Effective Date: March 1st, 2023

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

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

Who may collect personal information?

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

What is personal information?

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

What personal information is collected?

• • When you purchase a product from our websites, we may collect your name, mailing and billing address(es), telephone number, email address and/or credit card or checking account information.
  • When you register a product, we may collect your name, address, telephone number and email address.
  • When you download software or software updates that we make available, we may collect the date and time of the download, and information about the device onto which the software is downloaded. We may also collect your IP address temporarily to identify the geographic region in which the download takes place.
  • When you join one of our mailing lists, we may collect your name and email address.
  • When you contact our online customer support, we may collect your name, telephone number, email address and mailing address.
  • When you register for contests or giveaways hosted by the Services, we may collect your name, email address, telephone number, address and other information as specified in such contest or giveaway.

How is personal information used by Turtle Beach?

Turtle Beach collects and uses your personal information:

• • To fulfill or meet the reason you provided the information. For example, when you place an order with us on our website, we will request certain information from you. This information is likely to include your name, e-mail address, payment card details, billing address, shipping address and telephone number. This information will be used to process your order, arrange delivery of your order and correspond with you in relation to your order. Additionally, we may also save your information to facilitate new product orders or to process returns.
  • To provide, support, personalize and develop our Services. For example, we may automatically record which Services you use to join our mailing list so that we communicate with you in that language in the future.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent fraud. For example, when you place an order, we may share your name, physical and email address and order details (date, amount, product) with Signifyd for fraud prevention services. Signifyd’s privacy policy is available here: https://www.signifyd.com/privacy/.
  • To respond to requests for support or otherwise provide customer service, including to investigate and address your concerns and monitor and improve our responses.
  • To inform you of other products or services available from Turtle Beach and its affiliates and about promotions and events.
  • To contact you to inquire whether you want to provide a review of the products you purchased or to provide other feedback regarding your purchase.
  • To conduct research about your opinion of current products and services or of potential new products or services.
  • To notify you of the results of any contests or giveaways.
  • To research and analyze data and trends to improve our Services and our marketing and informational communications with you.
  • To send you important notices about the website, including updates to the Terms of Sale and Terms of Use.
  • To help maintain the safety, security, and integrity of our Services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Services.
  • To enforce contractual commitments that you may enter into with us including, but not limited to, collection actions.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

In addition to the personal information described above, we may collect, or we may authorize third-party companies to collect on our behalf, information to help us learn what products are of the most interest to users and to improve the Services’ design and content. Some examples are:

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

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

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

We may combine the information we collect through cookies with other information we have collected from you or other sources.

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

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

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

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

Our Services may contain links to third-party websites or permit you to log in to third-party services, which may have privacy policies that differ from our own.

For example, Roccat’s Swarm software may give users the option to log in to third-party services in order to enable “message waiting” and “incoming call” notifications from those third-party services or otherwise enhance the functionality of our Services.

Turtle Beach does not have control over and is not responsible for the privacy policies and practices of such third-party websites and services. Please refer to the privacy policies of the applicable third-party website or service to learn about how they handle your personal information before disclosing any personal information.

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

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

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

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

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

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

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

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

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

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

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

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

Our U.S. State Privacy Supplement (the “Supplement”) provides additional information about our personal data processing practices in accordance with U.S. state privacy law requirements. Unless otherwise expressly stated, all terms defined in the Supplement retain the same meaning in this Privacy Policy.

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

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

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

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

A parent or legal guardian who needs to access, change or delete personal information regarding their child should contact USPrivacy@turtlebeach.com. For consumers outside of the US, please use the contact information listed in the Turtle Beach privacy policy for your jurisdiction.

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

If you have any comments on or questions about this Privacy Policy or believe that Turtle Beach has not adhered to this Privacy Policy or any privacy law, please contact USPrivacy@turtlebeach.com. For consumers outside of the US, please use the contact information listed in the Turtle Beach Privacy Policy for your jurisdiction. If we need, or are required, to contact you concerning any event that involves your information, we may do so by email, telephone, or mail. If you make a purchase, we (or someone on our behalf) may will send you a confirmation email.