Turbify is part of the Infinite Computer Solutions, Inc. and its services and products (the "Services") are provided by Aabaco Small Business, LLC and their affiliates (the "Company") primarily to help fuel the growth and success of businesses on the Internet. The Company's Privacy Policy governs when You are on our site or are interacting with our products, services or technologies. If You are a merchant doing business with customers in the European Economic Area or other countries, You may have an obligation to comply with data protection laws beyond what is provided in this privacy policy, including a requirement to obtain consents for the processing of personal data, and these consents should include approval for the Company to process Your customers’ personal data.

This policy applies only to the Company and covers how we treat the Personal Data we collect through interaction with our sites, apps, products, and services. Personal Data is information about You that identifies You or Your device, like Your full name, address, email address, IP address, or phone number. The Company’s sites, products and services may not be used by children under the age of 13.

NOT COVERED:

• This policy does not override any elements of the terms directly established with the Company's customers or partners, including the Terms of Service. Capitalized terms not defined in this policy have the meanings set forth in the Terms of Service.
• The Company’s customers operate their own businesses, with their own websites, with or without the technical assistance of the Company, and all of their data collection and use is governed by their own privacy policies.
• This policy does not apply to the practices of companies that the Company does not own or control, or to people that the Company does not employ or manage.

The Company collects Personal Data when You register with the Company; when You interact with the Company's sites, apps, products, development tools, marketing programs, or services, and pages of the Company's customers and some partners; when You sign-up for a newsletter or when You enter a promotion or sweepstakes. The Company may combine information about You that we have with information we obtain from customers or partners, publicly available information, or other companies.

When You register or provide additional account information, we may ask for information such as Your full name, company name, email address, birth date, gender, phone number, mobile phone number, address, credit card number, tax identification number, business type, industry, and other details. When You register with the Company and use our sites, products, or services, You are not anonymous to us. For certain products, we may ask you to enable location information.

The Company collects information about Your transactions with us, our customers, and with some of our partners, including information about Your use of products and services that we offer.

The Company automatically receives and records information from Your computer and browser, including Your IP Address, the Company's cookies and other device information, software and hardware attributes, and the page You requested.

The Company uses information for various purposes, including for the performance of a contract, to meet the Company’s legal obligations, for legitimate business purposes, and also with Your consent, subject to the choices You have made. The Company also uses Your information for the following general purposes: to enable Your account, customize Your experiences, content, and advertising with us, our customers and some of our partners; fulfill, bill, and collect for Your requests for products and services; improve our services; provide recommendations; contact You; investigate fraud; conduct research; and provide reporting for our customers, internal purposes and partners.

When You register and provide Your contact information, You will be given options related to receiving marketing calls, text messages, and emails from the Company and others calling, texting, or emailing on its behalf. You may change Your preferences by signing in to Your account and going to Your "Profile." Such calls, text messages, and emails may include, for example, marketing messages, password reminders, authentication messages, account- or service-related alerts and reminders, customer service communications, satisfaction surveys, and other types of calls and text messages. You may not opt-out of receiving these communications for purposes of communications regarding Your account, Services, and the security of Your account.

Your Personal Data may be transferred outside of the country in which You reside for processing and storage. In the event of such transfers, the Company puts contractual protections in place to protect Your Personal Data.

The Company may share Personal Data about You within the Infinite Computer Solutions family of companies, with your consent, and under the following circumstances:

• Service Providers, Contractors, and Agents: We provide information to third parties who work on behalf of or with the Company under confidentiality agreements. These companies do not have any independent right to use or share this information for their own purposes.
• Legal Process: We respond to subpoenas, court orders, and legal process requests, and we may also share Personal Information to establish or exercise our legal rights, comply with regulatory requirements, or defend against legal claims.
• Security & Fraud: We may share Your information to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Service, or as otherwise required by law.
• Merger & Acquisition: We transfer information about You if the Company is acquired by or merged with another company.

The Company enters partnerships with third parties to provide or augment some of its sites, products, and services. In some cases, these partners may collect Personal Data about Your interaction with that page, product, or service subject to their own privacy policies. The Company may display targeted advertisements based on Your Personal Data or partner with companies who provide similar services. To learn more about Your choices with respect to interest-based advertising, including opting out, please visit the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising or other similar self-regulatory programs around the world such as the Internet Advertising Bureau. The Company does not support the Do Not Track standard.

The Company may set and access cookies on Your computer. We may also set and access device identifiers which could include IP address, user agent information (browser version, OS type and version), device provided identifiers, or computed identifiers. Once You log into a Service on Your device, the Company may link that device to Your account to provide a more personalized experience, independent of Your device settings.

We use tools such as cookies to provide services to You, and for advertising purposes. Some of these cookies are essential, while others help us to improve Your experience by providing insights into how the site is being used. When You first access our site, You will be presented with choices related to cookies. You may not opt out of cookies that are essential to Your experience on our site.

What types of cookies do we use?

• Essential cookies: These cookies are essential to deliver website services. Disabling these cookies may affect the functionality of the website. You may not opt out of essential cookies.
• Performance cookies: These include usage preferences cookies, which are activated when You make certain choices on our sites and remember settings preferences, permitting us to tailor services we provide to You, and analytical cookies, which allow us to recognize and measure Your use of our sites, compile a record of this usage information and help us improve and develop the way our sites work. Our sites use Google Analytics and other service provider cookies to help analyze how users use our sites. The information generated by the cookie about the use of the website will normally be stored on a Google or other service provider server in the USA. However, if You are located within the EU or the European Economic Area, Your IP address may be shortened by Google or other service provider beforehand. In exceptional cases only, Your full address will be transmitted to a server in the USA and shortened there. On behalf of the Company, Google and other service providers will use this information for the purpose of compiling reports on website activity and providing other services relating to website activity and internet usage. The IP address transmitted from Your browser as part of Google Analytics and other services will not be associated with any other data held by such providers. You may prevent web usage data (including Your IP address) generated by the cookie from being transmitted to Google or these service providers for this purpose and processed there if You download and install a browser plugin. You can manage Your preferences related to these types of cookies by going to Manage Your Cookies.
• Advertising cookies: These allow us and third parties to (a) provide a customized experience via advertisements across devices on certain of our websites or advertisements on third party websites and apps, or (b) monitor the effectiveness of our digital marketing campaigns. You can manage Your preferences related to advertising cookies when You are presented with a cookie banner, by going to the Manage Your Cookies link in the footer of our website, or by opting out of receiving interest-based ads for online advertising by going to the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising or other similar self-regulatory programs around the world such as the Internet Advertising Bureau.
• Third party cookies: When You use certain of our sites, You may receive cookies, web beacons, and SDKs set by the Company’s customers and partners. These cookies are used for some of the purposes described herein. These partners do not have access to the Company's cookies. You may wish to check the third party websites for more information about their use of cookies and how to manage them.

The Company may use web beacons, small segments of code that run on a web page, APIs (application programming interfaces) or SDKs (software development kits) within mobile apps, to access the Company’s cookies and device identifiers inside and outside our network of websites and in connection with the Services.

Subject to applicable law, You may ask to access, update, correct, port, and, where reasonably practical, delete Your personal data, or withdraw your consent to our use of Your personal data. You may exercise Your rights by emailing us at emeadataprotection@turbify.com or by mail at the address below. Please note, however, that withdrawing consent or choosing to delete some types of personal information may prevent us from supplying certain services to You. If You are in the EEA, You have the right to lodge a complaint with Your local authority responsible for privacy protection, and You may also have this right in other countries.

You can edit or deactivate Your account at any time. Domain registration may continue through Your current term unless You take steps to transfer to another provider. Certain technologies and development tools may continue to collect information until You remove them.

You may receive product update communications, calls, text messages, emails, newsletters and other communications about or related to the Services. You will have the opportunity to opt out of marketing and optional communications by clicking on unsubscribe links or by following unsubscribe instructions.

We limit access to Personal Data about You to employees, contractors, or service providers who we believe reasonably need to come into contact with that information to provide products or services to You.

We have technical, administrative, and physical safeguards in place to help protect against unauthorized access, use or disclosure of Personal Data about You.

The Company may update this privacy policy. We will notify You about materially significant changes in the way we treat previously collected Personal Data by sending a notice to the primary email address specified in Your account or by placing a prominent notice on our site.

If You have questions, suggestions, or wish to make a complaint, You can email us at privacyoffice@turbify.com or contact us as follows:

Aabaco Small Business, LLC
2600 Tower Oaks Blvd., Suite 700
Rockville, MD 20852
Fax:(301)330-8501

Effective date: July 1, 2024