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© Turtle Island 2022

Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy has been created with the help of the Privacy Policy Template.

As far as EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016. You can, of course, read this basic EU data protection regulation online on EUR-Lex, the access to EU law, at EUR-Lex - 32016R0679 - EN - EUR-Lex (europa.eu)

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Turtle Island, Puntigamerstraße 7, 8041 Graz, Austria.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: Austria

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

Service refers to the Website.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to Turtle Island, accessible from www.turtle-island.at

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Newsletter - Sendinblue

We offer you the opportunity to register for our free newsletter on our website. We use Sendinblue to send newsletters. Sendinblue is a service provided by the company Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, hereinafter referred to as "Sendinblue". For more details please check https://www.sendinblue.com/legal/privacypolicy/

If you sign up to receive our newsletter, the data requested during the registration process (your email address) will be processed by Sendinblue. For this your IP address and the date of your registration will be saved along with the time. As a further part of the registration process, your consent to the sending of the newsletter will be obtained, the content will be described in concrete terms and reference made to this data protection declaration.

Sendinblue offers further data protection information. The newsletters sent by Sendinblue contain technologies by which we can analyse whether and when an email was opened and whether and which links contained in the newsletter were followed. We save this data in addition to the technical data (system data and IP address) so that the respective newsletter can be best tailored to your wishes and interests. The data thus collected is used to continuously improve the quality of our newsletters.

The legal basis for sending the newsletter and the analysis is Art. 6 Para. 1 lit. a.) EU General Data Protection Regulation (GDPR).

Consent to the newsletter being sent can be revoked at any time with future effect in accordance with Art. 7 Para. 3 GDPR. To do this, you only have to inform us of your revocation or click the unsubscribe link contained in each newsletter.

Google Analytics

On this website, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics the controller uses the application “gat. anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://policies.google.com/privacy?hl=en and under https://marketingplatform.google.com/about/analytics/terms/us/ Google Analytics is further explained under the following Link https://marketingplatform.google.com/about/analytics/

Meta (Facebook & Instagram)

On this website, the controller has integrated components of the enterprise Meta. Meta is a social network.

A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Meta allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Meta is Meta, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Meta Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Meta component (Meta plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Meta component from Meta through the Meta component. An overview of all the Meta Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Meta is made aware of what specific sub-site of our website was visited by the data subject.

If the data subject is logged in at the same time on Meta, Meta detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Meta component and associated with the respective Meta account of the data subject. If the data subject clicks on one of the Meta buttons integrated into our website, e.g. the “Like” button, or if the data subject submits a comment, then Meta matches this information with the personal Meta user account of the data subject and stores the personal data.

Meta always receives, through the Meta component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Meta during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Meta component or not. If such a transmission of information to Meta is not desirable for the data subject, then he or she may prevent this by logging off from their Meta account before a call-up to our website is made.

The data protection guideline published by Meta, which is available for Facebook at https://www.facebook.com/about/privacy/ and for Instagram at https://help.instagram.com/519522125107875 provides information about the collection, processing and use of personal data by Meta. In addition, it is explained there what setting options Meta offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Meta. These applications may be used by the data subject to eliminate a data transmission to Meta.

Stripe Privacy Policy

On our website we use a payment tool by Stripe, an American technology company and online payment service. Stripe Payments Europe (Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland) is responsible for customers within the EU. Therefore, if you choose Stripe as your payment method, your payment will be processed via Stripe Payments. Hence, the data required for the payment process is forwarded to Stripe where it is then stored. In this privacy policy we will give you an overview of Stripe’s data processing and retention. Moreover, we will explain why we use Stripe on our website. The technology company Stripe offers payment solutions for online payments. Stripe enables us to accept credit and debit card payments in our webshop while it handles the entire payment process. A major advantage of Stripe is that you never have to leave our website or shop during the payment process. Moreover, payments are processed very quickly via Stripe.

If you choose Stripe as your payment method, your personal data (transaction data) will be transmitted to Stripe where it will be stored. These data include the payment method (i.e. credit card, debit card or account number), bank sort code, currency, as well as the amount and the payment date. During a transaction, your name, email address, billing or shipping address and sometimes your transaction history may also be transmitted. These data are necessary for authentication. Furthermore, Stripe may also collect relevant data for the purpose of fraud prevention, financial reporting and for providing its services in full. These data may include your name, address, telephone number as well as your country in addition to technical data about your device (such as your IP address).

Stripe does not sell any of your data to independent third parties, such as marketing agencies or other companies that have nothing to do with Stripe. However, data may be forwarded to internal departments, a limited number of Stripe’s external partners or for legal compliance reasons. What is more, Stripe uses cookies to collect data. 

Generally, personal data are stored for the duration of the provided service. This means that the data will be stored until we terminate our cooperation with Stripe. However, in order to meet legal and official obligations, Stripe may also store personal data for longer than the duration of the provided service. Furthermore, since Stripe is a global company, your data may be stored in any of the countries Stripe offers its services in. Therefore, your data may be stored outside your country, such as in the USA for example. 

Stripe is still a participant of the EU-U.S. Privacy Shield Framework which regulated correct and secure transfer of personal data until July 16, 2020. However, since the European Court of Justice declared the agreement to be invalid, the company no longer relies on this agreement, but still acts according to the principles of Privacy Shield. 

You always reserve the right to information, correction and deletion of your personal data. Should you have any questions, you can contact the Stripe team at https://support.stripe.com/contact/email.

You can delete, deactivate or manage cookies in your browser that Stripe uses for its functions. This works differently depending on which browser you are using. 

We have now given you a general overview of Stripe’s data processing and retention. If you want more information, Stripe’s detailed privacy policy at https://stripe.com/at/privacy is a good source.

Paypal Privacy Policy

For processing payments, we offer additionally to Stripe the payment service of the third-party company PayPal. When you make a purchase from us, your payment data (for example, name, payment amount, account details, credit card number) will be processed by the payment service provider. The respective contractual and data protection provisions of the provider apply to these transactions, which can be viewed here at PayPal.

The legal basis for the use of payment services is Article 6, Paragraph 1, Section 1, Point b of the GDPR (contract processing). Insofar as your consent is requested for certain actions, Article 6, Paragraph 1, Section 1, Point a of the GDPR is the legal basis for data processing; consents can be revoked at any time for the future.

The following data is transmitted to PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg:

Price

Product

Language (ISO 639 code)

Invoice and delivery addresses


By selecting this payment option, you agree to the disclosure of personal data required for payment processing.

This disclosure is necessary to process your order with the payment method you have selected, in particular to confirm your identity, to administer your payment and the customer relationship. Please note however, that personal data may also be disclosed by PayPal to service providers, subcontractors or other affiliated companies to the extent necessary to fulfill the contractual obligations arising from your order or to process the personal data on your behalf. Depending on the payment method selected via PayPal, e.g., invoice or direct debit, the personal data disclosed to PayPal will be transmitted by PayPal to credit agencies. This transmission serves to check your identity and creditworthiness in relation to the order you have placed. You can find out which credit agencies are involved and which data is generally collected, processed, stored and passed on by PayPal in PayPal's privacy policy: https://www.paypal.com/us/webapps/mpp/ua/privacy-full

Embedded YouTube Videos

On some parts of our website we embed Youtube videos. The corresponding plug-ins are operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. When you visit a page with the YouTube plug-in, it connects to servers of Youtube. Youtube will be informed which pages you visit. If you are logged into your Youtube account, Youtube can assign your surfing behavior to you personally. This can be prevented by logging out of your Youtube account. If a Youtube video is started, the provider uses cookies that collect information about user behavior.

Anyone who has disabled the storage of cookies for the Google Ad program will not have to expect such cookies when watching YouTube videos. Youtube also stores non-personal usage information in other cookies. If you want to prevent this, you must block the storage of cookies in the browser.

For more information on data protection at "Youtube", see the privacy policy of the provider at: https://www.google.de/intl/en/policies/privacy/ or https://support.google.com/youtube/topic/9257518?hl=en&ref_topic=9257107

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Email address

First name and last name

Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

·         Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

·         Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at https://www.adobe.com/products/flashplayer/end-of-life.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_

·         Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies: Cookies by PrivacyPolicies Generator.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.

To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

To manage Your requests: To attend and manage Your requests to Us.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

·         With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.

·         For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

·         With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

·         With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

·         With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

·         With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

·         Comply with a legal obligation

·         Protect and defend the rights or property of the Company

·         Prevent or investigate possible wrongdoing in connection with the Service

·         Protect the personal safety of Users of the Service or the public

·         Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

·         By email: office@turtle-island.at

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