Privacy Policy For Turba Media R&D PTY LTD

This Privacy Policy explains how we will process the data relating to you, including the personal
data that you provide to us or that we may collect when you visit our website at www.turbamedia.io
(Website), and applies to all use of data by Turba Media PTY LTD

The Website is operated by Turba Media PTY LTD (“Turba Media”, “Turba”,“we”, “us” and “our”), a

company incorporated in AU & USA

Phone – 1 300 926 895
Email – info@turbamedia.io

Turba Media Pty Ltd provides bespoke marketing services to customers to help them identify and
improve their understanding of their existing and prospective customers and target audiences, to
develop tailored marketing strategies and appropriate marketing content.
Where we decide the purpose and means for the processing of the personal data that you provide
to us, including via our Website, or that we obtain about you from others, we are the “data
controller,” such as in relation to Website Data and setting up a Turba customer account. Where we
process personal data in accordance with the specifications and instructions that we receive from
our customers, in particular in relation to Social Media and Customer Data, it is our customers who
decide the purpose and means for the processing of this personal data. In those instances, it is our
customers who are the data controller and we are the data processor. Whether we are acting in our
capacity as data controllers or as data processor, we will comply with all applicable data protection
laws.

This policy should be read together with our Website Terms of Use.
Our Website may contain hyperlinks to third-party websites. These websites operate fully
independently from us, and we cannot accept any responsibility or liability for the privacy practices
of such third parties or the availability of these external sites or resources. The appearance of
such links on our Website is not an endorsement. Should you use any of these websites, such use
is at your own risk and we would advise that you review their respective privacy policies.
Please read this Privacy Policy carefully as it contains important information about the following:
What information Turba media may collect about you
How Turba Media will use the information we collect about you
Whether Turba Media will disclose your details to anyone else
Your choices and rights regarding the personal information we hold about you
If you have any questions or comments about this Privacy Policy, please contact Turba media:

Phone – 1 300 926 895
By email: info@turbamedia.io

1. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

When you visit our Website, we may collect and process information (which may include your
personal information) for the purposes of processing and on the legal bases listed below, and we
may sometimes share this information as follows.
General Enquires and visiting our Website (Website Data)
Types of DataProcessing Purpose and BasisThird Party Recipients
We may collect and store personal information you provide when using the Website, including
when you log in to access your account or contact us with general enquiries or about job
openings displayed on our “Join Us” webpage by emailing us at info@turbamedia.io

Personal data that we may obtain includes:
your name
your email address and/or postal address
your company name
your username (typically your email address) and password
online identifiers, such as IP address, cookies and tracking data and other unique user identifiers
your data held by social media, such as Google (where you opt to log in via Google)
any other personal information you provide in a message you submit to us (including your CV and
personal statement, where applying for jobs)
We may legally process the personal information that we collect on the basis that we have a
legitimate interest, under our legal obligations and/or in the performance of a contract:
to register and administer your user account
(in relation to company accounts) to analyse your company budget and/or capacity to purchase our
products or services, including tracking whether your company receives investment or raises large
amounts of capital
to respond to your enquiries
to provide you with information about the bespoke marketing services that we offer to customers to
identify and improve understanding of their target audiences
to respond when you submit job applications or related queries
to manage risk or prevent other illegal or prohibited activities;
to resolve issues or fix problems on the Website.
We keep your information confidential. We will not sell your information. We may disclose your
information to our personnel (including personnel in our group of companies) and to third-party
suppliers or subcontractors (including our independent consultants, data analytics providers and
cloud-based data processing and hosting providers).
If we do share your information, we will only do so insofar as it is reasonably necessary for the
purposes set out in this Privacy Policy, and provided that the recipients do not make independent
use of the information and have agreed to adhere to the rules set out in this Privacy Policy.
In some instances, this data sharing may involve the transfer of information outside the AU & USA.
Please see our section on International Data Transfers below.
As part of the service we provide, we use YouTube API under YouTube Terms of Service
https://www.youtube.com/t/terms (ToS) in API Client’s ToS and Google Privacy Policy
https://policies.google.com/privacy As part of those, Turba users will be agreeing with the YouTube
ToS.
Setting Up Your Account
Types of Data Processing Purpose and BasisThird Party Recipients
When you set up your Turba customer account, we will ask you to provide the following personal
information, depending on whether you register as a company or sole trader/individual.
All account holders may be asked to provide:
full name
email address, postal address, telephone number(s)
your username and password (which you create)

To create an account and use our products and services, you may be asked to provide us
and/or our third-party service providers:
photographic proof of identity (e.g. passport or driving licence)
proof of authority to act on behalf of your company
access to data (including personal data) in your customer database
To enable authorised users, such as employees and/or consultants of the account holder, to access
the account and our platform, we may require those end users to provide::
full name
company name and job title
email address, postal address, telephone number(s)
your username and password (which you create)
We can only provide our services, including account set-up, where you have provided certain
requisite personal data.
We will process this information based on either our legal obligations, for the performance of a
contract or where we have a legitimate interest to do so in the operation of our bespoke marketing
services business, in order to:
create and maintain your account with us
perform our contract for the provision of targeted marketing analysis and strategy development
services
provide authorised access and use of the consumer insight tool and platform, and to communicate
with those users
conduct identify and credit reference checks and for credit score reporting
manage risk or prevent other illegal or prohibited activities, including in relation to anti-money
laundering and prevention of fraud
respond to your enquiries and provide assistance
We may share the personal information that you provide with third-party service providers, such as
external credit reference and reporting providers, to enable us to assess credit worthiness of
prospective customers, or other third-party sub-processors.
Where we share your personal data with third parties, we will only do so as far as it is reasonably
necessary for the purposes set out in the policy, provided that they do not make independent use
of the information and have agreed to adhere to the rules set out in the Privacy Policy.
In some instances, this sharing of data may involve the transfer of personal data outside of the AU
& USA. Please see our section on International Data Transfers below.
Social Media and Customer Data
Types of DataProcessing Purpose and BasisThird Party Recipients
In order to provide our customers with our business’ core service of bespoke, targeted marketing
analysis and strategy development, which we provide in accordance with our customer’s identified
needs and to their specification, we will need information about our customer’s existing and
prospective customers. To fulfil our customer’s instructions, we will process personal data as part
of the service we provide to help them identify, understand and more effectively reach their own
customers or intended audience.

In doing so, we may retrieve publicly available personal and non-personal information about
individuals that have been made available to social media platforms such as Facebook YouTube,
Instagram, Twitter and LinkedIn. This may include:
full name
your posted comments (which may contain personal data, such as your preferences and opinions)
user IDs
location and device data
To provide our customers with analysis in line with their specifications and instructions, we may
collect and process your social media data and data provided by our customers (Customer Data)
to enable us to provide our core business services, including bespoke targeted marketing analysis
and advisory services, which may include:
to conduct analytics on visits to our Website, websites of our customers, and social media
platforms (such as those administered by our customers and generally)
to build aggregated and anonymised group profiles with respect of a particular customer’s target
markets to analyse user trends and preferences to advise on and devise appropriate marketing
content for customers to understand which potential new features, advertising or campaigns are
likely to interest our customers and/or their customers and targeted audiences to create a
database to assist with analysis and provision of advice on appropriate marketing content,
including (where applicable) the attribution of social media accounts to audience segments to
improve the quality and design of our services. We minimise the collection of information to the
minimum required to enable us to perform under our contracts for the provision of services with our
customers, including to provide and operate customer accounts, to fulfil legal obligations, and/or
where there are other lawful bases for processing.

The information obtained, as set out in this section, may be used in order to enable the remarking
of users and may be shared with Google. We will not provide further personal information to these
payment service providers beyond the financial details that you have provided.
As part of the service that we provide, including the maintenance and operation of your account
and our Open Banking services, we will receive and hold financial information that you may provide
directly to our third-party service providers. We will only provide such information to other third
parties where we have received your prior consent to do so or where we are legally obliged to do
so.
As part of the service we provide, we use YouTube API under YouTube Terms of Service
https://www.youtube.com/t/terms (ToS) in API Client’s ToS and Google Privacy Policy
https://policies.google.com/privacy As part of those, Turba users will be agreeing with the YouTube
ToS.
Social Media and Customer Data
Types of DataProcessing Purpose and BasisThird Party Recipients
Our Website does not contain third-party advertising.
We may collect information about you in order to send you our promotional or marketing
communications, including our blogs and updates, such as:
your name
your email address
your company name
your job title

While we do not permit third-party advertising on our Website, if you do link to one of our Turba or
Turba Media Pty Ltd social media platforms you may be subject to targeted marketing via that site.
Where we provide you with information about our products, services or offers via our email
updates, blogs or e-newsletters, we will only use your personal information in this way in
accordance with laws relating to marketing directly to individuals, and in the pursuit of our
legitimate interest of marketing our business.
If you have asked to be added to our mailing list, such as by submitting your details via our
Website sign-up, we will provide your details to a third-party company that helps us to produce and
manage the circulation of our blogs and newsletters. We provide these communications on the
basis that you have asked to receive these.
If you change your mind, you may opt out at any time via the unsubscribe feature that appears in
our emails or by emailing info@turbamedia.io
You may also be asked to opt in to receive updates or information about similar services from our
network of trusted third parties or to receive promotional material, including vouchers or discount
offers, from these suppliers.
We will not share with any third party the personal information that we obtain about you for the
purposes of marketing, except for as stated in this policy and only where those third parties have
agreed to make no independent or further use of that data and to maintain its confidentiality.
Our Approach to Objectionable Content
If you send us objectionable content, or behave in a disruptive manner when using our website,
we may process any personal information that you have submitted to us, including your personal
messages, to respond to and stop such behaviour.
We will only process personal information in this way for the following legitimate interests:
ensuring that the use of our Website is lawful;
ensuring that users do not disrupt or harass our staff, customers or other Website users; and
enforcing our legal rights and complying with our legal obligations.
Where we reasonably believe that you are or may be in breach of the law (i.e. the content you
share on the Website amounts to harassment or is defamatory), we may use your personal
information to inform relevant third parties about the content, such as:
your email or internet provider; or
law enforcement agencies
When we process personal information in this way, we will hold that personal information on our
systems for as long as is reasonably necessary to achieve these objectives.

2. DATA SHARING WITH OTHER PARTIES

We will only ever share your information with third parties in the ways that are described in this
Privacy Policy. If you would like to find out more about how those third parties listed in this Privacy
Policy use your information, this should be set out in their respective privacy policies accessible on
their websites.
Personnel, Suppliers and Subcontractors

We keep your information confidential but may disclose it to any member of our group (which
means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section
1159 of the Companies Act 2006), our personnel or independent contractors and our suppliers or
service providers insofar as it is reasonably necessary for the purposes set out in this Privacy
Policy. However, this is on the basis that they do not make independent use of the information, and
have agreed to safeguard this information. For further detail of third-party service providers
that we engage, please see below.
Change of Control
If we are involved in a merger, acquisition, or sale of all or a portion of our business or its assets,
you will be notified of any change in ownership or uses of this information, as well as any choices
you may have regarding this information.
Disclosure Required by Law or for Protection of the Business
In addition, we may disclose your information to the extent that we are required to do so by law
(which may include to government bodies and law enforcement agencies), in connection with any
legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend
our legal rights (including providing information to others for fraud prevention).
We may also disclose your personal information to third parties in order to enforce or apply the
terms of agreements between us, to investigate potential breaches, or to protect the rights,
property or safety of Turba Media, our customers, or others. This includes exchanging information
with other companies and organisations for the purposes of fraud protection and credit risk
reduction.
Third-party service providers
In addition to the processing that we undertake ourselves, we also use third-party processors to
collect, export, store and otherwise process our data, including personal data, on our behalf. The
processors that we engage include (without limitation):
Facebook, Inc. (including Instagram) (Social Media Platform)
Location: US (AU & USA-US Privacy Shield certified)
https://www.facebook.com/privacy/policy
Twitter (Social Media Platform)
Location: Ireland (for non-US customers)
https://twitter.com/en/privacy
LinkedIn (Social Media Platform)
Location: Various, including UK and US
https://www.linkedin.com/legal/privacy-policy
Intercom, Inc. (Digital Marketing / Customer Messaging Platform)
Location:www.intercom.com
https://www.intercom.com/terms-and-policies#privacy
HubSpot, Inc.
Location:https://www.hubspot.com/
https://legal.hubspot.com/privacy-policy
Google LLC (for Google Analytics and Google Cloud) (Web Management Tools)
Location: US (AU & USA-US Privacy Shield certified)
https://policies.google.com/privacy?hl=en

3. COOKIES & ANALYTICS

Our Website uses cookies and other mechanisms to collect log and analytical information, to help
analyse how visitors use the site, to personalise content, support our security function and to
compile statistical reports on Website activity.
Cookies may be used by us to do the following:
enable us to respond to you and to tailor our operations to your needs, including remembering your
preferences and to assist with account or user security (such as sending reset password
reminders)
assist us in the continued improvement and effective operation of the Website
enable Website traffic to be logged to identify the web pages you visit and use so we may better
understand browsing behaviour (including which web pages browsers find more useful) and
improve our Website
To find out more about the use of cookies generally, please visit http://www.allaboutcookies.org/.
Our Website also uses website analytics, including Google Analytics as well as our own analytics
software, to evaluate and improve our Website, personalise your experience and to offer the best,
most accessible service possible to all of our customers.
To find out more about Google Analytics and to learn how to opt-out, please visit:
How Google uses data when you use our partners' sites or apps, or
https://tools.google.com/dlpage/gaoptout/.
When you visit our Website, these analytics service providers may collect the following data, which
will almost always be anonymised and aggregated before reporting back to us:
number of visitors to our Website
pages visited while at the Website and time spent per page
page interaction information, such as scrolling, clicks and browsing methods
websites where visitors have come from and where they go afterwards
page response times and any download errors
date and time of the visit
other technical information relating to end-user device, such as IP address, access status/HTTP
status code, your operating system and interface or browser plug-in
We process this information to understand how visitors use our Website and to compile statistical
reports regarding that activity (for example, your IP address is used to approximate the geographic
locations (e.g. country, region, city) from which you access our Website, and we aggregate this
information together so we know, for example, whether most of the visitors to our Website are
Melbourne-based, originate from the AU or come from elsewhere).
This processing is crucial to the running of our online business and we therefore undertake such
monitoring in the pursuit of our legitimate interests in improving our Website to provide a better
service and source of information to visitors and our customers.

4. YOUR RIGHTS IN RELATION TO THE PERSONAL DATA THAT WE PROCESS

You have the following rights over the way we process personal data relating to you. We aim to
comply without undue delay and within one month at the latest:
to ask for confirmation and information about the personal data that we process about you,
including a copy of data we are processing about you;
to have inaccuracies corrected or incomplete personal data made complete; 

to ask us to restrict, stop processing, or to delete your personal data;
to request a machine-readable copy of your personal data, which you can use with another service
provider. Where it is technically feasible, you can ask us to send this information directly to another
provider if you prefer; and
to not be subject to automated decision-making, including profiling; and
to make a complaint to a data protection regulator.
To make a request in relation to any of the aforementioned rights, please email us at
info@Turbamedia.io.
If you are unhappy with the way that we are processing your personal data, please let us know.
The best way to bring this to our attention is by emailing us at info@Turbamedia.io

5. CHILDREN

We do not knowingly use the Website or our services to solicit data from or market to anyone
under the age of 18 (including, in particular, children under the age of 13) nor do we sell any of our
products or services to children.
If a parent or guardian becomes aware that his or her child has provided us with information or
may be receiving communications from us or has been otherwise interacting with us via our
Website without consent of a parent or guardian, we ask that this be brought to our immediate
attention. We will make it our priority to address this situation and delete information relating to a
child as soon as practicable. In such an event, please contact us at info@Turbamedia.io

6. SECURITY

We will take commercially reasonable, appropriate technical and organisational measures to
ensure a level of security appropriate to the risk that could be encountered via the use of our
Website and services, taking into account the likelihood and severity those risks might pose to the
rights and freedoms of our Website visitors.
In particular, we will take precautions to protect against the accidental or unlawful destruction, loss
or alteration, and unauthorised disclosure of or access to the personal information transmitted,
stored or otherwise processed by us.
Please be aware that, while we make the security of our Website and your personal information a
high priority and devote considerable time and resources to maintain robust IT security, no security
system can prevent all security breaches. When you choose to share your personal information
with us, you accept the aforesaid and provide your information at your own risk.

7. RETENTION

In accordance with data protection laws and good commercial practice, we do not retain data in a
form that permits identification of the person(s) to whom it relates for any longer than is necessary.
We only keep copies of all types of data for the purposes and duration of providing our services.
Once the purpose for which information has been collected has been fulfilled, we will either delete
your personal information or remove all identifiers within it so that it is no longer personal data. We
may use such anonymised data for research and/or business analysis purposes. For example:
Once our services have been completed and delivered to our customers, all Customer Data and
Social Media Data will be purged from our system.
Where you have provided us with personal information in order to set up an account with us, we
will retain those details for as long as your account remains active.
Where you have signed up to our mailing list, we will retain your details for as long as you remain
on that list. If you unsubscribe, we will remove your details from the list.

Where we obtain your personal data in relation to the use or purchase of our services, including
VAT or invoicing information, we are obligated by law to keep this for a minimum of 6 years.
All data that we receive from our customers is stored separately from data that we collect
ourselves. No customer data is stored by us after the services have been completed for the
relevant customers.
If you would like us to stop using your personal information or restrict its use, please email us at
info@Turbamedia.io

8. INTERNATIONAL DATA TRANSFERS

Our servers are located in the AU & USA and the information that we collect directly from you will
be stored in these servers. We may also transfer your personal data to our third-party service
providers, many of whom may be located outside of the AU & USA, operate from multiple locations
including non-AU & USA based operations or engaging sub-processors located outside the AU &
USA.
There are agreements in place to ensure that any international transfers of personal data to our
affiliates or third-party service providers have appropriate safeguards that meet the requirements of
AU & USA data protection laws.
Such appropriate safeguards may include standard data protection clauses adopted by a data
protection regulator and approved by the AU & USA Commission, such as the AU & USA
Commission’s standard contractual clauses. Alternatively, where personal data is transferred to the
US, many of those US third-party service providers are certified under the AU & USA-US Privacy
Shield framework approved by the AU & USA Commission.

To find out more about the AU & USA-US Privacy Shield certification, please visit:
https://www.privacyshield.gov/Program-Overview
If you would like to find out more about these safeguards or our international transfer of data,
please let us know by emailing us at info@turbamedia.io

9. CHANGES TO THIS POLICY

This Privacy Policy may be updated from time to time. We will notify you of any changes to this
policy by posting the updated policy on our Website. You are advised to consult this Privacy Policy
webpage regularly for any changes.

10. CONTACT

Questions, comments and requests in relation to this Privacy Policy are welcome and should be
addressed to Turba Media Pty Ltd,
2023 © TurbaPrivacy statement
info@Turbamedia.io