PRIVACY POLICY
**Last updated April 26, 2025**
This Privacy Notice for TurboLinked ("**we**," "**us**," or "**our**"), describes how and why we might access, collect, store, use, and/or share ("**process**") your personal information when you use our services ("**Services**"), including when you:
* Visit our website at http://www.turbolinked.com, or any website of ours that links to this Privacy Notice
* Engage with us in other related ways, including any sales, marketing, or events
**Questions or concerns?** Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@turbolinked.com.
## SUMMARY OF KEY POINTS
***This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our*** [***table of contents***](#toc) ***below to find the section you are looking for.*****What personal information do we process?** When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about [personal information you disclose to us](#personalinfo).**Do we process any sensitive personal information?** Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.**Do we collect any information from third parties?** We do not collect any information from third parties.**How do we process your information?** We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about [how we process your information](#infouse).**In what situations and with which parties do we share personal information?** We may share information in specific situations and with specific third parties. Learn more about [when and with whom we share your personal information](#whoshare).**How do we keep your information safe?** We have adequate organizational and technical processes and procedures in place to protect your personal information. However, 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. Learn more about [how we keep your information safe](#infosafe).**What are your rights?** Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about [your privacy rights](#privacyrights).**How do you exercise your rights?** The easiest way to exercise your rights is by [submitting a data subject access request](https://app.termly.io/notify/0b54c8b3-39ad-4ece-9089-0243e21f6a57), or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.Want to learn more about what we do with any information we collect? [Review the Privacy Notice in full](#toc).
## TABLE OF CONTENTS
1. [WHAT INFORMATION DO WE COLLECT?]
2. [HOW DO WE PROCESS YOUR INFORMATION?]
3. [WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?]
4. [WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?]
5. [DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?]
6. [HOW DO WE HANDLE YOUR SOCIAL LOGINS?]
7. [HOW LONG DO WE KEEP YOUR INFORMATION?]
8. [HOW DO WE KEEP YOUR INFORMATION SAFE?]
9. [DO WE COLLECT INFORMATION FROM MINORS?]
10. [WHAT ARE YOUR PRIVACY RIGHTS?]
11. [CONTROLS FOR DO-NOT-TRACK FEATURES]
12. [DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?]
13. [DO WE MAKE UPDATES TO THIS NOTICE?]
14. [HOW CAN YOU CONTACT US ABOUT THIS NOTICE?]
15. [HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?]
## 1. WHAT INFORMATION DO WE COLLECT?
### Personal information you disclose to us
***In Short:*** *We collect personal information that you provide to us.*We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.**Personal Information Provided by You.** 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:* names
* email addresses
* passwords
* contact or authentication data
* billing addresses
* debit/credit card numbers
* phone numbers
* job titles**Sensitive Information.** We do not process sensitive information.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.### Information automatically collected***In Short:*** *Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.*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.Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice.The information we collect automatically includes:* ***Log and Usage Data.*** Log and usage data is service-related, diagnostic, usage, and performance information 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 in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps")), and hardware settings.
* ***Device Information.*** We collect device information such as your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device information may include your device type, operating system, device ID, unique device identifiers, application identification number, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system, and system configuration information.
* ***Location Information.*** We may collect information about your device's location, which can be either precise or imprecise. The amount of location 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. However, if you choose to opt out, you may not be able to use certain aspects of the Services.## 2. HOW DO WE PROCESS YOUR INFORMATION?***In Short:*** *We process your personal information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your personal information for other purposes with your consent.***We process your personal information for a variety of reasons, depending on how you interact with our Services, including:*** **To facilitate account creation and logon process.** If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed those third parties to share with us to facilitate your account creation and logon process for the performance of the contract.
* **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.**
* **To respond to legal requests and prevent harm.** If we receive a subpoena or other legal request, we may need to inspect the personal information we hold to determine how to respond.
* **To fulfill and manage your orders.** We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
* **To administer prize draws and competitions.** When you participate in prize draws and competitions, we use your information to administer these events.
* **To deliver targeted advertising to you.** We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
* **To identify usage trends.** We may process information about how you use our Services to better understand how they are being utilized so we can improve them.
* **To determine the effectiveness of our marketing and promotional campaigns.** We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
* **To save or protect user's device.** We may process your information when necessary to save or protect a vital interest of yours or of another natural person, such as in situations involving potential harm.## 3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?***In Short:*** *We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.*The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:* **Consent.** We may process your information if you have given us your specific consent for a specific purpose.
* **Legitimate Interests.** We may process your information when it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in this notice, such as for marketing, improving our Services, and preventing fraud.
* **Performance of a Contract.** We may process your personal information when it is necessary to fulfill our contractual obligations to you, including providing our Services, or at your request prior to entering into a contract.
* **Legal Obligations.** We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
* **Vital Interests.** We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of you or another person.In legal terms, we are generally the "**data controller**" of the personal information described in this Privacy Notice, since we determine the purposes and means of the processing of personal information.## 4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?***In Short:*** *We may share information in specific situations and with specific third parties.*We may need to 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.
* **When we use Google Maps Platform APIs.** We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). We will use your information in accordance with their Terms of Service.
* **Affiliates.** We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
* **Business Partners.** We may share your information with our business partners to offer you certain products, services, or promotions.
* **Other Users.** When you share personal information or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly distributed outside our Services in perpetuity. Similarly, if you interact with other users and register for our Services through a social network (such as Facebook), your social network contacts will see your name, profile photo, and descriptions of your activity.## 5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?***In Short:*** *We may use artificial intelligence (AI) to provide certain features in our Services.*We may use AI tools and technologies to enhance the functionality and user experience of our Services. These AI systems may process and analyze user data to provide features such as personalized recommendations, content generation, and automated responses.When we use AI, we are committed to doing so responsibly and transparently. We aim to ensure that our AI systems are fair, accurate, and do not infringe on your privacy rights. We will provide clear information about when and how AI is used in our Services, and where applicable, offer you choices regarding your interaction with AI features.## 6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?***In Short:*** *If you choose to register or log in to our Services using your social media account, we may have access to certain information about you.*Our Services may offer you the ability to register and log in using your third-party social media account details (like your Facebook or Google logins). 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, and other information you chose to make public on such social media platform.We will use the information we receive only for purposes that are described in this privacy notice or that are otherwise made clear to you on the 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.## 7. HOW LONG DO WE KEEP YOUR INFORMATION?***In Short:*** *We keep your personal information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.*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 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 it, 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.## 8. HOW DO WE KEEP YOUR INFORMATION SAFE?***In Short:*** *We aim to protect your personal information through a system of organizational and technical security measures.*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.## 9. DO WE COLLECT INFORMATION FROM MINORS?***In Short:*** *We do not knowingly solicit data from or market to children under 18 years of age.*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 we have collected personal information from a user under 18 years of age, 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 hello@turbolinked.com.## 10. WHAT ARE YOUR PRIVACY RIGHTS?***In Short:*** *In some regions (like the European Economic Area (EEA) and the United Kingdom (UK)), you have certain rights under applicable data protection laws.*In some regions (like the EEA and the UK), you have certain rights under applicable data protection laws regarding your personal information, such as the right to **access** and **erase** your personal information, to **restrict** its processing, to **object** to processing, and if applicable, the right to data **portability**. In certain circumstances, you may also have the right **not to be subject to a decision based solely on automated processing**, including profiling, that produces legal effects concerning you or similarly significantly affects you.### Your rights regarding your Personal DataYou may withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing based on consent before its withdrawal.If you are located in the EEA or UK 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](http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm).If you are located in Switzerland, the contact details for the data protection authorities are available here: [https://www.edoeb.admin.ch/edoeb/en/home.html](https://www.edoeb.admin.ch/edoeb/en/home.html).### 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 and reject cookies. If you choose to remove or reject cookies, this could affect certain features or services of our Services.## 11. CONTROLS FOR DO-NOT-TRACK FEATURESMost 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 notice.## 12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?***In Short:*** *If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you have specific rights regarding your personal information.*State privacy laws grant their residents specific rights regarding their personal information. If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you have the following rights:* **The right to know** and **the right to access**. You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you.
* **The right to correct** inaccuracies in your personal information.
* **The right to request deletion** of your personal information.
* **The right to opt out of the sale** of your personal information. Please note that we do not sell your personal information.
* **The right to opt out of targeted advertising.**
* **The right to opt out of profiling** in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
* **The right to nondiscrimination** for exercising any of your consumer rights, including the right not to be denied services or charged different prices or rates for goods or services.### Exercising your rightsYou can exercise these rights by [submitting a data subject access request](https://app.termly.io/notify/0b54c8b3-39ad-4ece-9089-0243e21f6a57) or by contacting us at hello@turbolinked.com.We will respond to your request within the timeframes specified under applicable law.### Verification processWhen we receive your request, we need to verify your identity to ensure your personal information is not disclosed to anyone else. To verify your identity, we may request you to log in to your account if you have one with us, or we may ask for additional information to match with the information we already have about you. Depending on the sensitivity of the personal information you are requesting, we may require further verification from you. We will use all information you provide in your request only to verify your identity.### Right to appealIf we decline your request and you are a resident of Colorado, Connecticut, or Virginia, you have the right to appeal our decision. Please contact us at hello@turbolinked.com with information about your appeal.## 13. DO WE MAKE UPDATES TO THIS NOTICE?***In Short:*** *Yes, we will update this notice as necessary to stay compliant with relevant laws.*We may update this privacy notice 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 notice, 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 notice frequently to be informed of how we are protecting your information.## 14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?If you have questions or comments about this notice, you may contact us by email at hello@turbolinked.com or by post to:TurboLinked
[Your Address Here]
Houston, Texas [Your Zip Code]
United States## 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. To request to review, update, or delete your personal information, please [submit a data subject access request](https://app.termly.io/notify/0b54c8b3-39ad-4ece-9089-0243e21f6a57).