Effective Date: 25 July 2025
Last Updated: 25 July 2025

1. Introduction
Hopeful Turtles (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our website at hopefulturtles.com and our subscription services.
This Privacy Policy applies to all users of our services, including those in the European Union and the United States.

2. Information We Collect

2.1 Information You Provide Directly

Account Information:

Name and email address
Username and password
Payment information (processed securely through Stripe)
Profile information you choose to share

Service Usage Data:

Recovery journal entries (stored encrypted)
Mood tracking data
Achievement and progress information
Forum posts and community contributions
Fitness challenge participation data
Feedback and support communications

2.2 Information Collected Automatically
Technical Information:

IP address and location data
Browser type and version
Device information
Operating system
Website usage patterns and analytics
Cookies and similar tracking technologies

Usage Analytics:

Pages visited and time spent
Features used within your dashboard
Click patterns and navigation behavior
Service performance data

3. How We Use Your Information
We use your personal information for the following purposes:

3.1 Service Provision

Create and manage your subscription account
Process payments and billing
Deliver our recovery and investment educational content
Provide personalized dashboard features
Enable community forum participation
Track your progress and achievements

3.2 Communication

Send service-related notifications
Provide customer support
Send newsletters and updates (with your consent)
Respond to your inquiries and feedback

3.3 Service Improvement

Analyze usage patterns to improve our services
Develop new features and content
Conduct research and analytics
Ensure security and prevent fraud

3.4 Legal Compliance

Comply with applicable laws and regulations
Respond to legal requests and prevent fraud
Protect our rights and the rights of our users

4. Legal Basis for Processing (EU Users)
Under the General Data Protection Regulation (GDPR), we process your personal data based on:

Contract Performance: To provide our subscription services
Legitimate Interest: To improve our services and ensure security
Consent: For marketing communications and optional features
Legal Obligation: To comply with applicable laws

5. Data Storage and Security

5.1 Data Storage

Your data is stored in WordPress databases hosted on secure servers
Recovery journal entries are encrypted for additional privacy protection
Payment information is processed and stored securely by Stripe (PCI DSS compliant)
We implement appropriate technical and organizational security measures

5.2 Data Security Measures

SSL encryption for data transmission
Regular security updates and monitoring
Access controls and authentication protocols
Regular backups and disaster recovery procedures
Staff training on data protection practices

5.3 Data Retention

Account data: Retained while your account is active
Recovery journal entries: Retained for as long as you maintain your account
Payment records: Retained as required by law (typically 7 years)
Analytics data: Retained for up to 2 years
Marketing data: Retained until you withdraw consent

6. Data Sharing and Disclosure

6.1 We Do Not Sell Your Data
We do not sell, rent, or trade your personal information to third parties for marketing purposes.

6.2 Service Providers
We may share your information with trusted service providers who help us operate our business:

Stripe: Payment processing (under their privacy policy)
Hosting providers: Website and database hosting
Analytics services: Website performance and usage analytics
Email services: Communication and newsletter delivery

6.3 Legal Requirements
We may disclose your information when required by law or to:

Comply with legal obligations
Protect our rights and property
Prevent fraud or security threats
Respond to lawful government requests

6.4 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to the same privacy protections.

7. International Data Transfers
As we serve users in both the EU and US, your data may be transferred and processed in different countries. When transferring data outside the EU, we ensure adequate protection through:

Standard Contractual Clauses approved by the European Commission
Adequacy decisions by the European Commission
Other appropriate safeguards as required by law

8. Your Privacy Rights

8.1 Rights for All Users

Access: View your personal data through your account dashboard
Correction: Update your account information at any time
Deletion: Request deletion of your account and associated data
Data Portability: Request a copy of your data in a portable format

8.2 Additional Rights for EU Users (GDPR)

Right to Rectification: Correct inaccurate personal data
Right to Erasure: Request deletion of your personal data
Right to Restrict Processing: Limit how we process your data
Right to Object: Object to processing based on legitimate interests
Right to Data Portability: Receive your data in a structured format
Right to Withdraw Consent: Withdraw consent for processing at any time

8.3 Exercising Your Rights
To exercise your privacy rights:

Access your account dashboard for basic data management
Contact us at support@hopefulturtles.com for specific requests
We will respond to requests within 30 days (1 month for GDPR requests)

9. Cookies and Tracking Technologies

9.1 Types of Cookies We Use

Essential Cookies: Required for website functionality
Analytics Cookies: Help us understand website usage
Preference Cookies: Remember your settings and preferences
Marketing Cookies: Personalize your experience (with consent)

9.2 Cookie Management
You can control cookies through your browser settings. Note that disabling essential cookies may affect website functionality.

10. Third-Party Services
Our website may contain links to third-party services. This Privacy Policy does not apply to third-party websites or services. We encourage you to review their privacy policies.
Key Third-Party Services:

Stripe: Payment processing (see Stripe’s privacy policy)
Analytics providers: Website usage analysis
Content delivery networks: Website performance optimization

11. Children’s Privacy
Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will delete it promptly.

12. Data Breach Notification
In the event of a data breach that may affect your personal information:

We will notify relevant supervisory authorities within 72 hours (if required by law)
We will notify affected users without undue delay
We will provide clear information about the breach and steps we’re taking

13. Updates to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by:

Posting the updated policy on our website
Updating the “Last Updated” date
Sending email notifications for significant changes
Requesting consent where required by law

14. Contact Information

14.1 General Privacy Questions
For questions about this Privacy Policy or our privacy practices:

Email: support@hopefulturtles.com
Website: hopefulturtles.com

14.2 Data Protection Officer (EU Users)
For GDPR-related inquiries, you can contact our Data Protection Officer at:

Email: support@hopefulturtles.com

14.3 Supervisory Authority (EU Users)
If you’re not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with your local data protection authority in the European Union.

14.4 Our Business Address
Hopeful Turtles
Dordrecht, Pijnenburg 8, 3328DA
Netherlands

This Privacy Policy is designed to be transparent and help you understand how we protect your personal information. If you have any questions, please don’t hesitate to contact us.