Turtles.com Inc. and its Affiliates (collectively, "Turtles," "we," "us," or "our") are committed to making the products, websites, applications, and services we operate (the "Service") accessible to the widest possible audience, regardless of ability, disability, or assistive technology used. This Accessibility Policy describes our approach, our standards, our customers' responsibilities, and how to give us feedback.

This Policy is part of, and incorporated by reference into, the Terms of Use and our other legal agreements.

1. Our commitment

We design and build the Service so that as many people as possible can use it independently, with or without assistive technology. We treat accessibility as part of product quality — not an add-on. We invest in accessibility throughout the design and development lifecycle: design reviews, code reviews, automated and manual testing, and ongoing audits.

2. Conformance standards

We design, build, and test the Service against the following standards, as applicable:

• Web Content Accessibility Guidelines (WCAG) 2.2, Level AA, as published by the World Wide Web Consortium (W3C);
• Title III of the Americans with Disabilities Act (ADA), including in light of guidance issued by the U.S. Department of Justice;
• Section 508 of the Rehabilitation Act (29 U.S.C. § 794d), including the Section 508 ICT Refresh standards (36 CFR Part 1194), where the Service is provided to U.S. federal agencies or required by procurement;
• the Twenty-First Century Communications and Video Accessibility Act (CVAA), where applicable; and
• applicable U.S. state accessibility laws (such as the Unruh Civil Rights Act in California).

Where standards conflict or evolve, we apply the standard that provides the higher level of accessibility, to the extent reasonably feasible.

3. What we do

To advance accessibility, our practices include:

3.1 Design

• Adopting and maintaining a design system whose primitive components are built with accessibility in mind, including focus states, semantic structure, color-contrast tokens, and ARIA usage.
• Designing flows for keyboard-only, screen-reader, and reduced-motion experiences.
• Providing scalable typography that respects user-defined font sizes and zoom up to 200% without loss of content or functionality.
• Maintaining sufficient color-contrast ratios consistent with WCAG 2.2 AA (4.5:1 for body text, 3:1 for large text and meaningful non-text content).
• Avoiding color as the sole indicator of state, error, or meaning.

3.2 Engineering

• Using semantic HTML and accessible component patterns; supplementing with ARIA only where needed and consistent with the WAI-ARIA Authoring Practices.
• Ensuring all interactive elements are reachable, operable, and understandable via the keyboard.
• Providing visible focus indicators, skip links, landmark regions, and consistent navigation.
• Providing programmatic labels, names, and roles for form controls, inputs, buttons, and other interactive elements.
• Providing meaningful alternative text for images and meaningful labels for icons used as controls.
• Captioning and providing transcripts for audio and video content we author.
• Honoring user preferences for reduced motion, dark mode, and high contrast where the platform exposes those preferences.

3.3 Testing

• Automated accessibility testing in our continuous integration pipeline using established tooling.
• Manual testing with assistive technologies, including current versions of NVDA and JAWS on Windows, VoiceOver on macOS and iOS, TalkBack on Android, and recent Chromium and Firefox keyboard navigation.
• Periodic third-party expert audits.
• Inclusion of accessibility issues in our standard prioritization and triage processes.

4. Scope

This Policy covers the products, applications, and websites that Turtles itself operates and publishes, including the Turtles.com marketing site and the Turtles dashboards, admin tools, and developer tooling that Operators and Sellers use directly.

Each Turtles-powered marketplace is, however, configured, themed, branded, and operated by a third-party Operator. Operators are independently responsible for the accessibility of their marketplace's storefront, listings, content, customer support channels, and any custom features they build. We provide guidance, design tokens, and tooling to support Operator accessibility, but we do not warrant that any individual Marketplace conforms to a particular standard.

5. Operator and Seller responsibilities

Operators and Sellers control the content shown on their marketplaces and listings. They must, at a minimum:

• Provide meaningful alternative text for product images and other non-text content;
• Provide accurate, plain-language product descriptions and metadata;
• Provide captions or transcripts for video content where reasonably practicable;
• Avoid content patterns known to cause accessibility issues (e.g., flashing content, tiny tap targets, text embedded as images);
• Ensure that any custom themes, scripts, or third-party widgets they install do not break accessibility provided by the Turtles platform;
• Comply with Applicable Law in the jurisdictions where they operate.

Failure to comply with these obligations may result in remediation requests, content removal, or other actions consistent with the Terms of Use, the MSA, the SSA, and our Community Guidelines.

6. Known limitations

We work to identify and address accessibility issues, but the Service is large and constantly evolving. Areas where we know more work is needed include:

• Some legacy storefront templates and historical features that have not yet been migrated to our current design system;
• Third-party integrations and embedded content that the platform cannot fully control;
• Complex data-visualization features where keyboard equivalents and accessible names for chart data are still being improved;
• Real-time, dynamic, or media-heavy features that may have edge-case accessibility issues we have not yet identified.

We are committed to continuously improving these areas and welcome reports from users that help us prioritize.

7. Alternative formats and reasonable accommodation

If you encounter an accessibility barrier that prevents you from using the Service, or if you would like to request information in an alternative format (such as large print, accessible PDF, or plain-text email), please contact us at accessibility@turtles.com. Where reasonably possible, and consistent with our other obligations, we will provide the requested information or assist with completing the relevant action through an alternative method.

We will also make reasonable accommodations for individuals with disabilities who participate in our recruitment and employment processes; please contact our People team or accessibility@turtles.com.

8. Feedback

If you experience an accessibility issue while using the Service, please tell us. The more specific information you provide, the more efficiently we can investigate.

Accessibility team — Turtles.com Inc. — accessibility@turtles.com

When reporting an issue, please include:

• the URL or page where the issue occurred;
• the operating system, browser, and assistive technology you were using (with versions, if known);
• a description of what you expected to happen and what actually happened;
• any steps you took (so we can reproduce the issue); and
• whether you would like us to follow up with you (and how).

We will review reports and address them as we are reasonably able. Some issues may take longer to resolve depending on complexity, and we may not be able to respond to every report.

9. Continuous improvement

We update this Policy and our accessibility practices over time as standards, technology, and best practices evolve.

10. No warranty; relationship to other terms

Nothing in this Policy creates a warranty, representation, or guarantee that any particular feature, page, or marketplace conforms to a specific accessibility standard at a specific moment. The disclaimers and limitations of liability set out in the Terms of Use apply to this Policy. This Policy supplements (and does not replace) the rest of the Agreement.

11. Updates

We may update this Policy from time to time. The effective date above reflects the most recent version.

12. Contact

Turtles.com Inc. — accessibility@turtles.com