Tercumer Ltd - Privacy Policy

1. INTRODUCTION AND SCOPE

Tercumer Ltd (“we,” “our,” or “us”). We operate a web-based search platform (the “Service”). We understand the importance of privacy and are committed to being transparent about the data we collect, how it is used, and the options available to you. This policy applies to all users and covers information gathered when you visit any domain or subdomain (e.g., secure.tercumer.com), use our browser extensions, or access our mobile applications.

Jurisdiction and Governing Law. Our headquarters and data processing facilities are located in Ludlow, Shropshire, United Kingdom. By accessing or using our Service from any location, you consent to the transfer, storage, and processing of your information in the UK and any other jurisdiction where our vendors operate. All aspects of this policy and your use of our Service are governed by the laws of England and Wales.

Age Restriction. Our Service is not intended for children under 16. We do not knowingly collect personal data from anyone under 16 without parental consent. If you are under 16, please do not use or provide information to our Service.

External Links. Our Service may contain links to third-party websites, advertising networks, or social media platforms. We do not control those sites and are not responsible for their privacy practices. We encourage you to review the privacy policies of any external websites you visit.

2. DATA WE COLLECT AND HOW WE USE IT

We collect and process the following categories of information when you engage with our Service:

IP Address

Your IP address is logged automatically when you visit our Service. We use it to:

• Customise search results and advertisements based on your region.
• Detect and prevent fraudulent or malicious activity.
• Generate aggregated analytics for performance monitoring.

Device and Browser Information

We record details such as your browser type, screen resolution, and operating system through server logs and cookies in order to:

• Optimise the layout and functionality of our Service on different devices.
• Troubleshoot and diagnose technical issues.
• Monitor overall usage patterns to improve usability.

Unique Browser Identifier

When you arrive at our Service, a unique identifier (cookie ID) is generated and stored in your browser. This allows us to:

• Recognise repeat visits and preserve your language or theme preferences.
• Enable interest-based advertising and measure ad performance.

Search Queries and Interaction Data

Whenever you perform a search or click on results, we log:

• The query terms you enter.
• The results you select.
• The referring page or source (if applicable).

This information helps us:

• Refine and rank search results for relevance.
• Measure popular search trends and user engagement.
• Improve the accuracy and speed of our Service.

Cookies, Pixels, and Similar Technologies

We and our authorised partners place cookies, web beacons, and similar tools on your device to:

• Deliver personalised advertisements based on browsing behaviour.
• Retarget users who have previously visited our pages.
• Measure the effectiveness of ad campaigns.

Support Inquiries

When you submit a message via our contact or support forms, we collect:

• Your name and email address (if provided).
• The content of your request or feedback.

We use this information to:

• Respond to technical or account-related questions.
• Maintain a record of communications for quality assurance.

3. THIRD-PARTY SHARING AND ACCESS

We do not sell your personal data to unaffiliated third parties. However, to operate and enhance our Service, we may share certain information with:

• Hosting and Infrastructure Providers: Companies that manage our servers and network operations.
• Analytics and Monitoring Services: Partners that aggregate usage metrics and performance data.
• Advertising Networks: Third parties that assist in serving targeted ads and measuring ad reach.
• Customer Support Platforms: Vendor platforms (e.g., helpdesk software) that facilitate issue tracking and resolution.

All third-party partners are bound by contractual obligations to use data only for the purposes we authorise. We also implement encryption and access controls to ensure that your information remains protected while in transit and at rest.

4. REGIONAL PRIVACY PROVISIONS

A. EEA (excluding UK)

i. Lawful Processing

If you access our Service from within the European Economic Area (EEA), we rely on one or more of the following legal bases to process your personal data:

• Contractual Necessity: To deliver the core search functionality and associated features you actively choose to use, as part of fulfilling our service agreement with you.
• Legitimate Interests: For security monitoring, service optimisation, and prevention of fraud.
• Consent: When we place non-essential cookies or use tracking technologies for analytics or marketing. You may withdraw consent at any time via our Cookie Preference Centre or your browser settings.
• Legal Obligation: To comply with applicable laws, respond to valid legal requests, or enforce our rights.

ii. Cookies and Tracking

We and our authorised partners use cookies and similar technologies on EEA users’ devices to:

• Remember your language preference, theme choice, and other settings.
• Collect aggregated statistics on Service usage (e.g., Google Analytics).
• Deliver personalised ads and measure their performance.

To manage or opt out of non-essential cookies, visit our Cookie Preference Centre or adjust your browser settings. Disabling certain cookies may limit functionality.

iii. User Rights

Under GDPR, EEA residents have the following rights regarding their personal data:

• Right of Access: Request a copy of personal data we hold about you.
• Right to Rectification: Ask us to correct any inaccurate or incomplete information.
• Right to Erasure (“Right to Be Forgotten”): Request deletion of personal data when it is no longer needed, or if you withdraw consent (subject to legal exceptions).
• Right to Restrict Processing: Request that we limit how we use your data (e.g., during dispute over accuracy).
• Right to Data Portability: Request transfer of your data to another provider or controller in a structured, machine-readable format.
• Right to Object: Object to processing based on legitimate interests or direct marketing, including profiling.
• Right to Withdraw Consent: If our processing is based on consent, you may withdraw it at any time without affecting prior processing.

To submit any of these requests, see Section 5 below.

B. United Kingdom

i. Data Handling under UK GDPR

For users in the United Kingdom, we process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We rely on the following lawful bases:

• Performance of a Contract: To provide the search services and related features you have requested, ensuring the service operates as expected under our agreement with you.
• Legitimate Interests: To secure our Service, prevent fraud, and improve functionality.
• Consent: For non-essential cookies or marketing purposes. You may withdraw consent at any time via our Cookie Preference Centre or your browser settings.
• Legal Obligation: To comply with UK law, respond to lawful requests, or enforce our rights.

ii. UK Data Subject Rights

Under UK GDPR, UK residents have the following rights:

• Right of Access: Obtain a copy of personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure: Ask us to delete your personal data when it is no longer necessary or if you withdraw consent (subject to legal exceptions).
• Right to Restrict Processing: Ask us to limit how we use your data (e.g., during a dispute over accuracy).
• Right to Data Portability: Request transfer of your data to another controller in a structured, machine-readable format.
• Right to Object: Object to processing based on legitimate interests or for direct marketing, including profiling.
• Right to Withdraw Consent: You may withdraw consent at any time without affecting processing prior to withdrawal.

To submit any of these requests, see Section 5 below.

5. EXERCISING YOUR RIGHTS

To exercise any of the rights described above, please send an email to [email protected] with “Privacy Request” in the subject line. In your message, include:

• Your full name.
• The email address you used to interact with our Service (if applicable).
• A clear description of the specific right(s) you wish to exercise (e.g., “I would like to access my personal data,” or “Please delete all personal data you have about me”).
• If you are a UK or EEA resident, confirm your region so we can honour the appropriate legal framework.
• Any documentation required to verify your identity (for instance, a copy of a photo ID) or to clarify your request.

We will acknowledge receipt of your request within 10 business days and aim to fulfil verifiable requests within one month. If we require additional time or information to process your request, we will notify you and provide an estimated resolution date.

6. PRIVACY PREFERENCES

6.i. Cookies & Tracking

Our Service uses cookies, web beacons, pixel tags, and similar mechanisms to:

• Keep you signed in and preserve your language and display preferences.
• Track which pages are most frequently visited and measure feature usage.
• Support fraud detection, security monitoring, and load balancing.
• Serve personalised advertisements and measure their performance.

You can manage or disable non-essential cookies through our Cookie Preference Centre (link in the footer) or via your browser’s privacy settings. Disabling certain cookies may limit or disable some features of our Service.

6.ii. Email Communications

We may send you transactional emails (e.g., support confirmations, Service notifications). If you receive marketing or promotional emails from us, you may opt out by clicking the “Unsubscribe” link contained in any such email. Alternatively, email us at [email protected] with “Unsubscribe” in the subject line. Please allow up to 10 business days for processing.

6.iii. Do Not Track Signals

Our Service does not currently honour “Do Not Track” (DNT) signals from your browser. We recommend managing your tracking preferences through our Cookie Preference Centre or your browser settings.

7. DATA STORAGE AND TRANSFERS

All personal data collected through our Service is hosted, stored, and processed on servers located in the United Kingdom. By using our Service, you consent to the transfer, storage, and processing of your information in the UK and any other jurisdiction where our vendors operate. UK data protection laws may differ from those in your country of residence; however, we implement contractual, technical, and organisational safeguards (see Section 9) to maintain data security.

8. NON-DISCRIMINATION & GRIEVANCE PROCEDURES

8.i. Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights under applicable laws. You will not be denied access, charged differently, or provided a lower quality of service because you exercise a right described in this Privacy Policy.

8.ii. Filing a Complaint

If you have questions or disputes regarding how we handle your personal data, contact us at [email protected]. We will investigate and address your concerns promptly and transparently.

• EEA Residents: You may lodge a complaint with your local Data Protection Authority if you believe we have violated applicable data protection laws.
• UK Residents: You may complain to the Information Commissioner’s Office (ICO) if you believe we have breached UK data protection law.

9. DATA RETENTION & SECURITY PRACTICES

9.i. Retention Policies

We retain personal data only as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. Specifically:

• Search Logs & Interaction Data: Retained for up to 24 months to analyse trends, prevent abuse, and improve search relevance.
• Cookies & Identifiers: Persist for up to 12 months, unless deleted earlier.
• Support Tickets & Correspondence: Retained for 5 years to maintain a record of enquiries and provide ongoing assistance.
• Other Personal Data: Kept only as long as required to provide services, comply with legal obligations, or support legitimate business needs (e.g., fraud prevention).

When data is no longer needed for its intended purpose, we securely delete or anonymise it in accordance with industry best practices.

9.ii. Security Measures

We employ administrative, technical, and physical safeguards to protect your personal data from unauthorised access, disclosure, alteration, or destruction. Key measures include:

1. Encryption: All communications between your browser and our servers are encrypted using TLS (HTTPS). Sensitive data (e.g., support requests containing account credentials) is encrypted at rest.
2. Access Controls: Access to production systems and databases is restricted to authorised personnel on a need-to-know basis. Employees undergo regular security training.
3. Secure Development Practices: Our engineering teams follow a secure software development lifecycle (SSDLC), including code reviews, static/dynamic analysis, and periodic penetration testing. Critical vulnerabilities are addressed within 30 days or sooner.
4. Monitoring & Incident Response: We maintain intrusion detection systems and have an incident response plan. In the event of a data breach, we will notify affected individuals and regulatory authorities as required by law.
5. Vendor Oversight: Third-party vendors with access to personal data are contractually obliged to maintain equivalent security standards. We conduct due diligence and periodic audits to ensure compliance.

While we strive to protect your information, no system is entirely impervious. If we discover a breach that affects your personal data, we will notify you and take steps to mitigate potential harm.

10. POLICY REVISIONS & CONTACT

We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or Service enhancements. The “Effective Date” at the top indicates when it was last revised. If we make significant changes, we will post a prominent notice on tercumer.com. Your continued use of the Service after any update constitutes your acceptance of the revised policy.

If you have questions, concerns, or requests regarding this Privacy Policy, please feel free to contact us:

Email: [email protected]
Mailing Address:
Tercumer Ltd.
17 Tower St, Ludlow, Shropshire
Ludlow, SY8 1RL
United Kingdom

Thank you for trusting Tercumer Ltd. We remain committed to respecting and protecting your privacy.