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Privacy Policy

This Policy applies as between you, the User of this Web Site and Turtle Networks Ltd. the owner and provider of this Web Site.  This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein.

BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING AS DESCRIBED IN THIS PRIVACY POLICY. Note to Residents of the European Union: In order to comply with the requirements of the European General Data Protection Regulation (GDPR) for our European consumers and users, this Privacy Policy outlines the legal basis on which we process your Personal Data and provides other information required by the GDPR.

Who We Are

We are Turtle Networks Limited. We are a voice recognition technology solutions company offering Voice-to-Text services. We are developing a portfolio of solutions that utilise voice recognition technology.

Definitions and Interpretation

In this Agreement the following terms shall have the following meanings: 

Account means collectively the personal information, Payment Information and credentials used by Users to access Paid Content and / or any communications System on the Web Site;
Content means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Web Site;
Cookie means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Web Site;
Data means collectively all information that you submit to the Web Site. This includes, but is not limited to, Account details and information submitted using any of our Services or Systems;
Personal Data is information that can be used to identify you, directly or indirectly, alone or together with other information. This includes things such as your full name, email address, phone number, precise location, device IDs, certain cookie and network identifiers
Turtle Networks means Turtle Networks Limited;
Service means collectively any online facilities, tools, services or information that Turtle Networks makes available through the Web Site either now or in the future;
System means any online communications infrastructure that Turtle Networks makes available through the Web Site either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;
User' / 'Users means any third party that accesses the Web Site and is not employed by Turtle Networks and acting in the course of their employment; and
Web Site means the website that you are currently using (www.intrabench.com) unless expressly excluded by their own terms and conditions.

Data Collected

Without limitation, any of the following Data may be collected:

name; address; email address; telephone numbers; mobile numbers; credit / debit card numbers;

contact information such as email addresses and telephone numbers; demographic information such as post code, preferences and interests; financial information such as credit / debit card numbers; IP address (automatically collected); web browser type and version (automatically collected); operating system (automatically collected); a list of URLS starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected); and Cookie information.

We collect your Personal Data in a number of ways and for various purposes, including:


Legal Basis for Processing

This section addresses the legal basis for processing your data. Some processing is addressed in multiple sections because more than one legal basis may apply depending on the circumstances or service.
For the purposes of applicable data protection laws, Turtle Networks is the controller of the Personal Data you provide to us ("Data Controller"). As a Data Controller, we process the Personal Data we maintain about you in accordance with this Privacy Policy. If you have any questions or concerns regarding the processing of your Personal Data, or if you have questions regarding this Privacy Policy, please contact us via our website.

We collect and process your Personal Data for a variety of purposes outlined in this Privacy Policy. In certain cases, separate consent is not required, including:

Consent as a Basis for Processing

In some cases, we will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as permitted by law, ticking a box (or equivalent action) to indicate your consent when (i) providing us with your Personal Data through our Services or a form (including using the contact form); or (ii) registering or creating an account with us. Due to different countries' laws governing consent for the collection and use of Personal Data, the requirements for consent will differ across regions. We may request your consent for a number of activities including:

Managing Preferences and Withdrawing Consent

You may at any time withdraw your consent with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it, and exercise other controls regarding website and online data collection, interest-based advertising, your communication settings, and app preferences. Depending on the Service, collection and use of Personal Data may be required for the Services to work. We provide you several ways to manage your preferences:

Cookie Use and Controls

Cookies serve a wide variety of purposes. Cookies are pieces of data stored in your web browser that are transmitted to websites to remember your browser over time and distinguish it from other users. Cookies are used to remember your shopping cart and personalise your web experience and for security, analytics, marketing, and interest-based advertising. Our cookies are placed and read by our web servers, while other cookies are placed and read by other companies' web servers. Information on specific cookies is found on our website via the AdChoices link. You can block and control cookies using the information noted in this section. If you block all cookies, certain functionality on our website will not work.

One way to think about cookies is based on their function. The following settings will control our use of browser cookies, the use of IP address for tracking, and the collection and use of data for cookie-based, interest-based advertising.

IP Address Use

An IP address refers to an identifier assigned by a network to a computer, mobile device, Internet of Things (IoT) device, or routing device. IP addresses, for purposes of this Privacy Policy, include "public" IP addresses, such as the IP address for a home router that is visible to the Internet, as well as "local" IP addresses, which are IP addresses assigned to computers and mobile devices "behind" a router (such as a home router). Our advertising and analytics partners may use IP addresses to group or correlate devices for purposes of analytics, security and anti-fraud purposes, interest-based advertising, ad targeting, ad attribution, and limiting ad frequency.
You can choose not to have IP address used for purposes of advertising or analytics by using the cookie controls for "Advertising Cookies," and "Performance/Analytics," above.

If you elect not to provide personal data

You may choose not to provide Turtle Networks with your Personal Data. However, if you choose not to provide your Personal Data, you may not be able to enjoy the full range of Services.

How to exercise your rights

Turtle Networks takes steps to keep your Personal Data accurate and up to date. If you reside in the European Economic Area, you have certain rights to the Personal Data that we have collected about you. To exercise your rights to your Personal Data, please contact us through our contact page or at the address listed below. Subject to applicable law and in exceptional circumstances only, we may charge for this service and we will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

You have the following rights: Right of access to your Personal Data (Art. 15 GDPR): You have the right to ask us for confirmation on whether we are processing your Personal Data, and access to the Personal Data and related information on that processing (e.g., the purposes of the processing, or the categories of Personal Data involved). Right to correction (Art. 16 GDPR): You have the right to have your Personal Data corrected, as permitted by law.
Right to erasure (Art. 17 GDPR): You have the right to ask us to delete your Personal Data, as permitted by law. This right may be exercised among other things: (i) when your Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed; (ii) when you withdraw consent on which processing is based according to Art. 6 (1) (a) or Art. 9 (2) (a) GDPR and where there is no other legal ground for processing; (iii) when you object to processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or when you object to the processing pursuant to Art. 21 (2) GDPR; or, (iv) when your Personal Data has been unlawfully processed.
Right to restriction of processing (Art. 18 GDPR): You have the right to request the limiting of our processing under limited circumstances, including: when the accuracy of your Personal Data is contested; when the processing is unlawful and you oppose the erasure of your Personal Data and request the restriction of the use of your Personal Data instead; or when you have objected to processing pursuant to Art. 21 (1) GDPR pending the verification whether the legitimate grounds of Turtle Networks override your grounds.
Right to data portability (Art. 20 GDPR): You have the right to receive the Personal Data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.
Right to object (Art. 21 GDPR): You have the right to object to our processing of your Personal Data, as permitted by law. This right is limited to processing based on Art. 6 (1) (e) or (f) GDPR, and includes profiling based on those provisions, and processing for direct marketing purposes. After which, we will no longer process your Personal Data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Marketing communications

Where we are legally required to do so, we ask you for your prior consent before providing you with promotional materials or information. When required by local law, when marketing consent is obtained, we use the double-opt-in method (confirmation of your email address by email before sending you promotional messages) in order to verify your consent. You may revoke your consent at any time (this will not affect the processing of your Personal Data undertaken until the revocation). If you want to stop receiving promotional materials, etc., you can do so at any time by logging into your account online, going to Settings and clicking on the Marketing Email

Transfers of Your Personal Data to Other Countries

The Personal Data Turtle Networks processes, and all associated Services and systems, including registration, is housed on servers in the United Kingdom. If you are located outside of the United Kingdom, please be aware that Personal Data we collect will be processed and stored in the United Kingdom.. By using our Services and submitting your Personal Data, you agree to the transfer, storage, and/or processing of your Personal Data in the United Kingdom. Where and as required, we will seek your explicit consent as outlined in this Privacy Policy.

Data Retention

We will retain your Personal Data for as long as you maintain an account or as otherwise necessary to provide you the Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Where we no longer need to process your Personal Data for the purposes set out in this Privacy Policy, we will delete your Personal Data from our systems. Where permissible, we will also delete your Personal Data upon your request. To delete your data please log into your account, click on the settings tab and click delete data.
If you have questions about our data retention practices, please contact us through the contact page on the website.

Security

We implement appropriate technical and organisational safeguards to protect against unauthorised or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.
Links to Other Websites.

Please note that this Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. Our Services may provide a link or otherwise provide access to Third Party Sites. We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for Third Party Sites, their content, or any goods or services available through the Third Party Sites. Our Privacy Policy does not apply to Third Party Sites, and any data you provide to Third Party Sites, you provide at your own risk. We encourage you to review the privacy policies of any Third Party Sites with that you interact with.

Children

We do not knowingly collect Personal Data online from children under 16. If you become aware that a child has provided us with Personal Data without parental consent, please contact us through our contact page. If we become aware that a child under 16 has provided us with Personal Data without parental consent, we will take steps to remove the data and cancel the child's account.

How to Contact Us

If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us through our contact page or write to us at:
Turtle Networks Limited,
64 Cropley Street,
London
N1 7GX
UK.

Third Party Web Sites and Services

Turtle Networks may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, delivery of purchased items, search engine facilities, advertising and marketing. The providers of such services do have access to certain personal Data provided by Users of this Web Site. Any Data used by such parties is used only to the extent required by them to perform the services that Turtle Networks requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties must be processed within the terms of this Policy and in accordance with the Data Protection Act 1998.'

Changes of Business Ownership and Control

Turtle Networks may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you. In the event that any Data submitted by Users will be transferred in such a manner, you will not be contacted and informed of the changes.

Changes to this Policy

Turtle Networks reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law.  Any changes will be immediately posted on the Web Site and you are deemed to have accepted the terms of the Policy on your first use of the Web Site following the alterations.

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