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Privacy Policy

Effective Date: 11/3/2025

1. Introduction
Welcome to the website of Testudo Trust LLC (the “Company,” “we,” “us,” or “our”). This Privacy Policy describes how we collect, use, disclose, and protect personal information through our website at https://www.testudotrust.com/ (the “Site”). By using the Site, you agree to the terms of this Privacy Policy.

2. Who We Are
Testudo Trust LLC
56 Mill Road
East Longmeadow, MA 01028
Email: info@testudotrust.com
 

3. Information We Collect
We may collect both personal information (information that identifies you as an individual) and non-personal information (information that does not directly reveal your identity). Examples include:

  • Information you provide directly: e.g., name, email address, mailing address, phone number, when you contact us, sign up for newsletters, request information, or otherwise interact with the Site.

  • Automatic or technical information: e.g., your IP address, browser type, device type, operating system, referring URLs, date and time of access, pages visited, time spent, cookies and similar tracking technologies.

  • Cookies and usage data collected via tracking technologies.

4. How We Use Your Information
We use your information for purposes including, but not limited to:

  • To respond to your inquiries, provide information or services that you request.

  • To send you newsletters, marketing communications, updates or other correspondence (you may opt-out).

  • To monitor and analyze usage, trends and preferences so we can improve the Site and our services.

  • To provide a secure and efficient experience on the Site.

  • To comply with applicable legal or regulatory obligations.

5. Cookies and Tracking Technologies
We may use cookies, web beacons, tracking pixels, and other similar technologies to collect and store information about how you use the Site and to tailor your experience. You may choose to disable cookies through your browser settings, but doing so may impact your ability to interact with certain features of the Site.
We also recommend reviewing our separate Cookie Policy [if applicable] for more details.

6. Disclosure of Your Information
We will not sell your personal information. We may share your information in the following circumstances:

  • With service providers, contractors or vendors who perform functions on our behalf (for example, hosting, analytics, marketing) and who agree to keep the information confidential.

  • To comply with applicable law or legal process, enforce our rights, protect our property or safety, or defend against legal claims.

  • In connection with a business transaction such as a merger, acquisition, reorganization, sale of assets, or bankruptcy (in which case we will use reasonable efforts to require the recipient to honour the terms of this Privacy Policy).

7. Data Retention
We retain personal information for as long as needed to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Once no longer needed, we will securely delete or anonymize your information.

8. Security
We implement reasonable administrative, technical and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration or destruction. However, no internet-transmitted data or computer system is completely secure; therefore we cannot guarantee absolute security.

9. Your Rights
Depending on your jurisdiction, you may have rights regarding your personal information, including:

  • The right to access, correct, update or delete your personal information.

  • The right to opt-out of marketing communications.

  • The right to restrict or object to certain processing of your data.

  • The right to withdraw consent where applicable.
    If you wish to exercise any of these rights, please contact us at the information below. We may ask you to verify your identity before fulfilling your request.

10. Children’s Privacy
The Site is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete the information as soon as possible.

11. International Transfers
If you are accessing the Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States or other jurisdictions. By using the Site, you consent to such transfers.

12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. The “Effective Date” at the top will reflect when changes took effect. We encourage you to revisit this page periodically to stay informed of our privacy practices. If we make material changes, we may provide notice via the Site or by other means.

13. How to Contact Us

 

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:
Testudo Trust LLC
56 Mill Road
East Longmeadow, MA 01028
Email: info@testudotrust.com
 

Optional Additional Clauses
Depending on your actual practices you may consider adding:

  • A section on “Do Not Sell My Personal Information” if you are subject to laws such as the California Consumer Privacy Act (CCPA) or the California Privacy Rights Act (CPRA).

  • A section on “Legal Basis for Processing” if you collect data from EU/UK residents and are subject to the General Data Protection Regulation (GDPR).

  • A detailed list of third-party vendors, analytics providers, advertising networks and a cookie-consent/management tool.

  • A specific Cookie Policy or tracking-technologies appendix.

  • A retention schedule with specific time periods for different categories of data.

  • Links to resources for residents of specific states (e.g., California, Virginia, Colorado, etc.).

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