Privacy policy

Last updated: 01/12/2026 

Turtle Wax, Inc., located at 948 Springer Drive, Lombard, IL 60148, its subsidiaries and affiliates Turtle Wax Europe Limited, Marvel Oil Company Inc., TW India (“Turtle Wax,” the “Company,” “we,” “us,” or “our”) are committed to privacy and data protection. This Privacy Policy and Notice at Collection (“Notice”) describes the privacy practices that Turtle Wax follows when collecting and using personal information collected from you, through our interactions with you, through the websites under the control of Turtle Wax that link to this Notice, the Turtle Wax mobile app, in email, in text, and other electronic messages between you and our services, and our services (collectively the “Services”), as well as how we use and protect your personal information. 

This Notice explains who we are; what personal information we collect about you; how we use it (including who we share that personal information with), and your rights and choices regarding your personal information. 

We take out obligations very seriously and have appointed a data protection officer (“DPO”) who is responsible for overseeing questions or concerns you may have about this Notice, including any requests to exercise your legal rights, please contact us using the contact details provided in the section below marked “How do I contact Turtle Wax?” 

NOTICE AT COLLECTION

1. WHAT INFORMATION DOES Turtle Wax COLLECT ABOUT ME AND WHY?

We collect information that identifies, describes, or is reasonably capable of being associated with you (“personal information”). We use different methods to collect data from and about you, including when you fill out a form or give us information via the phone, by post, online or by email, or otherwise. We, our partners, our advertisers and third-party advertising networks use various technologies to collect information, including but not limited to cookies, pixels, scripts and device identifiers. Our partners, advertisers and third-party advertising networks may use these technologies to collect information about your online activity over time and across different websites or online services. The following discusses the categories of personal information we collect and have collected in the preceding 12 months. 

• Such as a real name, date of birth, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
• Your Opinions or Other Information. For example, if you review the products you have purchased from us or provide information about products, and the brands you use.
• Commercial Information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Financial Information. Such as your account number, payment card number, cvv, billing address, and related financial information. This may be considered sensitive personal information in some jurisdictions.
• Customer Records. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, address, telephone number, education, employment, employment history, credit card number, or debit card number. Some personal information included in this category may overlap with other categories.
• Sensitive Personal Information. Such as, social security, driver's license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; or genetic data. Physical, physiological, and mental health condition; Sexual orientation; Medical records and history; Biometric information; any detail relating to the above categories as provided to or received by use for processing or storage.
• Internet or Other Similar Network Activity. Such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. As described in more detail in our Cookie Policy (below), if you use our Services, we automatically collect information about your browsing and search history, interaction with the features of our Services, and responses to advertisements.
• Professional or Employment-Related Information. Such as current or past job history or performance evaluations. This will also cover all information related to educational qualification.
• Inferences Drawn from Other Personal Information. Such as a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes. For example, when you visit the website, we may use the personal information indicated above to provide you with tailored advertising, content and products that we think you may like.

We may use these categories of personal information for the following purposes: 

To provide you with the products and services that you have requested - This includes administering our relationship with you and to carry out our obligations arising from the relationship between you and us, including internal accounting and administration purposes, to process payment for purchases or other services, and to create and manage your account.

To provide you with products and services that you have requested we may collect: Identifiers; Your Opinions or Other Information; Commercial Information; Customer Records; and Sensitive Personal Information. 

To process your payments and deliver your order - After you place an order on our website you will need to make payment for the goods or services you have ordered. We use third-party payment processors as may be available in your location, currently Shopify, PayPal, Amazon Pay, Credit/Debit Cards (Visa, Mastercard, RuPay, Maestro,Amex), UPI (Google Pay, PhonePe, Paytm, BHIM), Net Banking (All major Indian banks), Wallets (Paytm Wallet, PhonePe, Amazon Pay, Mobikwik,), and EMI (on select cards and banks) (“Payment Processors”), to assist in securely processing your payment information. If you pay with a credit card, the payment information that you provide through the Services is encrypted and transmitted directly to Payment Processors.

We do not store your payment information and do not control and are not responsible for Payment Processors or their collection or use of your information. You may find out more about how Payment Processors store and use your payment information by accessing the privacy policy for Payment Processors’ services.

To process payments we may collect and process: Identifiers; Customer Records; and Sensitive Personal Information; Financial Information; and Commercial Information. 

To ask you to leave a review, take a survey, or partake in a prize draw or competition - We will occasionally conduct online surveys to better understand the needs and profile of our visitors. In addition, we may request personal information when you register to receive additional information regarding our products and services, sign up for a newsletter, partake in a prize draw or competition, or send us a question. Even if you choose not to provide the information we request, you can still visit most of the Turtle Wax website, but you may be unable to access certain options, offers, and services. 

To ask you to leave a review or take a survey we may collect: Identifiers; Customer Records. 

To administer and protect our business and this website - This includes troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data. We may use any information we collect to protect and defend the rights and property of Turtle Wax, our employees, and business partners. 

To administer and protect our business and this website we may collect: Identifiers; Customer Records; Commercial Information; and Internet of Other Similar Network Activity. 

For tailored advertising - In order to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, we, or with third-party vendors such as Klaviyo, may use your personal information to provide you with tailored advertising on third party-sites, including Social Sites (defined below in the section titled - “What if I access or use a social network or public forum through the Services?”) These advertisements are either: (i) “contextual” (meaning they are presented due to the webpage that you are viewing); or (ii) “behavioural advertising” or “interest-based advertising” (i.e., where advertisements are shown to you based upon your interests which we have inferred from your information including demographic, geographic, and interest-based data). We may use tailored advertising to specifically include or exclude individuals who have registered for our products to ensure that you are provided with information about those products that are most relevant to you. To do this, we may track your browsing activity across different websites, different Devices and/or different applications. We may match your browsing activity on one Device, such as your mobile phone, with your browsing activity on another Device, such as your tablet, to ensure our advertising is tailored to you. If you no longer wish to see tailored advertising, you can manage your cookie preferences and choose to opt out of those cookies by clicking, Cookies Settings. In addition, some third-party sites allow you to stop seeing advertisements from specific advertisers on that site, so you should also check your preferences on those websites. For more information on how Turtle Wax uses cookies please review our Cookie Policy (below).

To provide tailored advertising we may collect and process: Identifiers; Customer Records; Sensitive Personal Information; Commercial Information; and Internet or Other Similar Network Activity.

You can also learn more about our current advertisers and review your opt-out options on their websites: 

Google: https://adssettings.google.com/authenticated?hl=en

AdRoll: https://app.adroll.com/optout/

Meta: https://www.facebook.com/privacy/center/

TikTok: https://www.tiktok.com/legal/report/privacy

Facebook Pixel: https://www.facebook.com/privacy/explanation

Google Analytics: https://policies.google.com/privacy

Google Tag Manager: https://policies.google.com/privacy

Hotjar: https://www.hotjar.com/legal/policies/privacy

Microsoft Advertising: https://privacy.microsoft.com/en-ca/privacystatement

Facebook Custom Audiences: https://www.facebook.com/policy.php

Google: https://policies.google.com/privacy

Facebook Connect: https://www.facebook.com/policy.php

If you would like more information about advertisers’ practices, please see http://optout.aboutads.info/#!/. You can generally opt-out of receiving personalized ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (“NAI”) or who follow the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles for Online Behavioural Advertising by visiting the opt-out pages on the NAI website (http://optout.networkadvertising.org) and DAA website (http://www.aboutads.info/choices/). 

To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences - For example, we may analyse your personal information including your location, products and/or services requested, age, time zone, IP address and URL visited, against our wider customer base for internal business purposes, such as generating statistics and developing marketing plans, to improve our services and products and the website. We may also aggregate and de-identify your information to create customer segments and share with our affiliates and partners. 

To perform analytics we may collect and process: Internet or Other Similar Network Activity. 

For non-marketing communications - We may use your personal information to communicate with you about important information in relation to your account, the service you have requested or other non-marketing communications. This includes: (i) to process and respond to your questions and/or inquiries; (ii) emailing you to verify your identity when you sign-up; (iii) emailing you where you have requested a password and/or username reset; (iv) notifying you that a particular service has been suspended for maintenance or terminated; (v) letting you know that we have updated this Notice or our Terms of Use; (vi) letting you know about any products that you have requested or purchased; or (vii) contacting you with instructions on how to use the items you purchase. We will never contact you to ask for your password, please be careful if you receive any communications from people requesting this information. 

To provide non-marketing communications we may collect and process: Identifiers; and Customer Records 

To make suggestions and recommendations to you about goods or services that may be of interest to you - If you choose to receive marketing communications from us, we may use your personal information to keep you up to date with our latest products, services, surveys, announcements, upcoming events, sweepstakes, contests and other promotions via our newsletters, emails, or other communications. We may also contact you regarding items in your online shopping cart that you have not purchase. If you no longer wish to receive these marketing communications, details of how to opt out are described in the section below marked “How do I stop receiving marketing communications?” 

To make suggestions and recommendations to you about goods or services that may be of interest to you we may collect and process: Identifiers; Customer Records; Sensitive Personal Information. 

For SMS communications - When you sign up to receive text messages from us on our website or via text message or opt to receive news, offers, updates on out-of-stock items from us by entering your name and phone number and clicking subscribe or ticking a box at checkout indicating that you would like to receive text messages from us, we collect your phone number, information about your browser, information about the page you signed up on, and any other additional information you may provide to us. For more information on SMS messages, including instructions on how to opt-out, please read our Terms of Use. 

To provide SMS communications we may collect and process: Identifiers; and Commercial Information. 

For employment or internship application purposes - If you contact us in relation to your employment prospects, we will use your personal information to consider you for current and future employment opportunities and to contact you with respect to employment opportunities at Turtle Wax that you have expressed an interest in.

By selecting the Careers link you will be directed to a third-party recruitment services website, currently Paycom (“Recruitment Provider”). Your use of the Recruitment Provider’s services is governed by the Recruitment Provider terms of service and privacy policy available through the Recruitment Provider’s website.

To support employment consideration we may collect and process: Identifiers; and Professional or Employment-Related Information 

INFORMATION THAT WE COLLECT AUTOMATICALLY.

When you engage with Turtle Wax we may use cookies and similar tracking technology to collect the following information about you automatically (for further information please see our Cookie Policy for more information):

We may use cookie and tracking technologies to collect the following information: Internet or Other Electronic Network Activity Information; and Inferences Drawn from Other Personal Information. For example, when you visit the website, engage with Turtle Wax content or with us digitally, we may collect certain information from your computer, tablet or mobile phone (“Device”) such as your:

• IP address
• Device type (i.e., make and model)
• Unique device identification numbers
• Browser-type
• Time zone settings.

We may also collect information about how your Device has interacted with us including:

• The pages accessed and links clicked
• How you navigate to and from the website (such as how you scroll over the site, which parts you click and how long you spend on each page)
• Your preferences
• The products and/or services that you have viewed or searched for; and
• Crashes, download errors, and response times.

We may use the personal information indicated above to provide you with tailored advertising, content and products that we think you may like.

INFORMATION THAT WE OBTAIN FROM THIRD-PARTY SOURCES.

From time to time, we may receive personal information about you from third-party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. The types of personal information we collect from third parties includes: 

• Social Media Partners. For example, if you ‘log-in’ to the website using a social medial log in or use functionality such as “like” or “share” buttons, that social media site may pass information to us, including: the user id for that third-party site, the name, email address, photos, list of social media contacts, and location associated with the user id, and any other information permitted under the privacy policy for that website.
• Retailers, Distributors and Third-Party Brand Partners. For example, where permitted by applicable data protection law and, if applicable, where you have specifically consented, our retailers, distributors and third-party brand partners may pass information to us including your first name, last name, email address, postal address, telephone number, phone number, gender, date of birth, browsing patterns, geo-location and device identifiers, click through and other cookie data, demographic information including information about your appearance and information in relation to products purchased at their stores (whether on the high-street or online through their own website or a dedicated microsite) and services requested using their websites and/or applications.
• Technology Partners and Market Research Organizations. For example, where permitted by applicable data protection law and if applicable where you have specifically consented, our preferred technology partners may share information with us, including your browser patterns, geo-location, and Device identifiers.

USE OF NON-PERSONALLY IDENTIFIABLE INFORMATION

We may use non-personally identifiable information, such as anonymized and/or aggregated Services usage data, in any manner that does not identify individual users for the purpose of improving the operation and management of the Services, including to develop new features, functionality, and services, to conduct internal research, to better understand usage patterns, to resolve disputes, to troubleshoot problems, to fulfil user requests, or for security and compliance purposes. Aggregated data (your data combined with other people’s data) may come from your personal information but if it does not directly or indirectly reveal your identity, it is not considered personal information. Any non-personally identifiable information that is combined with personal information will be treated by us as personal information. 

CHANGE OF PURPOSE

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details provided in the section below marked “How do I contact Turtle Wax?” for more information on the specific legal ground we are relying on to process your personal information.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the business purpose which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

2. DO WE SELL OR SHARE PERSONAL INFORMATION?

We may disclose personal information about you to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed categories of third parties indicated in the chart below.

We may sell or share personal information about you to third parties, subject to your right to opt-out of those sales. Our personal information sales do not include information about individuals we know are under age 16. In the preceding twelve (12) months, Turtle Wax has sold the following categories of personal information to the categories of third parties indicated in the chart below. To opt-out of personal information sales or sharing, visit Do Not Sell of Share My Personal Information.

In India, we do not sell your personal information for monetary consideration. If, in the future, we intend to disclose or share your personal information with third parties for commercial gain or marketing purposes beyond what is necessary for service delivery, we will do so only with your prior, explicit, and informed consent. You will also have the ability to withdraw your consent at any time by contacting us at DPO@turtlewax.com.

3. HOW LONG DOES TURTLE WAX KEEP MY PERSONAL INFORMATION?

We retain personal information in identifiable form only for as long as necessary to fulfil the purposes for which the personal information was provided to us or, if longer, to comply with legal obligations, to satisfy accounting or reporting requirements, to resolve disputes, to enforce agreements, and similar essential purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal information are available in our retention policy which you can request from us by contacting us using the contact details provided in the section below marked “How do I contact Turtle Wax?” 

4. FOR WHAT BUSINESS PURPOSE CAN TURTLE WAX USE MY PERSONAL INFORMATION?

We are required to satisfy one or more of the reasons set out by applicable data privacy law before we can collect and use your personal information.

Generally, our business purpose for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally rely on the following reasons to collect and use your personal information: 

• Performance of a contract

Using your information may be necessary for us to perform our obligations under a contract with you or with a view to entering into such a contract. For example, where you have: (i) purchased services and/or products from us, we will need to use your information to provide those services and/or products; or (ii) approached us in relation to employment opportunities, the collection and use of your personal information is necessary to enable us to offer you the job role, process your acceptance of the offer, on-board you as an employee and fulfil our obligations as an employer.

• Compliance with our legal obligations

The collection and use of your personal information may be necessary to enable us to meet our legal obligations, for example, to verify your identity and undertake necessary due diligence checks. 

• Pursuing our legitimate interests

Where such processing is not overridden by your interests or fundamental rights, we are permitted to use your personal information where it is necessary in order to pursue our legitimate interests, for example to operate the website and our other digital offerings, to improve our products and services, content and our other digital offerings or to undertake marketing. We may have other legitimate interests and if appropriate we will make this clear to you at the relevant time. 

• Consent

In some limited circumstances, we may rely on your consent to collect and use your personal information. For example, we may rely on consent: (i) where you have approached us in relation to employment opportunities and have provided us with sensitive personal information, such as information in relation to your racial and ethnic origin, sexual orientation, religion, physical and mental health, disabilities or trade union membership; or (ii) in relation to the sending of e-marketing or communications.

• If we rely on consent, this will be made clear to you at the time we request your information. You can withdraw your consent at any point by using the mechanism provided at the time, or by contacting us using the contact details provided in the section “How do I contact Turtle Wax?” of this Notice.
• Vital interests

In some instances, we may need to use your personal information to protect your vital interests or those of another person. 

You may not always be required to provide the personal information that we have requested. However, if you choose not to provide certain information, you may not be able to take advantage of some of our Services. Any information that is so required is clearly marked as mandatory. If you would prefer that we not collect certain personal information from you, please do not provide us with any such information, or opt out of providing this information where applicable. 

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). 

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), these interests will normally be as set out in this Notice; however, if this changes we will make clear to you at the relevant time what those legitimate interests are. 

If you have any questions or need further information concerning the business purpose on which we collect and use your personal information, please contact us using the contact details provided in the section below marked “How do I contact Turtle Wax?”  

5. DOES TURTLE WAX SHARE MY PERSONAL INFORMATION WITH ANYONE?

In addition to the third parties identified under the “Do we sell or share personal information?” section, during the past twelve (12) months, we may have disclosed the categories of personal information listed in the section marked “What categories of personal information does Turtle Wax collect about me?” to the following categories of recipients: 

• With our affiliates – We may make your personal information available to Turtle Wax affiliated companies to allow us to provide our products and services to you, for the purposes described in this Notice, or as notified to you when we collect your personal information. This may include affiliates included in the Loyalty Lyon program.
• With third parties for marketing purposes - Certain promotions and events may offer you the opportunity to consent to receive marketing communications from our business. If you have given your consent, your personal information may be used by such third party for the purposes stated at the point you enter the event and/or sign-up to receive the promotional updates.
• With our service providers and business partners - We engage third-party service providers and business partners to perform functions on our behalf (for example, to support the delivery of our products, or the website). Turtle Wax will ensure that any service provider with which we share personal information agrees to safeguard it in substantially the same manner as Turtle Wax has described in this Notice and in accordance with all applicable laws. This includes but is not limited to sharing information with the following types of service providers or business partners:

o    advertising providers - including companies that provide: (i) advertising space for Turtle Wax; (ii) the provision of advertising related services, including agencies instructed to make advertising purchases on our behalf, providers of ad-exchanges (a digital marketplace to buy and sell advertising space) and providers of a demand-side platform (software used to purchase advertising in an automated fashion);

o    providers of marketing and customer relationship management databases and data management platforms - that enable Turtle Wax to manage your information in a safe and efficient manner;

o    data analysis firms - that provide insights and help us to analyze trends using the data that we and they hold;

o    customer support specialists - that provide customer support services on our behalf for Turtle Wax products and services;

o    fulfilment companies - this includes companies that manage your orders; ship your products; and coordinate email campaigns, sweepstakes, contests, or promotions on our behalf;

o    application development and web-hosting companies - to enable us to manage and improve the website;

o    information technology and related infrastructure providers;

o    email delivery providers; and

o    audit and professional service providers.

• As part of a business transfer - Turtle Wax may disclose your personal information to an actual or potential buyer (and its agents and advisers) in relation to any actual or proposed divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding.
• To comply with laws - Turtle Wax may disclose your personal information to any competent law enforcement body, regulatory, government agency, court, or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person; and
• To any other person with your consent to the disclosure.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.  

6. COOKIES POLICY & SIMILAR TECHNOLOGIES

How We Use Cookies

We use Cookies to track how you use the Services by providing usage statistics. Cookies are also used to allow product authentication to you based upon your browsing history and previous visits to the Services. Information supplied to us using cookies helps us to provide a better online experience to our visitors and users and send marketing communications to them. 

While this information on its own may not constitute "personal data", we may combine the information we collect via Cookies with personal data that we have collected from you to learn more about how you use the Services to improve them. 

Types of Cookies

We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your Device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on the Services can be grouped into the following categories:

• Strictly Necessary: These Cookies are necessary for the Services to work properly. They include any essential authentication and authorization cookies for the Services.
• Functionality: These Cookies enable technical performance and allow us to "remember" the choices you make while browsing the Services, including any preferences you set. They also include sign-in and authentication cookies and IDs that enable you to return without additional sign-in.
• Performance/Analytics: These Cookies allow us to collect certain information about how you navigate the Services running on your Device. They help us understand which areas you use and what we can do to improve them.
• Marketing and Customer Support: These Cookies are used to deliver relevant information related to the Services to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit the Services. Some of these types of Cookies on the Services are operated by third parties with our permission and are used to identify advertising sources that are effectively driving customers to the Services.

Representative List of Tracking Technologies Deployed

Below is a list of tracking and analytics technologies currently deployed on our Services, organized by category:

List of Cookies

Cookies Set by Third Party Sites

To enhance our content and to deliver a better online experience for our users, we sometimes embed images and videos from other websites on the Services. We currently, or may in the future, use content from websites such as Facebook, LinkedIn and Twitter. You may be presented with Cookies from these third-party websites. Please note that we do not control these Cookies. The privacy practices of these third parties will be governed by the third parties' own privacy statements or policies. We are not responsible for the security or privacy of any information collected by these third parties, using cookies or other means. You should consult and review the relevant third-party privacy statement or policy for information on how these cookies are used and how you can control them.

We also use Google, a third-party analytics provider, to collect information about Services usage and the users of the Services, including demographic and interest-level information. Google uses cookies to collect demographic and interest-level information and usage information from users that visit the Services, including information about the pages where users enter and exit the Services and what pages users view on the Services, time spent, browser, operating system, and IP address. Cookies allow Google to recognize a user when a user visits the Services and when the user visits other websites. Google uses the information it collects from the Services and other websites to share with us and other website operators' information about users including age range, gender, geographic regions, general interests, and details about devices used to visit websites and purchase items. We do not link information we receive from Google with any personal identifiable information. For more information regarding Google's use of cookies, and collection and use of information, see the Google Privacy Policy (available at https://policies.google.com/privacy?hl=en). If you would like to opt out of Google Analytics tracking, please visit the Google Analytics Opt-out Browser Add-on (available at https://tools.google.com/dlpage/gaoptout). 

Other Similar Technologies

Turtle Wax web pages may use other technologies such as web beacons to help deliver cookies on the Services and count users who have visited those websites. We also may include web beacons in our promotional email or newsletters to determine whether you open and act on them as well as for statistical purposes. 

In addition to standard cookies and web beacons, the Services can also use other similar technologies to store and read data files on your computer. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally. 

How to Control and Delete Cookies

Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the Help Section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your cookie preferences across these environments. 

If you are using a mobile device to access the Services, you will need to refer to your instruction manual or other help/settings resource to find out how you can control cookies on your Device. 

Please note: If you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the Services may not operate properly, and you may not have access to the Services available through the Services. Turtle Wax shall not be liable for any impossibility to use the Services or degraded functioning thereof, where such are caused by your settings and choices regarding cookies. 

To learn more about cookies and web beacons, visit https://www.allaboutcookies.org.  

7. THE DIGITAL PERSONAL DATA PROTECTION ACT, 2023 OF INDIA (DDPLA) and the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”)

Residents of India may be entitled to other rights under the IT Act and the SPDI Rules including the Digital Personal Data Protection Act, 2023 (DPDP Act). These rights are summarized below. We may require you to verify your identity before we respond to your requests to exercise your rights. If you are entitled to these rights you may exercise these rights with respect to your personal information and sensitive personal information that we collect and store:

• the right to withdraw your consent to the collection or use of your sensitive personal data or information at any time, by submitting a written request to us. (please note that this might prevent you from using certain aspects of the Services and we may no longer be able to provide you certain services that rely on that data);
• the right of access your personal information or sensitive personal data;
• the right to request a copy of your personal information or sensitive personal data;
• the right to correct any inaccuracies in your personal information or sensitive personal data;
• You may request information on the categories of third parties with whom we have shared your personal data, except where disclosure is restricted by law enforcement or regulatory exceptions.

Note: India has recently passed the Digital Personal Data Protection Act, 2023 (DPDP Act), which is expected to come into force soon. Once effective, this law will enhance your rights as a user, including rights to erasure, data access, and grievance redress. We are actively working to align our policies and practices with this upcoming framework. 

Any requests to exercise the above listed rights may be made to: DPO@turtlewax.com. If you are an EEA resident, you have the right to lodge a complaint with a Data Protection Authority about how we process your personal information at the following website: https://edpb.europa.eu/about-edpb/board/members_en.

8. THE GENERAL DATA PROTECTION REGULATION (“GDPR”) AND UNITED KINGDOM DATA PROTECTION LAWS (“UK GDPR”)

Residents of the EEA may be entitled to other rights under the GDPR. These rights are summarized below. We may require you to verify your identity before we respond to your requests to exercise your rights. If you are entitled to these rights, you may exercise these rights with respect to your personal information that we collect and store: 

• the right to withdraw your consent to data processing at any time (please note that this might prevent you from using certain aspects of the Services);
• the right of access your personal information;
• the right to request a copy of your personal information;
• the right to correct any inaccuracies in your personal information;
• the right to erase your personal information;
• the right to data portability, meaning to request a transfer of your personal information from us to any other person or entity as chosen by you;
• the right to request restriction of the processing of your personal information; and
• the right to object to processing of your personal information.
• the right to not be subject to automated decision-making, GDPR Article 22(1) and (4) do not take place in connection with your personal data.

 You may exercise these rights free of charge. These rights will be exercisable subject to limitations as provided for by the GDPR. Any requests to exercise the above listed rights may be made to: DPO@turtlewax.com. If you are an EEA resident, you have the right to lodge a complaint with a Data

Protection Authority about how we process your personal information at the following website: https://edpb.europa.eu/about-edpb/board/members_en. If you are a resident if the United Kingdom you may contact the UK supervisory authority, at the Information Commissioner’s Office. 

9. US AND OTHER DATA PROTECTION CHOICES AND RIGHTS

State consumer privacy laws may provide their residents with additional rights regarding our use of personal information. The following Section applies to individuals who reside in specific jurisdictions that provide additional privacy rights.

9.1 Your Rights and Choices

Right to Access Specific Information and Data Portability Right. You have the right to request that we disclose certain information to you about our collection and use of personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed personal information for a business purpose, the business purpose for which personal information was disclosed, and the personal information categories that each category of recipient obtained. 

Right to Correct Information. You have the right to request we update personal information about you that is incorrect in our systems. 

Right to Delete. You have the right to request that we delete any personal information about you that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) the personal information from our records, unless an exception applies. 

Right to Opt-out of the Sale or Sharing of Personal Information for Cross-Contextual Behavioural Advertising. To opt-out of personal information sales or sharing, visit Do Not Sell of Share My Personal Information. 

Right to Limit Sensitive Personal Information Use. You have the right to limit the use of sensitive personal information regarding you. 

Non-Discrimination. We will not discriminate against you for exercising any of your rights.

9.2 How to Exercise these Rights

To submit a request to exercise these rights you may use one of these three methods:

• Email: dpo@turtlewax.com
• Phone: 1-855-458-7639
• Submit a Request through the Verifiable Consumer Request Form

For all requests, please clearly state that the request is related to “Your Privacy Rights,” indicate which type of request you are making, and provide your name, street address, city, state, zip code and an e-mail address or phone number where we may contact you. We are not responsible for notices that are not labelled or sent properly or that do not include complete information. 

To appeal a decision regarding a consumer rights request, please submit your appeal using one of the three methods above. Your appeal should include an explanation of the reason you disagree with our decision. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. 

Only you, or a person registered with the applicable Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to personal information about you. You may also make a verifiable consumer request on behalf of your minor child. 

You may only make such a request for access or data portability twice within a twelve (12)-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the twelve (12)-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide the personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

9.3 Opt-out Preference Signals

Our website honours General Privacy Control (“GPC”) opt-out preference signals when such signals are configured through your browser. You can get further help in configuring your browser by visiting: https://globalprivacycontrol.org/ 

9.4 Personal Information Sales Opt-Out

If you are age 16 or older, you have the right to direct us to not sell personal information about you at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years old, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time. 

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet webpage link: Do Not Sell of Share My Personal Information.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. 

10. WHAT IF I ACCESS A THIRD-PARTY SITE THROUGH THE WEBSITE?

The website may contain links to or from third-party sites. Please be aware that we are not responsible for the privacy practices of such third parties. This Notice applies only to the personal information we collect as described above. We encourage you to read the privacy policies of third-party sites you access from links on the website or otherwise visit. 

11. WHAT IF I ACCESS OR USE A SOCIAL NETWORK OR PUBLIC FORUM THROUGH THE SERVICES?

Our website may facilitate easy access to certain social networking sites and other websites or services with user-generated content features, such as Facebook, Instagram, and Twitter (“Social Sites”). You understand that we do not control such services and are not liable for the manner in which they operate. Please review the Social Sites’ privacy policies if you would like more information about how they collect, use and share your personal information, your privacy rights, and how to change your privacy settings. 

Our website may enable you to:

• Access Social Sites: This may include: access to websites such as a YouTube video; or activation of third-party websites when you make a ‘comment’, ‘share’, or ‘like’ something on the Social Site using a third-party social network plug-in. In each instance, such third party’s privacy policy will apply to your interaction with that website or service;
• Submit content to Social Sites: For reviews, discussion forums, message boards, photographs, and other public features (“Public Forums”). We do not restrict the distribution of personal information that you voluntarily disclose in these Public Forums, so please be aware that any information you disclose there may be collected and used by us and others. For this reason, we encourage you to refrain from providing or sharing personal information about yourself in the Public Forums. We cannot prevent third parties from using such information in a way that may violate this Notice or applicable law;
• Accept certain cookies from the Site (for example “Facebook Pixels”). These types of cookies help us understand your activity including the Turtle Wax content you see, whether or not you have a Social Site account and if you are logged into that account. This information helps us to show you Turtle Wax content you might be interested in on the Social Sites and measure the effectiveness of the Turtle Wax content.
• Sign-in to the Site using a Social Site: For example, for a harmonized user experience.

Signing-in using a Social Site or other third-party account may allow us to access information that you have given the Social Site permission to share. The sign-in feature may also transfer information to the Social Site or third party, such as your username or social media handle, to authenticate you. The Social Site or third party may also automatically collect information such as your IP address, information about your browser and device, and the web page address of the Site. The sign-in feature may also place and read cookies from that third party that may contain a unique identifier the Social Site or other third party assigns to you. The functionality of and your use of the sign-in is governed by the privacy policy and terms of the Social Site. 

We may use your personal information to identify you on Social Sites and to show you ads that are more relevant for you. The Social Sites will not share your personal information with other parties and will delete the information promptly after the matching process is complete.

Our use of your personal information in relation to the Social Sites will be as set out in this Notice or as otherwise notified to you. Again, please note that third party sites (including the Social Sites) may be under the control of a third party and we encourage you to familiarize yourself with the privacy policies and terms of use of each third party site. 

12. HOW DO I STOP RECEIVING MARKETING COMMUNICATIONS?

We will only send you marketing communications if you have agreed to this, or if we are otherwise permitted by law. If at any time you decide that you no longer wish to receive marketing communications from us, you may opt out by clicking on the relevant ‘unsubscribe’ link in the emails you receive, by texting “STOP” in response to any text message or by contacting us using the details found in the section “How do I contact Turtle Wax?”. 

Please note, while we will honour your request to stop receiving marketing communications, we will continue to send you service-related communications such as emails confirming purchases through the website. 

13. DOES TURTLE WAX TRANSFER MY PERSONAL INFORMATION TO OTHER COUNTRIES?

In order to provide our services, we may need to transfer and process your personal information internationally (including to destinations outside the country in which you are located).

As a result, your information may be transferred to and/or processed in countries which may not guarantee the same level of protection for personal information as the country in which you reside. However, we have taken appropriate safeguards to ensure that your personal information will remain protected in accordance with this Notice. 

Further information can be provided on request: please contact us using the details found in the section “How do I contact Turtle Wax?” We have also implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request. 

14. IS MY PERSONAL INFORMATION SECURE?

We understand that you care how your personal information is used and/or shared with others, and we value your trust and seek to safeguard your personal information. 

We implement appropriate technical and organizational security measures, including physical, administrative, and technical safeguards to protect your personal information from unauthorized access, use, and disclosure. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

The measures we use to protect your personal information are designed to provide a level of security appropriate to the risk of processing your personal information. However, please be aware that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures that we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective. 

15. HOW OLD DO I HAVE TO BE TO USE THE TURTLE WAX SITES OR OTHER DIGITAL OFFERINGS?

You must be aged 13 or over to use the Turtle Wax sites and our other digital offerings. We do not knowingly process or disclose the personal information of individuals below the age of 18, except as required to deliver services and with appropriate guardian consent, where applicable. 

Turtle Wax encourages parents and guardians to monitor and participate in their children’s online activities. Unless you are viewing a website directed specifically to children, no information should be submitted to this site by users under 13 years of age, and users under 13 years old are not allowed to register for newsletters, clubs, or activities. In addition, users under 18 years of age are not allowed to make purchases or participate in contests, except for those specifically directed to children. Where appropriate, Turtle Wax may ask you to indicate your age to verify compliance with these policies. 

We take your privacy very seriously and we understand the importance of taking extra precautions to protect the privacy and safety of children who use our products and services. We do not solicit or knowingly collect personal information from children aged 13 and under. If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records. 

California Minors: If you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: dpo@turtlewax.com. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the content or information. Removal of your personal information from the Services does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.

16. DOES THIS NOTICE EVER CHANGE?

We may update or modify this Notice from time to time in response to changing legal, technical, or business developments. We will obtain your consent to any material Notice changes if and where this is required by applicable data protection laws. The date of the most recent version of this Notice will appear at the top of the page. 

When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. For example, we will notify you of any changes to this Notice by posting a new Notice and updating the “last updated” date at the top of this page or by sending the new Notice to you via email, where appropriate. 

17. HOW DO I CONTACT TURTLE WAX?

We have taken great measures to ensure that your visit to the website is an excellent one and that your privacy is respected. If you have any questions, comments, or concerns about our privacy practices and/or would like to submit a privacy request, please contact us either:

Ø Via email at dpo@turtlewax.com and/or

Ø  Via toll free telephone at 1-855-458-7639 and/or

Ø  Via postal mail at: Turtle Wax, Inc., Attn: Data Protection Officer, 948 Springer Drive, Lombard, IL 60148

California Shine the Light Law

California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to dpo@turtlewax.com or write us at: Turtle Wax, Inc., Attn: Data Protection Officer, 948 Springer Drive, Lombard, IL 60148 

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described in this Notice, or your choices and rights regarding such use please do not hesitate to contact us at:

Phone: 1-855-458-7639

E-mail: dpo@turtlewax.com

Postal Address: Turtle Wax, Inc., Attn: Data Protection Officer, 948 Springer Drive, Lombard, IL 60148 

Questions about our products should not be directed to this address and will not be replied to.

If you would like your email address removed from our database, please send an email to marketing@turtlewax.com and include “Remove from Mailing List” in the subject line, or, alternatively click here. 

Please use this contact information only for legal and privacy policy matters. For all other inquiries, refer to the Contact Us section of our home page