Privacy Policy

This Privacy Policy (“Policy”) describes how Turbo CTA. (“we,” “our,” or “us”) collects, uses, discloses, and otherwise processes personal information described in this Policy, as well as the rights and choices individuals have regarding such personal information.

By using our Services (as defined below), you agree that your personal information will be handled as described in this Policy. Your use of our Services and any dispute over privacy, is subject to this Policy and our Terms of Use, available at https://www.turbocta.com/terms-of-use/  including their applicable terms governing limitations on damages and the resolution of disputes.

1. Scope of this Policy

Except as otherwise described below, this Policy applies to the personal information we collect and process related to visitors to our website where this Policy is posted, including www.turbocta.com (the “Site”), and individuals who use our services on behalf of our customers (collectively, the “Services”).

Additional Notices. Depending on how you interact with us, we may provide you with other privacy notices with additional details about our privacy practices. For example, this Policy does not apply to job applicants or to our employees. Our processing of personal information belonging to our business clients is subject to our agreement with the respective client and their data handling practices.

2. Personal Information We Collect

We collect personal information directly from you, automatically through your use of the Services, and from other sources. To the extent permitted by applicable law, we may combine the information we collect from or about you.

Personal Information We Collect Directly From You. While the personal information we collect varies depending upon your use of our Services and our interactions with you, in general, we may collect the following Personal Information directly from you:

• Contact Information. When you use our Services or contact us, including if you sign up to learn more about our Services, request a demo, or otherwise contact us, we collect your name, company name, business email address, number of employees, the nature of your inquiry, and any other information you so choose to provide.
• Company Identifier Numbers and Beneficial Owner Details. For FinCEN reporting purposes, we will collect your business’s information, including the company name and address, as well as tax identification numbers like employer identification numbers. Additionally, we will collect details of beneficial owners, which encompasses their full legal names, residential addresses, dates of birth, and copies of documents such as licenses, ID cards, or passports. Furthermore, in the event that you utilize our Services for any electronic filings related to the TurboCTA Corporate Transparency Act, we may also acquire your specific FinCEN identifier number. This information will not be used for marketing or other purposes unrelated to filing FinCEN reports.
• Account Information. When you register for an account with us, we collect your name, company name, business email address, account name, password, and any other information used in connection with accessing your account.
• Communications and Interactions. When you communicate with us, we collect and maintain a record of your contact details, communications, and our responses.
• Responses and Feedback. If you participate in our surveys or questionnaires, we collect your responses and feedback, such as user satisfaction or other information related to your use of our Services, and any other information you so choose to provide.
• Marketing and Promotions. We may collect your email, name, phone number, preferences, cookies, and if relevant, information about your account and the Services and features you use. If you participate in promotions we offer, we collect your name and other information related to the activities available through our Services.
• Events and Other Requests. We also collect personal information related to your participation in our events as well as other requests that you submit to us related to our Services. For example, if you register for or attend an event or webinar that we host or sponsor, we may collect information related to your registration for and participation in such event.
• Preferences. We also may collect information about your preferences, including communications preferences.
• Business Development Information. To assess and pursue potential business opportunities, we may collect and receive personal information about current, former, and prospective vendors, business partners, and agents, including name, company information, contact details, and communications records.

Personal information We Collect Automatically. We and third parties automatically collect personal information related to your use of the Site, including through the use of cookies, pixel tags, and other similar technologies. The personal information automatically collected includes:

• Device and Browsing Information such as IP address, browser type, domain names, access times, date/time stamps, operating system, language, device type, unique ID, Internet service provider, referring and exiting URLs, clickstream data, and similar device and browsing information.
• Activities and Usage such as activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, time spent within the Services, your interactions with us within the Services, and other activity and usage information.
• Location Information such as general location information through your IP address.

For more information about cookies and other similar technologies, please see the “Cookies and Other Tracking Mechanisms” section below.

Personal Information We Collect from Other Sources. In addition, we may collect and receive certain personal information from business partners, customers, data analytics providers, government entities, public databases, and vendors who provide services or perform functions on our behalf. For example, we may collect your name, contact information, and certain transaction details from our business partners and vendors. We also may receive personal information from our customers for purposes of administering our Services.

3. How We May Use Personal Information

We collect, use, disclose and otherwise process the personal information we collect about you for the following purposes:

• Schedule a Demo. To allow you to schedule a demo of our Services.
• Services and Support. To allow you to maintain your account with us, provide and operate our Services, provide troubleshooting and technical support, respond to your inquiries, and to otherwise run our day-to-day operations.
• FinCEN Reporting.  To allow your company to file beneficial ownership information reports to FinCEN.
• Analytics and Improvement. To better understand how users access and use the Services and our product and service offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop our Services and its features, and for quality control and training purposes.
• Communicate With You. To respond to your inquiries or send you materials or information. We may also send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
• Marketing and Advertising. For marketing and advertising purposes. For example, to send you information about our Services, such as newsletters and other marketing content and to advertise to you on other sites.
• Research and Surveys. To administer surveys and questionnaires, such as for market research or user satisfaction purposes.
• Planning and Managing Events. For event and webinar planning, and other purposes, such as registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services.
• Security and Protection of Rights. To protect the Services and our operations and to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or act regarding illegal activities, suspected fraud, potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use or this Policy.
• Compliance and Legal Process. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
• Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions, and to maintain appropriate business records and enforce company policies and procedures.
• General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.

4. How We May Disclose Personal Information

Personal information is disclosed in the following ways for the purposes specified:

• Vendors and Service Providers. We may disclose the personal information we collect to vendors and service providers who perform functions on our behalf, such as IT and website hosting and customer support.
• Customers. We may disclose the personal information we collect to our customers as necessary to administer our Services.
• Marketing and Analytics Providers. We may also disclose personal information, such as device and browsing and activities and usage information to marketing and advertising networks, data analytics providers, and other companies who provide marketing or analytics service providers. For more information, see the “Cookies and Other Tracking Mechanisms” section below.
• Affiliated Companies. We may disclose the personal information we collect to our corporate affiliates and agents.
• Business Partners. We may also work with other businesses to offer our products and Services, and we may disclose personal information to those business partners.

• In Support of Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the personal information we have collected from you with or to the other company. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transactions such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
• Compliance and Legal Obligations. To comply with our legal and compliance obligations and to respond to the legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
• Security and Protection of Rights. Where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information to: prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services; in situations involving potential threats to the health, safety, or legal rights of any person or third party, or to enforce, detect, investigate, and take action in response to violations of our Terms of Use and Privacy. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
• Aggregate and Deidentified Information. Notwithstanding anything else in this Policy, we may use, disclose, and otherwise process aggregate and deidentified information related to our business and the Services with third parties for quality control, analytics, research, development, and other purposes.
• Other Disclosures. We may disclose personal information in other ways not described above, but will notify you and, if necessary, obtain your consent.

5. Cookies and Other Tracking Mechanisms

We and third parties use cookies, pixel tags, and other similar tracking mechanisms to automatically collect information about browsing activity, type of device, and similar information within our Site and Services. We use this information to analyze and understand how you access, use, and interact with us; to identify and resolve bugs and errors in our Services; to assess, secure, protect, optimize, and improve the performance of our Services; for marketing and advertising purposes, analytics purposes, and to personalize content in our Services. We may also aggregate such information to analyze trends, administer our Services, and gather broad demographic information.

Cookies. “Cookies” are alphanumeric identifiers we transfer to your device or browser. Some cookies allow us to make it easier for you to navigate our Services, to enable a faster log-in process, to support the security and performance of the Services, for advertising, analytics and marketing purposes, and to allow us to track activity and usage data within the Services.

Pixel Tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, and help us manage content and compile usage statistics. We may also use pixels in our emails to let us know when they have been opened or forwarded so we can track response rates and gauge the effectiveness of our communications.

Third Party Analytics. We use third party tools, such as Google Analytics, which are operated by third party companies, to evaluate usage of our Site and Services. These third-party analytics companies use cookies, pixels, and other tracking technologies to collect usage data about our Services to provide us with reports and metrics that help us evaluate usage of our Services, improve our Site, enhance performance and user experiences and for their own purposes. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Social Media Platforms. We may also collect personal information about you from social media platforms and networks if you post content publicly or to our social media account (e.g., by using a hashtag) or if you post content to third-party social media hosts.

Third Party Advertising. We work with third-party ad networks, analytics, measurement and other companies (“third-party ad companies”) to personalize content, conduct analytics, measure effectiveness and display advertising on third-party sites. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect browsing and activity information, IP address, unique IDs, cookie and advertising IDs, and other online identifiers within our Services and on third-party sites and services.

Do Not Track. Currently, our Site and Services do not recognize “Do-Not-Track” requests. You may, however, disable certain tracking as discussed below (e.g., by disabling cookies).

6. Your Privacy Choices

We make available several ways for you to manage choices about your personal information, including preferences regarding cookies, advertising, whether you want to receive marketing and promotional emails from us, and choices regarding your account and profile information.

• Cookie Settings. You can set your browser to block certain cookies or notify you when a cookie is set, and you can also delete certain cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Site, who disable cookies will be able to browse the Site, but some features may not function. If you clear your cookies or use a different browser or device, you will need set your preferences again.
• Industry Ad Choice Programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our Site, and those of third parties, in order to display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad companies at aboutads.info/choices (Digital Advertising Alliance). Opting out of participating third party ad networks does not opt you out of being served advertising. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.
• Marketing Communications. You can opt out of receiving marketing emails from us by using the unsubscribe feature in any such email we send you.
• Account and Profile Information. If you have an account with us, you may access, review, and update your account and profile information, such as your name, email address, contact information, preferences, and other profile information by logging in and accessing the information directly within your account. Please note that if your account was created by a filing link sent by a firm filing a FinCEN report on your behalf, you will not be able to update information on a FinCEN report once it is filed.

7. Children’s Information

Our Services are not designed for children, and we do not knowingly collect personal information from children. If you are a parent or legal guardian and you believe we have collected your child’s information in violation of applicable law, please contact us using the contact information below.

8. International Data Transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). Specifically, our servers are in the United States, and our third-party service providers and partners operate around the world. This means that when we collect your personal information, we may process it in any of these countries.

9. External Links and Features

Our Site and Services may contain links to third-party websites or features. Any access to and use of such linked websites or features is not governed by this Policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties, including their collection of your personal information. You should review the privacy policies and terms for any third parties before proceeding to those websites or using those features.

10. Security

We have implemented safeguards that are intended to protect the personal information that we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

11. Changes to this Policy

The Policy is current as of the date set forth above. We may modify this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy here.

12. Contact Us

If you have any questions or concerns regarding this Policy or our privacy practices, you may contact us at:
Turbo CTA., 3500 S. Dupont Hwy, Dover, DE 19901 or https://www.turbocta.com/contact-us/