This Privacy Notice applies to consumers who reside in states that have adopted consumer privacy laws and supplements the Privacy Statement, to the extent applicable. Because of differences in certain state laws, this supplement is broken into two sections, California (CCPA) Specific Notices, applicable to California residents only, and a California (CCPA) and other State Specific Sections, that may apply to residents of one or more states with consumer privacy laws requiring such information. Such states as of the date of this Privacy Notice are California, Colorado, Connecticut, Utah, and Virginia (collectively “US States Privacy Laws”).
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“CCPA personal information”). We collect the following categories of CCPA personal information from consumers:
“Identifiers” covers a broad range of information, including things like name, email address, postal address, telephone number, and IP address. We collect some CCPA personal information that falls into this category. For example, for streaming subscribers we’re going to have an email address, payment information (like a credit card), and for DVD customers we’re going to have a postal address. We collect IP addresses, identifiers from the devices you might use to connect, and characteristics about the networks you use when you connect to our service online (see also “Information we collect automatically” above in the Privacy Statement).
These sorts of identifiers are connected to your Turtle account. There are also identifiers we use for purposes like advertising (resettable device identifiers, third party advertising cookies on our website) that we do not associate with your account, but that can be used to reach you with promotional messages on other websites and applications.
In addition, there are identifiers (that may or may not be associated with your account) that we use for managing an ad supported subscription plan. We will also collect information such as gender, if you join an ad supported subscription plan.
Characteristics of protected classifications under California or federal law: This covers a broad range of information like race, sex, marital status, among other protected classes. We will collect this sort of information about you if you choose to participate in our optional research surveys, or other research activity such as an in person interview or panel. We do not collect this information when you register for the Turtle service. This will include date of birth and gender if you join an ad supported subscription plan.
This includes information about products or services considered, obtained or purchased. Internet or other electronic network activity information: We offer online services, so we collect CCPA personal information in this category, like your interactions with our Turtle service.
Our online services don’t collect precise geolocation data from GPS sensors. However, we do collect IP addresses from which we can determine your general location (such as your city, state/province, and postal code).
We may collect photos, audio and/or video of you in certain circumstances. For example if you contact customer service, we may record the call (voice recording).
We have a content recommendations system that strives to predict what you’ll be in the mood to watch when you log in. However, we do not have a list in our recommendations system that attaches socio-demographic information to you like “soccer dad who likes rom coms” or “financially savvy mom who craves action films” or “singleton high school grad who likes tiny houses.” We have a Help article that explains how our recommendations system works - You can read the article at https://support.turtle.onl/help-center/articles/11/recommendations.
Over the previous twelve months, we have collected each of the categories of CCPA personal information described above except the specific pieces of CCPA personal information collected in connection with an ad supported subscription plan (which has been available for less than twelve months as of the last update of this Privacy Notice).
We use each of the categories of CCPA personal information listed above for the purposes noted below. (Please see the Use of Information section of our Privacy Statement for additional details that may be of interest to you.) For ease of reference, we repeat those sections below:
We use personal information to provide, analyze, administer, enhance and personalize our services and marketing efforts, to provide, analyze, administer, enhance and select ads in connection with our ad supported subscription plans, to process your registration, your orders and your payments, and to communicate with you on these and other topics. For example, we use such information to:
provide you with customized and personalized viewing recommendations for movies, TV shows, and games we think will be of interest to you (collectively “Turtle content”);
determine your general geographic location (such as your city, state/province, and postal code); provide localized Turtle content; determine your ISP to support network troubleshooting for you (we also use aggregated ISP information for operational and business purposes); help us quickly and efficiently respond to inquiries and requests; to coordinate with Partners on making the Turtle service available to members and providing information to non members about the availability of the Turtle service, based on the specific relationship you have with the Partner;
prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and to enforce our terms (such as determining whether and for which Turtle TV signup offers you are eligible and determining whether a particular device is permitted to use the account consistent with our Terms of Use);
analyze and understand our audience, improve our service (including our user interface experiences) and optimize content selection, recommendation algorithms and delivery;
communicate with you concerning our Turtle service so that we can send you news about Turtle, details about new features and Turtle content available on Turtle TV, special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as password reset requests. These communications may be by various methods, such as email, push notifications, text message, online messaging channels, and matched identifier communications (described below). Please see the "Your Choices" section of our Privacy Statement to learn how to set or change your communications preferences.
Over the previous twelve months, we used each of the categories of CCPA personal information listed above for the purposes listed above. However, the specific pieces of CCPA personal information described as being used in relation to an ad supported subscription plan were not collected or used during the last twelve months (from the last updated date of this Privacy Notice).
We disclose the categories of CCPA personal information listed below for business purposes. (Please see the Disclosure of Information section of our Privacy Statement for additional details that may be of interest to you.)
Identifiers: We may disclose identifiers for business purposes with the following categories of third parties: Service Providers, Partners, an entity engaged in a business transfer, law enforcement, courts, governments and regulatory agencies. In the context of an ad supported subscription plan, certain identifiers may be shared with our Ad Service Providers, Ad Measurement Companies and Advertisers.
We may disclose these types of characteristics for business purposes with the following categories of third parties: Service Providers, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. In the context of an ad supported subscription plan, certain information characteristics may be shared with our Ad Service Providers, Ad Measurement Companies and Advertisers.
Service Providers, Partners, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. In the context of an ad supported subscription plan, certain pieces of commercial information may be shared with our Ad Service Providers, Ad Measurement Companies and Advertisers.
We may disclose these types of information for business purposes with the following categories of third parties: Service Providers, Partners, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. In the context of an ad supported subscription plan, certain Internet or other electronic network activity information may be shared with our Ad Service Providers, Ad Measurement Companies, and Advertisers.
Service Providers, Partners, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. In the context of an ad supported subscription plan, geolocation data may be shared with our Ad Service Providers, Ad Measurement Companies, and Advertisers.
We may disclose these types of information for business purposes with the following categories of third parties: Service Providers, Partners, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies.
We may disclose these types of data for business purposes with the following categories of third parties: an entity engaged in a business transfer/merger. In the context of an ad supported subscription plan, certain inferences may be shared with our Ad Service Providers, Ad Measurement Companies, and Advertisers.
Over the previous twelve months, we disclosed each of the categories of CCPA personal information listed above for the business purposes as described in this Privacy Notice and our Privacy Statement.
Please note that the specific pieces of personal information currently being disclosed for consumers using an ad supported subscription plan were not disclosed during the last twelve months, as this plan has been available for less than twelve months as of the last update of this Privacy Notice.
We explain our sources of information in the Collection of Information section of our Privacy Statement. (Please see that section for more information that may be of interest to you.) For ease of reference, in regard to CCPA personal information these are:
You (the consumer) when you provide us CCPA personal information directly, and when we collect it automatically based on your interactions with us (for example, through your computer or other Turtle capable device you might use to access our service (such as gaming systems, smart TVs, mobile devices, set top boxes, and other streaming media devices);
Partners (other companies with whom you have a relationship). These Partners might include (depending on what Turtle services you use): your TV or Internet service provider, or other streaming media device providers who make our Turtle service available on their device; mobile phone carriers or other companies who provide services to you and collect payment for the Turtle service for distribution to us; voice assistant platform providers who enable interaction with our Turtle service via voice commands; third party services that you are signed into that provide functions within Turtle TV such as TurtleTube, Turtle, Turtle Pics, Turtle Search, Turtle Chat, and Other sources.
Service Providers who support our business including: security and payment service providers; Ad Service Providers, Ad Measurement Companies, and Advertisers; publicly-available sources, specifically, public posts on social media platforms; and information about Internet Service Providers (ISPs) used by members to access Turtle TV through public databases associating IP addresses with ISPs.
As of the date of this Privacy Notice, we may use certain types of information to offer members an ad supported subscription plan or engage in certain marketing activities. Under the CCPA, this activity may be considered “selling” or “sharing.” This section includes important disclosures for California residents.
If you do not wish for us to sell or share CCPA personal information about you, you can learn how to make applicable choices by clicking the “Do Not Sell or Share My Personal Information” link located in the footer of tv.turtle.tube or by visiting this link: https://support.turtle.onl/help-center/articles/22/do-not-sell-my-personal-information. Using these choices will not opt you out of the use of previously “sold” (as defined by the CCPA) personal information, or stop all behavioral advertising.
We do not knowingly sell, share or use the personal information of minors under 16 years of age.
When you subscribe to Turtle TV you may choose an ad supported subscription plan. It is possible that some may interpret an ad supported subscription plan to fall within the meaning of a “financial incentive” for the purposes of the CCPA.
If you choose an ad supported subscription plan, you will receive a discount in the price of your monthly subscription and when you watch Turtle content on Turtle TV, you will be presented ads which may appear before, during, or after Turtle content viewed on Turtle TV. In certain circumstances some content and features (such as downloading and viewing content in other countries) may not be accessible under an ad supported subscription plan.
If you would like to stop participating in an ad supported subscription plan, you can simply access the Account Settings of your Turtle account through a web browser and select a different plan that is not an ad supported subscription plan.
The monthly fee associated with your Turtle TV subscription will likely increase if you move from an ad supported subscription plan to one that is not an ad supported subscription plan. We believe the reduction in monthly fee for participation in an ad supported subscription plan and use of the categories of CCPA personal information described above to present relevant ads to you represents a fair exchange to continue to provide members a high quality service at a lower direct out of pocket price to members.
When considering the size of reduction in monthly fee for participating in an ad supported subscription plan, we considered projected ad revenue generated by all members projected to participate in an ad supported subscription plan and the overall revenue required by Turtle to operate and innovate its business, produce the Turtle content to entertain its members and make a profit.
Sale and Use of Personal Information for Targeted Advertising Purposes. We may use certain types of information to offer members an ad supported subscription plan or engage in certain marketing activities. This activity may be considered “selling”, or “targeted advertising” under US States Privacy Laws. Our practices regarding sale or targeted advertising may depend on how you interact with us, the services you use and the choices you make.
If you do not wish for us to sell or use your personal information for targeted advertising purposes, you can learn how to make applicable choices by visiting this link: https://support.turtle.onl/help-center/articles/22/do-not-sell-my-personal-information. Using these choices will not opt you out of the use of previously sold personal information or stop all behavioral advertising.
We have not sold personal information in the past twelve months. We have also not “shared” or made available personal information for the purposes of targeted advertising in the past twelve months.
Use of De-Identified Information. As described in the Your Information and Rights section of our Privacy Statement, we may de-identify personal information in a secure manner when we determine it is appropriate as part of our business operations. We take reasonable measures to maintain and use the information in a de-identified manner. We do not make any attempts to re-identify such information, except as permitted under applicable law.
To the extent applicable under US States Privacy Laws, you may have the following rights in connection with your personal information:
what categories and specific pieces of CCPA personal information have been collected about you; the categories of sources from which CCPA personal information are collected; our business or commercial purpose for collecting, using, disclosing, selling or sharing personal information; the categories of third parties with whom we disclose, sell or share personal information; the categories of personal information we have disclosed, sold or shared about you for a business purpose.
You can assert these rights only where we receive a verified request from you. For information on how to exercise your rights, please see the Your Information and Rights section above.
If you are a consumer in a jurisdiction that recognizes the ability to use an authorized agent and wish to contact us through an authorized agent, the authorized agent can submit a request on your behalf to dpo@turtle.onl along with a statement, certified as may be required, that the agent is authorized to act on your behalf. In order to verify the request, we may ask you to verify your identity. For more information about how to access your information, including our verification process, please reference this help article: https://support.turtle.onl/help-center/articles/19/what-personal-information-turtle-holds-about-you-and-how-to-request-a-copy.
If you are in a jurisdiction that recognizes your ability to appeal a decision we have made in connection with your attempt to assert a right under applicable US States Privacy Laws, you may file an appeal of our decision refusing your request to exercise your rights under this Privacy Notice. Requests to change our policies or practices are not grounds for appeal. You may request an appeal of such decision by contacting us at https://support.turtle.onl/help-center/tickets/new, and select Privacy Appeals Dept, please provide the state that you are writing from, accompanied with documentation you may have regarding the matter you are appealing. If your jurisdiction allows you to file a complaint with the state’s Attorney General’s Office regarding any concerns with the result of your appeal request, you may do so by using the following links as may be applicable to you. You may submit a complaint to the Attorney General’s Office by selecting the appropriate link: Virginia (www.oag.state.va.us/consumer-protection/index.php/file-a-complaint), Colorado (coag.gov/file-complaint), and Connecticut (portal.ct.gov/AG/Common/Complaint-Form-Landing-page).
If you do not own a Turtle account, we may not be able to respond to requests to exercise rights under this Privacy Notice, including, for example, the right to know or delete personal information. Because we only collect limited information about individuals without an account, we are unable to verify requests from non-account holders to the standard required by the US States Privacy Laws.
Retention of Personal Information. We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes and to fulfill the purposes described in our Privacy Statement. Specifically, we retain information for our legitimate interests and essential business purposes, such as operating, maintaining and improving our Turtle services; complying with our legal obligations; and exercising our legal rights and remedies, including enforcing our terms of use. Our retention of information is based on many factors such as your relationship with Turtle (for example, are you a Turtle TV current member); the nature of the information; compliance with our legal obligations; defending or resolving actual or anticipated legal claims. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required. For information about deletion, removal and retention of information, please reference this help article: https://support.turtle.onl/help-center/articles/20/deletion,-removal-and-retention-of-information.