Privacy Policy

Effective Date: 3 May 2025

1. Introduction

The Turtle Bros (“we”, “us”, “our”) operates theturtlebros.com. We respect your privacy and are committed to protecting your personal data. This policy explains how we collect, use, and share information, and your rights under UK and EU (GDPR) law.

2. Data Controller

The Turtle Bros
Website: theturtlebros.com
Contact: Ben Salt <technical@naclstudios.co.uk>

3. Information We Collect

• No Direct Personal Data: We do not require you to register or submit personal information.
• Automatic Analytics Data: We use Google Analytics to gather technical and usage information (e.g. page views, device type, anonymized IP address) to help us improve the site.
• Third-Party Donation Processor: When you make a donation, we redirect you to PayHere.lk. Any personal data you provide there (e.g. name, billing address) is collected and processed by PayHere.lk. Please consult PayHere.lk’s privacy policy for details: https://www.payhere.lk/privacy/.

4. Cookies & Tracking

• Only Strictly Necessary Cookies: We do not use cookies beyond what is absolutely necessary for the site to function.
• Analytics Cookies: We employ Google Analytics for aggregate usage statistics; no personal identifiers are stored.
• No Other Tracking: We do not deploy advertising or third-party tracking cookies.
• Opt-Out: You can opt out of Google Analytics tracking by installing Google’s opt-out browser add-on.

5. Purposes & Legal Basis

• Analytics: To understand site usage and improve our content and performance; legal basis: our legitimate interest in improving the site.
• Donation Processing: To complete your donation via PayHere.lk; legal basis: performance of a contract (your donation agreement).

6. Data Sharing & Transfers

• Analytics: Google LLC (USA)—covered by EU-US and UK-US Data Privacy Frameworks.
• Donations: PayHere.lk (Sri Lanka)—please review their cross-border transfer safeguards.
• We never sell or rent your data to third parties.

7. Data Retention

• Analytics Data: Retained in accordance with your Google Analytics settings (typically up to 14 months).
• Donation Data: Retention governed by PayHere.lk’s policy.

8. Your Rights

Under GDPR you have the right to:

• Access, rectify, or erase your personal data.
• Restrict or object to processing.
• Withdraw consent (where given) without affecting prior processing.

To exercise any right, contact technical@naclstudios.co.uk.

9. Security

We implement appropriate technical and organizational measures to protect data (TLS encryption, access controls, etc.). However, no internet transmission is completely secure.

10. Changes to This Policy

We may update this policy; changes will be posted here with a new “Effective Date.” We encourage you to review it periodically.

11. Contact Us

For privacy questions or requests, email technical@naclstudios.co.uk.