Privacy Policy – Turtle.com 

Introduction
At www.turtle.com we consider the privacy of our visitors to be extremely important.
This Privacy Policy governs the manner in which Turtle collects, uses, maintains and discloses information collected from users (known as “Users”) of our website. This Privacy Policy applies to the Sites and all products and services offered by Turtle. When this policy mentions “Turtle,” “we,” “us,” or “our,” it refers to the Turtle Company that is responsible for your information under this Privacy Policy.
This Privacy Policy also applies to the Payment Services provided to you by Turtle Payments pursuant to the Payments Terms of Service (“Payments Terms”). Turtle shall be the Data Controller of your information related to the Payment Services depending on your preferred Payment Method.
Types of Information
There are two types of information collected and stored by Turtle:

Personal Identification Information (PII)
II. Automatically Collected Data

Personal Identification Information (PII)
Personally identifiable information (“PII”) is information that can be used to identify an individual person. As you use, access, or register for the Service, you may be asked to submit certain Personal information. If you choose to provide us with personal information, you are consenting to the transfer and storage of that information on our servers. Added such information shall be posted on Turtle.com and will be publicly available. We collect and store the following personal information:



Account Information - When you sign up for a Turtle Account, we require certain information such as your name, email address, passport info and date of birth.
Profile Information - To use certain features within the Turtle Platform, we may also ask you to complete a profile, which may include your address, phone number, and gender. Certain parts of your profile (like your profile picture, first name, and description) are a part of your public profile page, and will be publicly visible to others.
Other Authentication-Related Information - To help create and maintain a trusted environment, we may collect identification (like a photo of your government-issued Passport) or other authentication information.
Payment Information - We collect your financial information (like your bank account or credit card information) when you use the Payment Services to process payments.
Communications with Turtle and other Members - When you communicate with Turtle or use the Turtle Platform to communicate with other Members, we collect information about your communication and any information you choose to provide.
Other Information - You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Turtle Account, respond to surveys, post to community forums, participate in promotions, or use other features of the Turtle Platform

NOTE - We will collect personal identification information from users only if they voluntarily submit such information to us. Users can always refuse to supply personal identification information, but this may prevent them from engaging in certain activities related to the site.
Automatic Data Collection/Non Personal Identification Information
Turtle uses automatic data collection technology (when a user engages with the Service) to record information that identifies your computer, to track your use of the Service, and to collect certain basic information about you and your usage habits. Following information will be collected automatically:

Usage Information: We collect information about your interactions with the Turtle platform, such as the pages or other content you view, your searches, transactions you have made, and other actions on the Turtle platform.
Location Information: When you use certain features of the Turtle Platform, certain different types of information maybe collected about your general location (e.g. IP address, zip code) or more specific location information (e.g. precise location from your mobile GPS). Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu.
Log Data: We automatically collect log information when you use the Turtle Platform, even if you have not created a Turtle account or logged in. That information includes, among other things: IP address, access times, hardware and software information, device information, device event information (e.g., crashes, browser type).
Transaction Information. We collect information related to your transactions on the Turtle Platform, including the date and time, amounts charged, and other related transaction details.
Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. Our cookie policy is described below.

 
 
 
Use of PII
Any PII you provide to Turtle may be used by Turtle for the following purposes:

Provide, Improve, and Develop the Turtle Platform
II. Create and Maintain a Trusted and Safe Environment
Provide, Improve, and Develop the Turtle Platform


To protect the safety of Turtle users.
Verify or authenticate information/identifications provided by users.  
To enable access and use of the Turtle Platform.
To enable users to communicate with other members/account holders.
Operate, and improve the Turtle Platform and experience, by performing analytics and conducting research.
Personalize or customize user experience by, among other things, ranking search results or showing ads based on a search, search history, and preferences.
Enable you to access and use the Payment Services.
Provide customer service.
Send you service or support messages, such as updates, security alerts, and account notifications.
If you provide us with your contacts’ information, we may use and store this information:
(i) send requests for references, (ii) for fraud detection and prevention, and (iii) for any purpose you authorize at the time of collection.


Create and Maintain a Trusted and Safer Environment


Resolve and mediate disputes between any of the users
Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
Conduct investigations and risk assessments.
Conduct checks against databases and other information sources.
Comply with our legal obligations.

Protection of Information
Turtle adopt an appropriate and commercially reasonable security measures to protect against unauthorised access, alteration, disclosure or destruction of personal information, username, password, and other data stored on the sites.
Sensitive and private data exchange between users happens over a SSL secured communication channel and is encrypted and protected with digital signatures.

However, no security system is infallible. Ergo Turtle cannot guarantee the security of its databases, nor can it guarantee that your PII will not be intercepted, copied, accessed, or stolen.
NOTE :- If Turtle or substantially all of its assets are acquired, the information that Turtle has collected, including PII, may be transferred to the acquiring company along with other business assets.
Sharing of information
Please note the following in relation to sharing of stored and collected information

General Rule

As a general rule we do not sell, trade, or rent users’ personal identification information to others. We may share information with search engines so that the content you provide in feedback can be indexed. Our info sharing policy is solely based on your consent subject to very limited exceptions.

Safety and Compliance with Law

We may use and share the information about you to safeguard the security of our site, to protect Turtle and our users or the public from illegal activities or harm.
If we are of the opinion that disclosure is reasonably necessary to adhere to any regulation, legal process, applicable law or requests originating from governments (including taxing authorities) and to administer our “Terms and Conditions”, such disclosure of information will be done.

Service Providers

Turtle, like many businesses, sometimes hires third parties to perform certain business-related functions I.E ; mailing information, courier services, maintaining databases, hosting services, and processing payments.
When Turtle employs a third party to perform a function of this nature, we provide them with the information that they need to perform the specific function, and such info may include PII of users. However Turtle requires such third parties to maintain the confidentiality of such information and use such information only as necessary to provide Turtle with designated services.

Turtle Payments.

Turtle may share your personal information to the Payment Gateway service provider. Such info will include: (i) Credit/Debit card details (ii) Bank account details (iii) Transaction History.

Social Media tools and Third Party privacy policies

The site offer third party social sharing features which allow users to share actions and information with other websites, the general public, user community and/or the third-party operating the third-party site. You should consult the respective privacy policies of the third-parties that provide these social sharing features for more detailed information on their practices as well as for instructions about how to opt-out of such practices.
 
Cookie Policy
Turtle uses cookies and similar technologies to improve the user experience of our Services. Cookies are files that are placed on your computer when you access websites or online services. Turtle uses cookies to recognize you when you access the Service. Among other things, they allow us to store and recover information about your browsing habits and your computer, and help us to improve the Service. While you may disable the usage of cookies through your browser settings, Turtle’s service is not configured to respond to any “Do Not Track signal”. Therefore existence of any “Do Not Track signal” will not affect our use of cookies and other technologies to collect and store your Information. We may also allow our business partners to use these tracking technologies on the Turtle Platform, or engage others to track your behavior on our behalf.
Your privacy preferences

Privacy Options: You can change your privacy settings and set the information you share with others by logging into your profile and selecting your “Privacy options” (located in “My Account” - Privacy settings”)


Account Info: You can update your profile or deactivate your account whenever you wish by logging in and choosing the relevant option. Even after deactivating your account, certain information may be retained when required by law and to protect Turtle interests and users’ safety.

Changes to this Privacy Policy
Turtle reserves the discretion to update this Privacy Policy at any time. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of any modifications made.