Welcome to Testudo. This Privacy Notice explains how Testudo Global, Inc. (“Testudo”, “we”, “us”, or “our”) collects, uses, discloses, and otherwise processes personal data in connection with Testudo, as well as any other specific product, service, or application that references or links to this Privacy Notice (the “Services”).
This Privacy Notice does not address our privacy practices relating to Testudo job applicants, employees and other personnel, nor data that is not subject to applicable data protection laws (such as deidentified or publicly available information). This Privacy Notice is also not a contract and does not create any legal rights or obligations not otherwise provided by law.
Our Collection and Use of Personal Data
The categories of personal data we collect depend on how you interact with us and our Services. For example, you may provide us your personal data directly when you register for an account.
We also collect personal data automatically when you interact with our websites and other services and may also collect personal data from other sources and third parties.
Personal Data Provided by Individuals
We collect the following categories of personal data individuals provide us:
- Contact Information, including first and last name, email address, and communication preferences. We use this information primarily to fulfill any requests or transactions, and to communicate with you directly and to send you marketing communications in accordance with your preferences.
- Feedback and Support Information, including the contents of messages sent through forms, email addresses, or other contact information we make available to users (including through the use of automated tools provided by us or our third-party providers). We use this information primarily to investigate and respond to your inquiries, to communicate with you, and to improve our Services.
If you choose to contact us, we may need additional information to fulfill the request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the request we receive or personal data we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.
Personal Data Automatically Collected
We, and our third-party partners, automatically collect information you provide to us and information about how you access and use our Services when you engage with us. We typically collect this information through the use of a variety of our own and our third-party partners’ automatic data collection technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, and embedded scripts. Information we collect automatically about you may be combined with other personal data we collect directly from you or receive from other sources.
We, and our third-party partners, use automatic data collection technologies to automatically collect the following data when you use our Services or otherwise engage with us:
- Information About Your Device and Network, including the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID).
- Information About the Way Individuals Use Our Services and Interact With Us, including how frequently you access our Services, whether you open emails or click the links contained in emails, whether you access our Services from multiple devices, and other browsing behavior and actions you take on our Services (such as the pages you visit, the content you view, videos you watch, the communications you have through our Services, and the content and links you interact with).
All of the information collected automatically through these tools allows us to improve your user experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Services, to offer communications features, and to improve the effectiveness of our Services, offers, communications and user service.We may also use this information to:(a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Services.
For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to the Your Privacy Choices section below.
Personal Data from Other Sources and Third Parties
We may receive the same categories of personal data as described above from the following sources and other parties:
- Other Users: We may receive your personal data from our other users. For example, a user may provide us with your contact information as a part of a referral.
- Service Providers: Our service providers that perform services on our behalf, such as analytics providers, collect personal data and often share some or all of this information with us.
- Inferences: We may generate inferences or predictions about you and your interests and preferences based on the other personal data we collect and the interactions we have with you.
Additional Uses of Personal Data
In addition to the primary purposes for using personal data described above, we may also use personal data we collect to:
- Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations or to deliver the services requested;
- Manage our organization and its day-to-day operations;
- Communicate with you, including via email and chat;
- Facilitate the relationship we have with you and, where applicable, the company you represent;
- Request you provide us feedback about our product and service offerings;
- Address inquiries or complaints made by or about an individual in connection with our Services;
- Create and maintain accounts for our users;
- Verify your identity;
- Administer, improve, and personalize our Services, including by recognizing you and remembering your information when you return to our Services;
- Develop, operate, improve, maintain, protect, and provide the features and functionality of our Services;
- Identify and analyze how you use our Services;
- Infer additional information about you from your use of our Services, such as your interests;
- Create aggregated or de-identified information that cannot reasonably be used to identify you, which information we may use for purposes outside the scope of this Privacy Notice;
- Conduct research and analytics on our user base and our Services, including to better understand the demographics of our users;
- Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
- Test, enhance, update, and monitor the Services, or diagnose or fix technology problems;
- Help maintain and enhance the safety, security, and integrity of our property, products, services, technology, assets, and business;
- Defend, protect, or enforce our rights or applicable contracts and agreements (including our Terms of Service), as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
- Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Testudo and others;
- Facilitate business transactions and reorganizations impacting the structure of our business;
- Comply with contractual and legal obligations and requirements;
- Fulfill any other purpose for which you provide your personal data, or for which you have otherwise consented.
Our Disclosure of Personal Data
We disclose or otherwise make available personal data in the following ways:
- To Service Providers: We engage other third parties to perform certain services on our behalf in connection with the uses of personal data described in the sections above. Depending on the applicable services, these service providers may process personal data on our behalf or have access to personal data while performing services on our behalf.
- In Connection with a Business Transaction or Reorganization: We may take part in or be involved with a business transaction or reorganization, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose, transfer, or assign personal data to a third party during negotiation of, in connection with, or as an asset in such a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal data may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets.
- To Facilitate Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights and property of our agents, customers, users, and others, including to enforce our agreements, policies, and terms of use;
- to detect, suppress, or prevent fraud;
- to reduce credit risk and collect debts owed to us;
- to protect the health and safety of us, our users, or any person; or
- as otherwise required by applicable law.
- With Your Consent or Direction: We may disclose your personal data to certain other third parties or publicly with your consent or direction. For example, with your permission, we may post your testimonial on our websites.
Your Privacy Choices
The following privacy choices are made available to all individuals with whom we interact.
Email Communication Preferences
You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in any of our email communications. Please note you cannot opt-out of service-related email communications (such as, account verification, transaction confirmation, or service update emails).
Automatic Data Collection Preferences
Certain of our Services may provide you the ability to adjust your preferences regarding our use of automatic data collection technologies. [For example, there is a “Cookie Preferences” manager linked in the footer of our websites that allows you to adjust your preferences regarding certain automatic data collection technologies on the specific website you are visiting for the specific device and browser you are using at that time (which means you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting).]
Where a Testudo-specific preference manager or privacy setting is not available, you may be able to utilize third-party tools and features to further restrict our use of automatic data collection technologies. For example, (i) most browsers allow you to change browser settings to limit automatic data collection technologies on websites, (ii) most email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies, and (iii) many devices allow you to change your device settings to limit automatic data collection technologies for device applications. Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our Services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.
Partner-Specific Preferences
Certain of our third-party providers and partners offer additional ways that you may exercise control over your personal data, or automatically impose limitations on the way we can use personal data in connection with the services they provide:
- Device-Specific / Platform-Specific Preferences: The device and/or platform you use to interact with us (such as your mobile device or browser), may provide you additional choices with regard to the data you choose to share with us. For example, many mobile devices allow you to change your device permissions to prevent our products and services from accessing certain types of information from your device (such as your contact lists). Please refer to your device provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.
- Google Analytics: Google Analytics allows us to better understand how our users interact with our Services. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website here: www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Add-On here: https://tools.google.com/dlpage/gaoptout/.We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://myadcenter.google.com/personalizationoff?sasb=true&ref=ad-settings.
Third-Party Websites and Services
Our Services may include links to third-party websites, plug-ins, applications and other services. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to any personal data practices of third parties. To learn about the personal data practices of third parties, please visit their respective privacy notices.
Updates to This Privacy Notice
We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on this website or our other platforms, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
Contact Us
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to george.lewin-smith@testudo.co.
Nevada Residents
If you are a resident of the state of Nevada in the United States, you have the right to opt out of the sale of your personal data. Although we do not currently sell personal data of Nevada residents (as defined under Nevada law), you may submit a request to opt-out of the sale of your personal data by emailing to info@testudo.co.