This privacy policy describes how Turtle Privacy & Security AB (“Turtle” or “we”) and our product (“Turtle App”) might collect and process your personal data, in compliance with applicable laws protecting your privacy, when you use Turtle’s privacy and security services.

Title 1 – Turtle Features you may use

Section 1. Privacy & Security Services in the Turtle App

Turtle App is a mobile application available on iOS (and soon to be available on Android) that helps you protect your online privacy and security.

By using the Turtle App, you are asking the Turtle App to make changes to your privacy settings and/or personal data. This is what we call “processing of your personal data”. When you open the Turtle App for the first time, you will see a pop-up displaying a link to this privacy policy.

Before using the Turtle App, please read this privacy policy carefully and agree to its terms to continue using the Turtle App. If you do not agree with this privacy policy, please do not use the Turtle App.

A. Functionalities

The Turtle App will never change anything in your accounts without your prior authorization. Consequently, we are only processing your data because you have consented to it and/or because we are performing a service you have requested from us.

(i) Subscription to certain plans

If you subscribe to certain services or plans (i.e. subscription services as described in our Terms of Service) your payment may be handled by third-parties such as Google, Apple or Stripe, depending on factors such as your phone’s make or model, the plan you choose, the country in which you are located, and the features made available to you.

We may provide these companies access to data required to process the payment for a Turtle subscription. Your personal data may be stored by us and/or these payment providers as required by tax regulations and/or payment network requirements (e.g. visa, mastercard, etc.)

For more information on how Apple, Google or Stripe may use your data, please consult Title 2 on Sub-Processors.

(ii) Change of the privacy settings of your online accounts

The Turtle App offers you the ability to scan the privacy settings on some of your online accounts and suggests changes to maximize your privacy. You can choose which of your online accounts you want Turtle to scan.

To provide this service, you are asked to log into your account(s) through the Turtle App. Your account authentication details, i.e., username and password, remain locally in your device during the whole process. We do not copy or store any of this personal data on Turtle servers/database.

In no event will your password be transmitted to Turtle Privacy. If you do not wish for your password to be stored locally within the Turtle App in your device, please do not use this feature. To delete your passwords, simply disconnect your account from the Turtle App.

(iii) Data breach feature

The Data Breach feature requires Turtle to process the email address(es) you want to protect and monitor and transmit it to our data breach service provider haveibeenpwned (see Title 2, Section 7 for more about this provider).

For security and privacy, the email address(es) you provide is transmitted as a “one-way-function” or hash, which looks like “324020b42e8f7706c14dc395f3b1f4ad72055ef” instead of e.g. [email protected].