If you access our applications, services, or websites, from the EU, Iceland, Liechtenstein, or Norway, this Privacy Notice explains how Aabaco Small Business, LLC and its affiliates (the "Company") collects, uses, and discloses your personal data when you register with us on our website or use our digital small business services ("Turbify Services"). Collection, use, and disclosure of personal data is sometimes referred to as processing. This notice also explains your rights related to this data.

1. Personal data we use: Any data that could reasonably be used to identify you is personal data. We collect your personal data when you provide it to us and when you use the Turbify Services. Turbify collects personal data from you including your name, work or personal address, wireline and/or mobile telephone number, email address, IP address, payment details (including credit card and payment account information), social media information, business emails, any photos, images or videos you provide, and if we speak to you by phone, your call audio and other personal information provided during the call(s).

2. The data controller: Aabaco Small Business LLC located at 2600 Tower Oaks Blvd., Suite 700, Rockville, MD 20852, USA.

3. Contact email: emeadataprotection@turbify.com

4. Turbify’ reasons for processing your personal data: Your personal data is processed for the following purposes:

   1. If you are a consumer or small business contracting for Turbify Services to manage service delivery: We process your personal data to: (1) provide you with Turbify Services; (2) identify you and authenticate your registration and subsequent requests to access Turbify Services; (3); process purchase orders; (4) provide customer support services, account management and handle complaints; (5) improve Turbify Services; and (6) when necessary, exercise our legal rights. Our legal basis for processing your personal data is our necessity to process data to fulfill our contractual commitments to provide you with Turbify Services.

   2. If you are an individual acting on behalf of a Turbify customer to manage service delivery: We process your personal data to: (1) identify you and authenticate your registration and subsequent requests to access Turbify Services; (2) process purchase orders (3) provide customer support services, account management and handle complaints (4) improve Turbify Services; (5) communicate with you with respect to the operation of Turbify Services; and (6) when necessary, exercise our legal rights. Our legal basis for processing your personal data is our necessity to process such data for the purposes of our legitimate business interests. We have put in place safeguards to ensure that your privacy is protected and that our legitimate interests do not override your interests or fundamental rights and freedoms.

   3. Provision of marketing to you: Upon your opt in consent, Turbify shall use your personal data to (1) contact you with marketing and offers relating to products and services offered by us and (2) to personalise marketing messages we send you to make them more relevant by analysing your use of our services to make suggestions for other products. Our legal basis for processing your personal data is your consent to receive our marketing. You may withdraw your consent to receive such marketing by accessing your Profile Page and toggling off the marketing opt-in. Further information with respect to Turbify’ privacy practices is set forth in the Privacy Policy.

5. International transfer of your personal data: Your personal data will, in many instances, be processed outside of the EEA by Turbify or our approved third party suppliers, operating in areas such as: (1) IT Hardware and Software Services; (2) Cloud Services; (3) Advertising & Marketing; (4) Business Services & Human Capital Management; and (5) Administration & Field Services. We have safeguards in place in accordance with applicable law to ensure that your personal data will, at all times and in all locations, be adequately protected to the standards required by applicable EEA Data Protection laws.

6. When we share your personal data: We may share your personal data among the Turbify family of companies, with our approved third party suppliers and as set forth in the Privacy Policy.

7. Personal data retention period: We will keep your personal data for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal data for a period of time that enables us to: (1) maintain business records for analysis and/or audit purposes; (2) comply with record retention requirements under the law; (3) defend or bring any existing or potential legal claims; and (4) deal with any complaints regarding the services. We will delete your personal data when it is no longer required for these purposes. If there is any personal data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of that data. Please contact emeadataprotection@turbify.com if you would like additional information about data retention.

8. Right to object: In certain circumstances, you may object to Turbify’s use of your personal data. Please contact emeadataprotection@turbify.com about your right to object.

9. Additional rights: You may access your personal data or request that Turbify erase or restrict the processing of your personal data by contacting us at emeadataprotection@turbify.com. You also have the right to complain to your data protection regulator. For more information about your rights, please review the Privacy Policy.