We understand the importance of protecting children's privacy in the interactive online world. The Services are not designed for, or intentionally targeted at, children under 18 years of age. It is not our policy to intentionally collect or maintain information about anyone under the age of 18. No one under the age of 18 should submit any personal information to us or the Services. Further, minors under 18 years of age may have the personal information that they have provided to us through the Services deleted by sending an email to USPrivacy@turtlebeach.com requesting deletion. 

As used in this Supplement, the term “personal information” means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device, or would otherwise qualify as “personal information” or “personal data” under U.S. State Privacy Laws (“personal information”).

 “Personal information” does not include: 

• De-identified or aggregated consumer information,
• Publicly available information from government records,
• Information excluded from the scope of the individual U.S. State Privacy Laws including, but not limited to, personal information covered by sector-specific privacy laws like the Fair Credit Reporting Act, the Graham-Leach-Bliley Act, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994, and
• Health or medical information covered by the Health Insurance Portability Accountability Act, the California Confidentiality of Medical Information Act or clinical trial data.

Sales, Sharing or Targeted Advertising

As further described in the “Interest-Based Advertising and Third-Party Partnerships” section of our Privacy Policy, we may “sell” or “share” your personal information (as those terms are defined by U.S. State Privacy Laws), subject to your right to opt out of such sales and sharing (see “Your Privacy Choices” below).

We do not “sell” or “share” the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

Sensitive Information

The following personal information elements we collect may be classified as “sensitive” under certain U.S. State Privacy Laws (“sensitive information”): account log-in in combination with any required security or access code, password or credentials allowing access to the account.

We use this sensitive information for the purposes set forth in our Privacy Policy. We do not use or disclose sensitive information for any purpose other than for what would reasonably be expected in connection with the Services, for detecting security incidents, fraud and other illegal actions, or for short term transient use. We do not sell sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.

Deidentified Information

We may at times receive, or process personal information to create, deidentified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified data, we will maintain and use the data in deidentified form and not attempt to reidentify the data except as required or permitted by law.

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

Submitting Privacy Rights Requests

You can submit a request to exercise one of the privacy rights identified above by:

• Calling us at (855) 868-5067;
  
  
• Submitting a request to us here; or
  
  
• Sending us an email to the following email address: USPrivacy@turtlebeach.com

Before processing your request, we may need to verify your identity and confirm you are a resident of a state that offers the requested right(s). Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include sending us an email from the address you used when establishing an account, placing an order, when signing up for our newsletters, when entering a contest, or by logging into your account and making the request through your account portal.
  
  
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

The response we provide will explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

• Deny you goods or services.
  
  
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  
  
• Provide you a different level or quality of goods or services.
  
  
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  

Please note that we may offer you certain financial incentives permitted by U.S. State Privacy Laws that can result in different prices, rates, or quality levels as described below.

To Exercise Your Right to Opt-Out of Personal information Sales or Sharing

As is common practice among companies that operate online, we allow certain third-party advertising networks, social media companies and other third party businesses to collect information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our website, use our apps or otherwise engage with us online. For example, these third parties may collect Internet/network information, such as a cookie or device ID, browsing history and website usage, geolocation data, and inferences generated from your browsing history and interactions with our service as well as other sites and services. These third parties use this information to serve relevant ads on our site, on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks. To learn more, please see our Privacy Policy.

By visiting here, you can opt out from sales of this type of personal information by businesses that participate in the opt-out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s App-based Opt-Out Tool, you can download the appropriate app at https://www.privacyrights.info/. We may also respond to opt-out preference signals on your browser or device.

To exercise the Right to Opt-Out of Personal information Sales or Sharing, you may also submit a request by clicking on the following link:

Submitting Authorized Agent Requests

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Appealing Privacy Rights Decisions

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted using our online form or by calling (855) 868-5067.