Last modified: April 25th, 2026

This Privacy Policy (this “Policy”) sets out how Piolet, LLC, a Michigan limited liability company doing business as Adventurtle (“Company”, “we”, “our”, and “us”), uses and protects your personal data. This Policy is provided in a layered format so you can click through the specific areas set out below. Alternatively, you can view the full version of the Policy here [link] or download a copy of the Policy here [link].

Important Information and Who We Are
Children Under the Age of 18
Types of Personal Data We Collect About You
How Is Your Personal Data Collected?
How We Use Your Personal Data
1. Legal Basis
2. Purposes for Which We Will Use Your Personal Information
3. Tracking Technologies
4. Third-Party Use of Cookies and Other Tracking Technologies
5. Direct Marketing
Disclosures of Your Personal Information
International Transfers
Data Security
Data Retention
Your Legal Rights
1. United States Customers (Excluding California)
2. California Customers
3. International Customers
4. No Fee Usually Required
5. What We May Need from You
6. Time Limit to Respond
7. Exercising Your Rights
8. Third Parties’ Collection of Your Information
Contact Details
Complaints
Changes to the Policy and Your Duty to Inform Us of Changes
Third Party Links

1. Important Information and Who We Are

This Policy describes the types of information we may collect from you or that you may provide when you visit the website https://www.adventurtle.com/ (our “Website”) or our mobile application (the “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. We respect your privacy and are committed to protecting it through our compliance with this Policy.

This Policy applies to information we collect:

On our Services.
In email, text, and other electronic messages between you and us.
Through mobile and desktop applications you download from our Services, which provide dedicated non-browser-based interaction between you and us.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not use our Services. By accessing or using our Services, you agree to this Policy. This Policy may change from time to time (see Changes to the Policy and Your Duty to Inform Us of
Changes).

Company is the controller and is responsible for your personal data. We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO using the information set out in the Contact Details section.

2. Children Under the Age of 18

This Website and our Services are not intended for children under 18 years of age, and we do not knowingly collect data relating to or from children under 18.

No one under age 18 may provide any information to or on the Services. If you are under 18, do not use or provide any information on our Services, Website, or through any of their features; register on the Website or through the Services; make any purchases through the Website or Services; use any of the interactive or public comment features of our Website or Services; or provide any information about yourself to us, including your name, address, telephone number, email address, or any username you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at contact@adventurtle.com.

3. Types of Personal Data We Collect About You

“Personal data” or “personal information” means any information about an individual from which that person can be identified. We may collect, use, store, and transfer several different types of personal data about you which we have grouped together as follows:

“Identity Data”, which includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth, and gender.
“Contact Data” includes billing address, postal or delivery address, email address, and telephone numbers.
“Financial Data” includes bank account and payment card details.
“Transaction Data” includes details about payments to and from you and other details of products and services you have purchased from us.
“Technical Data” includes internet protocol (“IP”) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID, and other technology on the devices you use to access this Website or our Services.
“Profile Data” includes your username and password, purchases or orders made by you, and your interests, preferences, feedback, and survey responses.
“Usage Data” includes information about how you interact with and use our Website, Services, and products.
“Marketing and Communications Data” includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share aggregated data, such as statistical or demographic data, which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific Website feature in order to analyze general trends in how users are interacting with our Website and/or Services to help improve them.

4. How Is Your Personal Data Collected?

We use different methods to collect information from and about you through our Website and Services, including through:

Your interactions with us. We may receive your personal data directly from you when you provide it to us by filling in online forms or corresponding with us by post, phone, email, or otherwise. This includes personal data that you provide when you:
- Register or create an account to use our Services;
- Subscribe to our Services or any publications through our Website;
- Request marketing be sent to you;
- Enter a competition, giveaway, promotion, or survey;
- Give us feedback or report any issues with our Services;
- Contact us;
- Request further services;
- Carry out a transaction through our Website or in furtherance of our Services; or
- Search queries through our Website.
Your User Contributions. You may provide information to be published or displayed (“posted”) on public areas of the Services, or transmitted to other users of the Services or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. You can review and change your personal information by logging into the Services and visiting your account profile page. Depending on your state, country, or region’s applicable data privacy laws, you may be able to delete your User Contributions from the Services, though copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Services users. Proper access and use of information provided on the Services, including User Contributions, is governed by our terms of use (https://www.adventurtle.com/terms-of-use).

Automated technologies or interactions. As you navigate through or use our Website or the Services, we will automatically collect Technical Data which may include information about your equipment, usage details, IP addresses, and browsing actions or patterns. We collect this personal information through cookies, web beacons, and other similar tracking technologies. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (e.g., behavioral tracking). Please access your browser, phone, or application settings for information regarding whether you can opt out of tracking.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources. For example, from Google Analytics, we collect Technical Data from you. Moreover, we may receive other forms of personal data from our business partners.

5. How We Use Your Personal Data

a. Legal Basis

Applicable law requires us to have a legal basis for collecting your personal information. we rely on one or more of the following legal bases for our collection of such data:

Performance of a contract with you. We may utilize your personal information to perform the contract we are about to enter into or have entered into with you.
Legitimate interests. We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests. For example, such use may be necessary to prevent fraud and enable us to give you the best and most secure customer experience when utilizing our Website and Services. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal information for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by applicable law).
Legal obligation. We may use your personal information where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent. We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose. For example, if you subscribe to an email newsletter, you have consented to our utilization of your personal information in order to send you our communications.

b. Purposes for Which We Will Use Your Personal Information

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

If you do not want us to use your personal data in any of the aforementioned ways, please do not use the Services.

c. Tracking Technologies

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Services according to your individual interests.
Speed up your searches.
Recognize you when you return to our Services.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services. Third-party providers, such as Google Analytics, may also utilize cookies. When required by law – such as for visitors from countries that have implemented the General Data Protection Regulation (“GDPR”) – we will only place analytics cookies (such as Google Analytics cookies) after you have provided your consent.
Web Beacons. Pages of our Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email, and for other related website statistics (e.g., recording the popularity of certain Website content or verifying system and server integrity).
Flash Cookies. Certain features of our Services may use local stored objects (or flash cookies) to collect and store information about your preferences and navigation to, from, and on our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Your Legal Rights below.

d. Third-Party Use of Cookies and Other Tracking Technologies

Content and parts of the Services may be served by third-parties, including service providers, advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

In particular, we use Google Analytics (provided by Google LLC and, for users from the United Kingdom or European Economic Area, Google Ireland Limited) to help us understand how visitors interact with our Website and to improve the performance, content, and user experience of our Services. Google Analytics collects certain information automatically, such as your device type, browser information, operating system, IP address, approximate location, pages viewed, time spent on pages, and interactions with website features.

Google Analytics uses cookies and similar technologies to recognize your browser or device and to collect this information. Where required by applicable law (such as under the GDPR in the UK/EEA), we only activate Google Analytics after you have provided consent through our cookie banner or settings tool. We implement IP anonymization for Google Analytics where supported, so that your IP address is shortened before it is stored or processed by Google.

Google uses the information collected through Google Analytics to provide us aggregated reports and insights. Google may also process this information as a data controller where it uses it for its own purposes, as described in Google’s privacy policies.

For more information about how Google collects and processes data, please see:

Google’s Privacy & Terms overview: https://policies.google.com/privacy.
“How Google uses information from sites or apps that use our services”: https://policies.google.com/technologies/partner-sites.
Google Technologies / Cookies: https://policies.google.com/technologies/cookies.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Legal Rights below.

e. Direct Marketing

When you create an account to utilize our Services our download the App, you will receive marketing communications from us. You will also automatically opt in to our marketing communications if you have requested information from us or purchased goods or Services from us. Our Services necessarily involve using your personal information to contact you about our own and third-parties’ goods and services that may be of interest to you.

We may also analyze your Identity Data, Contact Data, Technical Data, Usage Data, and/or Profile Data to form a perspective regarding which of our products, Services, and other offers may be of interest to you so that we can then send you relevant marketing communications.

Further, we may use the personal data we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Please note we will get your express consent before we share your personal data with any third party for their own direct marketing purposes. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

You can opt out of our marketing communications at any time by sending us an email with your request to contact@adventurtle.com. If you opt out of receiving marketing communications, you will still receive Services-related communications that are essential for administrative or customer service purposes.

6. Disclosures of Your Personal Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction in accordance with applicable law.

We may share your personal data where necessary with the parties set out below for the purposes set out in the above Purposes for Which We Will Use Your Personal Data table. Such parties may include:

Our subsidiaries and affiliates.
Contractors, service providers, and other third parties we use to support our business.
A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Services users is among the assets transferred.

We may also disclose your personal information:

To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our terms of use (https://www.adventurtle.com/terms-of-use) and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International Transfers

We are based in the state of Michigan in the United States. We provide the Services for use only be persons located in the countries and geographic regions specifically listed in our terms of use (https://www.adventurtle.com/terms-of-use).

Whenever we transfer your personal data outside of the United States to countries which have laws that do not provide the same level of data protect as the United States, we always ensure that a similar or increased (where applicable) degree of protection is afforded to it.

We will only transfer your personal information to countries that we have determined provide an adequate level of protection for personal data in accordance with that country’s applicable laws. For instance, if your data is transferred to a country that has implemented the GDPR, we will ensure that appropriate safeguards are in place to protect your personal information and that it receives a level of protection consistent with the requirements of the GDPR.

8. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services like message boards. The information you share in public areas may be viewed by any user of the Services.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

Please note we have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so under applicable law.

9. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

We retain Google Analytics data in accordance with the retention settings available within Google Analytics and only for as long as necessary to fulfill the purposes described in this privacy policy. For information about Google’s data retention practices, please refer to: https://policies.google.com/privacy#infodelete.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure of your personal data; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal, regulatory, tax, accounting, or other requirements.

Depending on your country of residence, under applicable law, we may have to keep basic information about you as a customer (including your Contact Data, Identity Data, Financial Data, and Transaction Data) for six years after you cease being a customer for tax purposes.

In some circumstances you can ask us to delete your data. Please see Your Legal Rights below for further information.

10. Your Legal Rights

a. United States Customers (Excluding California)

If you are located in the United States, depending on your state of residency, you may have certain rights related to your personal data, including:

Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information’s nature and processing purpose.
Deletion. You may request that we delete personal data about you that we maintain, subject to certain exceptions under applicable law.
Opt Out of Using Personal Data for Targeted Advertising, Profiling, and Sales. You may request that we do not use your personal data for these purposes, if applicable.

The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data “sales” as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

Nevada provides its residents with a limited right to opt out of certain personal data sales. Residents who wish to exercise their sales opt out rights may submit a request to us at the information provided in the Contact Details section below. However, please know we do not currently sell data triggering that statute’s opt out requirements.

b. California Customers

If you are a California resident, the California Consumer Privacy Act (“CCPA”) grants you the following rights regarding your personal information:

Right to Know and Data Portability Requests. You have the right to request that we disclose certain information to you about our collection and use of your personal information, including the specific pieces of personal information we have collected about you (a “data portability request”). You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity, we will disclose to you: the categories of personal data we collected about you and the sources from which we collected your personal information; the business or commercial purpose for collecting your personal data and, if applicable, selling or sharing your personal information; if applicable, the categories of persons, including third parties, to whom we disclosed your personal data, including separate disclosures identifying the categories of your personal information that we disclosed for a business purpose to each category of persons; and/or sold or shared to each category of third parties; and when your right to know submission includes a data portability request, a copy of your personal information, subject to any permitted redactions.
Right to Delete. You have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions and limitations. Once we receive your request and confirm your identity, we will delete your personal data from our systems unless an exception allows us to retain it. We will also notify our service providers, contractors, and other recipients to take appropriate action.
Right to Correct. You have the right to request correction of personal information we maintain about you that you believe is inaccurate. We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients to take appropriate action.
Right to Limit Sensitive Personal Information (“SPI”) Use and Disclosure to Permitted SPI Purposes. You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA’s Permitted SPI Purposes. Once we receive your valid request, we will limit the use and disclosure of your sensitive personal information to the Permitted SPI Purposes. For more information on the CCPA’s Permitted SPI purposes, please contact us at the information provided in the Contact Details section below.
Personal Information Sales or Sharing Opt Out and Opt-In Rights. You have the right to request that businesses stop selling or sharing your personal data at any time, including through a user-enabled opt out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer’s parent or guardian for consumers under age 13. We cannot sell or share your personal information after we receive your request to opt out unless you later consent to the sale or sharing of your personal information.
ADMT Rights. When a business uses automated decision-making technology (“ADMT”) to make significant decisions about you, you may have rights to obtain certain information about how the business uses ADMT that is specific to you or you may opt out of the ADMT use unless the business provides you with a method to appeal the decision to a human reviewer with the authority to overturn the decision or another exception applies. ADMTs are technologies that process personal data and use computation to execute a decision and either replace or substantially replace human decision-making, resulting in decisions made without human involvement. Decisions are significant when they result in the provision or denial of financial or lending services, housing, education enrollment or opportunities, employment or independent contracting opportunities or compensation, or healthcare services. Advertising is not a significant decision. We do not currently use ADMT to make significant decisions about consumers, so we do not provide ADMT access, opt out, or appeal rights.
Right to Non-Discrimination. You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.

c. Certain International Customers

If you are an international customer in certain other countries, you may have a number of rights under your country’s applicable data protection laws in relation to your personal data. You may have the right to:

Subject Access Request. You may have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Correction Request. Under your country’s applicable data privacy laws, you may have the right to request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Erasure Request. You may have the right to request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully, or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Objection. Under your country’s applicable data privacy laws, you may have the right to object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your personal information (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which may override your right to object. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
Transfer of Personal Information. You may have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Consent Withdrawal. Depending on your country’s applicable data privacy laws, you may have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Please note if you withdraw your consent, we may not be able to provide certain products, our Website, or our Services to you.
Restriction Request. You may have the right to request restriction of our processing of your personal information. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data’s accuracy;
- Where our use of the information is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or
- You have objected to our use of your information, but we need to verify whether we have overriding legitimate grounds to use it.

d. No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

e. What We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights) under your state, country, or region’s applicable data privacy laws. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

f. Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

g. Exercising Your Rights

We strive to provide you with choices regarding the personal information you provide to us. There may be mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You may be able to set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Location Information. You can choose whether or not to allow the Services to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Services may become inaccessible or not function properly.
Disclosure of Your Information for Advertising and the Company’s Promotional Offers. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by sending us an email with your request to contact@adventurtle.com.

If you wish to exercise any of your applicable privacy rights detailed in this Policy, please contact our DPO at the information provided in the Contact Details section below.

h. Third Parties’ Collection of Your Information

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Moreover, regarding Google Analytics’ practices, you can withdraw or modify your consent for analytics cookies at any time through the Company’s cookie settings. You may also install the Google Analytics Opt-Out Browser Add-On, available at: https://tools.google.com/dlpage/gaoptout.

11. Contact Details

If you have any questions or comments about this Policy or about our privacy practices, or if you want to exercise your privacy rights in any way, please contact our DPO in the following ways:

Email address: contact@adventurtle.com

Postal address: Adventurtle

Attention: Data Protection Officer

25 N. Main Street

Mount Clemens, Michigan 48043

United States of America

12. Complaints

If you reside in a country that has implemented the GDPR, you have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the United Kingdom regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance at the information provided in the Contact Details section above.

13. Changes to the Policy and Your Duty to Inform Us of Changes

It is our policy to post any changes we make to our Policy on this page with a notice that the Policy has been updated on the Services home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account or through a notice on the Services. The date the Policy was last revised is identified at the top of the page.

You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Services and this Policy to check for any changes. Please keep us informed if your personal data changes during your relationship with us.

14. Third Party Links

Our Website or Services may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website or our Services, we encourage you to read the privacy policy of every website you visit.

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