Privacy Policy

Last Updated: August 2023

Table Of Contents

1. About This Privacy Policy
2. What is “Personal Information”?
3. Personal Information We Collect And How We Collect It process
4. How We Use Personal Information
5. How We Share Personal Information
6. Cookies And Online Tracking
7. Your Rights And Choices
8. Links To Third Party Sites
9. Children’s Privacy
10. Data Subjects In The EEA, United Kingdom and Switzerland
11. Changes To This Policy
12. Contact Us

1. About This Privacy Policy

Turbu, Inc. (“Turbu” or “we”) respects your privacy and is committed to protecting it. This Privacy Policy (“Policy”) describes how we may collect, use, and share Personal Information in connection with operating our website located at, mobile application or other platform (collectively the “Platform,”) and any mobile application or other online service that links to this Policy (collectively, with the Platform, the “Services”). It also explains related rights and choices you may have.You may see other privacy notices when we collect your Personal Information for certain purposes. Those notices supplement this Policy. This Policy also contains a statement specific to individuals in the European Economic Area, United Kingdom and Switzerland hereinafter. That statements supplements the rest of this Policy, but to the extent it differs from other parts of the Policy, the statement governs with respect to those areas.

2. What is "Personal Information"?

When we say “Personal Information,” we mean information that can reasonably be linked to a particular individual, as defined in laws that may apply to you. Generally speaking, this includes your unique identifiers (full name, phone number, email address, account number, etc.), and information about your characteristics, conditions or behavior that is associated with one of your identifiers or could otherwise reasonably be linked to you.“Non-Personal Information,” on the other hand, has been anonymized, aggregated or de-identified such that it cannot reasonably be linked to a particular individual.

3. Personal Information We Collect And How We Collect It

General Methods

The protection of your personal data is of utmost importance to us. We utilize industry standard methods to seek to ensure protection of your personal data. Our Platform employs Secure Sockets Layer (“SSL”) technology to allow for the encryption of your personal data. We suggest you also engage in good practices to help to ensure protection of your data by appropriately selecting and securing your account sign-on credentials, limiting access to your devices, and signing out of the Platform after you have finished each session of use. Although we work to protect the security of your account and data, please be aware that no method of transmitting or storing data over the Internet is entirely secure. Accordingly, we cannot guarantee the complete security of any data you share with us. Except as may expressly be required by applicable law, we are not responsible for the loss or inadvertent disclosure of your information or content. We retain personal data about you for as long as you have an active account on the Platform, or as is otherwise necessary to provide you with our Services or as required by law. Data that is held in an aggregated, anonymous form is subject to retention, in perpetuity.


    While we may disclose other categories to you at the point of collection, the categories of Personal Information that we generally collect include:
  • “Identifiers,” such as first and last name, address, email address, phone number, social media address, username, signature, IP address, and similar information.
  • “Demographic Information,” such as age and similar information. Demographic Information may include legally protected classifications.
  • “Financial Information,” such as payment card information.
  • “Commercial or Product Information,” such as products or services purchased, obtained or considered, or information about how you use our product.
  • “Professional or Employment Information,” such as job title and business or employer name.
  • “Internet Activity,” such as device or browser information, comments or other content posted to our Service or shared with us via email, browsing activity, social media content, interactions with our Service, and interactions with marketing communications sent on our behalf.
  • “Geolocation Data,” such as your approximate geographic location at the time you access our Service.
  • Collection Sources

    From You When You Provide It. We may collect Personal Information from you directly when you visit our Platform; fill out a form; use a Service; make a purchase; open an account; register a product or warranty; subscribe to receive communications from us; call to make an inquiry; interact with us on social media; or otherwise communicate with us.Automatically From Your Device. Like most online services, our Platform and other Services may passively collect some information from users’ devices in order to make site features function correctly, customize the user experience, understand how the site is being used, or measure the effectiveness of marketing efforts. Some of this data may be collected through the use of browser cookies or similar online tracking tools, which are explained hereinafter. In some cases, we limit this type of collection to Non-Personal Information. However, this data may include Personal Information such as online Identifiers and Internet Activity in some circumstances.From Third Party Sources. We may obtain information about you from other third-party sources. For example, we may collect Identifiers, Professional or Employment Information, or Internet Activity that you have chosen to disclose on social media platforms.We may combine information collected from other sources with information collected from you or your device. To the extent the information, alone or in combination, constitutes Personal Information, we will treat it as Personal Information as described in this Policy.

    4. How We Use Personal Information

      We use Personal Information for the following purposes, subject to legal restrictions in certain areas:
  • To present our Platform to you and analyze how it is used;
  • To secure our Platform and Services against fraud, malicious activity, or conduct that may violate our terms of use;
  • To personalize and improve your experience with the Platform and Services;
  • To provide you with information, products, or services that you request from us;
  • To notify you about changes to our Platform and Services and any products or services we offer or provide though them;
  • To allow you to participate in interactive features on our Services;
  • To allow you to pay applicable fees, purchase products and process payments through the Platform;
  • To provide you with periodic product newsletters and offers;
  • To contact you and provide you with help if you have customer service issues;
  • To notify you of new products or services we think you might be interested in;
  • To comply with our legal obligations, such as “know your customer” requirements;
  • In any other way we may describe when we collect the information; and
  • For any other purpose with your consent.
  • Under applicable laws and subject to exceptions, you may request additional information regarding the pieces of personal information that we have about you, and may request to correct and/or delete your personal information. To submit an access or deletion request, please send a request to [email protected].
    We may use Non-Personal Information for any purpose.

    5. How We Share Personal Information


    We may share Personal Information with contractors, service providers, and other vendors who provide services to us. Examples of these services include hosting our website, storing data, performing analytics, processing payments, or sending marketing communications.Where necessary and appropriate, our agreements with vendors prohibit them from retaining, using or disclosing the Personal Information we share with them for any purpose other than providing services to us.

    Analytics, Social Media and Advertising Partners

    We may share your Personal Information with analytics providers, advertising networks, or social media companies to measure performance of our Platform or marketing efforts, offer social media features, or deliver interest-based advertising. This sharing may involve the use of “Cookies” placed through our Service by our partners, as explained hereinafter. For example, when you visit our Platform, our partner’s Cookie may cause your browser to automatically send a request to our partner’s server and provide our partner with your IP address, other Identifiers, and Internet Activity.

    Mandatory Disclosures And Legal Proceedings

    We may have a legal obligation to disclose Personal Information to government authorities or other third parties pursuant to a valid regulatory request, subpoena or court order. We may also need to disclose and otherwise process your Personal Information in accordance with applicable law to prevent physical harm or financial loss, protect the vital interests of a person, enforce our various policies or terms of use, protect our property, services and legal rights, prevent fraud, support auditing, compliance and corporate governance functions, or comply with applicable law.

    Change In Control Or Merger

    We may transfer your information in the event of the sale of substantially all of the assets of our business to a third-party or in the event of a corporate merger, consolidation, acquisition or reorganization. However, in such event, any acquirer will be subject to the provisions of our commitments to you or we will not disclose your information.

    With Your Direction Or Consent

    We will share your Personal Information with other third parties as you may direct or otherwise consent.

    6. Cookies And Online Tracking

    What Are Cookies?

    A browser cookie is a small piece of data that a website stores in your device’s browser. It holds information that the site uses to function properly, remember your preferences, or personalize your experience. A typical cookie contains a cookie ID, which is a unique string of characters used to identify your browser during the browsing session, or in some cases, during subsequent browsing sessions. Cookies, cookie ID’s and similar pieces of data may be considered Personal Information (Identifiers or Internet Activity) under applicable law.Other online technologies, similar to cookies, may allow users to be identified and tracked across multiple browsing sessions, and in some cases tracked across different websites and online services. These technologies include, but are not necessarily limited to, pixels, web beacons and scripts (collectively with browser cookies, “Cookies”).

    How We May Use Cookies

    Our Services use “first party” Cookies, which are set by our web domain ( Our Services may also use some “third party” Cookies, which are set by other web domains associated with our vendors or partners. This means that, when you visit our site, your browser may automatically connect to our partner’s web server, as well as ours, and provide our partner with access to your online Identifiers and Internet Activity.

    We may use Cookies for the following purposes:

  • Essential: Essential Cookies are necessary in order to enable you to move around our Platform and use its features.
  • Analytics: Analytics Cookies allow us to analyze use of our Platform or Service to evaluate and improve performance.
  • Marketing: Marketing Cookies are used to display ads or other content based on your interests, or to measure performance of marketing efforts, and may be used to track visitors across different online services.
  • Where required by applicable law, we will not use non-essential cookies unless you provide consent or another lawful basis for their use applies.We use analytics Cookies and related business tools provided by Google: use marketing Cookies and related business tools provided by Facebook:

    How You Can Block Cookies

    You can block, disable or delete cookies at any time by changing the settings in your browser. However, blocking, disabling, or deleting cookies may limit your ability to view all the pages of our site or other sites. You can find more information about Cookies and other options you may have for restricting them at,,

    "Do Not Track"

    Your browser may offer a Do Not Track (DNT) setting. If you turn that setting on, your browser sends a signal to websites indicating that you don’t want to be tracked over time or across third party sites. We don’t currently respond to these signals because there is not yet a common understanding of how to process them or a consensus on what “tracking” means.

    7. Your Rights And Choices

    Opt-Out Of Marketing CommunicationsYou may opt-out of our marketing emails by using the unsubscribe link provided in the email.Your Browser and Device SettingsSee Section 6 for options to restrict Cookies.Area-Specific Rights And ChoicesIf you are in the EEA, United Kingdom or Switzerland you may have other rights and choices as identified hereinafter.

    8. Links To Third Party Sites

    Our online Services may contain links to third-party websites, products or services. If you use these links, you will leave our site. Such links do not constitute or imply an endorsement, sponsorship or recommendation by us of the third party, the third-party website or the information contained therein, and we shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

    9. Children's Privacy

    Our Platform may be subject to the Children’s Online Privacy Protection Act (“COPPA”), which requires that online service providers obtain parental consent before knowingly collecting personally identifiable information from children under the age of thirteen (13). We do not knowingly collect such information from children under the age of thirteen (13). If you are under the age of thirteen (13), please do not attempt to register for or use our Services or provide any personal information to us. If we become aware that we have inadvertently collected personal information from a child under the age of thirteen (13), we will take steps to delete that information as quickly as possible. If you believe that a child under the age of thirteen (13) has provided us with personal information, please contact us immediately at [email protected].

    10. Data Subjects In The EEA, United Kingdom and Switzerland

    Data Controller

    Personal Information that we collect regarding individuals who reside in a member state of the European Economic Area, the United Kingdom or Switzerland (collectively, the “Designated Countries”) is controlled by Turbu, Inc., a Delaware corporation, which is headquartered in San Francisco, California, United States of America. Turbu’s contact information is identified in Section 12 hereinafter.

    Lawful Bases For Processing

      We may process your Personal Information for the purposes described herein if at least one of the following grounds for processing applies:
  • Processing is necessary for us to perform a contract with you or to take steps at your request prior to entering into a contract;
  • Processing is necessary to comply with our legal obligations;
  • Processing fulfills our legitimate interests in a manner that does not outweigh your rights and freedoms. Our legitimate interests include: protecting our Services against malicious intrusions and unauthorized use; maintaining and improving our Services; understanding how our Services are used; personalizing our Services; promoting our Services effectively; and complying with legal obligations and protecting our legal rights.
  • Processing is necessary to protect the vital interests of you or another individual;
  • You have consented to the processing.
  • International transfers

    Turbu has its headquarters in the United States. Information we collect about you will therefore be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Commission under Article 45 of the General Data Protection Regulation (“GDPR”). To the extent we make transfers of Personal Information to third parties in the United States or other countries that have not received an adequacy finding, we rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we make such transfers: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. We endeavor to apply suitable safeguards to protect the privacy and security of your Personal Information and to use it only consistent with your relationship with us and the practices described in this Privacy Policy. We also endeavor to enter into data processing agreements and European Commission-approved model clauses with service providers whenever feasible and appropriate.

    Automated decision making

    We do not make any decisions involving the use of algorithms or profiling that significantly affects you.

    Your Rights Under GDPR

      The GDPR provides you with the following rights, which you can exercise by contacting Turbu:
  • The right to request access to and rectification of your personal information. You may obtain additional information about our processing and a copy of your stored information. You also have the right to request that we update your information if it is inaccurate or incomplete.
  • The right to request erasure of your personal information. You may request for us to erase your information from our systems if it is no longer necessary for the reason we collected it, or you withdraw consent and no other legal basis for processing exists.
  • The right to restrict our processing of your personal information. You have the right to restrict our processing if: (1) you disagree with the accuracy of your information; (2) our processing is deemed unlawful and you do not want us to erase your information; or (3) we no longer need your information for the purposes for which we collected it but we must store it to comply with our legal obligations.
  • The right to data portability. You may receive and transmit your personal information to another controller where our processing is based on consent you gave us and was carried out by automated means.
  • The right to object. You have the right to object to our processing of your personal information where we process it because of a legitimate interest.
  • You also have the right to file a complaint with the supervisory authority of your member state.

    11. Changes To This Policy

    We will update this Policy from time to time as necessary to reflect changes in applicable law, our privacy practices, or our Services. If we have your contact information, we will notify you of material changes, and you should periodically review this Policy to remain aware of our current practices.

    12. Contact Us

    If you have any questions or concerns about this Policy or our practices, or wish to exercise your rights regarding your Personal Information under applicable law, please contact us by e-mail at [email protected].