Effective Date: 09-09-2021
Table Of Contents- 1. SCOPE
- 2. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
- 3. HOW DO WE COLLECT YOUR PERSONAL DATA?
- 4. MARKETING
- 5. HOW WE WILL USE THE INFORMATION WE COLLECT ABOUT YOU
- 6. DATA COLLECTION TECHNOLOGY
- 7. USING YOUR PERSONAL DATA
- 8. POLICIES FOR CHILDREN
- 9. DISCLOSURES OF YOUR PERSONAL DATA
- 10. THE GENERAL DATA PROTECTION REGULATION (“GDPR”)
- 11. DATA SECURITY
- 12. HOW LONG WILL YOU USE MY PERSONAL DATA?
- 13. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
- 14. LINKED SITES
- 16. CONTACT INFORMATION
This policy is intended to help you understand how Turtle Wax, Inc. its subsidiaries - including Turtle Wax Europe Limited and Marvel Oil Company Inc.- and affiliates ("Turtle Wax," "we," or "us") collect, use and safeguard the information you provide on our website. If you are in the EU, Turtle Wax Europe Limited is the controller responsible for your personal data.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
Turtle Wax collects different kinds of personal data from you when you use our website, below are some examples:
• Identifiers. Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
• 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.
• Protected Classification Characteristics. Such as age (40 years or older), sex (including gender, gender identity).
• Commercial information. Such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other similar network activity. Such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
• Geolocation data. Such as physical location or movements.
• Professional or employment-related information. Such as current or past job history or performance evaluations.
If you browse the Turtle Wax website, you may generally do so anonymously without providing any personal data. However, there are cases in which we may ask you for personal data. Personal data is information that relates to an identified or identifiable natural person, this means a human being. Anonymous data, where you cannot find out who the data relates to, is not personal data.
We will occasionally conduct on-line surveys to better understand the needs and profile of our visitors. In addition, we may request personal data when you register to receive additional information regarding our products and services, sign up for a newsletter, 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.
In case you change your mind or wish to update or delete personal data (such as your zip code), we will take action to correct, update or remove the personal data you give us. You can do this by using the contact points specified below (See Contact Information).
When you place an order for a product, we need to know your name, e-mail address, mailing address, credit card number and expiration date. This personal data is required so that we can process and fulfill your order, send an order or shipping confirmation, as well as notify you of your order status.
All internet transactions with Turtle Wax are performed on a secure server that encrypts your credit card information to ensure it is not read by unauthorized third parties.
We may collect anonymized details about your use of the website for the purposes of aggregate statistics or reporting purposes. Aggregated data (your data combined with other people’s data) may come from your personal data but if it does not directly or indirectly reveal your identity, it is not considered personal data. For example, we may combine and analyze your use of the website to work out the number of users accessing a specific website feature.
3. HOW DO WE COLLECT YOUR PERSONAL DATA?
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. Other instances where we may collect information are, when you:
• Visit our website or social media pages (e.g. through cookies);
• Enter a competition or promotion;
• Sign up for our mailing list/newsletter;
• Inquire about or order products through our website or via phone, fax, email, post or in person;
• Buy our products or services;
• Create an account on our website;
• Provide feedback;
• Fill in a form on our website; and/or
• Otherwise contact us.
If you make a payment to Turtle Wax, we will ask for Payment Data and other information requested for processing your payment.
4 . MARKETING
We would like to send you information about products and services of ours which may be of interest to you such as product updates, special offers, important issues and new products of Turtle Wax. If you have consented to receive marketing, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other companies.
If you no longer wish to be contacted for marketing purposes, please use the contact points specified below (See Contact Information), or alternatively please click here.
5. HOW WE WILL USE THE INFORMATION WE COLLECT ABOUT YOU
Personal data provided by users who are 13+ years of age may be used for marketing and promotional purposes only by Turtle Wax. Turtle Wax does not rent, sell or otherwise distribute to third parties, your personal data entered on this site without your consent, unless required by law or as disclosed to you when the information is collected.
If you do provide us with consent to share your information with other companies, we may share your information with companies who offer products and services that may be of interest to you. These companies may then contact you directly with product or sample offers, personalized offers and information, or to ask for your feedback on products and programs that they think may be of interest to you.
While we use all reasonable efforts to safeguard the confidentiality of your information, in relation to third parties, Turtle Wax will have no liability for disclosure of any information obtained due to errors in transmission or their unauthorized acts. Turtle Wax also reserves the right to change or update this policy, or any other policy or practice, at any time, with reasonable notice to users of its website.
Any changes or updates will be effective immediately upon posting to the Turtle Wax site. We may share statistical or aggregated non-personal data about our users with advertisers, business partners, sponsors and other third parties. This data is used to customize Turtle Wax website content and advertising to deliver a better experience to our users.
6. DATA COLLECTION TECHNOLOGY
Data Collection Technology deployed through the website includes cookies and web beacons.
Web Beacons: A web beacon (also called a pixel tag or clear GIF) is computer code that communicates information from your device to a server. Some of Turtle Wax’s content and emails may contain embedded web beacons that allow a server to read certain types of information from your device, allow us to count the number of people who have viewed content, to know when you opened an email message and the IP address of your device. Web beacons help Turtle Wax develop statistical information to provide better and more personalized content.
Cookies: Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using the website.
The website uses the following cookies:
• Strictly necessary cookies, which are required for the operation of the website. Without them, for example, you would not be able to register or log in for the website that Turtle Wax offers.
• Analytical/performance cookies, which allow Turtle Wax to recognize and count the number of visitors, learn how visitors navigate the website and improve the website.
• Functionality cookies, which Turtle Wax uses to recognize you when you return to the website.
To learn more about cookies and web beacons, visit www.allaboutcookies.org.
Turtle Wax also uses analytics services, such as Google Analytics and Facebook Pixels, to collect Other Information. Generally, analytics services do not identify individual users. Many analytics services allow you to opt out of data collection. For example, to learn more about Google Analytics practices and to opt out, visit www.google.com/settings/ads or by downloading the Google Analytics opt-out browser add-on at tools.google.com/dlpage/gaoptout.
How Turtle Wax Uses Data Collection Technology: Some Data Collection Technology is deployed by Turtle Wax when you visit the website. Other Data Collection Technology is deployed by third parties with which Turtle Wax partners to deliver the website.
Data Collection Technology helps us improve your experience of the website by, measuring the success of marketing campaigns, compiling statistics about use of the website and helping us analyze technical and navigational information about the website.
We also may use Data Collection Technology to collect information from the device that you use to access the website, such as your operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located.
Your Control of Cookies: Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the website.
Do Not Track: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Turtle Wax, do not respond to DNT signals.
7. USING YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(b) Customer Records
(c) Customer Records
(d) Commercial Information
Performance of a contract with you
(b) Customer Records
Necessary to comply with a legal obligation
To ask you to leave a review or take a survey
(b) Customer Records
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(b) Customer Records
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Internet and Network Activity
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
To contact you regarding items in your online shopping cart that you have not purchased.
Necessary for our legitimate interests (to establish if customers are still interested in items left unpurchased in their shopping cart)
To contact you with instructions on how to use the items you purchase.
Performance of a contract with you
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 data (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 firstname.lastname@example.org or write to us at:
Data Protection Officer
Turtle Wax, Inc.
2250 W. Pinehurst Blvd.
Addison IL, 60101
8. POLICIES FOR CHILDREN
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.
Turtle Wax does not knowingly collect information from our guests under 13 years of age or provide any personally identifying information from such guests to any third party for any reason whatsoever. We do not allow guests known to be under 13 years of age to receive direct marketing communications from Turtle Wax or from third parties.
California Minors: While the Turtle Wax website is not intended for anyone under the age of 18, 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: email@example.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 content or information from the Service 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.
9. DISCLOSURES OF YOUR PERSONAL DATA
We do not disclose your personal data without your permission, unless the disclosure is:
• To our related companies;
• To third party service providers processing personal data on our behalf;
• To third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets; or
• Required or authorized by law.
We may disclose, or provide access to, your personal data to third parties in connection with the purposes described in the table above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
10. THE GENERAL DATA PROTECTION REGULATION (“GDPR”)
If you reside within the European Union you 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 data that we collect and store:
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need from You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limited to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We share your personal data within Turtle Wax. This will involve transferring your data outside the European Economic Area (EEA).
Some of our external third parties are also based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do so in compliance with our obligations regarding lawful data transfer pursuant to the GDPR.
Please contact us at email@example.com if you want further information about the specific mechanisms we use when transferring your personal data outside of the EEA.
Data Protection Officer
Turtle Wax Europe Limited
4th Floor Alaska House
11. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
While we take great care to protect your personal data on our website, unfortunately no information transmission over the Internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information you send to us or receive from us online. This is particularly true for information you send to us via email. We have no way of protecting that information until it reaches us.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
12. HOW LONG WILL YOU USE MY PERSONAL DATA?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data 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 data are available in our retention policy which you can request from us by contacting us at firstname.lastname@example.org.
13. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, the we collect or may have collected in the last twelve (12) months the categories of personal information as described in the “What Information Do We Collect About You?” section above.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the business purposes indicated in the “Using Your Personal Data” section above.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information 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. We share your personal information with the categories of third parties listed in the “Disclosures of Your Personal Data” section above.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
• California Customer Records personal information categories
• Commercial information
• Internet or other similar network activity
• Geolocation data
• Professional or employment-related information
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
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 your 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 your 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 Delete
You have the right to request that we delete any of your personal information 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) your personal information from our records, unless an exception applies.
Exercising Your Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
• Calling us at 1-855-458-7639
• Visiting www.turtlewax.com/privacy-policy/
• Sending us an e-mail at email@example.com
For submissions via email please use the downloadable Turtle Wax Verifiable Consumer Request Form.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. 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 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 endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 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 12-month period preceding the verifiable consumer request’s receipt. 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 your personal information that is readily useable 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.
We will not discriminate against you for exercising any of your CCPA rights.
Please be advised that our website may contain links to third party websites. The linked sites are not under the control of Turtle Wax, and we are not responsible for the contents or privacy practices of any linked site or any link on a linked site.
16. CONTACT INFORMATION
Data Protection Officer
Turtle Wax, Inc.
2250 W. Pinehurst Blvd.
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 firstname.lastname@example.org and type the word "Remove from Mailing List" in the subject line, or, alternatively click here.