Turtle (“Turtle,” “we,” “us,” “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our mobile application, website, and related services (the “Services”).
Payments: Processed by App Store/Google Play; we do not store full card details.
Cookies & Similar Tech (on web): To remember settings, prevent fraud, and measure performance.
3) How We Use Your Information
Provide and operate the Services (account creation, matchmaking, Focus Mode, daily limits).
Review profiles for community quality and safety.
Personalize recommendations and improve user experience.
Communicate with you about updates, support, and policy changes.
Detect, prevent, and respond to fraud, abuse, or security incidents.
Comply with legal obligations and enforce our Terms.
4) Legal Bases (GDPR)
Contract: To provide the Services you request.
Legitimate Interests: Safety, prevention of abuse, product improvement, analytics.
Consent: Where required (e.g., marketing, precise location).
Legal Obligation: Where laws require retention or disclosure.
5) Sharing & Disclosure
Other Users: Information you post on your profile or share in chats is visible to matches.
Service Providers: Hosting, analytics, moderation, and customer support providers under contract and subject to confidentiality.
Law Enforcement/Legal: When required by law or necessary to protect rights, safety, or property.
Business Transfers: In the event of a merger, acquisition, or asset sale, your data may be transferred under appropriate safeguards.
We do not sell personal data.
6) International Data Transfers
Your data may be processed in countries outside your residence (e.g., the U.S. or EU). Where required, we use safeguards such as Standard Contractual Clauses.
7) Data Retention
We retain personal data only as long as necessary for the purposes described. If you delete your account, we delete or anonymize personal data within [30–90 days], unless we must retain it to comply with legal obligations or resolve disputes.
8) Your Rights
Access/Portability: Request a copy of your data.
Rectification: Correct inaccurate or incomplete data.
Deletion: Request deletion of your data (subject to legal exceptions).
Restriction/Objection: Restrict or object to certain processing.
Withdraw Consent: Where we rely on consent (e.g., marketing), you can withdraw it anytime.
Appeals: You may contact your local data protection authority.
The Services are for users 18+. We do not knowingly collect data from children under 18. If you believe an under-18 user has provided data, contact us to remove it.
11) Security
We use technical and organizational measures (encryption in transit, access controls, monitoring) to protect your information. No system is 100% secure—use caution when sharing personal details.
12) Communications Preferences
You can manage push notifications and marketing preferences in your device or in-app settings. Transactional messages (e.g., security, legal notices) may still be sent.