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PRIVACY POLICY

Last Revised: January 8, 2024


This privacy policy (“Privacy Policy”) describes the types of information Voyetra Turtle Beach, Inc. and its affiliates (collectively, “Turtle Beach,” “we,” “our,” and “us”) process about you. This Privacy Policy applies when you:


  • Visit or interact with our website, https://ca.turtlebeach.com, and our affiliated websites (the “Websites”);
  • Interact with us online, including through the use of live and automated chat functionalities on our Websites and via social media; 
  • Interact with us offline, such as by telephone; and
  • Use our software (collectively, the “Services”). 


By accessing or using the Services on any computer, mobile phone, tablet, or other device, making a purchase from Turtle Beach, or otherwise communicating or interacting with Turtle Beach, you agree to the terms of this Privacy Policy and our Terms of Use, which are incorporated here by reference. If you do not agree to our Privacy Policy and Terms of Use, please do not use the Services.


As detailed in the “Changes to this Policy” section below, we reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Please check this page periodically for changes. If the changes are significant, we may provide a more prominent notice, as required by law. Your continued use of the Services indicates your acceptance of any revised Privacy Policy.


COLLECTION OF PERSONAL INFORMATION

We collect information about you in various ways and from various sources, including using electronic means. For example, you may provide personal information directly to us, we may receive personal information about you from someone else, we may collect certain information about you automatically through your use of the Services, or we may obtain information about you from service providers and other entities who are acting on our behalf.



Personal Information You Provide To Us:

Personal information that you may provide to us directly, or that we may receive from a service provider acting on our behalf may include the following:


  • Basic contact details, such as your name, mailing address, billing address, telephone number, or email address. For example, we may collect this information when you register a product, join one of our mailing lists, or contact us with a question.

  • Transaction information, such as your shipping address and your purchase history when you purchase a product from our Websites.

  • Account information, such as your username. For example, we collect this information when you create an account with us.

  • Content of communications with you or between you and our service providers, including, but not limited to, questions or comments submitted by you to our customer support solutions (e.g., through telephone, email, live chat, automated chat, or otherwise). When you communicate with us or service providers that act on our behalf, you may include personal information in those communications. Please note that, when you contact us via one of our customer support solutions, especially via telephone or through the live and automated chat features, we may make, receive, and retain recordings of such calls and chats. By contacting us through these methods, you agree to our recording and retention of such information. To learn about the criteria we use to determine how long such information is retained, please see the section entitled “Data Security and Retention” below.

  • Content you submit to our Websites. If you choose to submit content to our Websites (e.g., an online product review), we may publish your name and other information you have provided to us. You hereby consent to this. Please see our general Terms of Use for more information.

  • Registration information for contests or giveaways. When you register for contests or giveaways hosted by the Services, we may collect your name, email address, telephone number, address, and other information as specified in such contest or giveaway.


Personal Information We Collect Automatically:

We may automatically collect certain information when you interact with the Services, which may include personal information. To do this, we may use cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “tracking technologies”) to collect information about your activities on our Websites and to allow us to customize portions of the Services to your preferences. The information we collect automatically may include: 

  • Your IP address, which is a number that identifies your computer on the Internet.

  • Your unique device identifier.

  • Your device type, such as mobile phone, computer, or tablet.

  • The type of browser and operating system you are using.

  • The domain name of your internet service provider.

  • The date and time of your visit, and/or the site from which you came, and the site to which you are going when you leave our Websites.

  • Your activity and behavior on our Websites, such as the information about the content you view and the features you access, the number of links you click within the Websites, which pages of our Websites you visit, what terms you use in searching the Websites, the links you click, how frequently you access the Services, and/or what products you purchase.

  • Whether you open emails or click the links contained in emails that we send you.

  • Location-based information, such as the state or country from the device you used to access our Services.

  • When you download software or software updates that we make available, we may collect the date and time of the download, and information about the device onto which the software is downloaded.


We may collect unique identification numbers associated with your device (including, for example, a Unique ID for Advertisers , Google AdID, or External ID), mobile carrier, device type, model and manufacturer, device operating system brand and model, phone number, and, depending on your device settings, your geographical location data (with your permission), or we may be able to approximate a device’s location by analyzing other information, like an IP address.


Depending on your device and operating system, you may not be able to delete or block all tracking technologies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.


We may collect information through third-party analytics scripts, which facilitate features on our Websites including, but not limited to, social features such as embedding links to our social media, customer support solutions such as live and automated chat features, fraud detection, and other similar features.


We may combine the information we collect through cookies with additional information we have collected from you or other sources. For more information about tracking technologies, please see the section entitled Cookies and Other Tracking Technologies below.


HOW WE USE PERSONAL INFORMATION

Turtle Beach uses your personal information:


  • To fulfill or meet the reason you provided the information. For example, when you place an order with us on our Websites, we will request certain information from you. This information is likely to include your name, email address, payment card details, billing address, shipping address, and telephone number. This information will be used to process your order, arrange delivery of your order, and correspond with you in relation to your order. Additionally, we may also save your information to facilitate new product orders or to process returns.

  • To provide, support, personalize, and develop our Services. For example, we may automatically record which Services you use to join our mailing list so that we communicate with you in that language in the future.

  • To create, maintain, customize, and secure your account with us.

  • To register your product with us.

  • To process your requests, purchases, transactions, and payments, and to prevent fraud. For example, when you place an order, we may share your name, physical and email address, and order details (date, amount, product) with third parties, such as Signifyd, for fraud prevention services. Signifyd’s privacy policy is available here: https://www.signifyd.com/privacy/.

  • To respond to requests for support or otherwise provide customer service via telephone, email, live and automated chat features, including to assist you with questions about our product features and to investigate and address your concerns and monitor and improve our responses.

  • To inform you of other products or Services available from Turtle Beach and its affiliates and about promotions and events, unless you have opted-out from such use (see section entitled Opting Out below).

  • To contact you to inquire whether you want to provide a review of the products you purchased or to provide other feedback regarding your purchase.

  • To conduct research about your opinion of current products and Services or of potential new products or Services, unless you have opted-out from such use (see section entitled Opting Out below).

  • To administer and communicate with you about contests or giveaways.

  • To research and analyze data and trends to improve our Services and our marketing and informational communications with you.

  • To personalize the Services, our Websites, and our advertising to you based on your perceived interests.

  • To send you important notices about the Websites, including updates to this Privacy Policy, the Terms of Sale and Terms of Use.

  • To help maintain the safety, security, and integrity of our Services, databases and other technology assets, and business.

  • For testing, research, analysis, and product development, including to develop and improve our Services.

  • To enforce contractual commitments that you may enter into with us, including, but not limited to, collection actions.

  • To respond to law enforcement requests or as required by applicable law, court order, or governmental regulations.

HOW WE SHARE PERSONAL INFORMATION

We may share the information we collect about you or that you provide to us for various purposes, including any personal information, such as in the following circumstances:

  • With our vendors or other service providers that assist us with our business activities, which could include:

  • Payment processors.

  • Shipping vendors.

  • Data analytics vendors.

  • Cloud storage providers.

  • IT service management vendors.

  • Email marketing services vendors.

  • Security vendors.

  • Vendors who assist us with facilitating our customer support solutions, such as our live and automated chat features.

  • Vendors that provide us with fraud prevention services, such as Signifyd. For example, when you place an order, we may share your name, physical address, and email address and order details (date, amount, product, etc.) with Signifyd for consumer fraud prevention services.

  • With our affiliates or otherwise within our corporate group.

  • With third parties for marketing and advertising purposes, such as through targeted advertising based on your perceived interests.

  • To other users on our Websites, such as when you post a product review, including your name or other information about you.

  • If it is necessary to identify, contact, or bring legal action against persons or entities who may be causing injury to you, to Turtle Beach, or to others, or to establish or defend claims.

  • If we are required to do so in order to comply with any valid legal and regulatory process or governmental request (such as a court order, search warrant, subpoena, civil discovery request, investigation, or statutory requirement).

  • In connection with an asset sale, merger, bankruptcy, or other business transaction. In the event that Turtle Beach is merged with or acquired by another company, or in the event of a transfer of some or all of our assets, we may disclose or transfer personal information and other information about usage of the Services in connection with such a transaction, at all times in compliance with applicable laws.

  • To enforce this Privacy Policy and our Terms of Use.

  • To ensure the safety and security of the Company and/or its users.

  • When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations.

  • To seek advice and consultation from lawyers, auditors, insurance companies, accounting firms, and other professional advisors.

  • As we otherwise believe is required and/or authorized by law.

COOKIES AND OTHER TRACKING TECHNOLOGIES

On occasion, Turtle Beach may use third-party advertising companies that use tracking technologies to serve our advertisements based on your online browsing history and interests across the Internet. These advertising networks, social media companies, and other third-party services may collect information about your use of our Services and third-party websites and your interaction with our advertising and other communications. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third-party advertising partners to help identify you across devices. These advertising companies serve ads on behalf of us and others on nonaffiliated sites, and some of those ads may be personalized, meaning that they are intended to be relevant to you based on information collected about your use of the Services and elsewhere over time. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. You have the choice to tell us not to collect and use this information, and in some jurisdictions, we will only engage in interest-based advertising if you opt-in. To learn more about interest-based advertising and how you may be able to opt out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative (“NAI”)’s online resources, at http://www.aboutads.info/choices or http://www.networkadvertising.org/choices, and you can opt out of receiving some interest-based advertisements on mobile apps by visiting http://www.aboutads.info/appchoices. You may also be able to limit interest-based advertising through the settings menu on your mobile device by turning off “personalized ads” (iOS) or selecting “opt-out of interest-based ads” (Android). You may also be able to opt out of some—but not all—interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app. In Canada, please visit: http://youradchoices.ca/choices/


Google Analytics and Advertising.  We use Google Analytics to recognize you and link the devices you use when you visit our site or Services on your browser, log in to your account on our Services, or otherwise engage with us. We share a unique identifier with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.


We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.



LINKS TO THIRD-PARTY WEBSITES AND SERVICES

Our Services may contain links to third-party websites or permit you to log in to third-party services, which may have privacy policies that differ from our own.


For example, Turtle Beach’s Swarm software may give users the option to log in to third-party services in order to enable “message waiting” and “incoming call” notifications from those third-party services or otherwise enhance the functionality of our Services.


Turtle Beach does not have control over and is not responsible for the privacy policies and practices of such third-party websites and services. Please refer to the privacy policies of the applicable third-party website or service to learn about how they handle your personal information before disclosing any personal information.


LINKS FROM THIRD-PARTY WEBSITES

Turtle Beach may use outside marketing companies to place advertisements or links to our Websites on third-party websites. The marketing company or the operator of such third-party websites may collect information about people who click on an advertisement for or link to our Websites. Turtle Beach does not have control and is not responsible for privacy policies and practices of such marketing companies or third-party websites. Please refer to their privacy policies to learn about how they handle your personal information before disclosing any personal information.


TEXT MARKETING AND NOTIFICATIONS

By entering your phone number in the checkout and initializing a purchase, subscribing via our subscription form, or a keyword, you agree that we may send you text notifications (for your order, including abandoned cart reminders) and text marketing offers. Text marketing messages will not exceed 30 a month. You acknowledge that consent is not a condition for any purchase.


If you wish to unsubscribe from receiving text marketing messages and notifications reply with STOP to any mobile message sent from us or use the unsubscribe link we provided you within any of our messages. You understand and agree that alternative methods of opting out, such as using alternative words or requests will not be accounted for as a reasonable means of opting out. Message and data rates may apply.


For any questions please text HELP to the number you received the messages from. You can also contact us for more information. If you wish to opt out please follow the procedures above.


DATA SECURITY AND RETENTION

Please be aware that, despite our reasonable efforts to protect your information, no transmission over the Internet can be guaranteed 100% secure, as no security measures are perfect or impenetrable. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to or from the Services, and you do so at your own risk.


Please keep in mind that if you disclose personal information through public forums and bulletin boards on the Services, we have no way of controlling this information and you understand that this information may be collected and used by others. You are responsible for the personal information that you choose to share on the Services’ public forums and bulletin boards.


We will retain your personal information for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. To determine the appropriate retention period for your personal information, we will consider the amount, nature, and sensitivity of the personal information, the potential risk from unauthorized use or disclosure, the purposes for which we process personal information and whether we can achieve those purposes through other means, and applicable legal requirements.


OPTING OUT OF PROMOTIONAL MAIL AND EMAILS

While we hope that the information included in this Privacy Policy has helped you better understand how we use and protect your information to provide you with better service, we understand that you may still choose to not receive marketing and promotional information (including surveys) from Turtle Beach or our partners. As a part of our commitment to your privacy, we agree to honor customers’ requests not to receive marketing or promotional mail or email from Turtle Beach.


If you have previously opted to receive, or otherwise currently receive, promotional emails from us, you may unsubscribe by clicking the “unsubscribe” link in the email or by emailing us at privacy@turtlebeach.com. Within a reasonable period of time after unsubscribing, you will no longer receive marketing mailings and/or emails from Turtle Beach. You may still receive emails regarding your transactions, for example, confirming that you have placed an order or that a product you have ordered has shipped.


CROSS-BOARDER TRANSFER

We have business operations in the United States and we may use service providers who are operating outside of Canada. This means that in some cases, personal information that we manage may be transferred, processed and stored outside Canada and therefore may be subject to foreign laws and available to government authorities under lawful orders in such foreign jurisdictions. When we transfer your personal information outside your country of residence to a service provider, we enter into contractual arrangements to ensure the adequate protection of your personal information. 


ACCESS REQUEST

We respect your right to access and correct your personal information. If you wish to exercise this right, please contact us using the contact information detailed in the How to Contact Us section below.


RIGHT TO LODGE COMPLAINTS

Turtle Beach is transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us using the contact information detailed in the How to Contact Us section below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in Canada.


For information on how you can file a privacy complaint with the Office of the Privacy Commission of Canada (OPC), please visit: https://www.priv.gc.ca/en/report-a- concern/file-a-formal-privacy-complaint/.


CHILDREN AND PRIVACY

The Services are not intended for or directed to those under the age of 18 years. We will never request personal information from anyone whom we know to be under the age of 18 without verifiable parental consent. By using the Services, you represent and warrant that you are at least 18 years old. If we become aware that a customer is under the age of 18 and has provided us with personal information, we will take commercially reasonable efforts to remove his or her personal information from our database.


A parent or legal guardian who needs to access, change, or delete personal information regarding their child should contact privacy@turtlebeach.com.


CHANGES TO THIS POLICY

Turtle Beach reserves the right to amend this Privacy Policy at any time. We will post all changes to this Privacy Policy on our websites, in which case we will update the “Last Revised” date at the top of this Privacy Policy, so you should review it periodically. Any such amendments to this Privacy Policy may apply to information we collect in the future as well as any information we obtained prior to such amendment. If we make a material change to this Privacy Policy, we will provide appropriate notice as required by law. If you do not agree to any updates to this Privacy Policy, please do not access or continue to use the Services.


HOW TO CONTACT US

If you have any comments on or questions about this Privacy Policy or believe that Turtle Beach has not adhered to this Privacy Policy or any applicable privacy law, please contact privacy@turtlebeach.com.


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