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Legal
Privacy Policy
Effective date: May 14, 2026 · Last updated: November 2, 2026
1. Introduction
This Privacy Policy explains how Turtini LLC ("Turtini," "we," "our," or "us") collects, uses, shares, and protects information when you visit turtini.com or use the Turtini platform, including all of its modules, services, and features (collectively, the "Platform").
Turtini is a business operating platform. Organizations ("Orgs") use it to run their operations across integrated modules — including CRM, accounting and payroll, contracts and grants, scheduling and planning, websites and email, hospitality, property and rental management, fleet and maritime operations, lab environments, a developer marketplace, and more — alongside an AI assistant ("Wally"). Because the Platform spans so many workflows, the specific data involved depends on which modules an Org turns on.
Your use of the Platform is also governed by our Terms & Conditions.
2. Roles: Who Controls the Data
For your own account and profile, and for visitors to turtini.com, Turtini is the controller of personal information.
For data an Org puts into the Platform about its own customers, employees, vendors, guests, tenants, or other third parties, the Org is the controller and Turtini acts as a service provider / processor on the Org's behalf. If you are an individual whose data was entered by an Org (for example, you are a customer of a business that uses Turtini), please direct privacy requests to that Org; we will support them in responding.
3. Information We Collect
3.1 Information you provide to us
Account and identity information — name, email address(es), phone number, postal address, password and authentication credentials, multi-factor authentication factors (such as authenticator-app secrets, passkeys, and trusted-device records), profile photo, and the linked emails, phone numbers, and handles that make up your Turtini identity graph.
Organization and business data — Org names, business addresses, roles and team membership, and the business identity details used for verification (see 3.3).
Module content — everything you create or upload while using the Platform: contacts and accounts, opportunities, quotes and invoices, documents and files, calendar events, projects and tasks, products and inventory, properties, vehicles and vessels, reservations and guest records, recipes and menus, runbooks, websites, and similar records. This may include personal information about third parties that you choose to enter.
Payment and financial information — when you use payment, payroll, banking, or accounting features, this can include bank account connections, transaction and invoice records, payroll and tax records (such as W-9s, paystubs, and 1099s), and beneficial-owner and tax-identification details. Turtini does not store raw payment card numbers — card payments are handled directly by Stripe, our PCI-compliant payment processor.
Communications — emails, messages, and support requests you send through or to the Platform, and content from mailboxes or calendars you choose to connect.
AI assistant interactions — the messages, questions, voice input, and context you share with Wally (see Section 5).
3.2 Information we collect automatically
Device and usage data — browser type, device type, operating system, referring pages, the pages and features you use, and timestamps.
Approximate location — we derive an approximate location from your IP address: a country, and within some countries a state or equivalent subdivision. We do not derive or store anything more precise — no city, no postal code, no coordinates. Your IP address is used to make that determination and is then discarded; it is not stored on usage-event records or on form submissions, and is held only in a short-lived lookup cache keyed by a one-way hash.
Worlds free scenes — when you build a Worlds scene without an organization, we count it against the day's free scenes. Signed in, the count is kept against your account. As a guest, it is kept against your guest session and a one-way hash of your IP address, salted with a random value that changes every day, so the address itself is never stored and the hash means nothing on any other day. These counts are used only to apply the daily limit and expire after two days.
Sign-in location, only if you turn it on — the Places You've Been feature has a setting, off unless you switch it on, that adds the country and state (or equivalent region) your connection appears to come from each day you use the Platform, looked up by our location provider listed in Sec. 7. It never records the city, a postal code or coordinates. Each entry is listed on that page and you can delete any of them; turning the setting off erases all of them. Apart from the shared-screen sign-in record described next, this is the only place an approximate location derived from your IP address is kept on your account.
Signing in on a screen you do not own — when a TV, kiosk or other shared screen asks to sign in as you and you approve it from your phone, we keep the state (or equivalent region) and country that screen's request appeared to come from with that sign-in, so you can recognize the request before approving it and in your list of screens you are signed in on. It never records the city, and it is shown only to you.
Visitor and company analytics — we operate first-party analytics to understand how the Platform is used. As part of this, we identify the organization associated with a visit: for signed-in users, from the visitor's email domain; for anonymous visitors, through a reverse-IP company lookup performed by our provider IPinfo. This identifies companies only, never individuals, resolves only a portion of traffic, and is used to understand which businesses are evaluating Turtini.
Cookies and similar technologies — see Section 8.
3.3 Information we receive from third parties
Identity and business verification — when an Org goes through identity or business ("KYB") verification, we receive verification results and related business records from providers such as Stripe, Middesk, and Tax1099.
Contact enrichment — if an Org uses contact-enrichment features, we obtain business contact information (such as names, titles, and work contact details) for people at a company domain from Apollo, using the Apollo account the Org connects and pays Apollo for directly.
Connected integrations — if you connect a third-party account (for example Google Workspace / Gmail, Calendar, and Meet, GitHub, or social accounts), we receive data from that service according to the permissions you grant. What we do with data from a Google account is set out in full in Section 3.5.
Payment and banking partners — we receive transaction, payout, account, and status information from Stripe and Plaid in connection with payment and banking features.
3.4 Sensitive information
Some modules can involve sensitive categories of information — for example, financial account data, government identifiers used for payroll and tax, or wellbeing-related content in modules designed for personal support. We collect and use such information only to provide the relevant feature, apply heightened access controls to it, and do not use it for advertising. Do not enter sensitive personal information into free-text fields that are not intended for it.
3.5 Google user data (Gmail, Calendar, Meet)
This section covers the data Turtini receives when you connect a Google account. It applies to every Google account you connect, including additional mailboxes and calendars.
What we access, and why
Gmail (read, send, and settings). When you connect Gmail, you allow Turtini to read your messages, labels, and settings (the gmail.readonly and gmail.settings.basic permissions) and to send mail (the gmail.send permission). We use this to show, search, and sort your mail in Turtini Mail, to keep it up to date as new mail arrives, to send the mail you write, to apply the email signature you choose to your Gmail account, and to power the features below that you turn on.
Changing labels in Gmail (optional, not yet offered). We have built, but not yet turned on, an optional permission (gmail.modify) that you would grant separately. With it, when you act on a conversation in Turtini Mail, Turtini would make the same change in Gmail: mark it read or unread, star or unstar it, archive it, move it to or from the trash, or mark it as spam or not spam. Each change is made only in response to your action on that conversation, never in the background or in bulk. Until you grant it, opening a message marks it read in Turtini only.
Google Calendar. With calendar.readonly, we show your Google Calendar events in your Turtini calendar. With calendar.events, we add the events you ask us to add, such as a booking made through your Turtini site or a project milestone you push to your calendar. Calendar events are read from Google when you view them and are not stored by Turtini.
Google Meet. With meetings.space.readonly, when you click "Import as doc" on a meeting in /me/meetings, we read that meeting's transcript and write it into a document you own at /me/docs/:id. We do not list, store, or use Meet data for any other purpose.
Features that use your mail
CRM logging. If you belong to an organization on Turtini, a message you send to or receive from one of that organization's contacts is logged on that contact's record (sender, recipients, subject, date, and message text), and a short note naming the subject is added to the contact's account. Members of that organization who can see the contact can read the logged message. It becomes part of the organization's records.
Travel. When a flight confirmation arrives, we record its sender, subject, and booking reference, and add the flight to a matching trip in Turtini.
Expense reconciliation. If you or a reviewer in your organization runs reconciliation on your expense report, we search your connected mailboxes for receipts in the report's date range, extract the vendor, amount, and date, and attach the matching receipt email and its receipt files to the report, where its reviewers can see them.
Where it is stored, and for how long
Authorization tokens. The token that lets Turtini reach your Google account is stored on our servers and used only by our servers. It is never sent to your browser or to anyone else. We delete it when you disconnect the account.
Message list. To show your inbox quickly, we keep a list entry for each recent conversation: subject, a short preview, participants, labels, date, and unread count. Full messages are not stored in this list; they are fetched from Google when you open them. Recently fetched messages and lists are held for a short time in our servers' memory, and never written to our database. The list is kept while the mailbox is connected and is deleted when you disconnect it.
Read state. Because Turtini cannot mark mail read in Gmail without the optional permission above, we record which conversations you have opened in Turtini (the conversation and message identifiers only, for up to 2,000 conversations per mailbox). It is deleted when you disconnect the mailbox.
Copies you or your organization keep. Messages logged to an organization's CRM, receipts attached to an expense report, flights added to a trip, and drafts an AI assistant saves for you are records in those features. They stay after you disconnect and are kept and deleted on the same schedule as the rest of that organization's or your data, as set out in our Data Retention & Disposal Policy.
AI processing
Wally reply drafts. When you ask Wally to draft a reply, we send the conversation, short excerpts of a few of your recent sent messages (so the draft sounds like you), and the related CRM account details to our AI provider, Anthropic, to write that draft. You review it, and nothing is sent until you press Send.
Expense reconciliation. Receipt emails and their attached receipt files are sent to Anthropic to extract the vendor, amount, date, and category.
Your own AI assistant. If you connect your own AI assistant (such as ChatGPT, Claude, or Gemini) to your Turtini account and allow it to read your email, it can search and read your connected mail as text, with attachments listed by name only, and save drafts for you to review. That assistant receives the mail because you directed it to, and its provider's terms govern what it does with it. You can remove an assistant at any time from your Connected AI apps settings.
Under our agreement with Anthropic, it may not use the content we send to train its models. Turtini does not use Google user data to develop, improve, or train generalized or non-personalized AI or machine-learning models.
What we do not do
We do not sell Google user data, use it for advertising, or use it to build profiles for advertising. We do not transfer it to anyone except as described in this section: to provide the features you use, to the AI assistant you connect, to the people in your organization through the features described above, to comply with the law, or, with your explicit prior consent, as part of a merger, acquisition, or sale of assets. Turtini staff do not read your Google user data unless you ask us to and agree to it (for example, in a support request), it is needed for security purposes such as investigating abuse, or the law requires it.
Your controls
Disconnect a mailbox or calendar in Turtini at any time. Disconnecting stops syncing and deletes its authorization token, message list, and read state.
Revoke Turtini's access in your Google account at myaccount.google.com/permissions.
To delete the copies described above, delete them in the feature that holds them, ask your organization's administrator, or write to [email protected] (Section 17).
Turtini's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. The use of information received from Google Workspace APIs will also adhere to the Google Workspace API User Data and Developer Policy.
4. How We Use Information
To provide, operate, maintain, and secure the Platform and its modules.
To create and manage your account, Org membership, and permissions.
To process payments, payroll, invoicing, and other financial transactions you initiate, and to calculate and apply Platform fees.
To resolve your identity across the emails, phone numbers, and accounts that belong to you, and to merge duplicate accounts into a single account where appropriate.
To power AI features and assistant functionality (see Section 5).
To communicate with you about your account, transactions, security, and service changes.
To send newsletters and promotional material where you have not opted out (you can opt out at any time).
To understand usage and trends and to improve the Platform.
To detect, investigate, and prevent fraud, abuse, and security incidents, to moderate uploaded content for safety, and to enforce our Terms.
To comply with legal obligations and respond to lawful requests.
Automated content moderation. Images uploaded to the Platform are automatically screened for unsafe content using Google Cloud Vision before they are displayed. Content flagged by this process may be held for human review.
5. AI Features (Wally)
The Platform includes an AI assistant, Wally. When you interact with Wally, the content of your request — along with relevant context from your Org's data needed to answer it — is processed by a large language model to generate a response. By default this processing is performed by Anthropic (Claude). Voice input to Wally is transcribed using Google Cloud Speech-to-Text.
We do not use your data, and our model providers do not use data sent through the Platform, to train their general-purpose models. Orgs on supported plans may configure Wally to route to their own model endpoint instead of the Turtini-hosted default; in that case, AI processing is governed by that endpoint's terms.
6. How We Share Information
We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We share information only as described below:
Service providers and sub-processors — third parties that perform services for us (hosting, payments, communications, verification, AI, analytics). They may access information only to perform those services for us. See Section 7.
Within and between Orgs — data you put into an Org is visible to other members of that Org according to their roles and permissions. Orgs can connect with partner Orgs and share scoped data; where this happens, sharing follows the configuration chosen by the participating Orgs. Joining an Org may bring that Org's events into your unified calendar.
At your direction — when you connect an integration, install or publish a Marketplace template, export your data, share your Places You've Been map with a person you choose (they see which countries and states are colored, and dates only if you allow it), or otherwise instruct us to share.
Legal and safety — when we believe disclosure is required by law or legal process, or is necessary to protect the rights, property, or safety of Turtini, our users, or the public.
Business transfers — in connection with a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction.
7. Sub-processors
We rely on the following categories of providers to operate the Platform. Each receives only the information needed for its function:
Google Cloud / Firebase — application hosting, database, authentication, file storage, and serverless functions; Cloud Vision (image moderation); Cloud Speech-to-Text (voice input); and, where you connect them, Google Calendar, Gmail, and Google Meet (transcript import on user request).
Anthropic — large language model that powers the Wally assistant.
Stripe — payment processing, payouts, and business identity verification for organizations that use it.
Square — payment processing and payouts for organizations that choose it as their merchant account provider.
Plaid — secure bank-account connections for banking and accounting features.
Middesk — business and tax-identity verification.
Tax1099 — business and tax-identity verification.
Apollo — business contact enrichment.
Resend — outbound transactional and marketing email.
SendGrid — inbound email processing.
Cloudflare — content delivery, DNS, and custom-domain hosting.
Google Analytics — website and product usage measurement.
IPinfo — reverse-IP company identification for first-party analytics.
ipapi.co — IP-to-country and state-level region lookup.
Apple — Wallet pass issuance, where used.
GitHub — code export and connected-repository hosting, where used.
Checkr — applicant/tenant background screening, where an Org uses screening features.
Twilio — SMS and voice delivery for reminders, notifications, and campaign messaging; receives recipient phone numbers and message content.
Printful — print-on-demand fulfilment for merchandise orders, where an Org uses swag features; receives recipient names and shipping addresses.
We may update this list as the Platform evolves; the current version is always the one published here.
Business and government customers who need contractual data-protection terms can review our Data Processing Addendum, which incorporates this same sub-processor list.
8. Cookies and Tracking Technologies
We use cookies and similar technologies that are necessary to sign you in, keep your session secure, and remember your preferences. These are first-party and functional: they are what makes signing in, your cart, and your saved settings work.
We do not run third-party analytics or advertising on turtini.com. We previously used Google Analytics to count visits; it was removed in October 2026. We do not use cookies to serve you advertising, we do not sell or share your personal information for cross-context behavioral advertising, and there is no cookie consent banner on the Platform because there is nothing on it to consent to beyond the storage described above.
Sites built on Turtini are different. An organization can enable its own Google Analytics or advertising on the public website it builds here. Those run under that organization's accounts, are that organization's disclosure to make, and appear behind that site's own cookie notice — not ours. This Privacy Policy covers turtini.com; a Turtini-built site is governed by that organization's policy.
9. Data Retention
We keep personal information for as long as your account or your Org's account is active, and as needed to provide the Platform, comply with legal and financial-recordkeeping obligations, resolve disputes, and enforce our agreements.
The summary below is not the whole picture. Our Data Retention & Disposal Policy publishes the full schedule — every category, every period, exactly what an erasure request does and does not reach, and where automated enforcement is not yet in place.
Your account. Turtini accounts are designed to persist across job and life changes — one person, one account. You can delete your account at any time from Account, Safety, Delete my account. Deleting an account ends every organization membership it holds; the API keys and connections it created in those organizations stop working, and each organization's admins are told which ones. Any guardian relationship it is part of ends, and a parental consent resting on one is withdrawn. A record that the deletion happened, naming you, is kept for seven years and then reduced to dates and counts. If you are the only owner of an organization that has other members, or its only member, we will ask you to transfer ownership first, because deleting an account never deletes an organization or picks its next owner.
Org lifecycle. When an Org is paused or cancelled, its data enters a grace period before deletion and remains recoverable for a defined window after that, so an Org can come back without losing its history.
Workforce data. Records that belong to you as an individual — such as your paystubs and tax documents — remain available to you even after you leave an Org; the Org's other data is no longer shared with you once your membership ends.
Deletion. When data is deleted at the end of these periods or on request, it is removed from active systems; residual copies may persist briefly in routine system processes before being overwritten.
10. Your Rights and Choices
Depending on where you live, you may have some or all of the following rights:
Access — request a copy of the personal information we hold about you.
Correction — ask us to correct inaccurate or incomplete information.
Deletion — ask us to delete your personal information, subject to legal exceptions.
Portability and export — receive your information in a portable format. The Platform also provides built-in export and data-portability tools for moving your data out.
Restriction and objection — ask us to restrict or object to certain processing.
Opt out of marketing — unsubscribe from promotional email at any time using the link in those messages or by contacting us. We will still send necessary service and transactional messages.
No sale / no sharing — we do not sell or share personal information as those terms are defined under California law, so there is nothing to opt out of in that respect.
Withdraw consent — where processing is based on consent, you can withdraw it.
To exercise these rights, contact us at [email protected]. We will verify your request and respond within the timeframe required by applicable law. You will not be discriminated against for exercising your rights. If your data was entered into the Platform by an Org, please also see Section 2.
11. Data Security and Integrity
We use technical and organizational measures designed to protect personal information, including encryption of data in transit and at rest, role-based access controls and per-record security rules, available multi-factor authentication and passkeys, automated screening of uploaded images, and ongoing monitoring for fraud and abuse. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
No cloud or distributed system can be guaranteed against interruption, corruption, or loss of data. We operate the Platform with reasonable safeguards and recovery processes designed to reduce that risk, and we provide built-in export and data-portability tools so you can move your data out. You remain responsible for evaluating whether the Platform meets your business-continuity, archival, and regulatory requirements, and for taking independent backups of anything your operations cannot tolerate losing. The full allocation of responsibility for service availability and data integrity is set out in our Terms & Conditions.
12. International Data Transfers
Turtini is based in the United States and the Platform is hosted on infrastructure located in the United States. If you access the Platform from outside the United States, your information will be transferred to, stored in, and processed in the United States and other countries where we or our sub-processors operate, which may have different data-protection laws than your jurisdiction. Where required, we rely on appropriate safeguards for such transfers.
13. Children's Privacy
The Platform is intended for use by businesses and adults. It is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected such information, we will delete it. If you believe a child has provided us with personal information, contact us at [email protected].
14. Third-Party Sites and Services
The Platform may link to, or let you connect, third-party sites and services that we do not control. This Privacy Policy does not apply to those third parties; their own privacy policies govern your use of them. Marketplace modules and templates offered by third-party developers are subject to the developer's own terms in addition to ours.
15. Text Messaging (SMS)
Turtini offers optional text-message (SMS) notifications. This section describes that program and how you consent to it.
What you receive. When enabled, you may receive messages related to your account and the organizations you belong to — including group and team chat messages, direct messages, appointment and reservation reminders, and review requests. You can reply to conversational messages to participate in the thread.
How you opt in (consent). Text messaging is off by default and is entirely opt-in. To receive texts you (1) sign in and add your mobile number under Account → Profile, then (2) turn on "Text me when I'm offline" in Messages → preferences. Enabling that toggle is your express consent to receive the messages above at the mobile number on your profile. Consent is collected per person inside your authenticated account; Turtini never buys, rents, or shares phone numbers, and enabling messaging is not a condition of using the Platform.
Reservation reminders. Separately, if you book a reservation or appointment with a business on Turtini and provide your mobile number on that booking form, you consent to receive transactional text reminders about that specific reservation. These are not marketing messages, and the same STOP / HELP controls below apply.
Message frequency varies based on your activity and the organizations you belong to. Message and data rates may apply — Turtini does not charge you to receive texts, but your mobile carrier's standard rates apply.
Opt out or get help. Reply STOP to any message to unsubscribe and stop all further texts (or turn off "Text me when I'm offline" anytime). After opting out you receive one confirmation and no further messages unless you reply START to resubscribe. Reply HELP for help, or contact [email protected]. Carriers are not liable for delayed or undelivered messages. We do not share your mobile number or messaging opt-in with third parties for their marketing.
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above, and for material changes we will provide additional notice in the Platform or by email. Your continued use of the Platform after an update takes effect means you accept the revised policy.
Recent changes
October 26, 2026 — added Section 3.5, Google user data (Gmail, Calendar, Meet): what Turtini reads from a connected Google account, what it is used for, where it is kept and for how long, when it is sent to an AI provider, and how to disconnect. It replaces the Google Meet text that was in Section 3.3. Two practices changed with it: a Google authorization token can no longer be read from a browser, and disconnecting your main Gmail account now also deletes its message list and read state.
17. Contact Us
If you have questions about this Privacy Policy or how we handle your information, contact us at [email protected], or by mail:
Turtini LLC
400 Granby Street, Suite 107-9
Norfolk, VA 23510
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