Last Updated: 14.12.2025

This Privacy Notice explains how Turgiene Group LLC (“Company,” “we,” “us,” “our”) collects, uses, discloses, retains, and protects personal information when you apply to join our creator community as a UGC Creator and/or Product Tester (the “Program”) through our online application form (the “Application”). 

This notice applies to information we collect through the Application (e.g., Google Forms or similar form tools), our ads on Meta (Instagram/Facebook) and TikTok, and our websites/landing pages that link to the Application.

This Notice is intended to comply with applicable U.S. state privacy laws, including the California Consumer Privacy Rights Act (CPRA) and New Jersey Data Privacy Act (NJDPA). If you are accepted into the Program, additional agreements and disclosures may apply. 

1. Categories of Personal Information We Collect

We collect the following categories of personal information, as defined under the California Consumer Privacy Rights Act (“CPRA”):

A. Information You Provide Directly

• Identifiers: Name, email address

• Demographic Information: Age range

• Social Media Information: TikTok and Instagram usernames

• Creator Information:

• UGC experience

• Types of videos you can create

• Product categories of interest

• Optional information you choose to share in free-text fields

B. Information Collected Automatically

When you access or submit the Application, we and our service providers may automatically collect:

• Internet or Network Activity: IP address, browser type, device information

• Log Data: Submission timestamps, referral URLs, system logs

• Approximate Location: Derived from IP address

• Advertising & Attribution Data: Interaction with ads, campaign performance data

C. Sensitive Personal Information

We do not intentionally collect Sensitive Personal Information (as defined by CPRA).
Please do not include sensitive information (e.g., health data, precise location, government identifiers) in optional fields.

2. Purposes of Collection and Use 

We collect and use personal information for the following business and commercial purposes:

• Reviewing and evaluating Applications

• Contacting applicants regarding application status and creator opportunities

• Administering and managing the Program

• Matching creators with campaigns and products

• Preventing fraud, abuse, and unauthorized access

• Maintaining security of our systems

• Measuring and optimizing advertising performance on Meta and TikTok

• Complying with applicable laws and legal obligations

• Recordkeeping, audits, dispute resolution, and enforcement of legal rights

3. Purposes, Use & Categories Table 

4. Disclosure of Personal Information

We may disclose personal information to the following categories of recipients:

A. Service Providers: Including providers of

• Form and survey tools

• Cloud hosting and IT services

• CRM and email communication tools

• Analytics and attribution services

• Security and fraud prevention services

Service providers are contractually restricted to using personal information only to perform services on our behalf.

B. Advertising Platforms: We may share limited data with Meta and TikTok for advertising measurement and attribution.

C. Legal and Business Disclosures: We may disclose information:

• To comply with legal obligations or government requests

• To protect our rights, users, or property

• In connection with a merger, acquisition, or sale of assets

5. Sale or Sharing of Personal Information 

• We do not sell personal information for monetary consideration.

• We may share certain information (such as online activity or ad interaction data) with advertising platforms for cross-context behavioral advertising, which may constitute “sharing” under CPRA.

• California residents have the right to opt out of such sharing.

6. Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Notice, unless a longer retention period is required or permitted by law.

7. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, loss, or misuse. However, no system can be guaranteed to be 100% secure.

8. International Transfers

Your personal information may be processed and stored outside the United States by our service providers. We take reasonable steps to ensure appropriate safeguards are in place for such transfers.

9. Children’s Information

The Application is not intended for individuals under 16 years of age. We do not knowingly collect personal information from minors.

10. California Privacy Rights (CPRA)

If you are a California resident, you have the right to:

• Know / Access the personal information we collect about you

• Delete personal information, subject to legal exceptions

• Correct inaccurate personal information

• Opt Out of the sale or sharing of personal information

• Limit the use of sensitive personal information (where applicable)

• Non-Discrimination for exercising your rights

Exercising Your Rights: You may submit a request by contacting us at info@turgiene.com. We will verify your request and respond in accordance with applicable law.

11. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. The updated version will be posted with a revised “Last Updated” date.

12. Contact Information

Turgiene Group LLC
730 Madison Ave, Paterson, NJ 07501, USA
Email: info@turgiene.com