Effective Date: April 19, 2021

This Privacy Policy describes the types of information Voyetra Turtle Beach, Inc. and its affiliates (collectively, "Turtle Beach,” “we,” “our,” and “us”) collect, use, disclose and safeguard that you provide through our websites, https://www.turtlebeach.com/, https://www.roccat.com and affiliated websites (collectively, the “Site”). By accessing or using the Site on any computer, mobile phone, tablet, or other device, making a purchase from Turtle Beach, or otherwise communicating or interacting with Turtle Beach, you agree to the terms of this Privacy Policy. If you do not agree to this Policy, please do not use the Site.

As detailed in the “Changes to this Policy” section below, we reserve the right, at our discretion, to change, modify, add or remove portions of this Privacy Policy at any time. Please check this page periodically for changes. Your continued use of the Site indicates your acceptance of any revised Privacy Policy. Customers outside of the United States should reference the respective privacy policy applicable to their jurisdiction.

Who may collect personal information?

We may collect personal information from the Site or we may authorize third-party companies to collect personal information from the Site on our behalf.

What is personal information?

We consider information that personally identifies you or that can be used to contact you (such as your name, email address or billing information), and any data that is linked to such information, to be personal information.

What personal information is collected?

• • When you purchase a product from the Site, we may collect your name, mailing and billing address(es), telephone number, email address and/or credit card or checking account information.
  • When you register a product, we may collect your name, address, telephone number and email address.
  • When you join one of our mailing lists, we may collect your name and email address.
  • When you contact our online customer support, we may collect your name, telephone number, email address and mailing address.
  • When you register for contests or giveaways hosted by the Site, we may collect your name, email address, telephone number, address and other information as specified in such contest or giveaway.

How is personal information used by Turtle Beach?

Turtle Beach collects and uses your personal information:

• • To complete orders for products placed on the Site and to communicate with you about such orders (for example, order and shipment confirmations)
  • To respond to requests for support or otherwise provide customer service
  • To inform you of other products or services available from Turtle Beach and its affiliates and about promotions and events
  • To conduct research about your opinion of current products and services or of potential new products or services
  • To notify you of the results of any contests or giveaways
  • To research and analyze data and trends to improve our products and services
  • To send you important notices about the website, including updates to the Terms of Sale and Terms of Use.

In addition to your personal information, we may collect, or we may authorize third-party companies to collect on our behalf, information that, by itself, does not specifically identify you. This non-personal information is used to help us learn what products are of the most interest to users and to improve Site design and content. Some examples of non-personal information that we collect and use are:

• • When you purchase a product, register a product or contact customer support, in addition to collecting personal information, we may obtain information about the products that you own or use.
  • When you are using our Site, we may log your IP address (a number that identifies your computer on the Internet) for system administration and troubleshooting purposes and to examine overall Site traffic trends.
  • We use cookies (which are small data files stored on your computer) and other similar technologies to collect information about your activities on the Site and to allow us to customize portions of the Site to your preferences. For example, we may obtain information about which pages of the Site you visit, what terms you use in searching the Site and/or what products you purchase. In addition, we use cookies to remind us of who you are and to tailor our product selection to you, which helps personalize your experience on the Site.

The cookie, by itself, does not provide any personal information, such as your name or email address. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences. However, you may not be able to use some features of the Site if you set your browser to reject cookies.

The information collected by cookies may be collected directly by us, or it may be collected by a third-party service provider. These data are anonymous and are not linked to any information that personally identifies you.

In some jurisdictions, cookies can only be set or accessed with consent. Your use of the Site signifies your consent.

Non-personal information may be collected, used or disclosed for any purpose. We may combine the information we collect through cookies with other information we have collected from you or other sources. In the event that any non-personal information is associated or combined with your personal information, such information is also treated as personal information for purposes of this Privacy Policy.

On occasion, Turtle Beach may use third-party advertising companies that use tracking technologies to serve our advertisements across the Internet. These advertising companies may collect information about your visits to the Site and other third-party websites and your interaction with our advertising and other communications. These advertising companies serve ads on behalf of us and others on nonaffiliated sites, and some of those ads may be personalized, meaning that they are intended to be relevant to you based on information collected about your visits to the Site and elsewhere over time. Other companies may also use such technology to advertise on the Sites.

You have the choice to tell us not to collect and use this information, and in some jurisdictions, we will only engage in interest-based advertising if you opt-in. If you would like more information about this practice and to know your choices concerning interest-based ads, visit: https://optout.networkadvertising.org/ or https://youradchoices.com/control.

Turtle Beach may enter into a "co-branding" relationship with another company or organization. At times, we may communicate with customers on behalf of that company and customers may be directed to a partner website to purchase a specific item or learn about their services. In these cases, both Turtle Beach and the partner company may receive personal information you provide and you should refer to the privacy policy of the "co-branding" partner to learn about how they handle your personal information before disclosing any personal information. Turtle Beach does not have control over and is not responsible for privacy policies and practices of its co-branding partners.

1. Your personal information is processed in connection with our email marketing communications by Klaviyo, an email service provider, with its corporate address 125 Summer Street, Floor 6, Boston, MA, 02110. Klaviyo (www.klaviyo.com) acts on our behalf and processes your personal information on our instructions.

The Site may contain links to third-party websites, which may have privacy policies that differ from our own. Turtle Beach does not have control over and is not responsible for the privacy policies and practices of such third-party websites. Please refer to the privacy policies of the third-party website to learn about how they handle your personal information before disclosing any personal information.

Turtle Beach may use outside marketing companies to place advertisements or links to the Site on third-party websites. The marketing company or the operator of such third-party website may collect information about people who click on an advertisement for or link to the Site. Turtle Beach does not have control and is not responsible for privacy policies and practices of such marketing companies or third-party websites. Please refer to their privacy policies to learn about how they handle your personal information before disclosing any personal information.

You may choose to create accounts on websites or platforms owned or controlled by third-parties to purchase our products. These third parties may use your information for their own purposes, including for behavioral advertising and analytics purposes. Turtle Beach does not control and is not responsible for privacy policies and practices of these third parties. Please refer to their privacy policies to learn about how they handle your personal information before creating any account with them or using their platforms.

In the event that Turtle Beach is merged with or acquired by another company, or in the event of a transfer of our assets, we may disclose or transfer personal information and other information about usage of the Site in connection with such a transaction. You should also be aware that courts may have the authority under certain circumstances to permit personal information and other information about usage of the Site to be shared or transferred to third parties without your permission.

Non-Disclosure Except in Certain Circumstances

We will not use or disclose your personal information except: (1) as described in this Privacy Policy; (2) after obtaining your explicit consent to a specific use or disclosure; (3) if it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to Turtle Beach, or to others, or to establish or defend claims; (4) if we are required to do so in order to comply with any valid legal and regulatory process or governmental request (such as a court order, search warrant, subpoena, civil discovery request, investigation, or statutory requirement); (5) to seek advice and consultation from lawyers, auditors, insurance companies, and other professional advisors; or (6) as we otherwise believe is required by law.

Disclosure for Fraud Prevention

When you place an order, we may share your name, physical and email address and order details (date, amount, product) with Signifyd for fraud prevention services. Signifyd is located at 99 Almaden Blvd., 4th floor, San Jose, CA 95113, USA (www.signifyd.com) and is responsible for performing its service as set forth in an agreement with us, as an independent controller and not as a processor, namely for the purposes of fraud identification, prevention, dispute and monitoring, and to analyze data for the purpose of building, maintaining and improving Signifyd’s predictive models and fraud-related services through Signifyd’s own AI model for the same purposes. We have Module 1 EU Standard Contractual Clauses with Signifyd (controller-to-controller) with UK and Swiss addenda with Signifyd in place. Signifyd has a separate legitimate interest to process these sets data as Signifyd is independently endorsing an order, and it is in Signifyd’s sole discretion to approve a transaction/provide a financial guarantee to us for the order amount. Signifyd has received and actively maintains SOC 2, Type 2 and PCI compliance certifications from an independent third-party auditor. Signifyd’s privacy policy is available here https://www.signifyd.com/privacy/

The legal basis for this sharing of the mentioned personal data with Signifyd as an independent controller is that it is in our legitimate interest (Art. 6 (1) (f) GDPR) to discover fraud and to protect ourselves against fraudulent orders. The GDPR recognizes fraud identification, prevention, dispute and monitoring in Recitals 47 and 71 as legitimate interests that provide a legal basis for a controller to process personal data.

Turtle Beach’s server is located in the United States. We, as U.S. based company, do not solicit or knowingly collect personal data from individuals located outside of the United States through the Site. If you are located outside the United States and choose to contact us and send us personal information voluntarily (e.g., by placing an order online via our Site), please be advised that your personal information will be processed in the United States and that the protection of your personal information in the United States may be different from data protection in the country where you reside. Where this occurs, you acknowledge and where required, consent to such transfer in accordance with this Privacy Policy.

You are also advised to consider before you voluntarily send personal information to us that there might not be an independent data protection authority and/or safeguards of the data processing principles and/or safeguards of data subject rights in the United States as set forth under your data protection law, unless such rights are explicitly mentioned in this Privacy Policy.

By entering your phone number in the checkout and initializing a purchase, subscribing via our subscription form, or a keyword, you agree that we may send you text notifications (for your order, including abandoned cart reminders) and text marketing offers. Text marketing messages will not exceed 30 a month. You acknowledge that consent is not a condition for any purchase.

If you wish to unsubscribe from receiving text marketing messages and notifications reply with STOP to any mobile message sent from us or use the unsubscribe link we provided you within any of our messages. You understand and agree that alternative methods of opting out, such as using alternative words or requests will not be accounted for as a reasonable means of opting out. Message and data rates may apply.

For any questions please text HELP to the number you received the messages from. You can also contact us for more information. If you wish to opt-out please follow the procedures above.

We use encryption and authentication tools to protect the security of the information that you share with us. Once we receive your personal information via the Site, we do our best to protect its security on our systems. For example, we protect personal information we gather on a secured server that is located behind a firewall.

Unfortunately, however, no transmission over the Internet can be guaranteed 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to or from the Site, and you do so at your own risk. Accordingly, we disclaim liability for any theft, loss, or interception of or any unauthorized access or damage to any data or communications. By using the Site, you acknowledge that you understand and agree to assume these risks.

Please keep in mind that if you disclose personally identifiable information or personally sensitive data through public forums and bulletin boards on the Site, this information may be collected and used by others. You are responsible for the personal information that you choose to share on the Site's public forums and bulletin boards.

Privacy Policy Supplement Applicable to Residents of California and to which the California Consumer Privacy Act Currently Applies (“CCPA Supplement”)

Effective Date: January 1, 2020

Last Reviewed: December, 2019

Click Here

While we hope that the information included in this Privacy Policy has helped you better understand how we use and protect your information to provide you with better service, we understand that you may still choose to not receive information from Turtle Beach or our partners.

As a part of our commitment to your privacy, we agree to honor customers' requests not to receive mail or email from Turtle Beach.

If you have previously opted to receive, or otherwise currently receive, promotional emails from us, you may unsubscribe by emailing webmaster@turtlebeach.com. Within a reasonable period of time after unsubscribing, you will no longer receive marketing emails from Turtle Beach. You may still receive e-mails regarding your transactions, for example, confirming that you have placed an order or that a product you have ordered has shipped.

The Site is not intended for or directed to anyone under the age of 18 years. We will never request personally identifiable information from anyone whom we know to be under the age of 18 without verifiable parental consent. By using the Site, you represent and warrant that you are at least 18 years old. If we become aware that a customer is under the age of 18 and has provided us with personal information, we will remove his or her personal information.

A parent or legal guardian who needs to access, change or delete personal information regarding their child should contact webmaster@turtlebeach.com.

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium (W3C) has not yet established universal standards for recognizable DNT signals and therefore, Turtle Beach and the Site do not recognize DNT.

Turtle Beach reserves the right to amend this Privacy Policy at any time. We will post all changes to this Privacy Policy on the Site, so you should review it periodically. Any such amendments to this Privacy Policy may apply to information we collect in the future as well as any information we obtained prior to such amendment. If we make a material change to this Privacy Policy, we will provide appropriate notice as required by law.

If you have any comments on or questions about this Privacy Policy or believe that Turtle Beach has not adhered to this Privacy Policy or any privacy law, please contact webmaster@turtlebeach.com.

If we need, or are required, to contact you concerning any event that involves your information, we may do so by email, telephone, or mail. If you make a purchase, we (or someone on our behalf) may will send you a confirmation email.