Privacy Policy

Effective from: 22 October 2026
Last changed: 22 October 2026 (data protection review: retention table in section 7; sub-processor table with location and transfer basis in section 5; community and social features in section 2.7; deletion of an inactive customer account after 2 years and of provider data 12 months after the subscription ends; application-level encryption of health data and an access log in section 10; assistant Ina as artificial intelligence under Article 50 of Regulation (EU) 2024/1689 in section 13; rights and complaint to the Information Commissioner in section 8; minimum age 16; courses in section 2.3 and cosmetic salons in section 3)
Previous change: 21 October 2026 (section 13 on the assistant Ina and processing by Anthropic; blocking in messages and content reports; revocation of Sign in with Apple on account deletion; section 2.2 on the staff account)

This is a convenience translation of the Slovenian original, Politika zasebnosti. In case of any discrepancy, the Slovenian version prevails.

1. Who we are

The controller of personal data collected through the Termina platform (termina-booking.com and the Termina app) is:

Termina, računalniško programiranje, Neya Borysova s.p. Goriška ulica 4, 2000 Maribor, Slovenia Tax number: 16782062 Registration number: 7558252000 Email: info@termina-booking.com

We are committed to protecting your personal data and process it in accordance with the General Data Protection Regulation (GDPR) and the Slovenian Personal Data Protection Act (ZVOP-2).

We have not appointed a data protection officer, as we do not meet the statutory conditions (Article 37 GDPR; our activity is not large-scale regular monitoring of individuals, and large-scale processing of special categories of data is not our core activity but a feature individual providers enable). For all privacy questions write to the address above; the person responsible for data protection at Termina replies.

For customer data arising from a booking with a provider, the controller is the provider and Termina is the processor; this relationship is governed by the Data Processing Agreement. For questions about how a provider uses your data outside the platform, contact the provider.

2. Which data we process

2.1 Provider data

• Company details: business name, registered office, registration and tax number, legal form, country, VAT identification number

• Contact details: name and surname of the contact person, email address, phone number

• Business details: description of services, prices, opening hours, locations, photographs, logo, stories and posts, events

• Subscription details: chosen plan, period, payment history, issued invoices, discount codes and prize-draw rewards

• Usage data: sign-ins, actions in the account, bookings, acceptance of terms with version and time

• Verified person (a paid add-on, if the provider chooses it): the identity document and a face capture are verified by the payment provider Stripe (Stripe Identity); Termina does not receive or see the document or the capture, only the outcome (passed or not) and the date; after verification Stripe deletes the data at our request. Proof of qualifications, insurance and permits uploaded by the provider is reviewed by Termina's administrator; the profile shows only what is confirmed and until when.

2.2 Data of a provider's staff

When a provider works in a team: name, email address, working hours and assigned appointments. This data is entered by the provider, who is its controller; a staff member with an account sees their own calendar.

When a provider opens a staff account for a team member, we also process: the sign-in email address, the password (hashed only), sessions and sign-ins, calendar actions (cancelling an appointment, marking or removing a no-show, confirming a client's arrival) and the record of acceptance of the Terms for Staff and acknowledgement of this policy, with date and document version. For data arising from work for the provider, the controller is the provider and Termina is the processor. The acceptance record and security logs are kept by Termina as controller, to prove with which version of the terms the account was opened and for platform security (legitimate interest, Art. 6(1)(f) GDPR). The provider disables the account; you can request deletion on your calendar page, from the provider or at info@termina-booking.com, and export your data in the app on your calendar page.

2.3 Customer data

• Name and surname

• Email address and phone number

• Date of birth (only to check the minimum age of 16), gender (optional) and profile picture (optional)

• Email confirmation when creating an account (a 6-digit code valid for 15 minutes; only its fingerprint is stored)

• Booking data: provider, service, date and time, the person performing the service, notes, images you attach to the appointment

• Booking history, waiting list, free-slot offers

• Courses (visit packages of one service, paid in advance) you buy from a provider: service, number of visits and visits used, price, payment method (online or at the salon), validity, and extension or refund

• Gift cards you buy or receive: value, validity, code, use

• Service payments, deposits and surcharges: amount, status, method (online, bank transfer, at the salon); for split payments the shares and the people paying them

• Messages with the provider and Help messages

• Provider reviews

• Saved providers, follows and chosen activity groups (if you have an account)

• Push notification subscriptions (device address), if you enable them

• Health data, where a provider needs it to perform the service safely (allergies and the like) — which data, why and who sees it is described in section 3

2.4 Data of all visitors

• Technical data: IP address, device and browser type, language, time of visit (in the security log for 90 days)

• Anonymised usage data (pages visited, traffic source, country, device type), collected without cookies and without tracking individuals

2.5 Payment data

We do not collect, process or store payment card data. Payments are handled entirely by the payment provider Stripe. We receive only whether a payment succeeded, the last four digits of the card and the card type. For bank transfers we see only the provider's confirmation that the payment was received.

2.6 Provider data for the Financial Administration (DAC7)

Termina is a platform operator under the Slovenian Tax Procedure Act (chapter III.Č, which transposes Council Directive (EU) 2021/514, known as DAC7). For every provider that performs paid services through the platform we therefore collect and report once a year, by 31 January for the previous year, to the Financial Administration of the Republic of Slovenia:

• name and surname or business name, residential or registered address, tax identification number and issuing country, VAT identification number, for a company the registration number and the countries of permanent establishments, for a sole trader the date of birth, and the account number to which the provider receives payments, if we have it;
• per quarter: the amount of payments for services (excluding Termina's commissions), the number of services and the commissions Termina withheld or charged.

Purpose and legal basis: compliance with a legal obligation (Art. 6(1)(c) GDPR; chapter III.Č of the Tax Procedure Act). The provider enters the data on the dashboard; without it the report cannot be filed, so the law requires, after two reminders, restricting payments or closing the account.

Recipients: the Financial Administration of the Republic of Slovenia, which may exchange the data with tax authorities of other EU Member States where the provider is resident.

Protection: the tax number, date of birth and account number are encrypted in the database; only the provider (the account owner) sees them, never the provider's staff. Termina's administrator sees them only with an explicit, logged disclosure.

Retention: 10 years after the end of the year to which the report relates, then deleted. As a statutory record, this data remains after account deletion until that period expires (Art. 17(3)(b) GDPR). The provider receives it in the export of its data and sees it on the dashboard, together with what was reported about it.

2.7 Community and social features

Termina is also a network around services. Everything social is your choice, off by default and can be withdrawn at any time; your bookings are never visible to other customers.

• Following and For You: which providers you follow and which activity groups you chose; from this we build your For You feed. A provider sees the number of followers, not a list of names, unless you message or book.
• Customer profile and Friends: the profile is private by default. If you open it, your name, profile picture and what you post yourself are visible; Friends (connections between customers) arise only with mutual confirmation and can be ended at any time; a blocked person does not see your profile.
• Posts, comments, stories, questions and answers: the text, photos and videos you post, time of posting, name and profile picture; stories disappear after 24 hours (a provider may keep its own on its profile). Published content is visible to other users; photos are stored without location and device metadata.
• Book together and split payment: who invited whom, who confirmed and who paid their share; the invited person sees the name and service of the person who invited them, not their other bookings.
• Events: registrations for providers' events (name, email address, number of people).
• Blocks and content reports: section 14.

The legal basis for social features is performance of the contract (a service you enabled; Art. 6(1)(b) GDPR), and for recommendations in the For You feed based on your choices legitimate interest (Art. 6(1)(f)), which you can object to by removing follows or groups. We do not profile for advertising.

3. Health data

Some providers need information about your health before a service, mainly about allergies: gel polish, acrylics and nail adhesives contain acrylates, and hair and lash dyes contain substances the skin may react to; for cosmetic treatments (peels, waxing, lash and brow tinting) medication and skin condition also matter. Health data is a special category of personal data (Article 9 GDPR) and stricter rules apply to it than to other data. It is processed only with providers who enable this feature, and for one purpose only: so that the service is performed safely.

The controller of this data is the provider with whom it was collected; Termina processes it for the provider as processor under the Data Processing Agreement. Termina does not accept health services (doctors, dentists, physiotherapists, psychotherapists and the like cannot register on the platform) and does not require you to disclose health information in order to book.

3.1 Which data and from whom

• Pre-visit questionnaire (nail salons and other providers in the Beauty group, when they enable it). At your first booking with such a provider, the provider asks you to answer questions about: allergy to acrylates and methacrylates (for example HEMA); other allergies, with description; pregnancy; diabetes or circulation problems; skin and nail condition, with description; medication affecting skin or nails; and an optional note. You enter the answers yourself.

• Cosmetics questionnaire (cosmetic salons — cosmetics, facial care, lashes and brows, make-up, waxing — when they enable it). Instead of the nail questionnaire the salon asks you about: the medication isotretinoin (for example Roaccutane) in the last six months; retinoids or acids on the skin in the last week; photosensitising medication; corticosteroids; anticoagulants; pregnancy or breastfeeding; sun or solarium in the last 14 days; allergies (cosmetics, latex, lash and brow dyes, wax or rosin) with description; skin diseases (eczema, psoriasis, herpes) with description; diabetes; and an optional note. This is about the safety of a beauty service, not a diagnosis. The questionnaire is valid for one year: if the answers are older than 12 months, the salon asks you at the next appointment to check and confirm them again. Without answers the salon asks you at every appointment, unless you withdrew consent.

• Skin profile and treatment protocol (cosmetic salons). The provider may record skin type and phototype (a description of the skin for product choice, not health data) and skin conditions (acne, rosacea, pigmentation, dehydration, other), which are data close to health. For each visit it may record a treatment protocol: treatment, products with concentration and pH, exposure time, who performed the treatment, and the skin reaction (none, slight redness, strong reaction) with a note — the reaction is health data.

• Allergy test before colouring and sensitivity test (hair salons and other providers that require it for hair, lash or brow colouring; in cosmetic salons it is called a sensitivity test and applies for example before a lash lift or chemical peel). The provider records the result — passed or reaction — and optionally a short note. Bookings also show when you took the test or have one booked. A reaction with that provider closes booking of services that require the test until the provider reopens it.

• Hair profile (hair salons). The provider may record scalp sensitivity and allergies in the profile. Other profile data (hair type and colour, chemical treatments, colour formula) is not health data.

• Booking note. The note is free text for the provider, for example a wish or a question. The form does not ask about health in it and health information need not be written there. If you write it anyway, it is visible to the provider's owner account but not to staff with their own account; the note text is deleted 24 months after the appointment (3.5).

Health information may also follow indirectly from the booking itself (for example booking an allergy test or prenatal exercise). We process such data like all other booking data and with the same protection.

3.2 Legal basis and consent

• The questionnaire is stored only with your explicit consent (Art. 9(2)(a) GDPR). The consent is a separate checkbox, unticked by default, that states the purpose. Without it the server does not store the questionnaire — not the answers, not part of them — and you can still come to the appointment.

• Every consent given and withdrawn is recorded as a new entry with time and method (for example "questionnaire"), so it is possible to show what you chose and when. The record does not contain the answers.

• You can withdraw consent at any time on the questionnaire page with the button "Withdraw consent and delete answers". The answers are deleted immediately, at the moment of withdrawal; only the record that you withdrew consent remains. Withdrawal does not affect the lawfulness of processing before it.

• The cosmetics questionnaire is stored under the same conditions and with the same separate consent as the pre-visit questionnaire; at the annual renewal consent need not be given again, and a correction confirms it again.

• The result of the allergy or sensitivity test, the scalp and allergies in the hair profile and the skin conditions and skin reaction in the treatment protocol are recorded by the provider at your visit. Termina does not collect your consent for this; the provider as controller is responsible for an appropriate legal basis under Art. 9(2) GDPR (as a rule your explicit consent, which the provider explains to you and records). The platform reminds the provider of this at the first entry.

3.3 Who sees it

• Only the provider with whom it was collected. Every questionnaire, test result and profile is tied to one provider. Another provider does not see them, even if you are also their customer.

• The provider sees them on the customer card and at your appointment (for example the flags "Allergy" or "Pregnancy" and the allergy description). Questionnaire answers, scalp and allergies in the hair profile, the skin profile and treatment protocols, the allergy or sensitivity test result and progress photos are visible to the provider's owner account only.

• Staff with their own account do not open the customer card and do not see health data. At the appointment they perform they see only a neutral warning "Check the notes with the salon owner before the service", without content: it does not tell them whether it is an allergy, pregnancy or something else. What the salon owner tells staff before the service is the responsibility of the provider as controller.

• You see and correct your answers on the questionnaire page.

• Termina only collects, stores, displays, backs up and deletes them for the provider under the rules in this section. They are not displayed in Termina's administration interface and we do not review them. Every access to this data is written to an access log (section 10).

• Questionnaire answers and test results are never in email, SMS or push notifications. A notification may only mention the allergy test appointment (for example that it was cancelled). The system log records only that a questionnaire was submitted or withdrawn, without answers, and that an allergy test result was recorded, without the result and without the note; the log is deleted after 90 days.

3.4 What we do not do with this data

• we do not use it for advertising, newsletters, recommendations or profiling;

• we do not use it for analytics or statistics; the visit measurement tool (section 9) does not load at all on the questionnaire page and on other pages opened from a personal link in an email, and elsewhere it receives only the page path, without query string or fragment;

• we do not send it to the assistant Ina or any other language model and do not use it for AI training;

• we do not sell it or pass it to third parties. It is stored in the platform's database with the hosting provider listed among the Sub-processors, encrypted at application level (section 10); section 6 applies to the place of processing.

3.5 How long we keep it

• Questionnaire answers: 24 months after your last appointment with that provider (or after completion, if later); immediately on withdrawal of consent; immediately when the provider deletes your data.

• Cosmetics questionnaire answers: the same as above — 24 months after the last appointment, immediately on withdrawal. Being older than 12 months only means the salon asks you to renew them; they are deleted after 24 months.

• Skin conditions in the skin profile and skin reaction in treatment protocols: cleared 24 months after your last appointment with that provider (or after the last change of the profile, if later). The appointment protocol goes when the appointment is anonymised; the skin profile when you are no longer in the salon's book by name; both immediately when the provider deletes your data.

• Progress photos: 24 months after your last appointment with that provider, immediately on withdrawal of consent, immediately when the provider deletes your data (3.7).

• Allergy test results: 24 months after your last appointment with that provider (or after the test, if later); immediately when the provider deletes your data. The provider can also delete an individual record itself.

• Scalp and allergies in the hair profile: cleared 24 months after your last appointment with that provider (or after the last change of the profile, if later); immediately when the provider deletes your data.

• The consent record (when it was given or withdrawn, without answers) is kept as evidence of your decision; when the provider deletes your data, it loses your email address.

• Booking note: the note text is deleted 24 months after the appointment, and immediately when the provider deletes your data. The booking remains without it for as long as it must be kept as an accounting record.

• Backups: deleted data may remain in backups until they are replaced by newer ones (we keep the last 14 daily backups on the server); backups are encrypted and stored in the EU (section 10).

3.6 Your rights regarding health data

• Withdrawal, correction and deletion of answers you do yourself on the questionnaire page. The link to it is in the booking confirmation and at the upcoming appointment in My appointments. The link opens your appointment without signing in, so do not share it.

• Export: the data export in your account settings contains your answers (including cosmetics questionnaires), consents, allergy test results, hair profiles, skin profiles, treatment protocols and the list of progress photos (when, before or after, whether publication is permitted; the photos themselves you see at the appointment in My appointments) with all providers.

• Deletion of a test result or hair profile: ask the provider, who deletes your data on their dashboard, or write to info@termina-booking.com and we help the provider do so.

• Deleting your Termina account does not automatically delete this data, because the provider keeps it as controller. Use the withdrawal on the questionnaire page or ask the provider.

• Other rights and the complaint to the supervisory authority: section 8.

3.7 Nail photos, progress photos and images you attach to an appointment

• Below the questionnaire there is a second, separate consent: whether the provider may publish photos of your nails among its work, without face and name (Art. 6(1)(a) GDPR). It is not a condition of anything, is not given by default and you can withdraw it at any time on the questionnaire page or in My appointments. The provider sees your decision at the appointment and is responsible for respecting it.

• Progress photos (cosmetic salons, courses and treatments): the salon may photograph your skin before and after a treatment to show progress. A skin photo may reveal a skin condition, so the salon takes them only with your separate, explicit consent (Art. 9(2)(a) GDPR), which is not given by default and is not a condition of the appointment; without it the server does not accept the photos. You give or withdraw consent in My appointments or on the questionnaire page; withdrawal immediately deletes all progress photos with that salon, including publications made from them. The photos are stored separately from public images, without location and device metadata; only the salon's owner account and you at your appointment see them, staff with their own account do not. Publication of a photo among the salon's work is possible only if you permit it for each photo individually; when you withdraw the permission, the publication goes. They are kept 24 months after your last appointment with the salon. We do not use photos of the face or body for biometric recognition and do not compare them with each other.

• Images you attach to an appointment yourself (inspiration or your hair today) are visible only to the provider of that appointment. They are stored separately from public images, without location and device metadata, and are deleted when the appointment is cancelled and 30 days after the appointment.

4. Why we process data and on which legal basis

You can turn off non-essential notifications at any time; you receive cancellation or reschedule notifications even after opting out, because they are necessary for performing the contract. We do not carry out automated decision-making with legal effects (Art. 22 GDPR); decisions on reports, accounts and providers are made by a person.

5. Who receives the data

We do not sell personal data. We pass it on only to the extent necessary for the platform to operate:

To providers. When a customer books an appointment, the provider receives the data needed to perform the service. The provider is an independent controller for the further processing of that data and is solely responsible for it.

To processors (sub-processors) that perform individual services for us. Their list is always published on the Sub-processors page; it is derived from the platform's actual configuration, so it cannot lag behind reality and prevails over the table below where they differ. We notify providers of changes to the list 30 days before they take effect. We have data processing agreements under Art. 28 GDPR with all processors.

To public authorities where the law requires it (the Financial Administration under DAC7, courts, the police, the Information Commissioner, the Digital Services Coordinator).

5.1 Table of processors and recipients

6. Transfer of data outside the EU

We as a rule process data within the European Economic Area. If one of the processors transfers data to a third country (as shown in table 5.1 and on the Sub-processors page), this is done on the basis of a European Commission adequacy decision (for the USA the EU–US Data Privacy Framework where the recipient is certified) or the European Commission's standard contractual clauses with supplementary measures (encryption in transit, minimal data). You can request a copy of the safeguards at info@termina-booking.com.

7. How long we keep data

After the periods expire we delete or irreversibly anonymise the data. Where a period runs "after account deletion", personal data not listed in the table above is deleted immediately when the account is deleted.

8. Your rights

Under the GDPR you have the right to:

• access your personal data and obtain a copy of it (Article 15);

• rectification of inaccurate data or completion of incomplete data (Article 16);

• erasure of data ("right to be forgotten") where there is no longer a legal basis for processing (Article 17);

• restriction of processing in the cases set out in the GDPR (Article 18);

• data portability in a structured, commonly used and machine-readable format (Article 20);

• object to processing based on legitimate interest (Article 21), including to recommendations in the For You feed;

• withdraw consent at any time, without affecting the lawfulness of processing before withdrawal (Article 7).

You can export and erase your data directly in the app, in your account settings — without waiting and without a request. You withdraw consent to the health questionnaire on the questionnaire page and the answers are deleted immediately (3.6). For everything else send a request to info@termina-booking.com; we reply within one month of receipt at the latest, and for complex requests we may extend this by two months, of which we inform you. Exercising your rights is free of charge. For security we may ask for additional confirmation of your identity (for example a reply from the account's email address); we do not require an identity document. Where the provider is the controller (booking and health data), we help you exercise your rights and forward the request to the provider.

If you believe we process your data unlawfully, you have the right to lodge a complaint with the supervisory authority:

Information Commissioner of the Republic of Slovenia Dunajska cesta 22, 1000 Ljubljana gp.ip@ip-rs.si | www.ip-rs.si | phone +386 1 230 97 30

You may also lodge a complaint with the supervisory authority in the EU Member State where you live or work. For judicial remedies the courts in Slovenia or in your country of residence have jurisdiction.

9. Cookies

We use only essential cookies, which are needed for the site to work, for signing in and for security. The law does not require consent for these, so you will not see a cookie banner on the platform. What exactly is stored in your browser, and for how long, is described on the Cookies page.

We do not use analytics cookies or trackers. For measuring visits we use Umami, which sets no cookies, creates no visitor identifiers and does not allow tracking individuals across visits or websites. The data collected is aggregated and anonymised. Pages opened from a personal link (for example the questionnaire, an appointment, an invoice, a gift card or a password reset) do not load the tool at all; on other pages it receives only the page path, without query string or fragment, so it never receives tokens from links.

Stripe may set its own cookies at payment for fraud prevention; these are necessary for the secure execution of the payment.

10. Security

We implement technical and organisational measures under Article 32 GDPR, proportionate to the risk; health data has additional protection:

• encrypted transmission (HTTPS, HSTS), passwords stored only as hashes, sign-in sessions in HttpOnly cookies, sign-in throttling, confirmation of a new browser with a code from the email;
• application-level encryption for health data (questionnaire answers, test results, scalp and allergies, skin conditions and reaction, progress photos) and for tax data (DAC7): the key is separate from the database and the backups, so a copy of the database alone does not reveal them;
• an access log for health data (Article 22 ZVOP-2): who, when, what and for which customer, without content; the log is used only to verify lawfulness, for security and for error correction;
• role-based access (the customer sees their own data, the provider its customers, staff their own calendar, the administrator without access to health data); administrator sign-in in two steps with logged views;
• push notification content encrypted from the server to the device (RFC 8291); photos without metadata; pages with personal links without analytics;
• daily backups, encrypted, stored in the EU off the server, with a restore test on every copy;
• regular software updates, separate development and production environments, minimal data in logs (90 days);
• a security incident register with a procedure and a 72-hour deadline for notifying the supervisory authority.

Nevertheless no system is completely secure. In the event of a personal data breach likely to result in a high risk to your rights, we will inform you without undue delay in accordance with Art. 34 GDPR, and the provider as controller no later than 48 hours after we become aware of the breach; we notify the supervisory authority within 72 hours where the law requires it.

11. Children

The platform is not intended for persons under 16 years of age. When an account is created we check the date of birth; we do not knowingly collect children's personal data and we close an account we learn belongs to a younger person and delete the data. Parents or guardians can write to us at info@termina-booking.com.

12. Changes to this policy

We may update this policy. We will inform you of material changes by email or by a notice on the platform. The current version is always published on this page, together with the date of the last change; we send previous versions on request.

13. Assistant Ina

Ina is an assistant in the app and on the Help page that answers questions about Termina, bookings and free slots. Ina is an artificial intelligence system, not a person; the conversation itself tells you so (Article 50 of Regulation (EU) 2024/1689 on artificial intelligence). Her answers may be wrong and are not a binding statement by Termina. She answers frequent questions herself, without an external call. A question she does not recognise is sent to the language model Claude of Anthropic PBC (USA), which acts as a processor for us.

• What is sent: the text of the messages in this conversation with Ina (at most the last 12, each up to 600 characters), the language and today's date. Your name, email, bookings and other account data are not sent.
• Consent: before the first message the app tells you who processes the messages and asks for your consent. Without it Ina answers only from her own knowledge base and sends nothing on. The consent is remembered on the device; you withdraw it by clearing the app's or browser's data.
• Legal basis: consent (Art. 6(1)(a) GDPR).
• Retention: we do not store the content of the conversation at Termina; we record only the length and duration of the call. Under its commercial terms Anthropic does not use the content for model training and keeps it only for a limited time for abuse prevention.
• Transfer to the USA: on the basis of standard contractual clauses (section 6).
• Do not enter health data or other sensitive data; Ina does not need it. Ina makes no decisions about you; she does not decide on bookings, accounts or reports.

A provider may also use Ina for a suggested reply to a customer and for team scheduling. For a suggested reply, the last messages of the conversation with the customer and the salon's public data (description, price list, opening hours, address) are sent to Anthropic; for scheduling, the description the provider enters. A suggested reply does not reach the customer until the provider reviews and sends it; the provider is responsible for the sent message as for its own.

14. Content reports and blocks

When you report content or a person (terms of use, section 11), we keep the report with the reason, note and time until we handle it, and for a further 12 months as evidence of the decision (Digital Services Act). The author of the content does not learn who reported it. We inform the reporter and the author (with a statement of reasons) of the decision; both records are kept for the same period. Blocks in messages are kept until you remove them or until you delete your account; they are listed in the export of your data. Reports and decisions on them are handled by a person, not an automated system.

15. Sign in with Apple or Google

If you sign in with Apple or Google, we keep the link between your Termina account and the account with the sign-in provider. For Sign in with Apple we also keep Apple's refresh token, encrypted, for revocation on account deletion. On account deletion we delete the link and revoke the token with Apple. The sign-in provider is an independent controller for its own account under its own terms.

16. Who is the controller of what — short overview