Last updated 5 October 2026

Privacy policy

This privacy policy explains how TERVRA LIMITED handles personal data collected through the website at https://tervra.xyz. It is written for people who read the site, send an enquiry, or load the optional map on the contact page. It is a description of this website. It is not a description of every system TERVRA might later build for a client, and it is not a privacy notice for a product that a client operates.

TERVRA LIMITED is the controller for personal data processed through this website. The company can be reached at 108 Fonthill Road, London, N4 3HT, United Kingdom, by email at general@tervra.xyz, and by telephone on +44 7399 204815. No data protection officer is named on this website, because none has been published. Privacy requests can be sent to the same email address.

The policy is meant to be read with the cookie policy, the terms of service, and the terms and conditions. Those documents cover use of the site and the difference between an enquiry and a contract. This document covers personal data.

What this policy covers

The website is a set of pages about TERVRA LIMITED’s engineering practice: custom software, computer systems design, cloud and web hosting infrastructure, data processing and analytics, financial technology platforms, credit intermediation systems, investment and brokerage software, high-load databases, enterprise API integration, cybersecurity and data protection measures, IT consulting, and system maintenance and monitoring. The pages include a contact form on the index and on the contact page, and a map that loads only if a visitor asks for it.

Personal data means information that relates to an identified or identifiable person. A name and an email address in a form are personal data. An IP address can be personal data when it can be tied to a person. The contents of a message are personal data when they are about the sender or about someone else the sender mentions.

This policy covers data TERVRA receives because someone uses the website. It does not cover data that a client later places inside a system TERVRA builds under a separate written agreement. That later processing, if it happens, has to be described in that agreement. Sending a form is not that agreement.

The site is aimed at organisations that need engineering work. A person might still write in their own name, as a founder, an employee, or an adviser. The policy applies to that person. It also applies, so far as the law requires, to anyone else who is identifiable from what the sender chooses to include.

The short account

If you do nothing but read the pages, the site itself is built not to set a cookie and not to run an analytics product. The server that hosts the site may still keep a technical log. If you send the form, TERVRA receives your name, email address, and message, and the email that arrives also includes the IP address and the time of the submission so the message can be told apart from abuse. If you press “Show the map” on the contact page, your browser then loads OpenStreetMap, which is a separate organisation. If you never send the form and never open the map, the personal data the website asks you for is none.

TERVRA does not sell personal data, does not run a mailing list from this site, and does not use the form to make automated decisions about credit, insurance, or employment. A reply, if one is sent, is written by a person or prepared for a person to send. There is no score and no profile built for advertising.

The contact form

The form appears at the end of the homepage and again on the contact page. Both forms post to contact.php. The fields are name, email, and message. All three are required. The name is limited to 120 characters, the email to 160 characters, and the message to 5000 characters. There is also a hidden field that must be left blank. That field is a trap for automated submissions. People using the site normally never see it, and it is hidden from assistive technology. If it is filled, the submission is discarded and is not treated as an enquiry.

Before a message is accepted, the server checks that the form was posted from this site, that the email address has the shape of an email address, and that the name and message are not empty. It also limits how many validated attempts can come from one IP address in an hour. Those checks exist to reduce abuse. They are not a credit check and they are not a decision about whether TERVRA will take on work.

If the checks pass, the server tries to send an email to general@tervra.xyz. The email contains the name, the email address, the message, the IP address seen by the server, and the time in UTC. The visitor’s email address is placed in the reply-to header so a human reply can go back to that address. If the server’s mail function does not accept the message, the site shows an error and does not show the thank-you page. A failed attempt is not described as a successful delivery.

The thank-you page is shown only after the mail function reports that it accepted the message for delivery. Acceptance by the mail function means the server handed the message to its mail transport. It does not prove that a person has read it, and it does not prove that a project will follow.

You should write the message as if it will be read by the people who handle general@tervra.xyz. Do not send passwords, payment card numbers, national identity numbers, or special-category data. Special-category data includes information about health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data used for identification, sex life, or sexual orientation. The form does not ask for any of that. If you include it anyway, you do so without being asked, and TERVRA may delete it rather than store it as part of an ordinary enquiry.

Do not use the form to send personal data about your own customers, borrowers, investors, or employees unless you have a lawful reason to send it and the message is limited to what is needed to describe the engineering problem. A first enquiry rarely needs a live customer file. A description of the system is enough.

Information you give in other ways

You may email general@tervra.xyz directly, or you may call +44 7399 204815. Those channels are not the website form, but they reach the same company. An email you send yourself contains whatever you put in it, plus the technical headers your mail provider adds. A telephone call is not recorded by any system described on this website. This policy does not claim that a telecoms provider keeps no records of its own. TERVRA’s published practice is to use the content of a call or an email to answer the enquiry and, where needed, to keep a business record of the correspondence.

If you write about another person, you are responsible for having a proper reason to share their information. TERVRA cannot see, from the website, whether you have that reason. The practical request is simple: keep other people’s data out of the first message.

Technical logs

A website is served by a computer. The operator of that computer commonly keeps logs so the site can be kept available and so abuse can be investigated. Those logs can include the IP address of the requesting device, the date and time, the address of the page requested, the status code, the amount of data sent, and the user-agent string, which describes the browser and often the operating system. They can also include the referring address if the browser sent one.

This policy does not name a hosting company, a data-centre address, or a log-retention period in days, because those operational facts are not published with the company information on this site. What is stated is the purpose: logs of this kind are used to deliver the pages, to keep the service working, and to look into misuse such as attempts to flood the form. They are not used on this website to build advertising profiles, and they are not joined to an analytics product, because no analytics product is embedded.

If a log line can be linked to an enquiry, for example because the same IP address appears in the enquiry email, TERVRA may look at both when dealing with abuse or with a privacy request. That comparison is occasional. It is not a standing profile of visitors.

The map on the contact page

The contact page shows the address 108 Fonthill Road, London, N4 3HT. A map is available, but the page does not load it immediately. A visitor who wants the map presses “Show the map”. Only then does the browser request an embedded map from OpenStreetMap. OpenStreetMap is run by other people. Once the frame loads, OpenStreetMap receives the technical data that a browser normally sends with a page request, which can include the IP address, and it may set its own cookies. TERVRA does not operate those cookies and does not receive a copy of OpenStreetMap’s cookie store.

If you do not press the button, that request is not made from the contact page as published. You can also find the address without the map, because the street, the postcode, the city, and the country are written on the page. The cookie policy explains this choice in more detail, including how browser controls interact with a map you have chosen to load.

Fonts, and tools the site does not use

The typefaces on the site, Anek Latin and Ubuntu Sans, are files served from tervra.xyz itself. Reading a page does not require a request to a third-party font service. The site does not embed advertising, social-media pixels, session-replay scripts, or a tag manager. It does not ask you to create an account. There is no shopping cart and no payment page. There is no newsletter signup.

The pages do link to telephone and email, and they link between themselves. Following a mailto link opens whatever mail program you use. Following a tel link opens whatever calling program you use. Those programs are yours. This policy does not control them.

If a future version of the site adds a tool that collects personal data in a new way, this policy will need to change before or at the time that tool starts. The current text should be read as a description of the site as published on the date at the top, not as a promise that the site will never change.

Purposes

Enquiry data is used to read what you sent, to decide whether a reply is appropriate, and to send that reply if one is sent. It is used to keep a record of the correspondence so that a later message can be understood in context and so that TERVRA can show what was said if a question arises about the enquiry. It is used to protect the form against automated abuse, which is why the IP address and the time travel with the email and why repeated validated attempts from one address are limited.

Technical logs are used to operate the website and to investigate faults and misuse. Map requests, once you make them, are used only to show you the map. TERVRA does not use the map interaction as a marketing signal.

TERVRA does not use website data to train a public model, to sell a list, or to enrich an advertising audience. If a written service agreement later requires processing of personal data inside a client system, that processing is outside these purposes and must be defined in that agreement. The purposes in this policy are the purposes of the website.

Legal bases

Under the UK General Data Protection Regulation, a controller needs a lawful basis for each purpose. For the contact form, two bases are relevant, and which one fits depends on the message.

Where you write in order to ask about work that might become a contract, the processing of the enquiry is a step at your request before entering a contract. That is the basis in Article 6(1)(b). It covers reading the message, replying, and keeping the thread while the possible contract is being considered. It does not cover using the message for an unrelated promotion.

Where the message is a general question, a correction, a complaint about the website, or a privacy request, or where TERVRA keeps a short record after the conversation has ended so that it can answer a follow-up or show what was received, the basis is legitimate interests under Article 6(1)(f). The interest is in running a business correspondence, answering people who choose to write, and protecting the site from abuse. That interest is weighed below.

Abuse controls, including the rate limit and the recording of the IP address inside the enquiry email, also rest on legitimate interests: keeping the mailbox usable and reducing fraudulent or mechanical submissions. The same interest supports looking at server logs when something is wrong with the site.

A legal obligation, Article 6(1)(c), is not the everyday basis for the form. It can become relevant if the law requires TERVRA to keep or disclose a particular message, for example because a court or a regulator with power over the company orders it. This policy does not invent a standing statutory retention period for ordinary enquiries.

Consent is not the basis for the form. The form is how you ask to be contacted about your message. You are not asked to tick a box that pretends to authorise a wider use. You can still object to processing that is based on legitimate interests, as described later. Loading the map is a choice you make by pressing the button. That choice is about fetching third-party content. It is not used as consent for TERVRA to start a mailing list.

Legitimate interests

Where legitimate interests is the basis, the interest has to be real, the processing has to be necessary for it, and it has to not be overridden by your interests or rights. The interest here is ordinary and limited: to receive business enquiries, to answer them, to remember what was asked, and to stop the form being used as a funnel for abuse. The processing is the storage of the message in the mailbox, the use of the IP address and timestamp for that message, and the use of technical logs to run the site.

The data is the data you chose to send, plus the technical data a web request always carries. It is not a scrape of your other activity. The effect on you is that a small number of people who handle the mailbox can read what you wrote, and that a hosting environment may hold a log line. You can write without using the form, by email or telephone, if you prefer those channels. You can ask for deletion, and the request will be handled as described under your rights. Taken together, the interest in answering and protecting a simple enquiry channel is not overridden by the impact of holding that enquiry.

This balancing is about the website. It is not a balancing exercise for a client database, a credit file, or an investment record. Those would be different facts and would need their own analysis inside the relevant agreement.

How long information is kept

There is no single number of months printed here, because an enquiry is not one kind of thing. A short question that needs no reply beyond an acknowledgement is not the same as a thread that becomes a contract discussion, and neither is the same as a message that has to be kept because of a legal claim. Publishing one fixed period would either be too short for a real business record or too long for a trivial note, and it would pretend to a rule the company has not stated as an operational fact.

What is stated is the approach. Enquiry correspondence is kept for as long as it is needed to handle the enquiry and a reasonable record of that business conversation. When it is no longer needed for that purpose, and no legal reason requires it to be kept, it should be deleted or put beyond ordinary use. You may ask for deletion at any time. The request can be refused only where a specific reason remains, and that reason should be explained to you rather than hidden behind a slogan.

Server logs follow the hosting environment’s ordinary rotation. This policy does not publish that rotation as if it were a number TERVRA had chosen in this document. If you need to know what still exists about a particular visit, ask. If the log has already rotated away, the honest answer is that it is gone.

Rate-limit records used by the form are technical timestamps kept so that a burst of submissions can be slowed. They are not a marketing history. They live in a temporary file on the server and are pruned to the recent hour of activity as the script runs. They are not the enquiry itself.

Who receives personal data

The enquiry email is addressed to general@tervra.xyz. The people who can open that mailbox can read it. The provider that hosts the mailbox processes the message in order to deliver and store mail. The provider that hosts the website processes requests and logs in order to serve the pages and run contact.php. This policy does not name those providers, because the company information published for the site does not name them. They are not appointed in this document as if a contract with a named brand had been described here.

TERVRA does not sell the form data and does not pass it to advertisers. A professional adviser, such as a lawyer or an accountant, might see a message if a real dispute or a real instruction requires it. A court, the Information Commissioner’s Office, or another body with lawful authority might receive information if the law requires that disclosure. Those are exceptional paths, not the ordinary life of an enquiry.

OpenStreetMap receives technical data only if you load the map. Your own email provider and your own browser vendor see what their services normally see when you use them. TERVRA does not control those services.

Transfers outside the United Kingdom

TERVRA LIMITED is in London. The website does not add a list of overseas offices, because none is published. Even so, email and hosting providers sometimes store or route data outside the United Kingdom. This policy does not assert that every byte stays in the UK, and it does not assert the opposite, because the provider contracts are not reproduced here.

Where personal data is transferred outside the UK and the law requires a safeguard, the safeguard has to be one the law recognises, such as a transfer to a country covered by UK adequacy regulations or a transfer under an appropriate contractual instrument. If a provider is the party that moves the data as part of its infrastructure, the relevant instrument is the one that applies to that provider. TERVRA does not publish a transfer map on this website, because naming countries and instruments without the underlying contracts would be an invention. If you ask where a particular enquiry is held, the answer will be given so far as it is actually known.

Loading OpenStreetMap can involve servers outside the UK. That is a reason the map waits for a click. You can decline it and still use every other part of the site.

Security

The form checks obvious mistakes and refuses messages that are empty or far too long. It rejects submissions that do not come from the site’s own host. It slows repeated validated attempts from one network address. Mail headers are built so that the name and the message body cannot become extra email headers. Those are ordinary protections for a small form. They are not a certification, and they are not a promise that a transmission over the internet cannot be interfered with.

You should use a current browser and a connection you trust. You should not send secrets in the form. If you believe a message was sent in error, write to general@tervra.xyz and say so. No security measure on a public website makes it wise to include passwords or card numbers, and the form is the wrong place for them.

Access to the mailbox should be limited to people who need it for the enquiry. This policy states that as the proper practice. It does not publish a headcount or a list of staff, because those facts are not part of the company’s published information.

Your rights

If the UK GDPR applies to you, you have rights over personal data TERVRA holds about you from this website. The rights are not absolute. A request can be refused where the law allows a refusal, for example where a request is manifestly unfounded or where keeping the information is still necessary. Where a request is refused, you should be told, and you can complain to the Information Commissioner’s Office. Requests can be made by email to general@tervra.xyz. Say what you want and give enough detail to find the message, such as the name and the approximate date. TERVRA may need to confirm that the requester is the person the data is about, which may mean asking you to write from the same email address you used, or to confirm a detail that was in the message. That check is to avoid disclosing one person’s enquiry to someone else.

There is no fee for a ordinary request. A fee or a refusal is possible only in the cases the law already allows, and this policy does not add a private fee schedule.

Access

You can ask whether personal data from the website is being processed and, if it is, for a copy of the data that relates to you, together with the usual accompanying information: the purposes, the categories, the recipients or categories of recipients, the retention approach, and the existence of the other rights. For this site, a copy is likely to be the enquiry email and any reply, and a description of log data if a log line can still be found and linked to you. It will not be a dossier of your wider life, because the site does not collect one. If you ask for access and nothing remains, the answer is that nothing remains.

Rectification

You can ask for a correction if the name, email address, or another fact in the enquiry is wrong. A correction is made in the mailbox or in the reply thread where the text still exists. TERVRA will not rewrite your original message into something you did not send and then pretend that was the enquiry. The usual course is to add the correction and to use the corrected details from then on. If the message has already been deleted, there may be nothing left to correct.

Erasure

You can ask for deletion. For an ordinary enquiry held on legitimate interests, deletion is the expected result once the conversation is finished, unless a specific reason remains. A reason that can remain includes a need to deal with a legal claim, a need to show what the website did with a complaint, or a request that is really about a contract that has moved into its own file. If the enquiry has become the start of a written service agreement, the agreement’s own record-keeping may keep some of the same facts. That is a different file from the website form, and it should be explained if it is the reason a deletion is partial.

Erasure does not oblige a telecoms company or your own mail provider to forget a copy you also hold. It obliges TERVRA to deal with the copies it holds.

Restriction

You can ask for processing to be restricted in the situations the UK GDPR describes: while accuracy is contested, while an unlawful processing is opposed in favour of restriction rather than deletion, while TERVRA no longer needs the data but you need it for a legal claim, or while an objection is being considered. Restriction means the message is held and not used, apart from storage and the exceptions the law allows, such as defending a claim or protecting another person’s rights. On a simple mailbox, restriction is carried out by isolating the message from ordinary replies until the question is resolved.

Portability

The right to data portability applies to data you provided, where the basis is consent or a contract, and where the processing is automated. An enquiry processed on legitimate interests does not sit in that right. An enquiry processed as a step toward a contract can be closer to it. In practice, if you want a copy of what you sent, ask, and a copy of the message can be given in a common format such as plain text even where the formal portability right does not apply. The site does not hold an account export, because there are no accounts.

Objection

Where processing is based on legitimate interests, you can object. TERVRA must then stop, unless it can show compelling legitimate grounds that override your interests, rights, and freedoms, or unless the processing is for a legal claim. For a finished enquiry, the ordinary response to an objection is to stop using the message and to delete it if nothing stronger requires it to be kept. For a message that is in the middle of a contract discussion you asked for, the discussion itself may continue on the contract basis rather than on legitimate interests. An objection is not a way to erase TERVRA’s duty to answer a regulator, and it is not a way to force the company to enter a contract.

There is a separate right to object to direct marketing. This website does not send a marketing list. A reply about the subject you wrote in about is not a newsletter. If a message ever arrived that was marketing you did not ask for, you could object and it should stop.

Automated decisions

The site does not make a decision with legal or similarly significant effects about you by automated means. The rate limit is a technical throttle on the form. It does not decide credit, employment, insurance, or whether you may use a service of TERVRA’s. The honeypot discards a submission that fills a field humans are told to leave blank. That is abuse handling, not a profile. No scoring model reads the message.

Complaints

You can complain to TERVRA first, at general@tervra.xyz, and it is useful if you do, because many questions about a single email can be answered directly. You also have the right to complain to the Information Commissioner’s Office, the UK regulator for this kind of processing. The ICO’s public address is Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, and its public site is https://ico.org.uk. The ICO publishes its own guidance on how to complain. Nothing in this policy removes that right, and nothing here claims that TERVRA has an ICO registration number, because no registration number is published with the company details.

If you are in a country whose law also gives you a complaint route, this policy does not take that route away. The website is operated from the United Kingdom and is written against UK data protection law.

Children

The site describes business-to-business engineering. It is not directed at children, and the form is not designed to collect a child’s data. If you are under 18, do not send the form. If a child’s data has been sent by someone else, write to general@tervra.xyz and ask for it to be deleted. A child’s enquiry is not a category the company seeks.

Client systems are a different subject

TERVRA’s work, when it is commissioned, can involve software that processes personal data for a financial or investment firm: application records, operational logs, access lists, and similar material. That processing is the client’s processing, or it is joint or processor processing, only as a written agreement defines it. This website does not appoint TERVRA as your processor, does not accept a portfolio of customer records, and does not set a retention rule for a platform that does not yet exist.

If you are asking about a system that would process personal data, the useful enquiry describes the categories of data and the roles in outline. It does not attach the data. The agreement, if one is signed, is the place for the Article 28 terms or for whatever other arrangement the facts require. Those terms are not copied into this policy, because copying them here would pretend that every future project has the same shape.

The scenarios on the work page are illustrations. They are not records of real applicants or real investors. They should not be read as evidence that TERVRA holds a database of either.

Marketing and cookies

The site does not place a marketing cookie and does not ask you to join a list. A person who has written in may receive a reply about that subject. That reply is correspondence, not a campaign. The cookie policy explains that the pages are built not to set first-party cookies, and that the optional map is the point at which a third party may set some. Read that policy before you load the map if the distinction matters to you.

Changes to this policy

If the website starts to collect personal data in a new way, or if the purposes change, this page will be updated and the date at the top will change. Continuing to read the site after an update does not, by itself, waive a right the law gives you. An important change to how enquiries are handled should be visible on this page rather than buried in a design refresh. Older versions are not promised as a public archive. If you need the text that applied on a particular day, ask, and if a copy still exists it can be described.

How to ask a question

Write to general@tervra.xyz, call +44 7399 204815, or post to TERVRA LIMITED, 108 Fonthill Road, London, N4 3HT, United Kingdom. Say whether you are asking about an enquiry you sent, about a log, or about this policy. Include the date of the message if you know it. A clear request is faster to answer than a general complaint that does not identify the data. If you are writing for someone else, explain your authority. TERVRA will not send one person’s enquiry to another person on a bare assertion.

The company information on this page is limited to what the site actually publishes. It does not add a company number, a list of directors, a group structure, or a set of overseas entities. If a formal notice needs a detail that is not on the site, ask for the right address for that notice rather than guessing one.