TERNA Systems AB Privacy Policy

1. Identity of the controller

TERNA Systems AB, Swedish company registration number 559453-1351, Vendevägen 89, Danderyd, Sweden, is the controller for the personal data processing described in this Privacy Policy, unless we expressly state otherwise or process personal data on behalf of a customer as processor.

2. How we obtain personal data

We may obtain personal data from the following sources:

• directly from you, for example when you contact us, fill in a website contact form, subscribe to a newsletter, request a demo, submit a support case, register for an event, provide a business card or communicate with TERNA representatives;
• from your company or the customer, partner, distributor or prospect that you represent;
• from Authorized Users, customer administrators, support contacts and other persons involved in the use, administration or support of TERNA products and services;
• from use of TERNA websites, Software, Connected Services and Support Services, including cookies, logs, diagnostics, telemetry, device information and usage information;
• from Authorized Partners, suppliers, event providers, business partners and service providers that assist us in providing, supporting or marketing TERNA products and services; and
• from public sources and third-party data providers where permitted by applicable law and relevant to business-to-business sales, marketing, compliance or customer administration.

3. Categories of personal data we process

Depending on your relationship with TERNA and how you interact with us, we may process the following categories of personal data:

• Business contact and account data: name, job title, role, employer, business address, business email address, business telephone number, country, language preference, user account details and account administration information.
• Contract, order and billing data: customer or partner relationship, product or service interest, quotations, order information, purchase history, invoice and payment administration data, support or warranty entitlement and related correspondence.
• Communication and support data: emails, meeting notes, support tickets, service requests, RMA information, training or event registrations, feedback, survey responses and information you provide to TERNA representatives.
• Website, cookie, device and network data: IP address, cookie identifiers, browser type, device identifiers, operating system, referral source, pages visited, interaction data, approximate location derived from IP address and security logs.
• TERNA3D™ product and service data: user identifiers, device identifiers, network identifiers, product serial numbers, Software and Firmware versions, support logs, error logs, diagnostics, telemetry, usage data, settings, system outputs, machine data, positioning data, RTK or correction-service metadata, cloud and file-handling metadata, project or machine metadata and similar technical information.
• Marketing and prospecting data: product interests, event participation, newsletter preferences, marketing consents or objections, communication preferences and business-development notes.
• Compliance and rights-request data: information needed to handle data-subject requests, legal claims, security incidents, sanctions or export-control checks, accounting obligations and other legal or regulatory requirements.

TERNA does not intentionally collect special categories of personal data through its websites, Software or Connected Services. Please do not provide such information unless specifically requested and legally permitted.

4. Purposes and legal bases

The list below summarizes the main purposes for which we process personal data and the legal bases we generally rely on. Where we rely on legitimate interests, we have assessed that the processing is proportionate, particularly because TERNA mainly processes business contact data in a professional context.

Business inquiries, sales and customer relationship management

Responding to contact forms, demo requests, questions, proposals and business communications. Legal basis: legitimate interests in managing business relationships and responding to requests; steps before contract where applicable.

Order administration and invoicing

Preparing quotations, administering order forms, providing products and services to your company, invoicing and managing payments. Legal basis: legitimate interests in fulfilling agreements with your company; legal obligations for accounting, tax and recordkeeping.

User account and access administration

Creating and managing user accounts, roles, credentials, customer administrators and access rights. Legal basis: legitimate interests in providing secure and controlled access; customer agreement where applicable.

Provision and operation of TERNA products and services

Providing and operating TERNA websites, Software, Hardware, Connected Services, RTK services, cloud services, file handling and web/mobile functionality. Legal basis: legitimate interests in providing and securing services; customer agreement; DPA where TERNA acts as processor.

Support, maintenance, diagnostics and RMA

Handling support cases, troubleshooting, remote diagnostics, warranty/RMA administration, service improvement and customer communications. Legal basis: legitimate interests in supporting customers and maintaining products and services; customer agreement; legal obligations where applicable.

Security, misuse prevention and compliance

Protecting systems, detecting unauthorized access, investigating incidents, enforcing terms, sanctions/export control checks and legal compliance. Legal basis: legitimate interests in security and compliance; legal obligations where applicable.

Product improvement, analytics and development

Analyzing usage, diagnostics, telemetry, errors and aggregated statistics to improve products, support, reliability, safety and performance. Legal basis: legitimate interests in improving TERNA products and services; DPA/customer agreement where TERNA acts as processor; consent where required.

Marketing, prospecting, newsletters and events

Informing you in your professional capacity about TERNA products, services, publications and events that may be relevant to you or your company. Legal basis: legitimate interests in business-to-business marketing; consent where required by law or chosen by TERNA.

Cookies and website analytics

Operating the website, measuring website traffic and improving website functionality. Legal basis: legitimate interests for strictly necessary/security cookies; consent where required for analytics or similar cookies.

Legal claims and corporate administration

Managing disputes, exercising legal rights, responding to authorities, audits, corporate transactions and internal governance. Legal basis: legitimate interests in legal and corporate administration; legal obligations where applicable.

5. TERNA3D™ Software, Connected Services and Support Services

TERNA3D™ Software, Connected Services and Support Services may generate or transmit diagnostics, telemetry, device identifiers, network identifiers, product serial numbers, Software and Firmware versions, support logs, machine data, positioning data, usage data and error data. TERNA may process such data for support, security, warranty, service delivery, product improvement, troubleshooting, legal compliance and continued supportability.

Some TERNA3D™ product and service data may not identify an individual. Where such data relates to an identified or identifiable individual, it is treated as personal data. Where such data forms part of Customer Data and TERNA processes it on behalf of a customer, the customer is responsible for determining the applicable legal basis, providing required notices and obtaining any required rights, permissions or consents. TERNA’s processor processing is governed by the applicable customer agreement and DPA where required.

TERNA may create and use aggregated or anonymized data derived from the use, operation or performance of its products and services for analytics, benchmarking, development, product improvement and other business purposes. Once data is irreversibly anonymized and no longer relates to an identifiable individual, it is not personal data.

6. Recipients and sharing of personal data

We share personal data only where necessary for the purposes described in this Privacy Policy and subject to appropriate safeguards. Recipients or categories of recipients may include:

• TERNA personnel, consultants and contractors who need access for their work and are subject to confidentiality obligations;
• Authorized Partners, distributors, installers, service partners and support partners involved in sales, installation, calibration, support, maintenance or customer administration;
• suppliers and service providers that provide hosting, cloud infrastructure, customer relationship management, support desk, ticketing, email, communication, analytics, security, accounting, invoicing, payment, travel, event or IT services;
• professional advisers, auditors, insurers, legal agents and collection agencies where necessary;
• customers, customer administrators or partners that authorized your access to TERNA products or services;
• public authorities, courts, regulators or law-enforcement bodies where required by law or necessary to protect our rights; and
• potential buyers, investors or advisers in connection with a merger, acquisition, financing, restructuring or transfer of all or part of TERNA’s business, subject to appropriate confidentiality and legal safeguards.

7. Transfers of personal data outside the EU/EEA

TERNA and its suppliers may process personal data in countries outside the EU/EEA. Where personal data is transferred outside the EU/EEA, TERNA relies on an applicable adequacy decision, including the EU-U.S. Data Privacy Framework where the recipient is certified, or on appropriate safeguards such as the European Commission’s Standard Contractual Clauses and supplementary measures where required.

You may contact us if you would like more information about the safeguards used for a specific transfer, subject to confidentiality and legal limitations.

8. Retention of personal data

TERNA retains personal data only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. The retention periods below are general principles and may be adjusted where necessary for legal claims, security, compliance, customer agreements or DPAs.

Business inquiries and contact forms

Retained for as long as needed to respond to the inquiry and for reasonable follow-up, or longer if a business relationship is established.

Customer, partner and supplier representatives

Retained during the relevant business relationship and thereafter as needed for administration, legal claims, audit and statutory limitation periods.

Order, invoice, accounting and payment data

Retained for the period required by applicable accounting, tax and bookkeeping laws and for related legal claim periods.

Support cases, service requests, warranty and RMA data

Retained during the customer relationship and as needed for support history, warranty handling, troubleshooting, product safety, service improvement and legal claims.

TERNA3D™ logs, telemetry, diagnostics and usage data

Retained as needed for support, security, warranty, service delivery, product improvement, lifecycle management and legal compliance, or as stated in the applicable customer agreement, DPA or Documentation.

Marketing and prospecting data

Retained until you object, unsubscribe or withdraw consent where consent is used. Limited information may be retained on a suppression or “do not contact” list to respect your preference.

Cookies and analytics data

Retained in accordance with cookie settings, analytics settings and applicable law. Google Analytics data is currently retained for up to fifty (50) months unless a shorter period is configured or stated in a cookie notice.

Data-subject requests, complaints, legal and compliance records

Retained as long as needed to handle the request, demonstrate compliance, establish, exercise or defend legal claims, and comply with legal obligations.

9. Marketing and prospecting

We may process personal data to inform you in your professional capacity about TERNA products, services, publications and events that may be relevant to you or your company. We may obtain such data directly from you, from your company, from events, from business partners, from public sources or from third-party data providers where permitted by applicable law.

Unless we expressly request consent, we generally rely on TERNA’s legitimate interests in business-to-business marketing. You can opt out of direct marketing at any time by using the unsubscribe link in marketing emails or by contacting us at contact@ternasystems.com. If you opt out, we may retain limited information on a “do not contact” list to ensure that your preference is respected.

10. Cookies and analytics

A cookie is a small text file stored on your computer or mobile device when you visit a website. Cookies may help the website remember your actions and preferences and may help us understand how our website is used.

TERNA uses cookies and similar technologies for website operation, security and analytics. We use Google Analytics to better understand website traffic and user interactions. Google Analytics may collect cookies, IP addresses, device and browser information, approximate location derived from IP address, app-instance identifiers where applicable and similar usage information. Google provides tools to disable Google Analytics measurement, and most browsers allow you to block or delete cookies.

Where consent is required for analytics or other non-essential cookies, TERNA will request consent before placing such cookies. You can control or delete cookies through your browser settings. If you block cookies, some services and functionalities may not work properly. If TERNA introduces additional cookies or similar technologies, such as marketing cookies, we will provide additional information and obtain consent where required.

11. Security

TERNA maintains appropriate technical and organizational measures designed to protect personal data under TERNA’s control against unauthorized access, loss, misuse, alteration and unlawful disclosure. Access to personal data is limited to persons who need access for the purposes described in this Privacy Policy. Where processing is performed by service providers, TERNA uses contractual and organizational safeguards appropriate to the processing.

Customers and Authorized Users are responsible for the security of their own systems, devices, networks, credentials, backups, access rights and user conduct, as further described in the applicable customer agreement and Documentation.

12. Your rights

Subject to applicable law and the circumstances of the processing, you may have the following rights regarding your personal data:

• the right to request access to personal data TERNA processes about you;
• the right to request correction of inaccurate or incomplete personal data;
• the right to request deletion of personal data in certain circumstances;
• the right to request restriction of processing in certain circumstances;
• the right to object to processing based on legitimate interests, including the right to object at any time to direct marketing;
• the right to data portability where the legal requirements are met; and
• the right to withdraw consent at any time where processing is based on consent, without affecting processing carried out before withdrawal.

These rights are not absolute. TERNA may need to continue processing certain personal data where required or permitted by law, including for legal obligations, security, freedom of expression and information, or the establishment, exercise or defense of legal claims. Limitation or deletion of personal data may also affect TERNA’s ability to provide products, services, support or communications.

To exercise your rights, contact us at contact@ternasystems.com. TERNA may need to verify your identity before responding to a request. If your request relates to personal data that TERNA processes on behalf of a customer as processor, TERNA may refer the request to that customer or handle the request in accordance with the applicable DPA.

TERNA does not use solely automated decision-making that produces legal effects concerning you or similarly significantly affects you, unless we expressly inform you otherwise.

13. Objections and complaints

If you have objections or complaints regarding TERNA’s processing of your personal data, please contact us first at contact@ternasystems.com so that we can review and respond to your concern.

You also have the right to lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY) or another competent data protection supervisory authority.

14. Changes to this Privacy Policy

TERNA may update this Privacy Policy from time to time to reflect changes in our processing, products, services, legal requirements or business operations. The current version will be made available on TERNA’s website. This Privacy Policy was last amended on July 1, 2026.