# Teralo Privacy Policy

_Last Updated: 3 October 2026_

## Overview

Teralo respects your privacy and complies with applicable laws regarding personal information collection. "Personal information" includes any data that can identify you, such as your name, address, payment details, and device information.

This policy does not apply to third-party sites linked from our platform. Please review their privacy policies separately.

## Who We Are

This policy is issued by Teralo Pty Ltd (ABN 98 634 996 115, ACN 634 996 115), a proprietary company incorporated in Australia and based in Sydney, NSW, Australia. Teralo Pty Ltd is the entity accountable for the personal information described here, and it is the contracting party for the Teralo platform.

You can reach us about anything in this policy at support@teralo.co. Our registered office address is supplied on request, on signed order forms, and in vendor onboarding packs.

## Our Role: Controller and Processor

Teralo handles personal information in two different capacities. Which one applies changes who decides what happens to the information, and who you should approach about it.

**Teralo is the controller** for information about website visitors, prospective customers and the people who hold Teralo accounts. That covers names, email addresses, phone numbers, billing contacts, log and device data, and the website analytics described below. Teralo decides why and how that information is handled, and this policy governs it.

**Teralo is a processor** for everything an organisation puts into a project: project records and correspondence, drawings and documents, site diaries, inspections, incidents, inductions, worker records, progress claims and the files attached to any of them. The customer organisation is the controller of that information. Teralo handles it on that organisation's instructions and under its agreement with Teralo, and does not use it for its own purposes.

If your information is in Teralo because an organisation put it there, for example as a worker, a subcontractor or a site visitor, that organisation is the right first point of contact for access, correction or deletion. Teralo will assist that organisation with your request, and will ordinarily refer you to them rather than acting on their records directly.

## Information We Collect

### Voluntarily Provided Information

- Name, email, phone number, mailing address
- Information provided during account registration or subscription purchases
- Content you submit for publication
- Competition and survey entries
- Newsletter signups

### Automatically Collected Information

**Log Data:** When visiting the site, servers automatically log standard web browser data including IP address, browser type, pages visited, visit duration, and error information.

**Device Data:** Device type, operating system, unique identifiers, and device settings.

**Transaction Data:** Records, files, user profiles, analytics, and metrics generated through platform use.

## How We Use Your Information

We collect personal information for legitimate business purposes:

- Providing core platform features and services
- Customizing your experience
- Communications and support
- Analytics, market research, and business development (including Google Analytics for traffic analysis)
- Remarketing and advertising (showing relevant ads on third-party platforms to users who have visited our site)
- Marketing and promotional outreach
- Security and fraud prevention
- Legal compliance and dispute resolution
- Running competitions and promotions

## Data Security

We protect personal information using commercially acceptable security measures against loss, theft, and unauthorized access. However, no electronic transmission is completely secure. You're responsible for maintaining password security and protecting your account information.

## AI Processing

Teralo's AI features run on Google Gemini. The **Can access AI Chat** permission turns on AI Chat and the 3D model chat in a project. Other AI features, such as reading a safety data sheet from its PDF, follow the permissions of the tool they sit in, and the AI Assistant in the text editor is available to anyone who can edit that text. Each runs only when someone uses it, with one exception: opening the form to add an organisation, while signed in with a company email address, sends the text of that company's public website to Gemini, which uses it to suggest the organisation's details.

AI prompts and responses are sent to the Google Gemini Developer API, which under its paid-tier terms does not use them to train or improve Google products, and are not sent to Teralo's product analytics provider.

In practice that means four things:

- **Prompt and response content goes to Google and nowhere else.** Teralo's product analytics provider receives measurements of each call and nothing else: the model used, token counts, cost, latency, whether the call succeeded, and the error the API returned when it did not. It receives none of what you asked, none of what the assistant answered, and none of the project records the assistant read in order to answer.
- **Your conversation is stored in Teralo** like any other record, in the Sydney database, under the same access controls as the rest of your project data. It is kept until the person who created it deletes it, or until the project is deleted.
- **Teralo does not use prompts or responses to train models.** Google's paid-tier API terms state that Google does not use them to improve its products. Google logs them for 55 days in order to detect abuse, and states that it does not use that log to train any model other than those it uses to enforce its Prohibited Use Policy.
- **There is no regional processing guarantee.** Teralo uses the Gemini Developer API, which does not offer one, so a prompt may be processed on Google infrastructure outside Australia.

What the assistant can read, and what you must not submit to it, are set out in the [AI Product Terms](/legal/ai-product-terms).

## Facial Recognition and Biometric Information

Teralo offers optional face sign-in at a site kiosk, so a worker can sign on and off by looking at a tablet instead of typing. Biometric information is sensitive information under the Privacy Act, and this section describes exactly what happens.

**It is off unless a project turns it on.** Face recognition is a per-project setting, and it is disabled by default.

**Consent is collected before anything is captured.** A worker records consent during induction registration. Without recorded consent, no template is created, and none is ever sent to a kiosk.

**What is stored is a mathematical template, not a photograph.** During registration the worker's device computes a numeric descriptor from the camera image, using a face model that Teralo hosts and runs in the browser rather than sending the image to an outside service. That descriptor, a list of numbers, is what the kiosk matches against, and it cannot be turned back into a photograph. A worker's induction photograph, where a project collects one, is stored separately from the template and is never sent to a kiosk alongside it.

**It is used for one thing.** The template is used to recognise the worker at that project's sign-in kiosk, and for nothing else. It is not used for identification anywhere else in Teralo, not shared between organisations, and not shared with any third party. The face model runs on Teralo's own infrastructure and the templates are never sent to an external biometric service.

**Matching happens on the kiosk device.** The kiosk downloads the templates of that project's consenting, approved workers over an authenticated, expiring link, and compares them locally. A match only offers the worker's name for them to tap and confirm; it never signs anyone in by itself.

**A worker can decline, and can change their mind.** Declining is simply not giving consent at registration, and sign-in then works the ordinary way instead. Consent can be withdrawn at any time through the worker's registration, which deletes the stored template.

**How long it is kept.** Teralo deletes a template when consent is withdrawn, and when the worker's record is deleted. It is not currently deleted automatically when an induction expires, so a template can persist while a worker record remains on a project. Teralo is changing this so that templates are destroyed once the induction they support is no longer current, and this section will be updated when that ships.

## Data Retention

We retain personal information only as long as necessary for the stated purpose. For account holders, we retain information for the account's duration. If information becomes unnecessary, we delete or anonymize it, except where legal, accounting, reporting, or archival obligations apply.

## Children's Privacy

We do not knowingly collect personal information from children under 13 and do not target products to this age group.

## Third-Party Disclosures

We may share personal information with:

- Parent companies, subsidiaries, and affiliates
- Service providers (IT, hosting, analytics, payment processors)
- Business partners and agents
- Promotional sponsors
- Law enforcement and regulatory authorities (when required)
- Potential business acquirers

Every third party that receives data on Teralo's behalf is named, together with its purpose, the category of data it receives and where it processes that data, on the [sub-processor page](/legal/sub-processors). That page carries the date the list last changed, and Teralo notifies customers before adding a provider to it.

## Where Your Data Is Stored

Customer data rests in two places, and they carry different guarantees. Teralo describes them separately rather than as a single claim about Australia.

**The application database** is managed Postgres on Supabase, in the AWS ap-southeast-2 region in Sydney. This holds project records, account details, induction records and biometric templates. A Supabase project's region is fixed when the project is created, so it is a firm commitment rather than a preference.

**Uploaded files**, meaning documents, drawings, photos, mail and meeting attachments and signed PDFs, are held in Cloudflare R2 in a bucket carrying Cloudflare's Oceania location hint. Cloudflare documents a location hint as a best effort rather than a guarantee, and publishes no Australian jurisdiction that would make it one. Teralo therefore does not represent file storage as contractually resident in Australia.

Some data necessarily leaves the region. Static content and cached responses are served from Cloudflare's global edge network. Payment details go to Stripe. AI prompts and responses go to Google Gemini. Product usage events, and measurements of AI calls that carry no prompt or response content, go to PostHog in the United States. Address lookups for project and site locations go to Mapbox. Map tiles, and the IP address that requests them, come from CARTO. Website analytics go to Google Analytics and Umami. Each of these is listed on the [sub-processor page](/legal/sub-processors) with its location.

Transfers outside the European Economic Area comply with applicable laws and include appropriate safeguards.

## Your Rights and Control

- **Marketing Preferences:** Opt out of direct marketing at any time
- **Access:** Request details of information we hold about you
- **Correction:** Request corrections to inaccurate or outdated information
- **Non-Discrimination:** We won't deny services or charge differently for exercising privacy rights
- **Breach Notification:** We comply with applicable data breach laws
- **Complaints:** Contact us regarding potential violations; you may also contact regulatory authorities
- **Unsubscribe:** Use opt-out options in communications or contact us directly

## Cookies and Tracking Technologies

We use cookies and similar technologies to collect information about your activity and preferences. When you first visit our website, you will be presented with a consent banner that allows you to:

- Accept all cookies (analytics and marketing)
- Reject all non-essential cookies
- Customize your preferences by category

We use Google Consent Mode v2 to ensure your preferences are respected. Analytics and marketing cookies are only activated after you provide consent.

We also use Umami, a privacy-focused analytics service that does not use cookies and does not collect or store personal identifiers. Because it sets nothing on your device, it runs independently of your cookie consent choices.

For detailed information about the specific cookies we use, their purposes, and retention periods, please see our [Cookie Policy](/legal/cookie-policy). You may also manage your preferences at any time through the "Cookie Preferences" link in our website footer.

## Business Transfers

If we're acquired or face bankruptcy, personal information may be transferred as part of assets. Any acquiring party must continue following this privacy policy.

## Policy Changes

We may update this policy to reflect business changes or regulatory requirements. Significant changes will be communicated to registered users via your preferred contact method. Where required by law, we'll seek your consent for new uses of information.

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## Additional Compliance Sections

### Australian Privacy Act Compliance

Third parties we disclose information to may not be regulated by Australian Privacy Principles and cannot be held accountable under the Privacy Act.

### GDPR Compliance (EU)

**Controller and Processor:** Teralo is the controller of personal information about website visitors, prospective customers and account holders, and a processor of the information an organisation puts into a project, where that organisation is the controller. See Our Role above.

**Legal Bases for Processing:**

- Your consent
- Contract performance or preparatory steps
- Our legitimate interests (research, development, marketing, operations)
- Legal compliance obligations

**Your Rights:**

- **Restrict processing** if you're concerned about accuracy or lawful processing
- **Object to processing** based on legitimate interests
- **Data portability:** Request your information in accessible formats
- **Deletion:** Request removal of personal information (with limited exceptions)

### California Compliance (US)

**Do Not Track:** We currently don't respond to browser "Do Not Track" signals.

**Cookies and Pixels:** You may decline cookies if your browser permits.

**CCPA Financial Incentives:** We may offer permitted incentives with reasonable value relationships and clear written terms.

**Notice of Collection:** In the past 12 months, we've collected:

- Identifiers (name, email, IP address, account numbers)
- Audio/visual data (photos, videos you share)
- Inferences (interests, preferences, favorites)

**Right to Know and Delete:** California residents may request:

- Categories of personal information collected
- Sources of collection
- Categories of disclosure or sale
- Categories of recipients
- Business purposes for collection or sale
- Specific personal information held

**Shine the Light:** California residents may request information about third-party and affiliate sharing for direct marketing purposes. Include "California Privacy Rights Request" in requests sent to our contact address.

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## Contact Us

**Teralo Pty Ltd** (ABN 98 634 996 115, ACN 634 996 115)

Sydney, NSW, Australia

support@teralo.co