Privacy Policy
How we handle your data
Last Updated: January 21, 2026
TURTLE-BASED is committed to protecting your privacy. This policy explains how we collect, use, and protect your information.
Analytics
We use Fathom Analytics to understand how visitors use our site. Fathom is a privacy-first analytics service that respects your privacy.
What Fathom Collects
- Page views and visit duration
- Referral sources (where visitors came from)
- Device type (mobile/desktop/tablet)
- Country (based on anonymized IP address)
- Scroll depth milestones (25%, 50%, 75%, 90%)
- Button clicks (CTA conversions)
What Fathom Does NOT Collect
- Personal information (names, emails, phone numbers)
- Precise location data
- Individual visitor identifiers or user IDs
- Cross-site browsing history
- IP addresses (anonymized immediately)
Why Fathom Is Privacy-First
- No cookies: Fathom does not use cookies or local storage
- No personal data: No personally identifiable information is collected
- Anonymized IPs: Visitor IP addresses are anonymized on arrival
- No cross-site tracking: Does not track you across other websites
- GDPR/CCPA/PECR compliant: Meets all major privacy regulations
- No consent banner required: Because no personal data is collected
You can learn more about Fathom’s privacy practices at usefathom.com/privacy
Email List
If you join our waitlist via the form on this site, we collect your email address to notify you when TURTLE-BASED launches.
What We Collect
- Email address (required)
- Subscription timestamp (automatic)
- Source page (which page you signed up from)
- Device type (automatic)
How We Use Your Email
- Send updates about TURTLE-BASED development
- Notify you when early access is available
- Share hard-won lessons from the front edge of AI-built systems
- Nothing else. No spam, no third-party sharing, no marketing from other companies.
Your Email Service Provider
Your email address is stored by Kit.com (formerly ConvertKit), our email service provider. Kit.com is GDPR compliant and protects your data with industry-standard security measures.
You can learn more about Kit.com’s privacy practices at kit.com/privacy
Unsubscribe Anytime
Every email includes an unsubscribe link. Click it to remove yourself from the list immediately. No questions asked.
Duplicate Signups
If you submit the same email address multiple times, Kit.com automatically updates your existing subscriber record instead of creating duplicates.
Your Data Rights (GDPR)
If you are located in the European Union, you have the following rights under GDPR:
- Right to access your data: Request a copy of the personal data we hold about you
- Right to delete your data: Request deletion of your personal data (also known as “right to be forgotten”)
- Right to object to processing: Object to how we process your personal data
- Right to data portability: Request your data in a machine-readable format
- Right to rectification: Request correction of inaccurate personal data
To exercise these rights, contact us at privacy@turtlebased.dev with your request.
We will respond within 30 days of receiving your request.
Data Security
We take data security seriously:
- No passwords: We don’t store passwords (no login system required for landing page)
- HTTPS encryption: All data transmitted to/from our site is encrypted via HTTPS
- Third-party services: We only use reputable service providers (Fathom Analytics, Kit.com, Cloudflare Pages) that meet industry security standards
- Minimal data collection: We collect only the data necessary to provide our services
Third-Party Services
We use the following third-party services:
Cloudflare Pages (Hosting)
Our website is hosted on Cloudflare Pages, which provides CDN and DDoS protection. Cloudflare may collect technical data (IP addresses, user agents) for security purposes. Cloudflare Privacy Policy
Fathom Analytics (Analytics)
Privacy-first analytics without cookies or personal data collection. Fathom Privacy Policy
Kit.com (Email Service Provider)
GDPR-compliant email marketing platform for managing our waitlist. Kit.com Privacy Policy
Changes to This Policy
We may update this privacy policy from time to time. Changes will be posted on this page with an updated “Last Updated” date.
If we make significant changes that affect how we handle your data, we will notify waitlist subscribers via email.
Children’s Privacy
TURTLE-BASED is not intended for children under 13 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child under 13, please contact us immediately.
International Data Transfers
Our services are provided from the United States. If you access our site from outside the US, your data may be transferred to, stored, and processed in the United States or other countries.
By using our site and services, you consent to this transfer of data across international borders.
Questions or Concerns?
If you have any questions about this privacy policy or how we handle your data, please contact us:
Email: privacy@turtlebased.dev
We will respond to your inquiry within 5 business days.
Summary (TL;DR)
- Analytics: We use Fathom Analytics (no cookies, no personal data, GDPR compliant)
- Email: If you join our waitlist, we store your email in Kit.com and use it only for launch updates
- No sharing: We never share your data with third parties for marketing purposes
- Your rights: You can access, delete, or export your data anytime by contacting us
- Unsubscribe: Every email has an unsubscribe link - click it to opt out immediately
We respect your privacy. No tracking. No spam. No BS.