Privacy Policy
Effective date: [EFFECTIVE_DATE — set before publishing]
This policy explains how Tervano ([LEGAL_ENTITY_NAME]) handles personal data when you visit our website, when a dealership uses the Tervano platform, and when a dealership’s customer exchanges messages through it. It is designed with the EU General Data Protection Regulation (GDPR) and Irish ePrivacy requirements in mind. It has not yet been reviewed by a qualified data protection professional or lawyer — that review is planned before this policy is treated as final and legally binding. Nothing on this page should be read as a certification of legal compliance.
Who this applies to, and in what role
Tervano is a software platform that dealerships (our customers) use to manage their own customers’ vehicle enquiries. This creates two distinct roles under data protection law:
- Tervano as a data controller for account and billing data relating to the dealership and its team members who use Tervano directly — for example, sign-up details, login activity, and subscription information.
- Tervano as a data processor for the personal data of a dealership’s own customers — names, contact details, vehicle enquiries and conversation content — which the dealership controls and is responsible for under its own privacy notice to its customers. We process this data only on the dealership’s instructions, as set out in our Data Processing Agreement.
What we collect
From dealership accounts and team members
- Name, email address, phone number, and role within the dealership
- Login and authentication data (via Supabase Auth)
- Dealership details: name, address, business hours, description
- Billing information, handled by our payment processor (Stripe) — we do not store full card details
- Support requests and correspondence with us
From a dealership's customers, on the dealership's behalf
- Name, email address, and phone number provided in a vehicle enquiry
- The content of conversations between the customer and the dealership (including AI-assisted messages)
- Appointment details (viewings, test drives, calls)
- The source of the enquiry (e.g. website, Facebook, WhatsApp)
Automatically, from anyone visiting our website
- Necessary cookies required for the site and account sign-in to function — see our Cookie Policy
- Analytics cookies, only if you consent to them via our cookie preferences
How we use personal data
- To provide, operate and maintain the Tervano platform for dealership accounts
- To enable AI-assisted responses to a dealership’s customer enquiries, using the dealership’s own vehicle and business information as context
- To send account, billing and service-related communications
- To respond to demo requests and support enquiries
- To maintain the security and integrity of the platform, including preventing abuse
- Where you have consented, to understand website usage through analytics
We do not sell personal data. We do not use a dealership’s customer data to train AI models, and we do not share it with other dealerships.
Legal basis for processing (EU/EEA users)
Where GDPR applies, we rely on: performance of a contract (providing the service a dealership has signed up for); legitimate interests (securing the platform, preventing abuse, improving reliability); consent (analytics cookies, and any marketing communications); and legal obligation (e.g. tax and accounting records). The dealership, as controller of its own customers’ data, is responsible for identifying the correct legal basis for its own collection and use of that data (typically consent or legitimate interest in responding to a sales enquiry) — this is addressed further in our Data Processing Agreement.
AI processing
When AI-assisted responses are enabled, a customer’s message and relevant dealership/vehicle information are sent to a third-party AI provider (Anthropic and/or OpenAI, depending on the dealership's configuration) to generate a reply. These providers process this data under their own data processing terms and do not use it to train their models when accessed through their business/API offerings. See our Subprocessors page for details.
Subprocessors and international transfers
We use a small number of subprocessors to run Tervano — see the full, current list on our Subprocessors page. Where a subprocessor is located outside the EU/EEA, we rely on the safeguards that provider makes available (such as the EU Standard Contractual Clauses) to ensure an adequate level of protection for any transferred data.
Retention
We retain dealership account data for as long as the account is active, and for a reasonable period afterward to meet legal, accounting, and dispute-resolution obligations. A dealership’s customer data (leads, conversations, appointments) is retained according to the dealership’s own settings and instructions, since the dealership controls that data; on request, we will assist a dealership in deleting or exporting it.
Your rights
Depending on your location, you may have the right to access, correct, delete, restrict, or port your personal data, and to object to certain processing. If your enquiry relates to a specific dealership’s use of Tervano, we may need to direct your request to that dealership, since they control that data. To exercise a right regarding your own Tervano account, contact us at privacy@tervano.ie.
You also have the right to lodge a complaint with a supervisory authority — in Ireland, the Data Protection Commission (Ireland) — dataprotection.ie.
Security
Dealership data is isolated at the database level so one dealership can never access another’s records. Access to production systems is restricted, and passwords are never stored in plain text. No system is completely secure, and we cannot guarantee absolute security, but data protection is treated as a design requirement, not an afterthought.
Children
Tervano is a business-to-business platform and is not directed at, or knowingly used by, children.
Changes to this policy
We may update this policy as the product changes. Material changes will be reflected by updating the effective date above.
Contact
[LEGAL_ENTITY_NAME] · [REGISTERED_ADDRESS]
Privacy queries: privacy@tervano.ie