Privacy Policy

Privacy Policy

At Ternoa, we understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits the websites,, and (the “Ternoa Websites”) and only collect and use your personal data as described in this Privacy Policy. Any personal data we collect will only be used as permitted by applicable laws which are set forth in this Privacy Policy.

We recommend you to read this Privacy Policy carefully and ensure that you understand it. If you do not agree to the Privacy Policy you should stop using the Ternoa Websites immediately.

Information About Us

The Ternoa Websites are owned and operated by Capsule Corp, a simplified joint stock company (Société par actions simplifiée - SAS) under French law registered with the Bayonne Trade and Companies Register under the number 882 163 413, with its registered address located at Centre International d'Affaires 24 Boulevard Marcel Dassault 64200 Biarritz (France).

What Does This Policy Cover?

This Privacy Policy applies only to your use of the Ternoa Websites. The Ternoa Websites may contain links to third party websites. Please note that we have no control over how your data is collected, stored, or used by these third party websites and we strongly advise you to check the privacy policies of any such websites before providing any data to them.

What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the French Law No 78-17 of 6 January 1978 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name, address, phone number and other contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

Rights of Data Subjects

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details provided in this Privacy Policy.

  2. The right to access the personal data we hold about you. This Privacy Policy will tell you how to do this.

  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the link in section “How to contact us” to find out more.

  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the link in section “How to contact us” to find out more.

  5. The right to restrict (i.e. prevent) the processing of your personal data.

  6. The right to object to us using your personal data for a particular purpose or purposes.

  7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

  8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

  9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in this Privacy Policy.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the French Data Protection Authority - CNIL (Commission Nationale de l'Informatique et des Libertés).

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the CNIL. We would, however, welcome the opportunity to resolve your concerns ourselves. That is why we encourage you to contact us first, using the link in section “How to contact us”.

Depending upon your use of the Ternoa Websites, we may collect and hold your personal and non-personal data set out in the Privacy Policy. We do not collect any ‘special category’ or ‘sensitive’ personal data personal data relating to children data relating to criminal convictions and/or offences.

We may collect personal information about you either when you provide us with your personal information or through your use of our website.

Data you provide to us:

If you send us an email, we may collect your name, your email address, and any other information which you choose to give us. For the purposes of the Data Protection Legislation, We are the data controller responsible for such personal data.

We operate social media pages where you can get in touch with us either by directly messaging us or mentioning us in your posts. In such a case, we would see the data (including any personal data) you have decided to share with us. Depending on the medium, the personal information we might get about you could include, for example, your name, email address, where you work, job title or anything else.

When you contact us for help through the web forms on our Website we may collect certain information about you which directly identifies you. This information may include, name, email, address mail, or anything else you choose to share with us.

You may sign up for an account on the Ternoa Websites. We don’t, normally, ask for any personal information for your registration other than your email address. We may, thus, collect your personal information when you sign up on the Ternoa Websites.

Data we collect through your use of our Website

The Ternoa Websites collect certain information automatically, including your IP address, the type of browser you are using, and certain other non-personal data about your computer or device such as your operating system type or version.

We may also use cookies and other similar technologies (collectively “cookies”). These cookies may be used by us for analytics, performance, marketing purposes and other purposes. Cookies we use may be used to collect information about the use of our website, such as number of visits, pages visited, popularity of certain content, etc. More information about cookies can be found at a separate section within this Privacy Policy.

Lawful Basis of Processing

The Data Protection Legislation requires us to have a valid and lawful legal basis for processing personal data. We rely on the following legal basis:

The lawful basis under the Data Protection Legislation that allows us to use such information is article 6(1)(f) of the GDPR which allows us to process personal data when it is necessary for the purposes of our legitimate interests, in this case, the proper operation and functionality of the Ternoa Websites. If you contact us as described above, you will be required to consent to our use of your personal data to contact you. In this case, our lawful basis for using your personal data will be article 6(1)(a) of the GDPR, which allows us to use your personal data with your consent for a particular purpose or purposes. We may also rely on other legal bases such as Article 6(a)(b) and 6(1)(c) of the GDPR which allows us to use your personal information for the performance of a contract and for our legal obligations, depending on the circumstances.

How We Use Your Personal Data?

Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security please see section “How and Where Do We Store Your Data?”, below.

We will process your personal data in order to get back to you in order to answer your questions or feedback which we assume is the reason why you contact us using our email address, web forms or social media pages.

We will also process your personal data in order to provide you some of the services we offer on the Ternoa Websites. This is, especially, the case for (the “Ternoa Board”).

The reason for collecting technical data (including cookies) as referred to above is necessary for the technical operation of the Ternoa Websites and will not normally be used in any way to personally identify you and give you a better user experience on the Ternoa Websites.

We will not share any of your personal data with any third parties for any purposes other than storage of an email and/or web hosting server. We are relying on third-party service providers for these services. We make sure that these service providers are hosting your personal data within the European Economic Area (the “EEA”) which is considered a requirement under the GDPR.

How and Where Do We Store Your Data?

We will store your personal data within the EEA. The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, the GDPR, and/or to equivalent standards by law.

We may store some of your personal data in countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA and under the Data Protection Legislation as follows:

We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission. Otherwise, we will rely on standard contractual clauses approved by the EU Commission.

Personal data security is essential to us, and to protect personal data, we take the following measures:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the CNIL where we are legally required to do so;

  • We use Secure Sockets Layer (SSL) software to encrypt the information you enter on the Ternoa Websites in order to protect its security during transmission to and from the Ternoa Websites.

  • We use 2 Factor Authentication (2FA) for access to your account on the

Although we take all these security measures to ensure the safety and security of your personal data, you should note that no transmission over the Internet can ever be guaranteed to be secure. Consequently, we cannot fully guarantee the security of any personal information that you transfer over the Internet to us.

Do We Share Your Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

We are using third party service providers which may collect personal data of yours on our behalf (the “data processors''). They may have access to your personal information but we ensure that these service providers do not make use of your personal data for any secondary purposes other than our instructions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way that we have used it, as specified in this Privacy Policy (i.e. to communicate with you).

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “data subject access request”.

You can exercise your right to access your personal data by contacting us through any means. However, we would welcome any data subject access requests made in writing and sent to us via the link shown in section “How to contact us”. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 15 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.


We use cookies and similar technologies (collectively “cookies”) on the Ternoa Websites to distinguish you from other users. This helps us to provide you with the best possible experience while you are on the Ternoa Websites and also allows us to improve the Ternoa Websites and the services we are providing.

Cookies are small text files that are sent to your device (computer, tablet, smartphone, or another device) by the website you visit. Cookies are stored on your device (in your browser’s file directory) and are sent back by your browser to the website on each subsequent visit.

We use the following cookies on the Ternoa Websites:

How to Contact Us?

If you have any questions we would be happy to answer them. Do not hesitate to contact us for any inquiries you might have via this link.

Changes to Privacy Policy

We may change this Privacy Policy from time to time, at our sole discretion. This may be necessary, for example, in order to reflect changes in the laws and regulations, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on our Website and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Website following the alterations. We recommend that you check this page regularly to keep up-to-date.

This Privacy Policy was last updated on October, 22th 2022.

Last updated