COLLECTING PERSONAL INFORMATION
What is personal information?
We consider information that personally identifies you or that can be used to contact you (such as your name, email address or billing information), and any data that is linked to such information, to be personal information.
What personal information is collected?
· When you purchase a product from the Site, we may collect your name, mailing and billing address(es), telephone number, email address and/or credit card or checking account information.
· When you create an account with the Site, we may collect your name and email address. In addition, you are required to establish a password to create an account with the Site.
· When you register a product, we may collect your name, address, telephone number and email address.
· When you join one of our mailing lists, we may collect your name and email address.
· When you contact our online customer support, we may collect your name, telephone number, email address and mailing address.
· When you register for contests or give-aways hosted by the Site, we may collect your name, email address, telephone number and/or address.
How is personal information used by Turtle Beach?
Turtle Beach collects and uses your personal information:
· To complete orders for products placed on the Site and to communicate with you about such orders (for example, order and shipment confirmations);
· To respond to requests for support or otherwise provide customer service;
· To inform you of other products or services available from Turtle Beach and its affiliates and about promotions and events;
· To conduct research about your opinion of current products and services or of potential new products or services;
· To notify you of the results of any contests or give-aways;
· To research and analyze data and trends to improve our products and services; and
· To send you important notices about the website and your account, including updates to terms and conditions.
In addition to your personal information, we may collect information that, by itself, does not specifically identify you. This non-personal information is used to help us learn what products are of the most interest to users and to improve Site design and content. Some examples of non-personal information that we collect and use are:
· When you register an account on the Site, in addition to collecting personal information, we may collect your age, gender and country of residence.
· When you purchase a product, create an account, register a product or contact customer support, in addition to collecting personal information, we may obtain information about the products that you own or use.
· When you are using our Site, we may log your IP address (a number that identifies your computer on the Internet) for system administration and troubleshooting purposes and to examine overall Site traffic trends.
The cookie, by itself, does not provide any personal information, such as your name or email address. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.) However, you may not be able to use some features of the Site if you set your browser to reject cookies.
The information collected by cookies may be collected directly by us, or it may be collected by a third-party service provider. These data are anonymous and are not linked to any information that personally identifies you.
SHARING YOUR INFORMATION & THIRD PARTY PARTNERSHIPS
On occasion, Turtle Beach may share personal information collected from the Site with selected third-party companies who assist Turtle Beach in providing products and services or in advertising and marketing efforts. The information we provide to third parties for such purposes may include your name, address, email address and purchase information, which will help arrange product delivery, provide customer support or target marketing communications. The third parties to whom we provide such information agree to keep it confidential, and may not use it to send advertisements or other communications on behalf of anyone other than Turtle Beach and its affiliates.
Turtle Beach does not sell, rent or lease its customer lists to third parties. Turtle Beach or the third-party companies that assist us with marketing may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your personal information is not transferred to the third party.
Links from the Site to Third-Party Websites
The Site may contain links to third-party websites. Turtle Beach is not responsible for the collection or use of personal information by such third-party websites. Please refer to the privacy policies of the third-party website to learn about how they handle your personal information.
Links to the Site from Third-Party Websites
Turtle Beach may use outside marketing companies to place advertisements or links to the Site on third-party websites. The marketing company or the operator of such third-party website may collect information about people who click on an advertisement for or link to the Site. Turtle Beach is not responsible for the collection or use of information by such marketing companies or third-party websites. Please refer to their privacy policies to learn about how they handle your personal information.
Merger or Acquisition
In the event that Turtle Beach is merged with or acquired by another company, or in the event of a transfer of our assets, we may disclose or transfer personal information and other information about usage of the Site in connection with such a transaction. In the event of such a transfer, we will notify you of the change of control of your personal information. You should also be aware that courts may have the authority under certain circumstances to permit personal information and other information about usage of the Site to be shared or transferred to third parties without your permission.
DISCLOSURE OF YOUR PERSONAL INFORMATION
SECURITY OF OUR SITE
We use encryption and authentication tools to protect the security of the information that you share with us. Once we receive your personal information via the Site, we do our best to protect its security on our systems. For example, we protect personal information we gather on a secured server that is located behind a firewall and not directly connected to the Internet.
Unfortunately, however, no transmission over the Internet can be guaranteed 100% secure. 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 Site, and you do so at your own risk. Accordingly, we disclaim liability for any theft, loss, or interception of or any unauthorized access or damage to any data or communications. By using the Site, you acknowledge that you understand and agree to assume these risks.
Please keep in mind that if you disclose personally identifiable information or personally sensitive data through public forums and bulletin boards on the Site, this information may be collected and used by others. You are responsible for the personal information that you choose to share on the Site’s public forums and bulletin boards.
In addition, anyone with access to the email address and password you use to create an account with the Site can obtain access to the personal information you have provided to us. We urge you to keep your password in a safe place and not share it with anyone. Always sign out from your account and close your browser window when you have finished your visit to our Site, especially if you are using a shared or public computer, to ensure that others cannot access your account. You are responsible for maintaining the confidentiality of your account password, and you are responsible for any access to or use of the Site by any person or entity using your password, whether or not such access or use has been authorized by you.
As a part of our commitment to your privacy, we agree to: (1) provide customers with notice of their ability to opt out of information rental, sale or exchange with other marketers; (2) honor customers’ requests not to share their information with other marketers; and (3) honor customers’ requests not to receive mail or email from Turtle Beach.
When registering with the Site, you are provided with the opportunity to “opt-in” to our promotional emails. If you have previously opted to receive, or otherwise currently receive, promotional emails from us, you may unsubscribe by following the “[unsubscribe]” link in our emails or by emailing [email@example.com]. Immediately after unsubscribing, you will no longer receive marketing emails from Turtle Beach. You may still receive e-mails regarding your transactions, for example, confirming that you have placed an order or that a product you have ordered has shipped.
CHILDREN AND PRIVACY
The Site is not intended for or directed to children under the age of 13 years. We will never request personally identifiable information from anyone whom we know to be under the age of 13 without verifiable parental consent. By using the Site, you represent and warrant that you are at least 13 years old. If we become aware that a customer is under the age of 13 and has registered without prior verifiable parental consent, we will remove his or her personally identifiable registration information.
A parent or legal guardian who needs to access, change or delete personal information regarding their child should contact [firstname.lastname@example.org].
Turtle Beach complies with the safe harbor framework set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from the European Union and Switzerland. To learn more about the safe harbor, please visit http://www.export.gov/safeharbor/.]
REVIEWING AND REVISING YOUR ACCOUNT INFORMATION
You may review and make changes to the personal information that is stored in your user account by logging into the applicable portion of the Site. To access, correct or request the deletion of other personal information in our possession, email [email@example.com]. We will honor such requests to the extent that the request is not unreasonably burdensome or infringe on the rights of others.
 Note to Draft: Consider whether Turtle Beach qualifies to self-certify under the framework and whether it is desirable to do so.