Last updated: 10 September 2026
Privacy Policy
TernioX is a trading name of SIA MJ Management
Registered in Latvia, company number 40203768004
Ozolnieki, Latvia
This policy covers how we handle your personal information. Because our company is established in Latvia, we follow the EU General Data Protection Regulation (GDPR). Because we work with businesses in New Zealand, we also follow the Privacy Act 2020 and its Information Privacy Principles. Where the two differ, we apply whichever gives you more protection.
1. Information we collect
1.1 Information you give us
When you send our contact form, we collect your name, email address, business name and a short description of what your business does. You can also choose to give us your phone number, your current website address and anything you write in the message box.
If you email or call us instead, we collect whatever you choose to tell us, along with your email address or phone number.
1.2 Information collected automatically
Our host records standard server logs when any page is requested. These contain your IP address, the pages requested, the time of the request, and your browser and device type. They are generated by the web server and are not linked to you by name.
That is the complete list. We do not run analytics, and we do not track how you move around the site. See Section 6.
1.3 Client project information
If you go ahead with a build, we handle the business content you send us: logos, photographs, written copy, opening hours, and where you ask us to manage them, login details for platforms such as your Google Business Profile. We keep this confidential and use it only to do the work you asked for.
2. How we use your information
- To reply to your enquiry
- To design and build the free draft you asked for
- To discuss that draft with you and make changes
- To deliver, host and maintain your website if you go ahead
- To send invoices and process payments
- To send necessary messages about your account, project or plan
- To keep the site secure and working
- To meet our legal and tax obligations
We do not send newsletters and we do not use your details for marketing unless you separately ask us to.
3. How we share your information
3.1 Service providers
- Netlify — hosts this website and receives contact form submissions
- Our email provider — carries our replies to you
- Stripe — handles invoicing and card payments once you are a client. Your card details go directly to Stripe and are never seen or stored by us
Each of these receives only what it needs to do its job, and is required to handle it properly.
3.2 What we do not do
We do not sell, rent or trade your personal information. We do not pass it to advertisers or data brokers. We do not share it for anyone else’s marketing. There is no analytics provider and no advertising network in the list above because we do not use any.
3.3 Other disclosures
We may disclose information if the law, a court or a regulator requires it; where we need to protect our rights, property or safety or someone else’s; or if the business is sold, merged or restructured, in which case we will give notice where we can.
4. Our legal basis for using it
Under the GDPR we must tell you the lawful basis for each use.
- Steps taken at your request before a contract — replying to your enquiry and building your free draft
- Performance of a contract — building, hosting and maintaining your site once you go ahead
- Legitimate interests — responding to people who contact us on behalf of a business, and keeping our site secure. We have considered your rights and do not believe these uses override them
- Legal obligation — keeping accounting and tax records
Where we ever rely on consent, you can withdraw it at any time.
5. Sending information overseas
5.1 Where it goes
Our host operates internationally, so your enquiry may be stored or processed outside Latvia and outside New Zealand, including in the United States.
5.2 How it is protected
Where this involves transferring personal data out of the European Economic Area, we rely on the transfer safeguards our providers have in place, such as the European Commission’s standard contractual clauses. Under the New Zealand Privacy Act we take reasonable steps to ensure overseas recipients protect your information to a comparable standard.
6. Cookies and tracking
This site sets no cookies of its own. It runs no analytics, no advertising tags, no session recording, no remarketing and no tracking pixels. We do not store marketing attribution data in your browser. The fonts are served from our own domain rather than from a third party.
That is why you are not being asked to accept anything on this site.
If this changes — for example if we add analytics later — we will update this page first and, where the law requires it, ask for your consent before anything is set.
7. Data security
We protect personal information using encrypted connections (SSL/TLS across the whole site), reputable hosting, and limiting who can reach the data. No online system is completely secure and we cannot guarantee absolute security.
If a breach occurs that is likely to cause serious harm, we will notify the relevant regulator and the people affected, as both the GDPR and the New Zealand Privacy Act require.
8. How long we keep it
- Enquiries that do not become projects — 12 months, then deleted
- Client records — for the length of the relationship and 6 years afterwards, which is the period in which a claim could still be brought
- Billing and accounting records — 5 years after the end of the financial year, as Latvian accounting law requires
- Server logs — a short period, then rotated automatically by our host
You can ask us to delete your enquiry sooner, and we will, unless we are legally required to keep it.
9. Your rights
Under the GDPR you can ask us to:
- Give you a copy of the personal data we hold about you
- Correct it if it is wrong or incomplete
- Delete it
- Restrict what we do with it
- Send it to you, or to someone else, in a portable format
- Stop processing it where we rely on legitimate interests
Under the New Zealand Privacy Act you have the right to access the information we hold about you and to ask us to correct it.
Email info@terniox.com and we will respond within 20 working days, and in any case within one month. There is no charge, and we will not make it difficult.
10. Marketing communications
We do not run a mailing list. If that ever changes, you will have to opt in, and every message will carry an unsubscribe link.
Whatever you choose, we will still send necessary messages about your project, your plan or your invoices. Those are not marketing.
11. Other websites
This site links to other websites, including our own social media profiles. We are not responsible for how those sites handle your information. Check their policies before sharing anything with them.
12. Children’s privacy
Our services are aimed at businesses, not at children, and we do not knowingly collect information from anyone under 16. If you believe we have, contact us and we will delete it.
13. Changes to this policy
If we change how we handle your data, we will update this page and change the date at the top. For significant changes we will email active clients. We will not quietly broaden what we do with information you have already given us.
14. Contact us
Privacy questions or requests:
Email: info@terniox.com
Phone: 027 788 8304
Web: terniox.com/contact
15. Complaints
Please raise it with us first at info@terniox.com. We will look into it and respond within 20 working days.
If you are not satisfied, you can complain to a regulator. Which one depends on where you are, and you may go to either:
- Latvia and the EU — Data State Inspectorate (Datu valsts inspekcija), dvi.gov.lv
- New Zealand — Office of the Privacy Commissioner, privacy.org.nz