Privacy Policy

Effective Date: 20th April 2023

DefinitionsFor the purposes of this Privacy Policy, capitalised words shall have the following meaning and all definitions shall have the same meaning regardless of whether they are singular or plural:“Account” means a unique account created for You to access our Service or parts of our Service.“Company” refers to Terra Enabling Developers, Inc., with a principal place of business located at 1111B S Governors Ave #6127 Dover, DE 19904 and its affiliates and subsidiaries, including Terra Enabling Developers Ltd. (collectively referred to as either "the Company", "We", "Us", “Terra”, or "Our" in this Agreement)“Cookies” are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses."Device" means any device that can access the Service such as a computer, a smartphone or a digital table."Personal Data" is any information that relates to an identified or identifiable individual."Service”refers to the use of the Website, Terra’s APIs, Terra’s software“Service Provider”means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.“Usage Data” refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).“Website” refers to“You” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. “You” shall not include end users of Terra’s customers’ applications.
OverviewAt Terra, the privacy and safety of your data are paramount. One of our core principles is transparency and through this privacy policy (“Policy”), We seek to explain how Terra collects, uses, shares, and processes Your data. This Policy covers entities and individuals using Terra’s Services to connect their apps with their end users’ wearables and other health devices (collectively "wearables"). As well as data collected through Terra’s website, this Privacy Policy also covers data collected through other means such as via phone, email, or in person. This Policy does not cover data we collect from wearables about end users.
Data CollectionPersonal DataWhile using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Identifiers, such as email address, first name, and last name

Account data, such as username and password

Usage data, such as what time you logged in

Audio, electric and visual information, such as if you visit our offices in person

Other information you may provide to us

Usage DataUsage Data is collected automatically when using the Service.Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.We automatically log information about you and your computer, phone, tablet, or other devices you use to access the Site and Services. For example, when visiting our Site or when using the Company’s mobile applications, we may log your computer or device identification, operating system type, browser type, browser language, the website you visited before browsing our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site or in our mobile applications. How much of this information we collect depends on the type and settings of the device you use to access the Site and Services.We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.Tracking Technologies and CookiesWe may log information using “cookies.” Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Other similar tools we may use to collect information by automated means include web server logs, web beacons and pixel tags. This type of information is collected to make the Site and Services more useful to you and to tailor the experience with us to meet your interests and needs. For more information, see our Cookie Policy at AnalyticsWe may use Google Analytics to help analyse how users use the Site. Google Analytics uses Cookies to collect information such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to the Site. We only use the information from Google Analytics to improve our Site and Services. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Site, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.Session Replay TechnologyWe use session replay technology, such as Hotjar, to collect information regarding visitor behaviour on the Site and the Services. Hotjar is a full-session replay product that helps us see clearly what actions our Site visitors take and where they might get stuck or confused. Hotjar’s service allows us to record and replay an individual’s interaction with the Site and the Services. This helps us to understand our customer’s experience, where they might get stuck, and how we can improve the Site and the Services. You can review Hotjar’s privacy policy by visiting InformationIf you choose to interact on the Site or through the Services (such as by registering; using our Services; entering into agreements with us; or requesting information from us), we will collect the personal information that you provide. We may collect personal information about you that you provide through telephone, email, or other communications. If you provide us with personal information regarding another individual, please do not do so unless you have that person’s consent to give us their personal information.
Data UseThe Company may use Personal Data for the following purposes:

To provide and maintain Our Service, including monitoring the usage of our Service.

To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

Service Enhancement: to refine, strengthen, and extend our service offerings;

Product Development: to create new products and services;

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service or other means.

To provide you with effective customer service

To send you information about your relationship or transactions with us

To contact You: by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

To manage Your requests: attend and manage Your requests to Us.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

Consent-Based Usage: only with your explicit approval, we may use your information for other specified purposes or as directed by you.

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may also use your data for compliance and protection. We may use any of the categories of personal information described above to:

Comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or requests from government authorities.

Protect our, your and others’ rights, privacy, safety and property (including by making and defending legal claims).

Audit our internal processes for compliance with legal and contractual requirements and internal policies.

Enforce the terms and conditions that govern the Site and our Services.

Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal

activity, including cyberattacks and identity theft.

We may also use personal information for other purposes consistent with this Privacy Policy or that are explained to you at the time of collection of your personal information.
Data SharingThis section of the Policy outlines the categories of third parties with whom we may share your information to give you a clear understanding of how your data may be disclosed to others. We may share you data with:This section of the Policy outlines the categories of third parties with whom we may share your information to give you a clear understanding of how your data may be disclosed to others. We may share you data with:

Contractors that perform services for Terra or Terra’s employees;

Communication platform providers which facilitate communication and data transfer between Terra's employees and between Terra and our customers. These platforms may act as intermediaries in the data-sharing process, even if they cannot access the content of the messages directly;

Service providers that help Terra analyse data for Terra's business purposes. These platforms may help us track our customers’ engagement and behaviour, identify trends in data, and visualise data;

Cloud storage services providers that offer remote data storage solutions over the internet that allow us to store, manage, and/or access collected data in a secure and scalable environment;

Software development services providers that assist with software maintenance, software testing, quality assurance, and application support, among other things;

Terra group entities and/or subsidiaries that are wholly owned by Terra Enabling Developers, Inc., such as Terra Enabling Developers Ltd., our UK-based subsidiary;

Third parties to comply with relevant laws or to respond to subpoenas or warrants served on Terra; to protect or defend the rights or property of Terra or users of the Services; to investigate or assist in preventing any violation or potential violation of the law, this End User Privacy Policy, or our Terms of Service. For example, law enforcement or other governmental authorities.

Corporate RestructuringWe may share some or all of your data in connection with or during the negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, data may also be transferred as a business asset. If another company acquires Terra, our business, or assets, that company will possess the data collected by us and will assume the rights and obligations regarding your data described in this Privacy Policy.Third-Party WebsitesOur Site or Services may contain links to third-party websites or services. When you click on a link to any other website or location, you will leave our Site or the Services and go to another site and another entity may collect your personal information from you. We have no control over, do not review, and cannot be responsible for these outside websites or their content, or any collection of your personal information after you click on links to such outside websites. The links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, websites or privacy practices.
Data RetentionThe Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer periods.The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Protection of DataTerra is committed to protecting the security of your data. We use a variety of security technologies and procedures to help protect your data from unauthorised access, use, or disclosure. We do not use or store your data in non-production systems or environments. This means your data is not used or stored using technology not meant for live use of our services, such as systems or environments used for testing, staging, and development. No method of transmission over the internet, or method of electronic storage, is 100% secure, however. Therefore, while Terra uses reasonable efforts to protect your data, we cannot guarantee its absolute security.
International Data TransfersPlease note that our data processing takes place mainly in the United Kingdom. As such, our Services are governed by the laws of the United Kingdom. If you use our Services, your data will be subject to United Kingdom law and processed in the United Kingdom or in other countries. To operate our services, we may transmit your data internationally. We take steps to ensure the safety of your data should it be transferred internationally. We employ HTTPS encryption when transmitting your data between servers, regardless of their location. This ensures your data remains secure and protected from theft, tampering, or other threats during transit.
Data SecurityThe security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Notice to European End UsersThe information provided in this “Notice to European Users” section applies only to individuals in Europe.Personal informationReferences to “personal information” in this End User Privacy Policy are equivalent to “personal data” governed by European data protection legislation.ControllerTo the extent that we collect your data directly and determine the purposes and means of processing your data, Terra is the controller. Otherwise, Terra is the processor.We have appointed a Data Protection Officer, whose contact information is: Kyriakos Eleftheriou, CEO at Terra ([email protected])Legal Bases for ProcessingWe use your personal information only as permitted by law. The table below describes our legal bases for processing the personal information described in this Privacy Policy.
Processing Purpose
Legal Basis
Delivering Services
Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Services you access and request.
Product Development

Service Enhancement

Aid Assistance

Create Visualisations

Generate Insights

For compliance, fraud prevention and safety
These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise permitted to by law).
To comply with law
Processing is necessary to comply with our legal obligations.
With your consent
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it at any time in the manner indicated when you consent or in the Services.
Use for New PurposesWe may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.Sensitive Personal InformationWe ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us.If you provide us with any sensitive personal information when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through the Services.Automated Decision-Making and ProfilingWe do not use automated decision-making and/or profiling in regard to your personal information in connection with the Services.
Data Protection RightsThe following ensures that you are aware of your rights and how you can exercise them. Understanding your data protection rights enables you to make informed decisions about how your personal information is used and managed. We will honour the following rights, subject to limitations of the law. You may:

Withdraw the consent you previously provided us with to process your data;

Request the update or correction of inaccuracies in your data;

Access data collected about you;

Request the restriction of processing of your personal data;

Object to our reliance on legitimate interest as a legal basis for processing your data that impacts your rights;

Request that we erase or limit the processing of your data;

Request further details of the data types we have collected about you in the last six months;

Request that a machine-readable copy of your data be sent to a third party of your choice;

Request further details about the third parties your data has been shared with.

You may submit these requests by email to [email protected] or our postal address provided below. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Children's PrivacyOur Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
Do Not TrackWe currently do not support the Do Not Track browser setting or respond to Do Not Track signals. Do Not Track (or DNT) is a preference you can set in your browser to let the websites you visit know that you do not want them collecting certain information about you. For more details about Do Not Track, including how to enable or disable this preference, visit
ModificationsThis policy may change from time to time. If we update it, we will notify you.If you have any questions or complaints about this Policy or other privacy-related topics, you can contact us at [email protected]