Privacy Policy

TurboApproval (the "Company") respects your privacy and is committed to protecting it through this privacy policy (the "policy"). This policy describes the types of information the Company may collect from you or that you may provide when you use the services offered by the Company ("Services") on www.turbo-approval.com ("Website") and the Company's practices for collecting, using, keeping, protecting, and disclosing that information.

This policy applies to information the Company collects:

• When registering for or using the Services.
• In email, text, and other electronic messages between you and the Company.
• When you interact with the Company's advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
• When you interact with the Services through third-party social media platforms.

It does not apply to information collected by:

• the Company offline or through any other means, including on any other website or service operated by the Company or any third-party (including the Company's affiliates and subsidiaries); or
• any third-party (including the Company's affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible through the Website or the Services.

This Privacy Policy also explains how we process 'personal data' about people in the European Union (EU), as required under the General Data Protection Regulation (GDPR).

1. Are minors welcome?

The Services are not intended for persons under 18-years old. You will only access the Services or register if (1) you are at least 18-years old and (2) have reached the age of majority where you live. The Company prohibits all persons who do not meet the age requirements from accessing the Services. Minors must not access the Services.

The Company does not knowingly collect any information about children, minors, or anyone under the age of majority. Nor does the Company knowingly market to children, minors, or anyone under 18-years old. If you are under 18-years old, you must not submit information to the Company and must leave the Website. If the Company becomes aware that a child, minor, or anyone under 18-years old has registered with the Website and provided the Company with personal information, the Company will take steps to cancel that account. If the Company cancels your account because you are under 18-years old, the Company may keep your email and IP address to ensure that you do not elude the rules by creating a new account.

2. What types of information does the Company collect about you and how is it collected?

The Company may collect several types of information from and about users of the Website or Services, including information:

• by which you may be personally identified, including your name, postal address, email address, telephone number, date of birth, social security number/federal employment identification number, or any other information that the Company collects that is defined as personal or personally identifiable information under law ("personal information");
• that is about you but individually does not identify you, including your age, gender, location, and any other optional information you provide about yourself; or
• about your Internet connection, the equipment you use to access the Website or the Services, and usage details.

The Company collects this information:

• Directly from you when you provide it to the Company.
• Automatically as you navigate through the Website or the Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, the Company's business partners.

The information the Company collects on or through the Website or the Services may include:

• Information that you provide by filing in forms associated with the Services. This includes information provided at the time of registering to use the Services, signing up for an account, or requesting further services. Such information specifically includes your social media username, password, and other access information. The Company may also ask you for information when you report a problem with the Services.
• Records and copies of your correspondence (including email addresses), if you contact the Company.
• Your responses to surveys that the Company might ask you to complete for research purposes.
• Details of transactions you carry out through the Website or the Services and of the fulfillment of your requests. You may be required to provide financial information before placing an order through the Website or receiving payment from the Company.
• Your search queries on the Website.
• Your social media accounts associated with the Services.

You also may provide information to be published or displayed ("posted") through the Services, or transmitted to other users of the Services or third parties (collectively, "user contributions"). Your user contributions are posted through the Services and transmitted to others at your own risk. Although you may set certain privacy settings for this information by logging into your account, please be aware that no security measures are perfect or impenetrable. Additionally, the Company cannot control the actions of other users of the Services with whom you may choose to share your user contributions. Thus, the Company cannot and does not guarantee that your user contributions will not be viewed by unauthorized persons.

Information the Company Collects through Automatic Data Collection Technologies

As you navigate through and interact with the Website or the Services, the Company may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your activities associated with the Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Services.
• Information about your computer and Internet connection, including your IP address, device ID, operating system, and browser type.
• Information about your mobile device and Internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number. This information may also include details about your mobile carrier, your precise geographic location information, and other information described in this policy.

The information the Company collects automatically is statistical data and does not include personal information, but the Company may keep it or associate it with personal information the Company collects in other ways or receives from third parties. It helps the Company to improve the Services and to deliver a better and more personalized service, including by allowing the Company to:

• Estimate the Services' audience size and usage patterns.
• Store information about your preferences, thus allowing the Company to customize the Services according to your individual interests.
• Speed up your searches.
• Recognize you when you return to the Services.

The technologies the Company uses for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Your browser stores cookies in a manner associated with each website you visit. The Company uses cookies to enable its servers to recognize your browser and tells the Company how and when you visit the Website and use the services. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, the Company's system will issue cookies when you direct your browser to the Website. If you want to learn more about cookies, please visit www.allaboutcookies.org.
• Flash Cookies. Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, you can access your Flash management tools from Adobe's website.
• Web Beacons. Pages of the Website (and the Company's emails) may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages (or opened an email) and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). If you want to learn more about web beacons, please visit www.allaboutcookies.org/web-beacons/.

The Company does not collect personal information automatically, but it may tie this information to personal information about you that the Company collects from other sources or you provide to the Company.

3. How does the Company use your information?

The Company may use information that it collects about you or that you provide to the Company, including any personal information:

• To present the Website or the Services and their contents to you.
• To provide you with information, products, or services that you request from the Company.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account, including expiration and renewal notices.
• To carry out the Company's obligations and enforce its rights arising from any contracts entered into between you and the Company, including for billing and collection or to receive payment from the Company.
• To notify you about changes to the Services or any products or services the Company offers or provides through the Services.
• To allow you to participate in any interactive features on the Services.
• To monitor and analyze trends, usage, and activities in connection with the Services and for marketing or advertising purposes.
• To investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities.
• In any other way the Company may describe when you provide the information.
• For any other purpose with your consent.

4. With whom does the Company share your information?

TurboApproval will not share, sell, or otherwise distribute your personal information without your consent. However, TurboApproval may disclose personal information that we collect or you provide as described in this Policy:

• To fulfill the purpose for which you provide your information.
• For any other purpose disclosed by TurboApproval when you provide us your information.
• To protect the rights of TurboApproval and/or any third parties.
• To third-party service providers who assist us in operating this Website, conducting our business, or serving our users, so long as such information is kept confidential.
• To comply with any court order, law, legal process, and/or government or regulatory request.
• As part of a liquidation or bankruptcy proceeding, to a buyer or other successor in the event of a merger, reorganization, dissolution, or divestiture of some or all of TurboApproval's assets.

We use the information that we collect about you through your interaction with this Website as well as information that you provide to us, including personal information. This information is used:

• To present the contents of this Website to you.
• To deliver services that you have requested.
• To determine whether to extend an offer.
• To communicate with you via telephone, email, postal mail, and/or text message from us.
• To display advertising tailored to your interests or background.
• To perform data and statistical analysis from your use of this Website.
• To enforce our Terms and Conditions.
• To perform any other functions otherwise described to you when you provide us with your information.

The Company may also disclose your personal information:

• To comply with any court order, law, or legal process, including responding to any government or regulatory request.
• To enforce or apply the terms of use and other agreements, including for billing and collection purposes or to receive payment from the Company.
• If the Company believes disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, its customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

5. What choices do you have about how the Company uses and discloses your information?

The Company strives to provide you with choices about the personal information you provide to the Company. The Company has created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. To learn how you can manage your other cookies, visit www.allaboutcookies.org/manage-cookies/. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. Information gathered in the SMS campaign will not be shared with Third Parties or Affiliates for Marketing Purposes. You can also always opt-out by sending the Company an email to change user settings at support@turbo-approval.com or by replying STOP to any SMS message sent in the last 30 days.
• Promotional Offers from the Company. If you do not want to have your email address used by the Company to promote its own or third parties' products or services, you can opt-out by changing your email settings in your account or by sending the Company an email at support@turbo-approval.com. If the Company has sent you a promotional email, you may send the Company a return email asking to be omitted from future email distributions or click on the "unsubscribe" link at the bottom of the email. This opt-out does not apply to information provided to the Company as a result of a service purchase or other transactions.
• Targeted Advertising. If you do not want the Company to use information that it collects or that you provide to it to deliver advertisements according to its advertisers' target-audience preferences, you can opt-out by changing your email settings in your account. You can also always send the Company an email at support@turbo-approval.com or by replying STOP to any SMS message sent in the last 30 days

The Company does not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

6. How do you access and correct your information?

You can review and change your personal information by logging into the Website and visiting your account profile page. You may also email us at support@turbo-approval.com to request access to, correct, or delete any personal information that you have provided to the Company. The Company cannot delete your personal information except by also deleting your account. The Company will not accommodate a request to change information if it believes the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your user contributions from the Services, copies of your user contributions might remain viewable in cached and archived pages, stored on third-party networks, or might have been copied or stored by other users. The Website's terms of use govern proper access and use of the Services.

7. How does the Company protect your personal information?

The Company has implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, change, and disclosure. All information you provide to the Company is stored on its secure servers behind firewalls. The Company encrypts all payment transactions using SSL technology.

The safety and security of your information also depends on you. Where the Company has given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. The Company asks you not to share your password with anyone. In addition, the Company urges you to be careful about giving out information through the Services. The information you share online may be viewed by any user of the Services or third-party network.

Warning: The transmission of information over the Internet is not completely secure. Although the Company does its best to protect your personal information, the Company cannot guarantee the security of your personal information transmitted through the Website or the Services. Any transmission of personal information is at your own risk. The Company is not responsible for circumvention of any privacy settings or security measures used by the Company.

8. International Users

This policy is intended to cover the collection of information on or through the Website or the Services from residents of the United States. If you are visiting the Website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where the Company's servers are located. The data protection and other laws of the United States might not be as comprehensive as those in your country. Please be assured that the Company seeks to take reasonable steps to make sure that your privacy is protected. By using the Company's services, you acknowledge that your information may be transferred to the Company's facilities and those third parties with whom the Company shares it as described in this policy. When you provide personal information to the Company through the Website or the Services, you consent to the processing of your data in, and the transfer of your data to, the United States, or any other country in which the Company or its affiliates, subsidiaries, or service providers host these services.

9. Do Not Track Policy

Do Not Track ("DNT") is a privacy preference that you can set in your browser. DNT is a way for you to inform websites and services that you do not want certain information about your webpage visits collected over time and across websites or online services. The Company is committed to providing you with meaningful choices about the information it collects and that is why the Company provides you the ability to opt-out. However, the Company does not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. For more information, visit www.allaboutdnt.com.

10. Your California Privacy Rights

California Civil Code § 1798.83 permits users of the Website that are California residents to request certain information about the Company's disclosure of personal information to third parties for their direct marketing purposes. To make this request, please send the Company an email at support@turbo-approval.com.

Further, if you are a California resident and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please send the Company an email at support@turbo-approval.com. Please be advised that if you opt-out from permitting your personal information to be shared, you may still receive selected offers directly from the Company in accordance with California law.

11. Use of Data

TurboApproval uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

12. Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), TurboApproval legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

TurboApproval may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it's not overridden by your rights
• For payment processing purposes
• To comply with the law

13. Retention of Data

TurboApproval will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

TurboApproval will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

14. Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

TurboApproval will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

15. Disclosure of Data in a Business Transaction

If TurboApproval is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

16. Disclosure for Law Enforcement

Under certain circumstances, TurboApproval may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

17. Legal Requirements

TurboApproval may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of TurboApproval
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

18. Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

19. "Do Not Track" Signals

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

20. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. TurboApproval aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update, or to delete the information we have on you. Whenever made possible, you can access, update, or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where TurboApproval relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

21. Service Providers

We may employ third-party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services, or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

22. Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

• Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
• You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
• For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

23. Behavioral Remarketing

TurboApproval uses remarketing services to advertise on third-party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize, and serve ads based on your past visits to our Service.

• Google AdWords. Google AdWords remarketing service is provided by Google Inc.
• You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
• Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
• For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

24. Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g., payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• PayPal or Braintree. Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

25. Links to Other Websites

The Website may contain links to other websites. Please be aware that the Company is not responsible for the content or privacy practices of those other websites. The Company encourages its customers to be aware when they leave the Website and to read the privacy statements of any other website that collects personally identifiable information.

26. No Rights of Third Parties

This policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the Website or the Services.

27. Changes to Privacy Policy

The Company will post any changes it makes to this policy on this page. If the Company makes material changes to how it treats your personal information, the Company will notify you by email to the email address identified in your account or through a notice on the Website homepage. This policy identifies when the Company last updated it at the top of the page. You are responsible for making sure the Company has an up-to-date active and deliverable email address for you, and for frequently visiting the Website and this policy to check for any changes.

28. Contact Information

To ask questions or comment about this policy and the Company's privacy practices, contact the Company at support@turbo-approval.com.