Turtle Peak and all of its subsidiaries globally (collectively ’Turtle Peak’, ‘us’, ‘we’, ’our’) understand the importance of ensuring that we collect, use, store, share and dispose of (collectively ‘Use’) Personal Data about you in a fair, ethical, transparent, secure and lawful way.
This Privacy Statement describes what Personal Data we Use about you, how we Use it, and your choices and rights in relation to your Personal Data.
This Privacy Statement applies to our Use of your Personal Data in our interactions with you through our websites and social media sites (‘Sites’) that link to our Privacy Statement, or Personal Data about you that we may collect offline or receive from other parties.
Additional information on our privacy practices with respect to recruitment, certain products, services and solutions, may be provided in specific privacy statements and/or privacy sheets and/or other notices provided to you. To the extent that a specific statement, sheet or notice differs from this Privacy Statement, the specific statement, sheet or notice will take precedence.
If you have any questions about how we Use your Personal Data or would like to lodge a complaint, please contact us at firstname.lastname@example.org
Personal Data is any information that identifies you or relates to you.
We collect Personal Data about you from different sources including: Personal Data that we collect directly from you; Personal Data that we collect automatically about you as you use our Sites; and Personal Data that we collect from other sources, as described in this Privacy Statement.
The type of Personal Data that we collect about you varies based on our interactions with you.
Typically, we do not combine this information with other information that we have collected about you, including, other Personal Data.
Special Categories of Personal Data includes information relating to your health, biometric or genetic information, religion, political beliefs, union membership, race or sexual orientation. We ask that you do not send or provide this information to us.
You can choose not to provide Personal Data to us, in certain circumstances. However, if your Personal Data is necessary to provide you with our products, services and solutions as required by our contract or to perform customer relationship management and/or administrative functions related to our contract, we may be unable to provide this Service without your Personal Data.
When we Use your Personal Data in connection with the purposes set out in this Privacy Statement, we may rely on one or more of the following legal bases, depending on the purpose for which your Personal Data was collected and our relationship with you:
We may share your Personal Data with the following parties for the purposes set out in this Privacy Statement (as applicable):
We also may share Personal Data in the following circumstances:
Any Service Providers or other parties with whom we share Personal Data are contractually required to implement appropriate physical, administrative and technical safeguards to protect Personal Data and are not permitted to use Personal Data for any purpose other than the purpose for which they are provided with or given access to Personal Data by us.
We are committed to protecting your Personal Data from accidental or unlawful destruction, loss, alteration, unauthorized access or disclosure by using a combination of physical, administrative and technical safeguards and contractually requiring our service providers to whom we disclose your Personal Data to do the same.
Please note that we cannot guarantee 100% security of your Personal Data, and we recommend that you take reasonable steps to protect your Personal Data. (e.g., by not sharing your passwords, choosing strong passwords and other measures).
We keep information about you for as long as is necessary to fulfil the purpose for which it was collected, unless we are required to keep it for longer to comply with our legal obligations, resolve disputes, protect our assets, or enforce our rights. The criteria we use to determine how long we keep Personal Data includes:
In some instances, we may anonymize your information in accordance with our policies and may keep those anonymized records for longer periods.
As a global company, we may transfer your Personal Data to countries where we, our Service Providers or Business Partners do business or to international organizations in connection with the purposes identified above and in accordance with this Privacy Statement.
When we transfer your Personal Data outside of the country from where it was originally collected to a third country or international organization we ensure that appropriate safeguards are in place, in line with applicable law, to ensure that your Personal Data is protected. You may obtain a copy of these safeguards by contacting us in accordance with the ‘How to contact us’ section below.
You have rights under various data protection laws in various countries in relation to your Personal Data but we offer them irrespective of your location.
We are committed to upholding your rights, including:
Where you contact us, we may request specific information from you to verify your identify to enable us to search for and provide you with access to or a copy of your Personal Data, as permitted under applicable law. Where permitted under applicable law, we may charge you a reasonable fee to access your Personal Data; however, we will advise you of any fee in advance.
Individuals may hold additional rights in certain countries, which must be recognized and upheld.
In some situations, we may not be required to enforce these rights, where permitted under applicable law. We may also have a legitimate business interest to decline a request to action your rights.
You may contact us with requests, complaints or questions regarding these rights as set forth in the ‘How to contact us’
Our Sites may provide links to the websites and/or applications of other parties. You may further interact with us through third party applications, owned and operated by the company you work for or other third parties such as LinkedIn, WhatsApp, Slack, Microsoft Teams, Facebook, Twitter, Google+, and other social media sites or applications.
We are not responsible for and make no representations or warranties in relation to the security, privacy practices and content of these third-party websites and applications. Please ensure that you read the applicable privacy and cookie policies before sharing Personal Data on these websites applications. Your use of such websites and applications is at your own risk.
In some instances, you may provide TURTLE PEAK with consent to process your Personal Data such as where you have opted into receiving direct marketing communications from us. You can change your consent preference at any time, and manage your communication preferences by:
Once we have received and verified your opt-out request, we will comply with your request as soon as is reasonably practicable.
If you opt-out of receiving marketing related communications from us, we may still send you administrative messages or other required communications as part of your ongoing use of our products, services and solutions, which you are unable to opt-out of.
We do not provide your Personal Data to unaffiliated parties for their own direct marketing purposes or sell, rent, distribute or otherwise make Personal Data commercially available to any third party.
We encourage parents and guardians to take an active role in their children’s online activities. We do not aim our Sites at children. If you believe that we may have collected Personal Data about someone who is under the applicable age of consent in your country without proper consent of the child’s parent or guardian, please contact us.
We may update our Privacy Statement at any time. If we do, we will update the ‘Version’ and ’Last update’ information at the bottom of our Privacy Statement.
We encourage you to regularly review our Privacy Statement to stay informed about how we Use your Personal Data and privacy practices.
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