under the GDPR. If you wish to exercise the rights listed in this paragraph, or if you have any concerns about our processing of your personal data, please contact us at support@turtleos.com. We will consider and act upon any request in accordance with applicable data protection laws.

Filing a Complaint

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
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No Obligations to Provide Personal Information

You are under no statutory or contractual obligations to provide personal information to us.

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11. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

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‍‍12. Do California residents have specific privacy rights?

Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

(1) Rights to Access Your Personal Information, Know What Personal Information We Collect and with Whom We Share

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about (i) what information we collected from you, and (ii) categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please contact us at support@turtleos.com. We will respond to your request as promptly as we can.

(2) Right to Deletion

Unless a certain exception exists, you have the right to request deletion of your personal information. Examples of exceptions include when the information is required for us to (i) meet legal obligations, (ii) detect fraud, (iii) investigate violation of the terms and conditions of our Services, or (iii) fix security issues, We will delete your personal information upon your request and within a reasonable period of time unless an exception applies. We will direct our service providers to delete your personal information if you so request.

(3) Non-Discrimination

Whenever you make a request to exercise your rights, we will not hold it against you.

(4) Rights for Users under 18 Years of Age

If you are under 18 years of age, reside in California, and have a registered account with a Service, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us at support@turtleos.com, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

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‍‍13. Do we make updates to this notice?

Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

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14. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at support@turtleos.com.

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‍15. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit: support@turtleos.com. We will respond to your request within 30 days.

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Any questions? Contact support@turtleOS.com.