Privacy Policy

These Privacy Policy was updated on and went into effect from: September 16th, 2024

Bubbles. B.V. (collectively, “Turf“, “we,” “us,” or “our“) respect the privacy of individuals who interact with us, such as our website visitors, customers, leads and prospects, business partners, end users, event attendees, job applicants and recipients of marketing communications (“you” or “your“). This Privacy Policy explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.

This Privacy Policy only applies to personal information that is provided to or is collected by us (i) through our website ww.w.useturf.io (“Website“) and (ii) when you visit, interact with or use any of our offices, events, sales, marketing, and related online and offline activities. When we refer to any combination of the above in this Privacy Policy, we use the term “Services“.

This Privacy Policy also does not apply to websites, products, or services that display or link to different privacy statements or that are operated by companies other than Turf, or to business activities or practices of third parties. The controller of the personal information addressed in the Privacy Policy is Turf.

If you have any questions about this Privacy Policy, please contact our Privacy Team at info@useturf.io

When you access or use our Services, you acknowledge that you have read this Privacy Policy and understand its content. Your use of our Services and any dispute over privacy is subject to this Privacy Policy and any applicable service terms (including any applicable limitations on damages and the resolution of disputes).

Who we are

Turf is a company incorporated under the Dutch law. We own and operate a proprietary Customer Community platform (SaaS). While having a global presence we are located with our office in the Netherlands. For more information about Turf, please see our LinkedIn page or our Website.

What personal information do we collect?

The personal information that we collect about you depends on the context of your interactions with Turf and the choices you make, the Services and features you use, your location, and applicable laws, but broadly falls into the following categories which in the preceding 12 months included:

Information that you provide voluntarily

When you subscribe to marketing or one of our newsletters, request a free trial or demo or any online training materials, apply for a position, request information about our products and services, create an account, fill out our forms, visit our offices, register for an event or webinar, complete a survey and/or otherwise communicate with us in any way, we ask you to provide certain personal information. This may include:

• Contact information: such as your name, email address, mailing address or telephone number.

• Professional information: such as your employer’s name, job title, department or job role.

• Marketing information: such as your contact preferences.

• Applicant information if you apply for a job with Turf: such as your resume, desired pay, education and work history, whether you are over the age of 18, and visa status. You also may choose to provide your gender, ethnicity, veteran status, disability status, and links to your website, blog, portfolio, or LinkedIn profile.

• Online content: which includes personal information disclosed by you on message boards, chat features, blogs, communications and/or requests to Turf and other services or platforms to which you are able to post information and materials, including third party services and platforms.

We may also record or monitor our telephone or other communications with you, to the extent permitted by applicable law.

Providing your personal information is optional, but it may be necessary for certain Services, such as to access content like whitepapers, to activate or access an app or a cloud service. In such cases, if you do not provide your information, we may not be able to provide you with the requested Services.

Information we automatically collect

We automatically collect certain device and usage information including when you use or interact with our Websites and emails we send you.

The information we collect includes:

• Details about your computer, device, applications, and networks, including internet protocol (IP) address, cookie identifiers, mobile carrier, Bluetooth device IDs, mobile device ID, mobile advertising identifiers, MAC address, IMEI, Advertiser IDs, and other device identifiers that are automatically assigned to your computer or device when you access the Internet.

• Details about your internet, app, or network usage (including URLs or domain names of websites you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences).

• Geo-location (at country or city level only, not precise location).

• Performance information, crash logs, and other aggregate or statistical information.

We collect this information through our Website, Services and through other technologies, such as cookies and similar technologies like single-pixel gifs and web beacons. For more information, please review our Cookie Policy.

Information We Collect from Other Sources

We may receive information about you from other sources (including third parties from whom we have purchased personal information) and combine that information with the information we collect. For example, we collect personal information from joint marketing partners, channel partners, our affiliated companies, recruitment agencies, lead generation providers, public databases, data providers, and social media platforms.

This information may include mailing addresses, current and former job titles, email addresses, phone numbers, employment history, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs, and custom profiles and resumes.

How do we use the personal information that we collect?

We use the personal information that we collect about you for a variety of purposes and on the legal bases described in this Privacy Policy, which in the preceding 12 months included:

• Handling contact and user requests: If you fill out a web form or request support, if you contact us by other means, including via a phone call, we use your data to perform our contract with you or if we do not have a contract directly with you, in reliance on our legitimate interests in fulfilling your requests and communicating with you.

• Managing events: We use data to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you, to perform our contract with you or in reliance on our legitimate interests in administering and promoting the event.

• Sending marketing and promotional communications: We use data we collect to send promotional communications, including product recommendations, and other non-transactional communications (e.g. marketing newsletters, telemarketing calls, SMS, or push notifications) about Turf and our selected partners according to your marketing preferences. This may include information about our products, promotions, or events as necessary for our legitimate interest in conducting direct marketing, or to the extent you have provided your prior consent. Please see the Your Data Protection Rights section below to learn how you can control the processing of your personal information by Turf for marketing purposes.

• Displaying advertising and relevant offers: We use data we collect through our interactions with you to conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based on your activities and interests to the extent it is necessary for our legitimate interest in advertising our Services, or where necessary, to the extent that you have provided your prior consent. Please see the Your Data Protection section below to learn how you can control the processing of your personal information by Turf for personalized advertising. For these purposes, we may link or combine information about you with other personal information we get from third parties, to help understand your needs and provide you with better and more personalized service or content.

• Improving and developing the Services: We use data to analyze trends to identify future opportunities for the development, promotion, and improvement of our Services, in reliance on our legitimate interests in developing and improving our Services, or where required, with your consent. For example, we use data, often in a de-identified form, to develop new features, capabilities, or products, improve the user experience, assess capability requirements, and identify customer opportunities.

• Processing job applications: We process your personal information if you apply for a job with Turf, to evaluate your application and make hiring decisions, communicate with you and inform you of current and future career opportunities (unless you tell us that you do not want us to keep your details for such purposes), manage and improve our recruiting and hiring processes, or to conduct reference and background checks where required or permitted by applicable local law. We perform this processing to the extent that it is necessary to comply with our legal obligations, for our legitimate interest in assessing the suitability of our candidates and managing our recruiting process, or, where required by applicable law, with your consent.

• Securing the Services: We process data by tracking use of our Website and services for the purposes of maintaining the safety and security of our Services, including verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies, in reliance on our legitimate interest in promoting the safety and security of our Services, systems and applications and in protecting our rights and the rights of others.

• Registering office visitors: We may process your personal information for security reasons, to register visitors to our offices and to manage non-disclosure agreements that visitors may be required to sign, to the extent such processing is necessary for our legitimate interest in protecting our offices and our confidential information against unauthorized access.

• Complying with legal obligations: We process your personal information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws, to the extent this requires the processing or disclosure of personal information to protect our rights, or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, or to respond to lawful requests.

• For our business purposes: We may use data for other legitimate business purposes in reliance on our legitimate interests, such as to update, expand, and analyze our records, identify new customers, data analysis, to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, free trials and operating and expanding our business activities.

In carrying out these purposes, we combine data we collect from different contexts or that we obtain from third parties to give you a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes.

Who do we share your personal information with?

Whenever we share your personal information with a third party provider, we ensure that this is done so in accordance with applicable laws. The types of entities to whom we disclose and have disclosed information within the last 12 months, include:

• to our affiliates within the Turf corporate group and companies we may acquire in the future when they become part of the Turf corporate group, to the extent such sharing of data is necessary (for example, to fulfil a request you have submitted or for marketing or technical operations).

• to our contractors and third party service providers who provide services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Services), or who otherwise process personal information for purposes that are described in this Privacy Policy or notified to you when we collect your personal information.

• to our marketing partners of co-branded and/or co-sponsored marketing and promotional events (such as conference events or webinars) offered in conjunction with another company or companies. For example, if you attend an event or webinar organized by us, or download or access materials on our Website, we may share your data with sponsors of the event. If required by applicable law, you can consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. If you do not want your information shared, you can choose to not opt in upon registration or elect to not have your badge scanned, or you can opt out according to the Your Data Protection Rights section below.

• to analytics providers. We use Google Analytics, a service provided by Google, Inc. to gather information about how users engage with our Website. For more information about Google Analytics, please visit https://policies.google.com/technologies/partner-sites. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to https://tools.google.com/dlpage/gaoptout.

• 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;

• to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business or similar transaction with a third party involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of personal information to an unaffiliated third party;

• to any other person with your consent to the disclosure.

We may also share aggregated or deidentified usage data with third parties to help us perform analysis and make improvements. Additionally, we may share anonymous usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends in the use of our Services.

Any personal information or other information you choose to submit in communities, forums, blogs, or chat rooms on our websites may be read, collected, and used by others who visit these forums, depending on your account settings.

For further information on the recipients of your personal information, please contact our Privacy Team at info@useturf.io.

Links to Other Sites

Our Website may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service“). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access.
For example, our Websites include plugins of social media platforms, such as Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA; X (formerly Twitter Inc.), 795 Folsom St., Suite 600, San Francisco CA 94107, USA; and LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA. You can identify the plugins by the respective network’s logo. Details about purpose and extent of data collection, as well as processing and use of the data by the social media networks can be obtained by reading the privacy policies of Facebook, X, and LinkedIn.

Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively “Cookies”) to collect and use personal information about you. Please see Turf Cookie Policy, 

How do we keep your personal information secure?

We use appropriate administrative, organizational, technical and physical safeguards to protect the personal information we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information and to help ensure that your data is safe and secure. Specific measures we use include using encryption technologies and storage on physically and electronically secured servers. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Although we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. If you have any questions about the security of our Website, please contact us (see Contact Us below).

International data transfers

Your personal information may be collected, transferred to, and processed in, countries other than the country in which you are located. These countries may have data protection laws that are different to the laws of your country, and may not provide for the same level of data protection as your jurisdiction. We maintain our data centers in Frankfurt (AWS). We take steps designed to ensure that the data we collect under this Privacy Policy is processed as described in this Privacy Policy and according to applicable law.

We have implemented appropriate safeguards to ensure that the recipient of your personal information offers an adequate level of protection, including entering into the standard contractual clauses for the transfer of personal data, or where required, we will ask you for your prior written consent for such international data transfers.

Where we transfer your personal information to countries and territories outside of Europe, Switzerland and the UK which have been formally recognized as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” and “adequacy regulations” from the European Commission, Swiss and UK authorities.

Where the transfer is not subject to an adequacy decision, we take appropriate safeguards to ensure that your personal information will remain protected in accordance with this Privacy Policy and applicable laws. These safeguards include implementing the European Commission’s Standard Contractual Clauses as issued on 4 June 2021 under Article 46(2) GDPR for transfers originating in the EU and Switzerland; and the UK Addendum under Article 46(2) of the UK GDPR for the transfer of data originating in the UK.

Our Standard Contractual Clauses entered into by our group companies and with our third party service providers and partners can be provided on request. Please note that some sensitive commercial information will be redacted. If you have any questions or concerns related to international data transfers, please contact us using the information set forth below.

Legal basis for processing personal information (EEA visitors only)

If you are resident in or a visitor from the European Economic Area, our legal basis 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. In most cases we use personal information where we have your consent to do so, where we need it to perform a contract with you, or where the processing is in our legitimate business interests. In some cases, we have a legal obligation to collect personal information from you.

If we ask you to provide personal Information to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests, we will make clear to you at the relevant time what those legitimate interests are. Typically, our legitimate interests include: (i) improving our technology, products and services; (ii) for our marketing activities; and (iii) measuring the effectiveness of our marketing and promotional campaigns.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the Contact Us section.

We will give you an opportunity to opt out where personal information we control about you is to be disclosed to an independent third party, or is to be used for a purpose that is materially different from those set out in this Privacy Policy. If you otherwise wish to limit the use or disclosure of your personal information, please contact us via the contact details set out below.

Information about the types of third parties to which we disclose personal information and the purposes for which we do so is described in the “What personal information do we collect?” section. 

Please note that, under certain circumstances, we may be required to disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

You may also opt-out of receiving marketing communications from us by writing to us at the contact details provided below or by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you.

Data Retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements, to enforce our agreements or comply with our legal obligations). Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly. We determine the appropriate retention period for personal information based on the amount, nature and sensitivity of your personal information processed, the potential risk of harm from unauthorized use or disclosure of your personal information and whether we can achieve the purposes of the processing through other means, as well as applicable legal requirements (such as applicable statutes of limitation).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Please contact our Privacy Team at info@useturf.io if you have any questions about the information we collect and/or how we use the information we collect.

Your data protection rights

Where we are acting as a controller, and depending on your location and subject to applicable law, you may have the following rights regarding the personal information we control about you:

• You can access, review, change, update or delete your personal information at any time by contacting our Privacy Team at info@useturf.io. Please note that we may impose a small fee for access and disclosure of your personal information where permitted under applicable law, which will be communicated to you. We do not charge you to update or remove your personal information.

• To remove your personal information from a Website testimonial or request removal of your personal information from our blog or community forum, please contact our Privacy Team at info@useturf.io. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

• In addition, if you are a resident of the European Union, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. To exercise these rights please contact our Privacy Team at info@useturf.io.

• You can opt out of receiving promotional emails from us by emailing our Privacy Team at info@useturf.io. If you choose to no longer receive marketing information, we may still communicate with you regarding such things as your security updates, product functionality, responses to service requests, or other transactional, non-marketing/administrative related purposes.

• If you want your phone number to be added to our internal Do-Not-Call telemarketing register; (see Contact Us below). Please include your first name, last name, company, and the phone number you wish to add to our Do-Not-Call register. Alternatively, you can always let us know during a telemarketing call that you do not want to be called again for marketing purposes.

• If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area (“EEA“), the United Kingdom, Switzerland and certain non-European countries (including the USA and Canada) are available here.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your personal information.

Children

The Website and its content, as well as our products and services, are not directed at children. We do not knowingly collect, use or disclose any information from anyone under 16 years of age and do not knowingly target our Websites, products or services to children under the age of 16. Persons under 16 years of age should not use or provide any personal information through our Websites, products or services. If we learn we have collected or received personal information from a child under the age of 16, we will delete that personal information in accordance with applicable law. If you are a parent or guardian and you learn that your children have provided us with personal information, please see Contact Us below.

Notice to California Residents

The information in this section applies to residents of California. Please contact us at  info@useturf.io  if you have any questions about this Privacy Policy, including this section specific to California residents, or if you would like a printed copy of this Privacy Policy. You may also print a copy of this Privacy Policy by selecting the “Print” button in your web browser.

Categories of personal information that we collect

The categories of personal information that we have collected about you in the preceding 12 months and the third parties to whom we disclose such personal information for a business purpose are set forth below: