Effective date: November 08, 2022
1. INFORMATION WE COLLECT.
A. Information about You that You Provide. Savvy Turtle, and/or its Vendors (defined below), may collect information you provide via the Service. For example, Savvy Turtle collects information when you use or register for the Service, participate in the Style Editor program, subscribe to notifications, post on the Service, participate in promotional activities, contact us via Savvy Turtle Chat, or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties.
Savvy Turtle, its Vendors, and/or Third-Party Services may collect certain information that identifies you personally, such as your first and last name, e-mail address, social media handle, phone number, address, full payment account number, credit or debit card number, and photos (“Personal Information”).
B. Information Collected Automatically. Savvy Turtle, its Vendors, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service. Such automatically collected information may include your IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device).
The methods that may be used on the Service to automatically collect such information include:
- Log Information: Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
- Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.
- Some information about your use of the Service and certain third-party services may be collected using Tracking Technologies across time and services, and used by Savvy Turtle and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain third-party services.
2. HOW WE USE THE INFORMATION WE OBTAIN.
• Allow you to participate in the features we offer on the Service;
• Facilitate, manage, personalize, and improve your online experience;
• Process your registration, manage your account and/or upload your User Generated Content (“UGC”);
• Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices;
• Savvy Turtle Affiliates’ marketing and other purposes;
• Improve the Service and for any other internal business purposes;
• Tailor our content, advertisements, and offers;
• Fulfill other purposes disclosed at the time you provide Personal Information or otherwise where we are legally permitted or are required to do so;
• Determine your location and manage digital content rights (e.g., territory restrictions); and
• Prevent and address fraud, breach of policies or terms, and other threats or harm.
3. INFORMATION WE SHARE WITH THIRD PARTIES.
Savvy Turtle may share your information, including Personal Information, with third parties or Savvy Turtle Companies and their affiliates (“Affiliates”). Any such third-party activities are subject to those third parties’ privacy policies and practices.
• Savvy Turtle’s agents, service providers, consultants, Style Editors and other vendors (collectively “Vendors”) may receive, or be given access to, your information, including Personal Information, in connection with their work on Savvy Turtle’s behalf. We share your personal information with third party marketing partners for commercial purposes. In particular, we may provide your commercial information to vendors who combine such information with your mailing address in order to provide marketing offers via direct mail. You may opt out of such disclosure by submitting our online opt-out request form.
• To comply with the law, law enforcement or other legal process, and, where permitted, in response to a government request; and
In addition, Savvy Turtle may share your Personal Information in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Savvy Turtle assets, or transfer of all or a portion of Savvy Turtle’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).
4. SWEEPSTAKES, CONTESTS, AND PROMOTIONS.
5. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS.
Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, Savvy Turtle relies on you to only send to people that have given you permission to do so. The recipient’s Personal Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by Savvy Turtle for any other marketing purpose unless Savvy Turtle obtains consent from that person. Your contact information and message may be included in the communication.
6. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS.
The Service may include links to, or include on or in connection with, the Service (e.g., apps and plug-ins), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Information from you.
Certain functionalities on the Service may permit interactions that you initiate between the Service and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Savvy Turtle’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service or by the Third-Party Service that you use. You should review the terms, policies, and settings of Third-Party Services to learn more or adjust your connections. Similarly, if you post information on a third-party service that references the Service (e.g., by using a hashtag associated with Savvy Turtle in a tweet or status update), your post may be used on or in connection with the Service or otherwise by Savvy Turtle. We may also use third-party services, such as Apple or Android, to allow you to log into our app using facial recognition. We do not receive your biometric data from these Third-Party Services and you should consult their data privacy and security policies if you use these features. Also, both Savvy Turtle and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
Savvy Turtle may engage and work with Vendors and other third parties to serve advertisements on the Service and/or on third-party services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a third-party service after you have left the Service (i.e., “retargeting”).
7. DATA SECURITY AND MONITORING.
Savvy Turtle takes reasonable measures to protect Personal Information (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and Savvy Turtle does not guarantee the security of your information collected through the Service.
8. INTERNATIONAL TRANSFER.
9. CHILDREN’S PRIVACY.
The Service is intended for a general audience and not directed to children less than 13 years of age.
Savvy Turtle does not intend to collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.
10. ACCESSING AND CHANGING INFORMATION.
Savvy Turtle may provide web pages or other mechanisms allowing you to delete, correct, or update some of the information collected about you (e.g., profile and account information). You may also email us at firstname.lastname@example.org, write to us at 2623 Utah St. #B Jackson, MS 39213, or call us at 1-833-MY-SAVVY., 1-833-697-2889. Savvy Turtle will make good faith efforts to make requested changes as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from Savvy Turtle’s databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
11. CHOICES: TRACKING AND COMMUNICATIONS OPTIONS.
A. Tracking Technologies Generally. Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.
In addition, we may serve ads on third-party services that are targeted to reach people on those services that are also identified on one of more of our data bases (“Matched List Ads”). This is done by using Tracking Technologies or by matching common factors between our data bases and the data bases of the third-party services. For instance, we may use such ad services offered by Facebook or Twitter and other Third-Party Services. We are not responsible for these Third-Party Services, including without limitation their security of the data. You may review and adjust your ad options directly through your account settings on Third-Party Services such as Facebook or Twitter. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
C. Mobile Apps. With respect to Savvy Turtle’s mobile apps (“apps”), you can stop all collection of data generated by use of the app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., location-based services, push notifications, accessing calendar/contacts/photos, etc.), by adjusting the permissions in your mobile device and/or the app’s settings. If GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to wi-fi, Bluetooth, beacons, or our networks) may persist. See also the prior section regarding Interest-based Advertising choices.
D. Communications. You can opt out of receiving certain promotional communications (emails or text messaging) from Savvy Turtle at any time by (i) for promotional e-mails, following the unsubscribe instructions in any promotional e-mails you get from us, emailing us at email@example.com, or if available by changing your communication preferences by logging onto your account; (ii) for text messages, following the instructions provided in text messages from Savvy Turtle to text the word, “STOP,” emailing firstname.lastname@example.org and including your cell phone number, or calling 1-833-MY-SAVVY., 1-833-697-2889; and (iii) for app push notifications turning off push notifications on the settings of your device and/or the app, as applicable. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, Savvy Turtle may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Savvy Turtle’s ongoing business relations.
13. CONTACT SAVVY TURTLE.