This Privacy Policy describes how 1602002 B.C. Ltd. dba Turbobase (“Turbobase”, “we”, “us” or “our”) collects, uses and discloses personal information when you visit or interact with turbobase.io and its related webpages (collectively, the “Website”).
This Privacy Policy applies only to the Website and information collected in connection with the Website. It does not apply to the Turbobase platform or Customer Data processed through the Turbobase platform. Those activities are governed by the applicable customer agreement and related privacy terms.
1. Personal Information We Collect
Depending on how you interact with the Website, we may collect the following personal information:
Information you provide to us. When you submit an inquiry, request information or otherwise contact Turbobase, we may collect information such as your:
- first and last name;
- company name;
- company website;
- work email address;
- job title; and
- other information you choose to provide in your communications with us.
Technical and usage information. When you visit the Website, we and our service providers may automatically collect certain information about your visit, such as:
- IP address;
- browser and device information;
- operating system;
- pages viewed and interactions with the Website;
- date and time of access;
- referring website or source; and
- information collected through cookies and similar technologies.
We do not knowingly collect sensitive personal information through the Website and ask that you do not submit sensitive personal information through Website inquiry forms.
2. How We Use Personal Information
We may use personal information collected through the Website to:
- respond to inquiries and requests;
- communicate with you about Turbobase and our products and services;
- evaluate potential customer relationships;
- operate, maintain and secure the Website;
- understand how the Website is used;
- improve the Website and our communications;
- detect, prevent and investigate fraud, misuse and security incidents;
- maintain appropriate business and administrative records; and
- comply with applicable law and protect our legal rights.
Where permitted by applicable law, we may also use business contact information to send information about Turbobase, our products, services and events.
You may opt out of marketing emails at any time by using the unsubscribe mechanism included in the communication or by contacting us using the information below. Opting out of marketing communications will not prevent us from sending communications that are necessary to respond to your requests or administer an existing business relationship.
3. How We Disclose Personal Information
We may disclose personal information to third parties where reasonably necessary for the purposes described in this Privacy Policy, including:
- website hosting, infrastructure and security providers;
- customer relationship management and business communication providers;
- email and communications providers;
- analytics and technology providers;
- professional advisors, including legal and accounting advisors;
- government authorities, regulators or other persons where disclosure is required or permitted by law; and
- a purchaser, investor, successor or other relevant party in connection with a proposed or completed financing, merger, acquisition, reorganization, sale of assets or similar corporate transaction.
Service providers that process personal information on our behalf are permitted to use that information only as necessary to provide their services to us, subject to applicable contractual and legal requirements.
Turbobase does not sell personal information or share personal information for cross-context behavioural advertising or targeted advertising.
The Website may contain links to third-party websites or services, including social media services. This Privacy Policy does not apply to the privacy practices of those third parties. We encourage you to review their privacy policies before providing them with personal information.
4. Cookies and Similar Technologies
We and our service providers may use cookies and similar technologies in connection with the Website.
These technologies may include:
- necessary cookies, which are used to operate, secure and maintain the Website;
- functional cookies, which may be used to remember settings and improve Website functionality; and
- analytics cookies, which may be used to understand how visitors interact with the Website and improve its performance.
If Turbobase introduces advertising or marketing cookies, this Privacy Policy and our cookie controls will be updated as appropriate.
Where applicable law requires consent before a non-essential cookie or similar technology is used, we will obtain that consent before using the applicable technology. Where available, you may change your cookie preferences through our Website cookie controls. You may also be able to control cookies using your browser settings.
Disabling certain cookies may affect the operation or functionality of the Website.
Do Not Track and Opt-Out Signals
Some browsers provide “Do Not Track” signals or similar mechanisms. We do not currently respond to general browser Do Not Track signals except where required by applicable law.
Because Turbobase does not sell personal information or share personal information for cross-context behavioural advertising or targeted advertising, there is currently no sale, sharing or targeted advertising opt-out applicable to the Website.
Where applicable law requires us to recognize a legally valid opt-out preference signal for a processing activity in which we engage, we will do so.
5. Retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to respond to inquiries, maintain appropriate business records, manage existing or prospective business relationships, comply with legal obligations and resolve disputes.
The particular retention period will depend on the nature of the information, the purpose for which it was collected and applicable legal requirements.
When personal information is no longer reasonably required, we will delete, anonymize or otherwise dispose of it in accordance with applicable law and our retention practices.
6. Security
Turbobase uses reasonable administrative, technical and organizational safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration or loss.
No method of transmission over the Internet or method of electronic storage is completely secure. Accordingly, we cannot guarantee the absolute security of personal information.
7. International Processing and Transfers
Turbobase is based in British Columbia, Canada. We and our service providers may process personal information in Canada, the United States, the United Kingdom and other jurisdictions in which we or our service providers operate.
As a result, personal information may be subject to the laws of jurisdictions outside the jurisdiction in which you reside and may be accessible to courts, law enforcement agencies or governmental authorities in those jurisdictions in accordance with applicable law.
Where the European Union General Data Protection Regulation (“EU GDPR”), United Kingdom General Data Protection Regulation (“UK GDPR”) or another applicable law imposes requirements on an international transfer of personal information, we will take the steps required by applicable law, which may include relying on an adequacy decision or implementing appropriate contractual or other safeguards.
8. Canada Privacy Rights
Turbobase is responsible for personal information under its control and has designated a Privacy Officer to oversee its privacy practices.
Depending on applicable Canadian privacy law, you may have the right to:
- request access to personal information we hold about you;
- request correction of inaccurate or incomplete personal information; and
- withdraw consent to certain uses or disclosures of your personal information, subject to legal and contractual restrictions.
You may submit a request using the contact information in Section 12 below. We may take reasonable steps to verify your identity before responding.
You may also have the right to make a complaint to the privacy regulator having jurisdiction over your personal information.
9. United States Privacy Rights
Depending on where you reside and whether an applicable U.S. state privacy law applies to Turbobase, you may have certain rights regarding your personal information. These may include the right to:
- confirm whether we process your personal information;
- request access to or a copy of personal information;
- request correction of inaccurate personal information;
- request deletion of personal information;
- obtain certain personal information in a portable format;
- opt out of certain sales, sharing or targeted advertising;
- limit certain uses of sensitive personal information; and
- appeal a decision regarding a privacy request where provided by applicable law.
Turbobase does not sell personal information or share personal information for cross-context behavioural advertising or targeted advertising.
We will not discriminate against you for exercising a privacy right provided by applicable law.
To exercise an applicable privacy right, contact us using the information in Section 12 below. We may need to verify your identity before processing your request.
10. European Economic Area and United Kingdom
This Section applies where the EU GDPR or UK GDPR applies to Turbobase’s processing of your personal information.
Legal Bases for Processing
Depending on the circumstances, we may process personal information on one or more of the following legal bases:
Legitimate interests. We may process personal information where necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and interests. These interests include:
- responding to and managing business inquiries;
- developing and maintaining customer and prospective customer relationships;
- operating, securing and improving the Website;
- maintaining the security of our systems and business;
- understanding the use of the Website; and
- conducting ordinary business-to-business marketing.
Consent. We may rely on your consent where required by law, including for certain cookies, tracking technologies or marketing activities. Where we rely on consent, you may withdraw it at any time.
Contract or pre-contractual steps. Where applicable, we may process personal information where necessary to take steps at your request before entering into a contract or to perform a contract with you.
Legal obligations. We may process personal information where necessary to comply with a legal obligation.
Your EEA and UK Rights
Subject to applicable law, you may have the right to:
- access your personal information;
- correct inaccurate or incomplete personal information;
- request deletion of your personal information;
- restrict the processing of your personal information;
- receive certain personal information in a structured, commonly used and machine-readable format;
- object to certain processing based on legitimate interests;
- withdraw consent at any time where we rely on consent; and
- make a complaint to the applicable data protection supervisory authority.
You have the right to object at any time to the processing of your personal information for direct marketing purposes.
The exercise of these rights may be subject to limitations and exceptions under applicable law.
You may exercise your rights by contacting us using the information in Section 12.
We do not use personal information collected through the Website to make decisions based solely on automated processing that produce legal or similarly significant effects on individuals.
11. Children
The Website is intended for business and professional users and is not directed to children.
Turbobase does not knowingly collect personal information from children under the age of 13 through the Website. If we learn that we have collected personal information from a child contrary to applicable law, we will take reasonable steps to delete it.
12. Contact Us
Turbobase is responsible for personal information under its control.
Questions, requests or complaints regarding this Privacy Policy or Turbobase’s privacy practices may be directed to:
Privacy Officer: Adam Kundrat
1602002 B.C. Ltd. dba Turbobase
British Columbia, Canada
Email: privacy@turbobase.io
EU Representative: Adam Kundrat
UK Representative: Adam Kundrat
13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to the Website, our privacy practices or applicable law.
When we make changes, we will post the updated Privacy Policy on the Website and revise the Effective Date above. Where required by applicable law, we will provide additional notice or obtain consent before a material change takes effect.