PRIVACY POLICY
LAST UPDATED: January 15, 2024
Ⅰ. Introduction
When it comes to your personal data,Turbo Tools(collectively referred to “we”, or “us”), as well as our employees, contractors, and service providers, are committed to providing you with transparency. We process personal data in accordance with applicable legislation.
This Privacy Policy applies to the Turbo Tools app (our “Services”) that link to or reference this Policy. In this Policy, we describe how we collect, process, use and disclose personal data, and your rights and choices regarding our processing of your personal data.
Additional information on our personal data practices may be provided in terms of service or at the time we collect your personal data.
Ⅱ. Categories of Personal Data We Collect
We collect personal data about you from different sources as listed below.
In this Policy, “personal data” means any information relating to an identified or identifiable individual.
Personal Data You Provide to Us
When you interact directly with us, we may collect personal data that you provide to us, including:
● User Data. If you create an account with us, make a purchase, or request information about our product we collect information about you.
● Communications. If you contact us directly, we collect personal data about you, including identifiers, such as your name, email address, phone number, the contents of any message or attachments that you may send to us, and any other information you choose to provide. We may retain and review audio, electronic, visual, or similar information, such as audio call and chat recordings and/or the contents of the messages as required/permitted by law and our recording and information management policies. We will also collect identifiers from you, such as your email address and phone number, when you sign up to receive product updates, offers, and other promotional information or messages from us. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.
Personal Data We Collect Automatically
When you visit and use our Services, we may automatically collect data about your interaction with our websites and Services, including:
● Device Data. We collect information to facilitate installation and use of our products, including your device and system information such as operating system, device name, browser, network, and applications running on the device. This data can also include internal identifiers such as Wallet ID, Auto bill ID, payment transaction ID, serial numbers, MAC address, Norton Machine ID, account generated unique ID, mobile device IDs (UDID, IMEI, and IDFA), Wi-Fi MAC Address, install identifier, Member ID, and LifeLock ID.
● Service Data. This can include product license information, usage data, and/or preference information, browser activity, and URLs accessed. This data may include internet or other electronic network activity information, such as diagnostic data such as crash dumps, system logs, error reports, product and internet usage time, network connection activity, interactions with our websites and extensions, blocked websites, device or phone settings, and reviews from third parties which we collect to, as necessary, to troubleshoot any malfunctioning Services. This data also helps us better understand and better serve your interests, expectations, needs and requirements.
● Geolocation Data. When you use our Services, if you consent via the device interface to sharing the precise geolocation data of your device, we will receive your precise location information. We also infer your more general location information (for example, your IP address or time zone may indicate your more general geographic region).
● Monetization and Analytical data from other sources.Information collected by third-party SDKs is governed by the providers of those SDKs, and we have no control over such third parties. The third-party SDKs we use and the corresponding privacy policy are as follows
○ AdMob
○ Pangle
○ AppLovin
○ Unity
○ Vungle
○ Kochava
○ Huawei
Ⅲ. How We Use and Process Your Personal Data
We process your personal data:
Where it is necessary to fulfill our contract with you at your request, in order to:
● Provide you with information and Services that you request;
● Verify your identity and entitlement to Services, when you contact us or access our Services;
● Allow you to register the Services you purchase;
● Provide you with technical and customer support.
Where you have provided your consent, in order to:
● Send you marketing communications and information on new Services;
● Solicit your opinion or feedback and/or provide opportunities for you to test Services;
● Enable you to refer a friend who may be interested in our offerings, as permitted by law;
● As applicable, to enable non-essential cookies or similar technologies; and
● As applicable, to provide you with interest-based ads about Turbo Tools on sites other than our own.
For the purpose of promoting and operating our business and advancing our or a third party's legitimate interests, such as the effective delivery of our Services, and communications to you as well as to our other customers and partners, in order to:
● Enable participation in interactive features of our Services;
● Inform you about additional Services that provide solutions to issues detected as a result of your request;
● Better administer and understand the usability, performance, and effectiveness of our Services websites, and communications to you, including troubleshooting, debugging, reviewing customer service interactions, data analytics, testing, research, and statistical analysis;
● Improve our Services (including developing new Services) and customize and present content in the most relevant and effective manner for you and for your device, including suggestions and recommendations about things that may be of interest to you;
● Enhance the security of our own networks and information systems.
We only rely on our or a third party’s legitimate interests to process personal data when these interests are not overridden by your rights and interests.
Ⅳ. When and Why We Disclose Your Personal Data
We are committed to maintaining your trust, and we want you to understand when and why we disclose personal data to third parties. We do not sell your personal data or use or disclose sensitive personal information for purposes other than those set forth in the California Consumer Privacy Act (“CCPA”). Data obtained through short code programs will not be shared with any third-parties for their marketing reasons/purposes. We may disclose the categories of personal described above in “Categories of Personal Data We Collect” to the entities and for the purposes described below.
We may disclose personal data about you with your consent, or:
1. With our Partners
We may provide your personal data to our partners for the purpose of allowing them to conduct Turbo Securitybusiness.
2. With Our Advertising Partners
We engage in personalized (or targeted) advertising in our Services or on other sites when we advertise our Services elsewhere. We may provide or share (as defined by the CCPA) your personal data, including the data about your interests in our Services, to third parties for the purposes of serving you more relevant ads about our Services. Where we provide you with interest-based ads on an app other than our own, we do not track your other activities on that app. If you click on our ads, we will know the domain you came from.
3. With Data Analytics Providers
We may provide your personal data to third parties to use the personal data in aggregate form to help us understand how our Services are being used or to understand the effectiveness of our marketing campaigns.
4. With Service Providers Processing Data on Our Behalf
We may use contractors and service providers to process the personal data we collect for the purposes described in this Policy, the relevant Product and Service Privacy Policys, and for business purposes such as financial auditing, data storage and security, troubleshooting and debugging, improving the functionality and usability of our websites and Services, improving and operationalizing threat intelligence and counter-threat measures, and for marketing and promoting our Services.
5. We contractually require service providers to keep data confidential, and we do not allow our service providers to disclose our data or your personal data to others without our authorization, or to sell it or use it for purposes unrelated to the services they provide (e.g., their own marketing purposes). However, if you have a separate and/or independent relationship with these service providers, their privacy Policys will apply to such relationships. Such service providers may include benefit brokers, your employer (for products and services offered as an employee benefit), contact centers, payment card processors, and marketing, survey, or analytics suppliers.
6. In certain instances, it may be necessary for us to disclose any of the personal data we collect to comply with a legal obligation, at the request of public authorities, or as otherwise required by applicable law. No personal data will be disclosed except in response to:
A subpoena, warrant, or other legal process issued by a court or other public authority of competent jurisdiction;
Discovery requests or demands as part of a civil lawsuit or similar legal process;
Where disclosure is required to comply with applicable laws, or necessary for us to enforce our legal rights pursuant to applicable law;
A request with the purpose of identifying and/or preventing credit card fraud or identity theft; or
Where disclosure of personal data is necessary to prevent or lessen a serious and imminent threat of bodily or other significant harm to the data subject or other individuals potentially concerned.
Ⅴ. Retention and Deletion of Your Personal Data
We will keep your personal data on our systems as long as necessary to provide you with our Services, or for as long as we have another legitimate business purpose to do so, but not longer than permitted or required by law. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations. When we no longer have an ongoing legitimate business reason to keep your personal data, your personal data will either be securely disposed of, or de-identified through an appropriate anonymization means.
When you find that our collection and processing of your personal information violates the provisions of laws and regulations or this Privacy Policy, you have the right to ask us to delete the relevant personal information. For personal information that we have not provided you with a channel for correction or deletion, you can request that it be corrected or deleted by contacting sitompulmuhammad90@gmail.com.However, we may not grant your deleting request in some situations, for example, if you ask us to delete your transaction data when we are legally obligated to keep a record of that transaction to comply with the applicable local law. Please also kindly note that if you request to delete your information from our products and services, we may not remove the corresponding information from the backup system immediately due to some applicable local laws and technological limitations, however, we will securely store your personal information and isolate it from any further processing until the backup is updating or can be deleted or be made anonymous.
If we are involved in a reorganization, merger, acquisition, or sale of our assets, your personal data may be transferred as part of that transaction.
Ⅵ. How We Protect Your Personal Data
Securing personal data is an important aspect of protecting privacy. We take reasonable and appropriate physical, technical, and organizational security measures in accordance with applicable laws to protect your personal data against the risk of accidental loss, compromise, or any form of unauthorized access, disclosure, or processing.
The relevant security controls are communicated throughout Turbo Tools to support the secure development of Services and maintain a secure operating environment.
Please note that there are exceptions and limitations to each of these rights, and that while any changes will be reflected in active user databases instantly or within a reasonable period of time, we may retain personal data for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, to the extent permitted by applicable law.
We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on a Service may change or no longer be available to you where the processing of certain data is essential to the use of the Service or feature.
Ⅶ. Contact Us
Turbo Tools - Muhammad Studio
Email: sitompulmuhammad90@gmail.com
Ⅷ. Children’s Privacy
We understand the importance of safeguarding the personal data of children, therefore, children under the age of 14 or the equivalent age as specified by law in your jurisdiction (we will define children mainly based on the laws and regulations of the country or region where our business is located because laws of different countries may differ when defining the age of children) are not allowed to use our products or services without the consent and guidance of their legal guardians and such practice shall be permitted by relevant laws and regulations. In principle, we do not provide services directly to children, do not actively collect children’s personal data or do not use children’s personal information for the purposes of marketing. We will only collect, use and disclose a child's personal information with the explicit permission and consent of the child's guardian, to the extent permitted by law, and when it is indeed necessary to collect such information. If at any time the guardian needs to access, modify or delete the personal information related to the child under guardianship, please contact us by methods as described herein, and we will respond in a timely manner. If you find that a child’s information has been collected to us without the awareness of the legal guardian, please send an email to sitompulmuhammad90@gmail.com to contact us. We will remove the relevant information as soon as possible. If we find that we have collected the personal information of a child without the prior consent of a verifiable guardian, we will also remove the relevant content as soon as possible.
Ⅸ. Changes to this Policy
We reserve the right to revise or modify this Policy. In addition, we may update this Privacy Policy to reflect changes to our personal data processing practices. If we make any material changes in the way we collect, process, use and/or disclose your personal data previously collected from you through our Services, we will send a notice on this website prior to the change becoming effective. In the case of a material change to our personal data processing practices, any such change will only apply on a going-forward basis. We will not process the personal data currently in our possession in a materially different way without your prior consent. We encourage you to periodically review this page for the latest information on our privacy practices.