Who we are
How to contact us
Representation for data subjects in the UK
Our UK representative is located at 68 Hanbury Street, London, E1 5JL. If you want to make use of your data subject rights, our UK representative can be contacted directly by emailing them at email@example.com.
Representation for data subjects in the EU
As we do not have an establishment in the European Union (“EU”), we have appointed a representative based in the European Union, who you may address if you are located in the EU to raise any issues or queries you may have relating to our processing of your Personal Data. Our EU representative is Prighter. If you want to contact us via our representative Prighter or make use of your data subject rights, please visit: https://prighter.com/q/18168702908.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This version was last updated October 2022 and historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our Website and products may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email or text message, where you are not an existing customer and have not opted-out of such communications. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
We do not sell your personal data.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer contact/authorised user|
|To process and deliver your order including:|
|To manage our relationship with you which will include:|
|To enable you to partake in a prize draw, competition or complete a survey|
|To administer and protect our business and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you|
|To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences|
|To make suggestions and recommendations to you about goods or services that may be of interest to you|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have provided opt-in consent to such marketing (unless you are an existing customer) and not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside Turtl for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above.
|Amazon Web Services||for the provision of our systems architecture.|
|BrightTALK||for the provision of our webinar platform and communication channel.|
|Databricks||for the provision of a data warehouse that centralizes all our data to analytics accuracy and deeper analytics insights.|
|Datadog||for the provision of observability and real user monitoring.|
|DocRaptor||for the provision of generating PDF files.|
|Fastly||for the provision of a Content Delivery Network to speed up loading times by caching our pages.|
|Filestack||for the provision of uploading and optimizing assets (images, videos etc.)|
|Firebolt Analytics||a query optimization engine which sits on top of Databricks to provide fast and consistent response time.|
|Google Docs||for the provision of sharing documents and sheets internally.|
|Hevo Data||to facilitate data extraction and loading into Databricks.|
|HubSpot||Turtl’s main CRM for reasons including, but not limited to, marketing segmentation and communications), billing, record storage and product updates.|
|Intercom||for the provision of Customer Success tools to allow us to better support users of our platform.|
|MongoDB Atlas||for the provision of a managed database service.|
|OmniLab||for the provision of a media strategy and posting.|
|Pendo||for the provision of application usage metrics and to allow us to improve our platform and support.|
|RevM||for the provision of operation support in HubSpot and SalesLoft instances for campaign creation, segmentation, reporting and workflow builds.|
|SalesLoft||an outbound sales communication tool for email, calling and record keeping.|
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the Turtl Group. This will involve transferring your data outside the UK/EEA.
We ensure your personal data is protected by requiring all the Turtl Group to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.
Some of our external third parties are based outside the UK/EEA so their processing of your personal data will involve a transfer of data outside the UK/EEA.
Whenever we transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us using the relevant contact details above.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
California residents may submit requests for information under the CCPA to:
Email address: firstname.lastname@example.org
Postal address: 200 Berkeley Street, Boston, MA 02116, US
Please be specific when you exercise your rights under the CCPA and submit a request regarding your personal information. We need to verify your identify before we process your request.
Turtl will not discriminate against you in pricing or service for exercising any of your CCPA rights.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means any freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to you.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Whenever we refer to our Website in this document, we mean https://turtl.co, and any associated sub-domains.
Turtl processes personal data on your behalf as a Processor when performing our obligations under our license agreement, this includes any personal data that you elect to include in your Turtl Docs and/or any non-anonymised analytics data generated for the purpose of measuring the performance of your Turtl Docs. As a Processor, we will not process any personal data for any purpose other than those established by you as the Controller. We have a Data Processing Agreement in place covering all aspects of processing personal data which you can request from us by contacting us.