Last Updated: January 1, 2024

This Privacy Notice explains how Voyetra Turtle Beach, Inc. and its subsidiaries and affiliated companies (collectively, “Turtle Beach”, “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes personal information about our California-based employees, officers, directors, contractors, freelancers, contingent workers, consultants, and other outsourced and temporary workers in California (collectively, “personnel”), and their family members or other individuals about whom we process personal information as a result of the relationships those individuals have with personnel (collectively, “related persons”).

This Privacy Notice is not a contract and does not create any legal rights or obligations. This Privacy Notice also is not intended to replace other notices or disclosures we may provide to you in connection with your role in our organization, which will supersede any conflicting disclosures contained in this Privacy Notice.

What is Personal Information?

When we use the term “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual within the context of the individual’s role as a member of our personnel or a related person. It does not include aggregated or deidentified information that is maintained in a form that is not capable of being associated with or reasonably linked to an individual person.

Our Collection and Use of Personal Information

Personnel

Collection of Personal Information

In connection with your role as a member of our personnel, we collect certain personal information about you, which may include:

• Contact Information: such as your full name, email address (personal and work), home address, business address, telephone number, and emergency contact information.
• Identification Materials: such as your image, social security number or other national identification number, passport number, driver’s license number, or vehicle license plate number.
• Professional Information: such as your hire date, employment location, business unit, department, supervisor, job title, position/grade, hours and days worked, working arrangement, work restrictions or accommodations, employee identification number, licenses and certifications, attendance, career goals, performance reviews, disciplinary records, and information needed to establish your eligibility to work for us, including citizenship, immigration status, or visa information.
• Education & Training Information: such as your highest level of education, the schools you attended and when you were in attendance, degrees, certificates, or other educational qualifications you earned, and your transcripts or training records.
• Financial Information: such as your salary, bonus, benefits, expenses, stock or equity grants, bank account and routing information, and corporate credit card number.
• Benefits Information: such as your eligibility for benefits, information about your family members and other related persons under your benefits, and claims relating to your benefits.
• Equal Opportunity Information: such as age, race, ethnicity, national origin, citizenship or immigration status, sex, gender identity or transgender status, sexual orientation, religion, disability or accommodation request, or marital or veteran status when you choose to provide it, but it will not be used in employment-related decisions unless specifically permitted by law.
• Security Information: such as your work-related accounts and passwords, technical details about your use of work-related devices (including, for example, device information, logs, analytics data, IP address, device usage and your general location information derived from such address), your access to physical and electronic work-related locations, and photographs, videos and other visual images of you.
• Sensory Information, such as recordings of certain phone calls with customer service personnel.
• Other Work-Related Information: We also collect any personal information you choose to share with us or we receive from a third party in connection with your work for us, a grievance you are involved in, an agreement you enter into with us or additional roles you take on as a part of our organization.

Although we often collect the personal information described above directly from you, we also collect this information from supervisors, colleagues, customers, vendors, publicly available sources, and other third parties you may interact with as a member of our personnel. In addition, we may also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers, payroll providers and benefits providers.

Please note that some of the information described above may also be considered “sensitive information” under applicable law. For more information, please see the Sensitive Information section below for more information.

Use of Personal Information

We use the personal information we collect about our personnel to:

• Conduct organizational planning and development, including budget planning and administration;
• Analyze and monitor compliance with our personnel and compliance policies and practices;
• Administer recruiting, onboarding, staffing, leave, personnel evaluations, promotions, performance management, training, discipline, participation in available activities or programs and any other processing in connection with work-related purposes;
• Authorize, grant, administer, monitor (including by video surveillance), and terminate access to or use of company systems, facilities, records, property, and infrastructure;
• Communicate with and between personnel, as well as with designated emergency contacts;
• Support and manage personnel, including providing resources needed for personnel to perform their roles with us;
• Facilitate personnel compensation, payroll, and benefit planning and administration (e.g., salary, tax withholding, insurance);
• Conduct performance reviews and evaluations, as well as make decisions about promotions and job mobility;
• Manage business travel (e.g., car service/rentals, flights, hotels) and personnel expenses (e.g., reimbursement, corporate credit card).
• Operate our business, including marketing our personnel to customers, facilitating the work of our personnel and providing the products and services made available to our customers;
• Investigate, document and report work-related injuries, illness, or grievances;
• Conduct internal investigations, audits, compliance, risk management, problem resolution, and security operations;
• Fulfill contractual obligations to you and other third parties; and
• Comply with applicable law, rule, regulation, legal proceeding and government investigations, including relating to tax reporting and immigration.

Related Persons

Collection of Personal Information

At times, we receive personal information about our personnel’s family members and other related persons in connection with emergency contacts and the benefits and services we provide, which may include:

• Contact Information: such as full name, email address, home address, business address, telephone number, and emergency contact information.
• Identification Materials: such as image, social security number, or other national identification number, passport number, driver’s license number, or vehicle license plate number.
• Benefits and Services Information: We also collect personal information necessary to extend benefits and benefit-related services, including date of birth, gender, insurance-related information, claims-related information, and disbursement-related information.

Although we often collect the personal information described above directly from our personnel, we also may collect this information directly from the related person, and from our benefit administrators. In addition, we may also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers.

Use of Personal Information

We use the personal information we collect about related persons to:

• Communicate about eligibility benefits and services, events or activities that are happening, or in the event of an emergency;
• Administer benefits and services;
• Respond to requests and inquiries;
• Conduct internal investigations, audits, compliance, risk management, problem resolution, and security operations;
• Fulfill contractual obligations; and
• Comply with applicable law, rule, regulation, legal proceedings, and government investigations, including relating to tax reporting and immigration.

Sensitive Information

We may process personal information about our personnel or our personnel’s family members and other related persons that is sensitive in nature and is subject to special protection under applicable law ("Sensitive Information"). This information may include social security number, driver’s license, state ID, passport number, financial account information for payroll purposes, information relating to racial and ethnic origin, citizenship or immigration status, religious, political or philosophical beliefs, trade union membership or information about your health, disabilities, sexual orientation, gender identity, and transgender status. We may also ask about your parental status and military status. We collect this information from a variety of sources, including directly from you, from our benefits administrators, our service providers, or other third parties that perform services on our behalf. We process this personal data for a variety of reasons. For instance, we may collect this information to understand our employee demographics and address EEO requirements.

Turtle Beach does not use or disclose Sensitive Information for any purpose other than for performing services that would reasonably be expected in the personnel context (such as managing personnel files, payroll and benefits), for detecting security incidents, fraud, and other illegal actions, or for short term transient use. Please refer to the Our Collection and Use of Personal Information section above to learn more about the types of personal information we collect.

Our Disclosure of Your Personal Information

We may share your personal information with the following third parties for the purposes described below:

• Within Turtle Beach: We share personal information relating to personnel and related persons within our family of companies for internal administrative purposes and uses that are consistent with this Privacy Notice. For example, the Turtle Beach entity responsible for payroll may receive personal information about personnel employed by another Turtle Beach entity in order to determine the proper compensation to be provided.
• Benefit Administrators: In order to provide our personnel and related persons benefits and services available to them, we share personal information with the third parties we engage to offer and administer the benefits and services on our behalf. These third parties may also collect additional personal information from you in connection with these benefits and services, which will be subject to the relevant third party’s own privacy policies and notices.
• Payroll and Tax Providers: We share personal information with third parties who assist us in processing our payroll and other compensation-related obligations, including our tax withholding and reporting obligations.
• Other Service Providers: In addition to the third parties identified above, we engage other third parties to perform certain functions on our behalf in connection with the uses of personal information described in the Our Collection and Use of Personal Information section above, including assisting us with our personnel management, benefits and services offerings and other related business operations. Depending on the function the third party serves, the service provider may process personal information on our behalf or have access to personal information while performing functions on our behalf.
• Public Disclosure: We may disclose certain personal information about our personnel, such as name, job title, work-related contact information and experience, publicly in connection with our recruiting and business operations.
• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
• Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
• in connection with the establishment, exercise, or defense of legal claims;
• to comply with laws and regulations or to respond to lawful requests and legal process;
• to protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
• to detect, suppress, or prevent fraud;
• to reduce credit risk and collect debts owed to us;
• to protect the health and safety of us, our customers, or any person; or
• as otherwise required by applicable law.
• Consent: We may disclose personal information about you to certain other third parties with your consent.

Retention of Personal Information

We retain personal information only for as long as is reasonably necessary to fulfil the purpose for which it was collected. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax, and accounting requirements set by a legislature, regulator, or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store the personal information and isolate it from further processing until deletion or deidentification is possible.

Your Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law):

The Right to Know	The right to confirm whether we are processing personal information about you and to obtain certain personalized details about the personal information we have collected about you, including: The categories of personal information collected; The categories of sources of the personal information; The purposes for which the personal information were collected; The categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information were disclosed; The categories of personal information shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for those purposes; and The categories of personal information sold (if any), and the categories of third parties to whom the personal information were sold.
The Right to Access & Portability	The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
The Right to Correction	The right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
The Right to Deletion	The right to have us delete the personal information we maintain about you, subject to certain exceptions.

You also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, please note that if the exercise of these rights limits our ability to process personal information, we may no longer be able to engage with you in the same manner.

How to Exercise Your Privacy Rights

To exercise your rights, please submit a request by:

• Emailing us at HR_Privacy@turtlebeach.com
• Completing our online form; or
• Calling us at (855) 254-9741.

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your employment. This process may require us to request additional personal information from you, including, but not limited to, your employee ID, department, date of hire.

In certain circumstances, we may decline a request to exercise the rights described above. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Turtle Beach does not sell your personal information to third parties or share your data for the purposes of targeted advertising. Moreover, Turtle Beach does not use or disclose your Sensitive Information except in the context of the employer-employee relationship, to fulfill our legal obligations, or with your consent.

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the California Consumer Privacy Act) to submit requests on your behalf where we can verify the authorized agent’s authority to act on your behalf. Note that for requests to know, delete, or correct personal information, we require the following for verification purposes: (a) a power of attorney valid under the laws of California from you or your authorized agent; or (b) sufficient evidence to show that you have (i) provided the authorized agent signed permission to act on your behalf, and (ii) verified your own identity directly with us pursuant to the instructions set forth in these CA Disclosures; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

Updates to This Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the "Last Updated" date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you through appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please contact Ashley Zimowski, Director, Human Resources (ashley.zimowski@turtlebeach.com) or Megan Wynne, General Counsel (megan.wynne@turtlebeach.com).