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  1. Green Turtle Kava PRIVACY POLICY

Last Modified: June 29, 2021

  1. Introduction

Green Turtle Kava “GTK” is dedicated to protecting your personal information and informing you about how we use your information. This privacy policy applies to your use of GTK services including our website and services (collectively “Platform”). This Privacy Policy should be read in conjunction with the Terms of Use and is integrated into the Terms of Use. All capitalized proper nouns not defined in this Agreement will have the same definitions and meanings as defined by the Terms of Use. Please review this Privacy Policy periodically as we may revise it from time to time. If you do not agree with or accept our Privacy Policy in it’s entirety, you must not access or use the Platform. If you use the Platform following a change to the terms of this Privacy Policy you agree to accept the revised policies.

  1. Information Collected

At GTK, we collect personally identifiable information (“PII”) and non-personally identifiable (“Non-PII”) information from you. Personally identifiable information is information that can be used to identify you personally. Non-personally identifiable information is information that must be combined with other information to identify you personally.

Personally Identifiable Information Collected

You will not be required to provide us any information when you visit our Platform. However, in order to fully use our Platform, we may collect PII such as your name, date of birth, email, telephone number, website and business information, and address. We may also collect your relevant payment or credit card information if you wish to pay for any services offered via the Platform. Please be aware that all payment information shall be stored and processed by our third party payment processors.

Non-Identifying Information

Whenever you use our website, we may collect Non-PII from you, such as your IP address, zip code, gender, browsing history, search history, and registration history, interactions with the Platform, usage information, location, referring URL, browser, operating system, data usage, data transferred, and Internet service provider. We may also collect information including but not limited to postings you make on the public areas of our website, messages you send to us, and correspondence we receive from other members or third parties about your activities or postings.

  1. Use of Your Information

Some of your information will be visible to other users of the Platform to facilitate communication between users. We will never sell your information without your permission; however you agree that we may use your information in the following ways:

  • To provide any services offered and to operate GTK Platform.
  • To enhance or improve our users’ experiences.
  • To contact you via email or other electronic communications where you have an inquiry.
  • To notify you of additional GTK services and updates.
  • To share with third parties, with whom you have requested additional information relating to their products and services.
  • To process your transactions.
  • To share your information with third party partners or third parties hired by us to perform functions and provide services to us subject to the obligations consistent with this Privacy Policy and on the condition that the third parties use your information only on our behalf and pursuant to our instructions.
  1. Anonymized Data

Please be aware that we me may collect and aggregate personally identifiable information from our Platform and may anonymize that information for our own research or internal purposes. Once such data has been anonymized, it cannot be traced back to you, the user.

  1. Accessing, Editing, and Removing Your Information

You will be able to access any information contained in your account through our Platform. You may edit that information by removing or changing the information listed in your account. If you have any questions or wish to review, remove, change, or access any of your information collected by us, please contact us by submitting a ticket here. After you have cancelled your account please be aware that we may keep inaccessible copies of your PII and non-PII subject to our data retention policies.

  1. Permanent Removal Requests

If you wish to have any of your PII stored within GTK Platform permanently removed, please follow our instructions as stated within the policy titled “Removal of Information”. If you have any questions regarding such removal please contact us by submitting a ticket here.

  1. Cookies and Tracking

We use cookies as stated within our Cookie Policy. Cookies must be enabled in your browser in order for our Platform to function properly. Additionally, while using portions of our Platform, we may track your usage information so that we understand how you interact with our Platform. If you disable cookies from your web browser some portions of our Platform may not work.

  1. Third Party Access to Your Information

Although you are entering into an Agreement with GTK to disclose your information to us, we do use third party individuals and organizations to assist us, including contractors, web hosts, and others to allow you to access the Platform.

Throughout the course of our provision of our services to you, we may delegate our authority to collect, access, use, and disseminate your information. It is therefore necessary that you grant the third parties we may use in the course of our business the same rights that you afford us under this Privacy Policy. For this reason, you hereby agree that for every authorization which you grant to us in this Privacy Policy, you also grant to any third party that we may hire, contract, or otherwise retain the services of for the purpose of operating, maintaining, repairing, or otherwise improving or preserving our website or its underlying files or systems. You agree not to hold us liable for the actions of any of these third parties, even if we would normally be held vicariously liable for their actions, and that you must take legal action against them directly should they commit any tort or other actionable wrong against you.

  1. Law Enforcement

You agree that we may disclose your information to authorities if compelled to by a court order. Additionally, you agree that we may disclose your information if we reasonably believe that you have violated US laws, the terms of our Terms of Use or our Privacy Policy, or if we believe that a third party is at risk of bodily or economic harm. In the event that we receive a subpoena affecting your privacy, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either. We may also proactively report you and release your information without receiving any request to third parties where we believe that it is proper to do so for legal reasons, where your actions violate any law of the United States or any other country having jurisdiction over us, our Platform, or our Terms of Use. You release us from any damages that may arise from or relate to the release of your information to a request from law enforcement agencies or private litigants. We may release your information under the conditions listed in this paragraph whether it is to individuals or entities and to any state or federal authorities, as required.

  1. Opt Out of Commercial, Non-Commercial Communications and Do Not Track

If you decide to provide us with your contact information, you agree that we may send you communications via text and emails. However, you may unsubscribe from certain communications by notifying GTK that you no longer wish to receive these communications, we will endeavor to promptly remove you from our once we have received that request. We currently do not offer functionality for you to opt out through “do not track” listings. If you wish to opt out of certain communications or information collection, please contact us by submitting a ticket here.

  1. Third Parties

GTK or other users may post links to third party websites on Platform, which may include information that we have no control over. When accessing a third party site through our Platform, you acknowledge that you are aware that these third party websites are not screened for privacy or security issues by us, and you release us from any liability for the conduct of these third party websites.

Please be aware that this Privacy Policy, and any other policies in place, in addition to any amendments, does not create rights enforceable by third parties. GTK bears no responsibility for the information collected or used by any advertiser or third party website. You must review their Terms of Use and Privacy to understand how their information collection practices work.

  1. Security Measures

We make reasonable attempts to protect your information by using physical and electronic safeguards. For this reason we use SSL certificates to enhance our Platform security. However, as this is the Internet, we can make no guarantees as to the security or privacy of your information. For this reason, we recommend that you use anti-virus software, routine credit checks, firewalls, and other precautions to protect yourself from security and privacy threats.

  1. Your California Privacy Rights

GTK permits residents of the State of California to use its Platform, and complies with the California Business and Professions Code §§ 22575-22579. If you are a California resident you may request certain information regarding our disclosure of personal information to any third parties for their direct marketing purposes. Various provisions throughout this Privacy Policy address requirements of the Californian privacy statutes. Although we do not disseminate your information to third parties without permission, you must presume that we collect electronic information from all visitors. You may contact us by submitting a ticket here with any questions.

  1. Age Compliance

We intend to fully comply with American and international laws respecting children’s privacy including COPPA. Therefore, we do not collect or process any information for any persons under the age of 18. If you are under 18 and using our Platform, please stop immediately and do not submit any information to us. In the event that we have inadvertently collected any information from users under the age of 18 please contact us immediately.

  1. International Transfer

Your information may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. PII and Non-PII that is submitted to GTK will be collected, processed, stored, disclosed and disposed of in accordance with applicable U.S. law and this policy. If you are a non-U.S. member, you acknowledge and agree that GTK may collect and use your Information and disclose it to other entities outside your resident jurisdiction. In addition, such information may be stored on servers located outside your resident jurisdiction. U.S. law may not provide the degree of protection for information that is available in other countries.

  1. Merger and Acquisition

In the event that GTK is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. Please be aware that once the information is transferred your privacy rights may change.

  1. Amendments

Like our Terms of Use, we may amend this Privacy Policy from time to time. When we amend this Privacy Policy, we will modify the date listed on this Agreement or we may contact you. You must agree to the amendments as a condition of your continued use of our Platform. If you do not agree, you must immediately cease using our Platform and notify us of your refusal by submitting a ticket here.

  1. Privacy Notice for European Citizens

We respect the rights of persons living within the European Economic Community (EEC) and the rights afforded to them under the General Data Protection Regulation (GDPR), the sections 18-23 are referred to as our Privacy Notice and address additional privileges that EEC users may have under our Privacy Policy. This Privacy Notice explains how we shall assist our users who live within the EEC.

Legal Rights Your Rights Under the GDPR
The right to be informed GTK wishes to keep you informed as to what we do with your personal information. We strive to be transparent about how we use your data.
The right to access You have the right to access your information at any time. Please contact us by submitting a ticket here if you wish to access the personal information GTK holds about you.
The right to rectification If the information GTK holds about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data. Please contact us by submitting a ticket here for more information.
The right to erasure Sometimes called ‘the right to be forgotten’. You have the right to request that GTK to erase all your personal data, if you wish to do so please our team by submitting a ticket here.
The right to restrict processing You have the right to ask GTK to restrict how we process your data. This means we are permitted to store the data but not further process it. We will only keep enough data to ensure that we can accommodate any additional requests. Please contact our team by submitting a ticket here.
The right to data portability GTK must allow you to port and reuse your personal data for your own purposes across different platforms. Please contact our team by submitting a ticket here if you wish to receive additional information on how to port your data elsewhere. This right only applies to personal data that you have provided to us as a data controller.
The right to object You have the right to object to GTK processing your data even if our processing is due to legitimate purposes as described in our Privacy Notice, if you have any objections please contact our team by submitting a ticket here.
The right to withdraw consent If you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and GTK must stop processing your data. If you want to withdraw your consent, please contact our team by submitting a ticket here.
  1. Legitimate Purposes for Collecting Your PII

The following are the specific legitimate purposes that we may use your PII for:

  • Contract Administration – We may use your PII to (1) negotiate, execute, renew and/or manage a contract with you; (2) process billing information and payments related thereto; and/or (3) communicate with you in respect of the above (including sending (legal) notifications).
  • Access and Communications to Our Platform – We may use your PII to (1) set-up and manage your GTK account; (2) interact with you through our Platform (e.g. software updates, Platform announcements, etc.): and/or (3) manage and respond to your questions or comments (e.g. technical, commercial or administrative) or requests for maintenance and support.
  • Use of the Platform – We may use your PII to (1) enable you to enjoy the use of, and easily navigate the Platform; and/or (2) better understand your needs and interests.
  • Sharing with Third Parties – We may use your PII to share with our partner companies that we share data with.
  • Allowing You To Access or Download Content – We may use your PII to allow you download data or content from the Platform.
  • Training and Improvements – We may use your PII to (1) train our employees or contractors to allow for a better Platform experience; and/or (2) improve the Platform.
  • Direct Marketing – We may use your PII to contact you for additional products and services that you may be interested in.

Please be aware that all legitimate purposes will be taken with minimal amounts of additional processing. Aside from the purposes listed, we may share your information where investigations or a legal dispute has occurred in accordance with our Privacy Policy.

  1. Retention of PII

GTK will only retain your PII for as long as required. We will keep your personal information:

  • For any legally required duration.
  • Until we no longer have a valid reason to keep or use your PII.
  • Upon your request to eliminate, delete, or modify any of you PII stored with us.

Where you have requested modification or deletion of your PII, we may keep just enough of your personal information to ensure that we comply with your requests not use your personal information or comply with your right to erasure. If you require additional details regarding the retention of your PII please contact us.

  1. Transfer of PII Outside of the EEC

Where your PII is transferred outside of the EEC, GTK shall ensure that your PII shall have an adequate level of protection and that your information will be accessible as stated under the Privacy Notice.

  1. Sharing of Data with Third Parties

Aside from the uses listed within this Privacy Notice, GTK does not share any of your PII with any third parties aside from third parties that are hired by us to assist us in processing your data (Data Processors). All Data Processors have entered into binding agreements with us to ensure that your rights to your PII are respected.

  1. Contact Information

If you have any questions or require additional information related to our information collection practices, please contact us by submitting a ticket here.

 

  1. REMOVING YOUR INFORMATION

At GTK we value your privacy and your right to access and control your personal information. We have implemented this policy so that you may request the permanent removal of any personal information stored within GTK Platform.

If you wish to have any of your personal information stored within GTK Platform removed, please contact us by submitting a ticket here and follow the directions stated within this policy. With each removal request you must list the information you wish to have removed exactly as listed. Please be aware that removal requests are not processed instantaneously. There may be a reasonable delay in processing and removing any information requested.

Although we will attempt to remove all of your personal information upon receipt of your removal request, please be aware that GTK may have multiple areas where your personal data is stored and a single removal request may not eliminate all of your personal information stored within our Platform. Therefore, you may be required to submit multiple requests. If your information repeatedly reappears please contact us.

You may make a removal request by submitting a ticket here, please label the first line of the ticket with the following: “Removal Request – Your Full Name and Account Name”.

ADDITIONAL RIGHTS FOR EEC USERS

If you reside in the European Economic Community (EEC) or if you are an EEC citizen you are afforded additional rights to your information.

Legal Rights Your Rights Under the GDPR
The right to be informed GTK wishes to keep you informed as to what we do with your personal information. We strive to be transparent about how we use your data.
The right to access You have the right to access your information at any time.
The right to rectification If the information GTK holds about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data.
The right to erasure Sometimes called ‘the right to be forgotten’. You have the right to request that GTK to erase all your personal data.
The right to restrict processing You have the right to ask GTK to restrict how we process your data. This means we are permitted to store the data but not further process it. We will only keep enough data to ensure that we can accommodate any additional requests.
The right to data portability GTK must allow you to port and reuse your personal data for your own purposes across different platforms. This right only applies to personal data that you have provided to us as a data controller.
The right to object You have the right to object to GTK processing your data even if our processing is due to legitimate purposes as described in our Privacy Policy
The right to withdraw consent If you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and GTK must stop processing your data.

If you wish to exercise any of these additional rights with regards to any of your PII, we’d be happy to assist you, please contact us by submitting a ticket here, please label the first line of the message with the following: “Request – Your Full Name and Account Name”.

 

III. GTK COOKIE POLICY

Last Updated: July 29, 2020

Thank you for visiting GTK platform (“Platform”). GTK is committed to protecting your personal information and ensuring your experience with us is as safe and as enjoyable as possible. In this section, you’ll find information on how and why we use “cookies” to improve our service and your web experience. You’ll also find out how to manage the information that is collected.

What Are Cookies?

Most websites use cookies to improve your browsing experience. Cookies are small amounts of information in the form of text files sent by websites to your computer, mobile phone or other device when you visit our website. They allow companies to do various things, including tailor the content you see, and ensure the security of your online experience. Cookies cannot be used to run programs or deliver viruses to your computer.

Cookie Types and Their Uses

GTK uses cookies to save your preferences. This allows us to assist you in remembering what types of preferences and settings you have created within GTK Platform and last time you have visited our Platform. These cookies also allow us to understand how you use our Platform, we use these cookies in an attempt to optimize your user experience.

Aside from assisting us in identifying you and remembering your preferences, we may use cookies to assist us in processing transactions. cookies allow us to remember your orders and to assist us in ensuring that transactions are properly processed.

Third Party Cookies

You may have seen references on other websites to “first party cookies” and “third party cookies.” Determining whether or not a cookie is a first or third party cookie depends on which website sets the cookie on your device. First party cookies are set by, or on behalf of, the company whose website you visit. Cookies set by any other company are third party cookies. For example, third party cookies may be used by advertising companies to serve ads when you visit their website.

Currently, GTK uses first party cookies as identified above. Please be aware that third party cookies may be employed on the Platform for the purposes of advertising.

What If I Don’t Want to Accept Cookies?

You can choose to restrict or block access to cookies set by GTK or any other company. You can set your browser to notify you when a web server attempts to write or load a cookie to your computer. This gives you a chance to accept or reject the cookie. Please be aware that rejecting any cookies may render some portions of the Platform inaccessible or otherwise cause the improper functioning of portions of the Platform.

How Can I Control Cookies?

Web Browser Cookies

If you don’t want to receive cookies, you can modify your browser so that you are alerted when any cookies are being placed on your computer. Additionally, you can reject all cookies or you may delete cookies that have already been set.

If you wish to restrict or block web browser cookies you may do so via your browser settings. The Help function within your browser should be able to assist you in this matter. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information regarding the management of cookies on your browser. Aboutcookies.org contains both general information and specific information regarding cookies and their usage.