Cookie Policy

Effective date: May 3, 2026

This Cookie Policy explains how Turtles.com Inc. and its Affiliates (collectively, "Turtles," "we," "us," or "our") use cookies and similar tracking technologies on the websites, applications, and services we operate (the "Service"), the choices you have, and how those choices interact with applicable privacy laws. This Policy is part of, and is incorporated by reference into, our Privacy Policy and Terms of Use.

This Policy describes Turtles' own use of cookies on Turtles-operated properties. Each Turtles-powered marketplace is operated by an independent Operator that may set its own cookies and similar technologies and is responsible for its own cookie disclosures and consents. If you are visiting a marketplace that runs on Turtles, please consult that marketplace's cookie notice for information specific to that property.

1. What are cookies and similar technologies?

A cookie is a small text file that a website asks your browser to store on your device. Cookies allow a website to recognize your device when it returns and to remember information about you between page loads or visits.

In this Policy, "cookies" includes other similar tracking technologies, such as:

  • Local storage and session storage (data stored in the browser);
  • Pixel tags / web beacons (transparent images that record page loads or email opens);
  • Software development kits (SDKs) that perform similar functions inside our mobile applications;
  • Mobile advertising identifiers (such as IDFA on iOS or AAID on Android);
  • Server logs correlated with device identifiers;
  • Tag managers and consent management platforms that load and govern other technologies.

The terms of this Policy apply to all such technologies whether or not they are technically "cookies."

2. Why we use cookies

We use cookies for purposes that include:

  • Operating the Service. Authenticating you, keeping you signed in, maintaining session state, balancing load across servers, securing forms against cross-site request forgery, fighting fraud, and remembering essential preferences.
  • Remembering your preferences. Such as language, region, theme, currency, recently viewed marketplaces, dismissed banners, and accessibility settings.
  • Analytics. Understanding how the Service is used so we can improve it. Where reasonably possible, analytics data is aggregated, shortened (e.g., truncated IP addresses), or pseudonymized.
  • Performance and reliability. Measuring page load times, monitoring for errors, sampling crash and exception data, and investigating outages.
  • Marketing and advertising. Promoting Turtles products and Turtles-powered marketplaces, measuring the effectiveness of marketing campaigns, attributing visits and conversions, and (in limited circumstances) supporting cross-site or cross-app interest-based advertising. Where required by law, we obtain consent for these uses.

3. Categories of cookies we use

For transparency, we group cookies into the following categories. The exact set of cookies on the Service varies over time; if you would like an up-to-date list, please email privacy@turtles.com.

3.1 Strictly necessary

These are required to provide the Service you have requested and cannot be turned off in our systems. They include cookies for authentication, session management, security tokens, fraud prevention, load balancing, and remembering your cookie consent choices. They do not store information that identifies you for advertising purposes.

3.2 Functional / preferences

These remember choices you make to provide a more tailored experience — for example, your language, region, theme, currency, or recently viewed marketplaces. Disabling these may degrade some features.

3.3 Analytics / performance

These help us understand how visitors use the Service so we can improve it. Examples include identifying which pages are visited most often, which features are used, where users encounter errors, and how the Service performs across devices and networks. We may use first-party analytics (run by us) or analytics services provided by partners (e.g., usage measurement, error logging).

3.4 Marketing / advertising

These are used to promote Turtles products and Turtles-powered marketplaces, to measure the effectiveness of advertising campaigns, and (in limited circumstances) to support cross-context behavioral advertising. They are typically set by advertising or attribution partners. Where required by Applicable Law, these technologies are loaded only after you give consent (or where opt-out frameworks apply, only until you opt out).

4. First-party and third-party cookies

  • First-party cookies are set directly by Turtles (under the turtles.com domain or a domain we control).
  • Third-party cookies are set by service providers and partners that help us operate, secure, analyze, and market the Service. These include providers in categories such as cloud infrastructure, content delivery, product analytics, error monitoring, customer support, payment processing, and advertising and measurement. Each third party uses cookies under its own privacy policy.

5. Cookie lifespan

  • Session cookies are deleted when you close your browser.
  • Persistent cookies remain on your device until they expire or you delete them. Lifespans vary; most expire within thirteen (13) months of being set or last accessed, consistent with industry guidance and applicable law.

6. Your choices

You have multiple ways to control cookies and similar technologies:

6.1 Cookie banner and settings

Where required by law, we present a cookie banner or similar interface that lets you accept, reject, or customize non-essential cookies. Strictly necessary cookies cannot be disabled because the Service will not function without them.

6.2 Browser controls

Most browsers let you block, delete, or limit cookies through settings or extensions. Mobile operating systems offer similar controls, including the ability to reset or limit advertising identifiers. Detailed instructions are usually available from your browser or device vendor's help center. Note that blocking strictly necessary cookies will prevent the Service from functioning correctly, including signing in.

6.3 Global Privacy Control (GPC) and similar signals

We honor browser-level Global Privacy Control (GPC) signals as a request to opt out of "sale" and "sharing" of personal information for cross-context behavioral advertising for residents of jurisdictions whose laws require recognition. If the signal is associated with a logged-in account, we apply the choice to that account; otherwise, we apply it to the browser or device.

6.4 Industry opt-out tools

For online interest-based advertising delivered by third parties, you can use industry opt-out tools, including:

These tools generally rely on cookies or identifiers and may not opt you out across all browsers or devices.

6.5 "Do Not Track"

The Service does not respond to "Do Not Track" browser signals at this time, because there is no industry-standard interpretation of those signals. We do honor the signals described in Section 6.3.

7. Specific notices

7.1 California, Virginia, Colorado, Connecticut, and other U.S. states

Some of our advertising activities may qualify as a "sale" or "sharing" of personal information under U.S. state privacy laws, even though we do not exchange personal information for monetary consideration. You may opt out by emailing privacy@turtles.com or by sending a Global Privacy Control signal from your browser.

7.2 Children

The Service is for adults only. Consistent with the Terms of Use, we do not knowingly direct cookies or similar technologies to anyone under eighteen (18).

7.3 Visitors from outside the United States

The Service is intended for users in the United States. If you access the Service from outside the United States, you do so at your own initiative; cookies and similar technologies will be set in accordance with this Policy.

8. Mobile applications

Where we offer mobile applications, we use SDKs and similar technologies that perform functions analogous to cookies. Your platform-level controls (for example, "Allow Apps to Request to Track" on iOS and "Reset advertising ID" or "Delete advertising ID" on Android) supplement the in-product controls described above.

9. Operators' and Sellers' use of cookies

When you visit a Turtles-powered marketplace operated by an Operator, that marketplace may set additional cookies under its own privacy and cookie notices. Operators are independent businesses responsible for the cookies they choose to set, the consent flows they implement, and the third parties they engage. Sellers may similarly use third-party tracking technology where Operators allow.

If you have questions about a particular marketplace's cookie practices, please contact that marketplace directly.

10. Changes to this Policy

We may update this Policy from time to time as we add or remove cookies, change service providers, or as Applicable Law evolves. The effective date above reflects the most recent version.

11. Contact

Turtles.com Inc.privacy@turtles.com