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Privacy Policy
Last updated August 10, 2023

The TurboLink Guiding Privacy Principles

TurboLink is a deep linking, in- app gamified growth and attribution analytics platform for app and website developers. We are proud of our commitment to providing our services in a privacy-first way. So we thought it would be helpful to lay out, in plain English, the TurboLink Guiding Privacy Principles that drive how we’ve chosen to design our services with privacy as a top priority. We further describe our privacy practices in the official Privacy Policy below this section, but we hope you’ll find this summary of our principles helpful.

  • We limit the data we collect. We practice data minimization, which means that we take steps to avoid collecting or storing information that we don’t need to provide our services. The personal data that we collect to provide our services is limited to data like IP address, and information derived from resettable cookies (the full list is below in our privacy policy). We do not collect or store information such as names, email addresses, physical addresses, or SSNs to provide our services. Nor do we want to. In fact, our Terms & Conditions prohibit our customers from providing TurboLink with any kind of sensitive end-user information.

  • We will only provide you with data about actual end-user activity on your apps or websites. Customers who subscribe to our linking and analytics platform can only access “earned” cookies or identifiers. This means that an end user must visit a customer’s site before our customer can see the cookie; and an end user must download a customer’s app in order for TurboLink to collect the end user’s device identifier for that customer. In short, the TurboLink services benefit customers who already have seen an end user across their platforms and want to understand the relationship between those web visits and app sessions.

  • We do not rent or sell customer end user data. No TurboLink customer can access another TurboLink customer’s end-user data. And we are not in the business of renting or selling any customer’s end-user data to anyone else. To enable customers to control their end-user personal data, they can request deletion of that data at any time, whether in bulk or for a specific end user. These controls are available to customers worldwide, although we designed them to comply with the CCPA and GDPR requirements.
     

Beyond these principles stated above, TurboLink will continue to find ways to design our services to respect end user privacy. We’re committed to making sure our customers understand how we use data they entrust to us and how they can control it so that they can, in turn, be transparent with their end users.

 

Introduction

TurboLink offers a linking and analytics platform enabling developers of applications (our "Clients")--whether those applications are websites or "apps," and across different types of devices ("Digital Properties")--to improve their end users’ ("Users") cross-application experiences, and to derive additional insights into how their Users download and utilize those applications. TurboLink recognizes and believes that data privacy is important to all Internet users, and therefore we design and operate our services in a privacy-first manner.
 

This Privacy Policy is divided into three parts:

  • Collection and Use of Information from Our Services: This section explains how TurboLink collects and uses information about Users in connection with our linking and analytics products and services (the "TurboLink Services" or the "Services").

  • Collection and Use of Information from Our Website and for Marketing Purposes: This section explains how we collect and use information about our website visitors through our website located at TurboLink (the “Website”), which includes the dashboard we provide to our Clients located at dashboard.branchcn.com. So, if you are a Client using our TurboLink dashboard, this section applies to the data we collect from you. It also explains how we collect information about potential Clients from vendors and other sources to enhance our marketing efforts.

  • Policies Applicable to Both Our Services & Our Website: This section lays out the parts of the TurboLink Privacy Policy that apply to both the Services and to the Website.
     

TurboLink and its Clients have entered into an agreement that governs the provision of Services by TurboLink and their use by Clients ("Agreement(s)"). Such Agreements may contain obligations on the parties with respect to the handling of information processed in the Services. Nothing in this Privacy Policy derogates from such obligations.
 

Collection and Use of Information from Our Services
 
What Information Does TurboLink Collect from Our Services?

Below, we explain what information we collect on behalf of our Clients through the Services, and how we use it. We process information in a way that is relevant for the purpose for which it was collected as described below.
 

The TurboLink Services: Overview

TurboLink provides a variety of Services intended to help Clients understand the use of their Digital Properties by their Users across a wide array of platforms, devices and applications. TurboLink helps Clients by connecting User interactions across siloed applications (email, SMS, web browsers, social platforms, native applications and others), so that Clients understand the multiple steps that a User took to ultimately complete a transaction with the Client. The Client can use this information to better inform marketing and product decisions as well as to provide improved user experiences by using their knowledge of continuity.

TurboLink has no direct relationship with Users. TurboLink’s Services are provided when TurboLink Clients install on their platforms “TurboLink Mechanisms” (including links, pixels, direct platform integrations, etc.) that capture User action on behalf of the Client. Using the information collected from these TurboLink Mechanisms, TurboLink uses a variety of attribution techniques to connect User actions across different channels and platforms. Some of these attribution techniques include a direct pass-through of identifiers from platform to platform, creating and storing identifiers unique to the TurboLink platform to connect User actions and identifiers together, and predictive modeling algorithms using real-time and historical data parameters observed from User interactions where there are no shared identifiers available, as well as using historical connections TurboLink has derived over time using our technology. In some cases, these connections are made without the use of cookies. These techniques help Clients match Users with devices they use, including matching the same User across multiple devices.
 

The key use cases of TurboLink’s Services are:

  • To support Clients in implementing deep linking, which uses TurboLink’s connection information in real time to improve the User experience. For example, if a User clicks on a link in an email or ad to a specific page in a Client’s app, TurboLink helps the User get to that page after they download the app.

  • To report individualized and aggregated analytics metrics about the performance of the Client’s product and marketing initiatives to the Client directly. For example, TurboLink can tell a Client how many Users that downloaded an app or that went to a specific page in an app came from clicking on a specific link and provide corresponding advertising or other identifiers.

  • To assist the Client by presenting real time, targeted messaging to their Users depending on past behavior observed across the Client’s tracked platforms with the purpose of driving more engagement to the Client. For example, TurboLink can use TurboLink Mechanisms to provide a tailored message like a coupon code or special offer in your website to users who have interacted with your app and/or website in the past.
     

TurboLink requires that each Client commit to disclose to TurboLink only information that it has lawfully obtained (including, where necessary, by obtaining consent from Users), and that it has the right to disclose to TurboLink. We strongly discourage Clients from disclosing sensitive User information with us, as such information is not necessary for the provision of the Services, and we prohibit them from providing us with data relating to children under 13 (or, in certain jurisdictions, under 16).

TurboLink collects data through various methods, including:
 

  • When the Client integrates TurboLink’s SDK’s, API’s, pixels, redirect links, JavaScript tags, cookies or similar data collection technologies into their Digital Properties and/or ads;

  • From the various advertising networks and third parties that are used by the Client in connection with the measurement and analysis of Client’s marketing campaigns and that have partnered with TurboLink;

  • When provided voluntarily by the Client as part of the TurboLink account registration process;
     

In the charts below, we summarize the information collected automatically by the Services.

 

Information Collected By TurboLink Links

TurboLink collects the following information from URLs created by the Client (i.e., TurboLink Links) and pixels placed on Client websites. TurboLink Links may be embedded into QR Codes as configured by the Client. Some of this information is considered personal data under applicable law (in other words, information that itself may identify a unique individual or can be linked back to an individual) (“Personal Data”). Since Clients have sole control over their Digital Properties and configuration of the Services, Clients are contractually prohibited from configuring the Services to collect directly identifiable personal information , unless otherwise agreed by TurboLink. If a Client has configured the Services to collect directly identifiable personal information, then TurboLink may receive and process such data. This includes, for example, a Client using an End User’s email address as a Client issued Developer ID.

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Information Collected by TurboLink SDKs

SDKs are Software Development Kits that include code that allows Clients to use the TurboLink Services. The TurboLink Mobile App SDKs, Web SDKs, and Over-the-Top (OTT) SDKs collect the following information when Clients use these SDKs in their applications or websites, some of which may be considered Personal Data under applicable.

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Information Collected By Other Parties

As part of TurboLink’s Services, TurboLink’s Clients may direct certain of their vendors or business partners (such as an ad network or vendor) that have partnered with TurboLink to provide certain Engagement Data to TurboLink on the Client’s behalf in connection with the measurement and analysis of the Client's marketing campaigns.

How Does TurboLink Use Information Collected by Our Services?

Data that TurboLink collects through the Services is processed to provide, maintain, optimize, research and improve the Services we provide our Clients, including to support other TurboLink products and services, to perform anti-fraud protection analysis, develop new products and services, and market products or services; to support the products and services of our Clients; and as permitted or required by applicable law.

We may aggregate and/or de-identify the data we collect through the Services. After data has been aggregated and/or de-identified, TurboLink cannot use it to personally identify an individual. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any other parties, including business partners, Clients, and/or others.

 

Our Clients’ Use of Information

Our Clients may use the information collected via the Services to improve their Users’ app experiences, customize their Digital Properties to Users, and to better understand their app marketing programs and how Users discover their apps. For example, a User may want to disclose information about a hotel that she found in a travel app to a friend. When that User sends her friend a TurboLink link to that hotel, after clicking the link the friend is brought directly to the content relating to that hotel within the app, rather than landing on the app’s homepage and having to search for the hotel. The travel app would also gain insights and analytics as to how the content is being disclosed from its app.

We require that our Clients utilize our Services responsibly and in accordance with our Terms & Conditions. TurboLink is not responsible for the data practices of any of our Clients through the Services or otherwise. Each Client’s practices are subject to each Client’s individual privacy policy. Users should review the privacy policy of each Client to understand how that Client uses User information collected through the Services.

User Choices

TurboLink recognizes a number of consumer choice mechanisms. Due to the nature of the Services, some functionality may be degraded or no longer work as a result if you exercise certain of the opt-outs below.

TurboLink’s Browser Cookie Opt-Out: Our cookie-based opt-out can be accessed by clicking here. This will place a TurboLink opt-out cookie on your browser. Where TurboLink detects the presence of that opt-out cookie, we will no longer read or set cookies (beyond the opt-out cookie itself). 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 computer browser, that opt out will not be effective on your mobile device.

Device-Based Opt-Out: You can submit a request to opt out of the TurboLink Services on a particular device by submitting a request here.

Device Identifiers: To use your device’s privacy settings controls, please visit the privacy settings menu of your device to review and access the privacy controls made available on the device. TurboLink will only be able to collect information from the device as permitted by these settings.

Client App Opt-out Controls: TurboLink‘s SDK Privacy Controls allow Clients to respect granular controls regarding User data. Clients can flag in the TurboLink SDK that a particular User’s data should not be processed by TurboLink, in which case TurboLink will no longer process engagement data on behalf of the Client for that User.

Engagement Builder: TurboLink's Engagement Builder feature may be used to help Clients conduct re-engagement and re-targeting campaigns. We require that Clients using TurboLink’s Engagement Builder feature for such purposes respect User opt-out preferences passed to them by TurboLink.

Collection and Use of Information from Our Website and for Marketing Purposes
What Information Does TurboLink Collect about Website Visitors and Potential Customers?

TurboLink collects information from Website visitors (“you” or “Website Users”) located at branchcn.com ( the “Website”), which includes the dashboard provided to our Clients located at dashboard.branchcn.com. The types of information we may collect and our privacy practices depend on the nature of the relationship you have with us and the requirements of applicable law. Below are the legal bases and some of the ways we collect information and how we use it. We process information in a way that is relevant for the purpose for which it was collected as described below.

What We Collect from Clients that Use the Website

TurboLink collects Personal Data and non-personal data via the Website. For example, when Clients register to use our Services, we ask them to provide us with Personal Data, including first and last name and email address.

Dashboard Information: Information we collect from visitors who register for an account on our dashboard includes the following, some of which is considered Personal Data under applicable law:

Screen Shot 2024-05-06 at 10.22.19 PM.png

When a Client creates an account and uses the Services, TurboLink may collect certain log data, such as IP address from which a Client is connecting to the Services, information related to the device being used to connect to the Services (e.g., browser type and version, device type, OS version) and the features and functions of the Services used by the Client (“Log Data”).

We also require Clients to set up a user ID and unique password for account security purposes. Clients must not disclose their passwords to anyone. Clients also have the option of adding other team members to their account. This account information enables us to set up an account for Clients, to provide the Services, and to otherwise manage Client accounts. We may also use this information to notify Clients about updates to our Services and provide them with promotional emails. We offer a mechanism to opt out from promotional emails as described in the “Opt-Out from Promotional Emails” section below.

Account and Billing Information: To the extent that we charge a fee for the Services, we may also collect limited billing, payment, and contract information from Clients through our payment and contract vendors.

Connection Information with Other Parties: Some features of the dashboard Services allow you to disclose your information through your accounts to other companies such as Facebook and Google. If you choose to connect TurboLink to such services provided by other parties, we may collect information related to your use of those services provided by other parties, such as authentication tokens that allow us to connect to your accounts with those other parties. We will ask you for permission before you authorize our collection of this information. We may also collect information about how you are using the Services to interact with those connected services.

Information from Other Sources: In addition to the information collected through our Website, we or our vendors may obtain and disclose additional information, such as job title or contact information, from other public and non-public sources such as business websites, social networking platforms, or databases maintained by other parties. We use this information to better enable TurboLink to identify and contact businesses that might be interested in engaging our Services, and to gain a better understanding of a potential Client’s business needs.

Communications with TurboLink: Some Website Users may provide Personal Data to TurboLink by sending us an email or filling out an online form on the Website. We use this information to answer their question(s), and may store that information for our record keeping, marketing, and advertising purposes.

Research/Survey Solicitations: From time to time, we may perform research (online and offline) via surveys. We may engage vendors to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Website, various types of communications, advertising campaigns and/or promotional activities.

Cookies, Pixels and Web Beacons: We also collect other data via the Website from Website Users, including Website Users employed by or affiliated with Clients, through cookies and/or web beacons. Such information, some of which may be considered Personal Data under applicable law, may include IP address, pages viewed, browser type, Internet browsing and usage habits, how you browse and navigate the Website, Internet Service Provider, domain name, the time/date of your visit to the Website, the referring URL, and your computer’s operating system. For example, we may collect on a real-time basis information on how you use and navigate the Website.

If your browser settings permit the use of cookies and web beacons when you visit and continue to use the Website, we will collect information through those tools. Cookies are small data files stored on your hard drive by a website and web beacons are electronic images that may be used on our Website or in our emails. Cookies help us improve your experience on the Website as well as our marketing activities. We use cookies to see which areas and features are popular and to count visits to our Website. For more information about cookies and web beacons, please visit https://www.cookiepro.com/knowledgebase/knowledge_categories/cookies-101/. For more information about how to opt-out of cookies and web beacons after you have consented to their use, see the “Opt-out from Website Cookies/Web Beacons” section below.

How Does TurboLink Use the Information Collected?

TurboLink processes the data described in the section above for the following purposes:

  • to provide, maintain, optimize, research and improve the Website;

  • to fulfill your and prospective Clients’ requests for the Services;

  • to send information about the Services including confirmations, invoices, payment processing, technical notices, updates, security alerts, and support and administrative messages;

  • to communicate about products and services offered by TurboLink and TurboLink's selected partners. We receive opt-in consent to send promotional and marketing messages to Website Users where required by applicable law. You can opt-out of receiving these messages at any time as described below in the section titled: “Opt-out from Promotional Emails”;

  • to conduct research;

  • to manage your information and account, to improve and administer our Website, to contact Website Users to answer questions or resolve problems, or to verify your identity;

  • to conduct research to help us to optimally deliver our existing Services or develop new products, processes and services;

  • for ad delivery and reporting purposes and to create data and analytics products and services;

  • to make the Website easier to use by reducing the need for Clients and Website Users to enter information;

  • for other purposes disclosed to you at the time you provide data to us;

  • with your consent; or

  • where TurboLink otherwise has a legitimate interest in collecting the data, such as direct marketing, individual or market research, product improvement, anti-fraud protection, protecting the safety of us, our Website Users, or other parties, or where required by law.
     

Opt-Out & Do Not Track - Your Choice Mechanisms

In some cases, we rely on your consent to process Personal Data about you. In those cases, and where you have consented to TurboLink's processing of your Personal Data in connection with your use of the Website, you may withdraw that consent at any time by following the instructions below. Additionally, before we use Personal Data collected with your consent for any new purpose not originally authorized by you, we will provide information regarding the new purpose and ask for your consent for the new purpose. Where your consent for the processing of Personal Data is otherwise required by law or contract, we will comply with the law or contract. In other cases, we do not rely on your consent to process Personal Data about you (for example, if we have a different legal basis to process that data).
 

Opt Out from Promotional Emails

You can opt-out of receiving promotional emails from us by following the instructions in those emails, or by filling out this form. You can also opt-out of certain categories of emails using this form. If you opt-out using any of these tools, we may still send you non-promotional emails, such as certain updates about your account or updates to our Terms & Conditions and this Privacy Policy and/or use of the Services.
 

Opt Out from Website Cookies/Web Beacons

We will only use cookies consistent with your cookie settings and permissions granted on our Website. If you permit us to use cookies/web beacons as discussed above (“What Information Does TurboLink Collect from our Website”), but would like to opt-out:

  • For all other users, click on “Cookie Consent” at the bottom right-hand corner of our homepage (https://www.branchcn.com/), and click on the opt-out link.
     

Also, you can choose to set your browser to remove cookies and to reject cookies. To exercise the "Do Not Track" settings available on certain web browsers, please visit the privacy settings of your browser. Where TurboLink is able to see that such a selection has been made, we will not use information collected from that device to target advertising on that browser. Dashboard users must use the “Cookie Consent” feature to revoke permission to place cookies. Please note that "Do Not Track" is a different privacy mechanism than the Global Privacy Control browser choice referenced below.

Note that, even if you opt out, we may still collect and use non-personal data regarding your activities on our Website. This also does not opt you out of being served advertising altogether; you will continue to receive generic advertisements.

Vendor Tools/Analytics on the Website

The Website utilizes tracking tools from vendors, which may enable these vendors to analyze our Website traffic for analytics purposes. Some of these vendors may collect information from this Website for retargeting and interest-based advertising purposes. For more information about these forms of ad targeting and to understand your right to opt-out from these practices, please visit http://www.aboutads.info/choices/. All of these tools are hosted by the parties who provide them, and your interactions with these features are governed by the privacy policies of the parties providing them. These tools include, but are not limited to, those below.

Google. We may use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on our Website, and to develop website content. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt-out of Google’s collection and processing of data generated by your use of the Website by going to http://tools.google.com/dlpage/gaoptout.

Mixpanel. We use a service provided by Mixpanel, Inc. (“Mixpanel”) to provide us with analytics data regarding Website Users’ interactions with our Website and Services. You may opt-out of Mixpanel’s automatic retention of data that is collected while using the Services by visiting https://mixpanel.com/optout/. To track opt-outs, Mixpanel uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the Mixpanel opt-out cookie.

Facebook. We may use certain tools offered by Facebook, Inc. (“Facebook”) that enable it to collect or receive information about actions Website Users take on our Website through use of cookies, web beacons and other storage technologies or in order to provide measurement services, targeted ads and other services. For more information regarding the collection and use of such information by Facebook, please see the Facebook Data Policy, available at: https://www.facebook.com/policy.php.

Drift. We use certain tools offered by Drift to power our Website’s live-chat experience. If you provide information about yourself through that live-chat experience, then we may store that information for marketing purposes. Drift may also infer information about the company that you work for you based on your IP address.

Policies Applicable to Both Our Services & Our Website

When does TurboLink Disclose Information?

In addition to the ways described in our Terms & Conditions and this Privacy Policy, TurboLink may also disclose information to others under the following circumstances:

  • With vendors, consultants, global partners, and other parties who assist TurboLink to provide, support, and maintain the Services and the Website and need access to information we collect to do so;

  • With our Clients and their agents, as described in this Policy;

  • To other parties (such as advertising networks or vendors used by our Clients), as directed by our Clients;

  • To comply with laws or to respond to lawful requests and legal process including to meet national security or law enforcement requirements;

  • To investigate, prevent, or take action regarding suspected, or actual, prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person;

  • To protect the rights and property of TurboLink, our agents, Clients, Users, Website Users, and others including to enforce our agreements, policies, and Terms & Conditions;

  • To TurboLink’s subsidiaries and affiliates as necessary to help us provide, support, and maintain the Services; and

  • In connection with or during negotiation of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
     

Updating Your Information and Contact Preferences

We provide Clients with a mechanism to access, review and update information via the dashboard. If you wish to review or update your information, please visit dashboard.branchcn.com and login using the username and password you created. Next, please select “Account Settings” which can be found in the lower left corner of the dashboard screen, then select the “User” tab near the top.

 

We Secure the Information We Collect

Securing the information provided by our Clients and collected through our Website is important to us. TurboLink has implemented industry-standard technical, administrative, and physical safeguards to help protect the information on our servers against unauthorized access, alteration, disclosure or destruction. You are responsible for maintaining the secrecy of your own passwords.

 

TurboLink implements technical and organizational measures designed to protect against unauthorized access, accidental loss, destruction or damage of Client’s data. If you have questions about the security of your personal information, or if you have reason to believe that the personal information that we hold about you is no longer secure, please contact us immediately as described in this Privacy Policy.

Our Data Retention Policy

For our Services: TurboLink retains the information collected by the Services for no more time than is needed to serve the legitimate business need for which it was collected. For example, TurboLink stores the information collected by our Services for the purposes of establishing matches between devices used by Users (see the “What Information Does TurboLink Collect from our Services?” section above) so long as our systems continue to encounter that User. After that User has been inactive for 30 days (or 90 days for specific attribution products), information collected from that User by our Services for the purposes of establishing matches between devices used by will be deleted unless otherwise required by applicable law or otherwise agreed between TurboLink and the Client.

Usage activity logs of Users, which are used for the purpose of providing reporting and analytics to the Client, are stored in an identifiable form for no more than 7 days (or up to 60 days as determined by the Client or for specific fields), after which these logs are removed or pseudonymized. Any and all pseudonymized usage activity logs are deleted after 12 months, unless otherwise required by applicable law or otherwise agreed between TurboLink and the Client.

Aggregated reporting metrics disclosed to Clients are retained (in aggregate and anonymized form) for up to 24 months, unless otherwise required by applicable law or otherwise agreed between TurboLink and the Client.

TurboLink may retain information collected by our Services beyond these periods for fraud prevention, analysis, or response, or to protect the safety of TurboLink, its Clients, Users or the public.

For the Website: We retain the information collected by the Website for no more time than is needed to serve the legitimate business need for which it was collected. For example, we store Personal Data such as email address or billing details for so long as you continue to have a business relationship with TurboLink and for a reasonable time thereafter for record-keeping purposes. If applicable to you, you may ask us to delete that information as described in the “Data Subject Rights” section below or pursuant to your right of erasure as described in the “Data Subject Rights” section below.

Links to Other Websites

The Website and/or Services may contain links to other websites and other websites may reference or link to our Website and/or Services. These other domains and websites are not controlled by TurboLink, and we do not endorse or make any representations about websites or social media platforms operated by other parties. We encourage you to read the privacy policies of each and every website and application that you interact with. We do not endorse, screen, or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

 

International Data Transfers

All information collected via the Website and Services is stored on servers located in the United States. In the process of providing the Services, we may transfer information across borders from other countries or jurisdictions into the United States. Data protection laws in the United States may differ from your country, and the data TurboLink processes may be accessible to law enforcement and national security authorities under certain circumstances. By using the Services, each Client and Website User consents to the transfer and processing of information to the U.S. in accordance with this Privacy Policy. Data transfers from the European Union, United Kingdom, and Switzerland are transferred on the basis of legal mechanisms approved by the European Commission and other relevant authorities for cross-border data transfers, such as Standard Contractual Clauses or the Data Privacy Framework mechanism discussed in the “Data Privacy Framework For EU, UK, and Swiss Personal Data Transferred into the United States” section below.

 

Data Privacy Framework For EU, UK, and Swiss Personal Data Transferred into the United States

TurboLink complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-US Data Privacy Framework (Swiss-U.S. DPF) (collectively, “Data Privacy Frameworks”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data from European Union member countries (including European Economic Area member countries), the United Kingdom, and Switzerland transferred to the United States pursuant to the Data Privacy Frameworks. TurboLink has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom in reliance on the UK Extension to the EU-U.S. DPF. TurboLink has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the policies in this Privacy Policy and data subject rights under the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the applicable Principles (“DPF Principles”) shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification page, please visit https://www.dataprivacyframework.gov/.

TurboLink no longer relies on the EU-U.S. Privacy Shield to transfer data that originated in the EEA or the United Kingdom to the U.S.

The Federal Trade Commission has jurisdiction over TurboLink’s compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

Pursuant to the Data Privacy Frameworks we are obliged to inform EU, UK, and Swiss individuals whose data is being transferred into the United States that we may be required to release Personal Data in response to lawful requests by public authorities including to meet national security and law enforcement requirements.

TurboLink remains liable for the onward transfer of EU, UK, and Swiss personal data to other parties pursuant to the Data Privacy Frameworks unless we can prove we were not a party to the actions giving rise to the damages.

 

Data Subject Rights
California Consumer Privacy Act

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to natural persons who are residents of California. Our CCPA privacy notice is available here.

Rights of Residents of the European Economic Area and United Kingdom

The European General Data Protection Regulation of 2018 (“GDPR”) and equivalent requirements in the United Kingdom including the Data Protection Act 2018 and the United Kingdom General Data Protection Regulation (“UK Data Protection Law”) provides certain rights to residents of Europe. Information on how you can exercise rights under the GDPR and UK Data Protection Law are set forth here.

Lei Geral de Proteção de Dados

Lei Geral de Proteção de Dados (“LGPD”) provides certain rights to residents of Brazil. Information on how you can exercise rights under the LGPD are set forth here.

Our Policy Regarding Children

Services: The TurboLink Services are not directed to children. We require that Clients agree to not send to us data relating to any children under 13 (or, in certain jurisdictions, under 16).

If you believe that we might have any information from or about a child under 13 (and in certain jurisdictions under 16) in violation of applicable law, please contact us so that we can promptly investigate and delete any information that it may have been provided inappropriately as required by law.

Website: The TurboLink Website is not directed to children. We do not knowingly collect through the Website Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register or send any information about yourself to us, including your name, address, telephone number, or email address. No one under 16 may provide any Personal Data to us. In the event that we learn that we have collected any such data from a child under 16 through our Website, we will take reasonable steps to delete that information as quickly as possible.

Contact Us, Questions, Changes to This Privacy Policy

We may change this Privacy Policy at any time in our sole discretion. We will post all changes to this Privacy Policy on this page and will indicate at the top of the page the modified Privacy Policy’s effective date. If you have any questions or suggestions regarding this Privacy Policy, please contact us at info@turbolink.ai

 

Compliance

This Privacy Policy shall be implemented by TurboLink and all its operating divisions, subsidiaries and affiliates. TurboLink has put in place mechanisms to verify ongoing compliance with this Privacy Policy.

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