1. Important information and who we are
privacy manager in the following ways:
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your access to and use of third-party websites or services accessible through the Totem Platform
Totem includes links to third-party websites and applications as well as to partner providers of multiple different types of services associated with a specific event.
Third party web sites and applications
Clicking on links to third party web sites, content or applications may allow those third parties to collector share data about you. We do not control those third-party websites or content and are not responsible for their privacy statements or the way in which they collect or use your data.
We will never share your data with any third-party service provider whether online or offline without your express permission.
We are a platform provider. Totem is made available to you to attend like any other offline event, we do not engage in any correspondence, or the relationship, between you as a user of Totem or attendee at any event and any services you make use of which are made available to you as part of your access to the Totem platform or an event (except where it is provided directly by Totem to you).
In particular we do not participate in any part of any service or any contract for services which may be provided to you by any other party at any event or any event organiser or otherwise available to you as a user. You accept all responsibility in respect to ensuring that any specific services which you make use of are suitable for you.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with access to Totem, or a specific event itself and particular services).
3. How is your personal data collected?
We use different methods to collect data from and about you including via:
4. How we use your personal data
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground
has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a user of Totem||(a) Identity (b) Contact||Performance of a contract with you|
|To process any paid entry to an event if applicable: (a) Communicating with you, for example sending you confirmation of your attendance for an event.||(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests|
|To administer and protect our business and our services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (for running our business, administering our CRM, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|To enable you to partake in a competition or complete a survey||(a) Identity (b) Contact (c) Profile (d) Usage >(e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how users use Totem and to develop and grow our business)|
|To deliver relevant platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests (to study how users use Totem and to grow our business and inform our marketing and growth strategy)|
|To use data analytics to improve our Platform, products/services, marketing, user and Partner relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of users for certain platform services and to keep our services and web site updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about Events or other services available through Totem that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications||Necessary for our legitimate interests (to develop the products and services available through Totem)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Recommendations from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think may be of interest to you. This is how we decide which services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us previously used services or purchased products or services through the Totem Virtual Events Platform and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your use of the Totem Virtual Events Platform or any associated services.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.
Where third parties provide events or support the provision of services made available to you through Totem, these third parties may receive certain personal data from you. Whilst we are not in control of any third parties to whom you request your data to be shared, we require all third parties to respect the security of your personal data and to treat it in accordance with the law.
To help constantly improve and tailor the service we provide to you through our platform, we may use aggregated information so that we can administer and improve our services, analyse trends, gather broad demographic information and most importantly monitor and improve our operations on a day to day basis. In carrying out this activity, we may pass some information to third parties in aggregate and anonymised format.
Your disclosure to third parties
6. International transfers
We may transfer your personal data outside the European Economic Area (EEA) in our performance of services.
Whenever we transfer your personal data out of the EEA, we ensure an appropriate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a
complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of the rights set out above, we may forward this request to the event organiser to confirm the removal of the data or provide the data request submitted under the rights of the user.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
If you exercise any of your rights under data protection law, the event organiser you are dealing with must respond as quickly as possible. This must be no later than one calendar month, starting from the day they receive the request.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. In respect to Totem, that is the performance of our agreement with you to make the platform and its services available. We are not involved in the processing of your Personal Data during any engagement you enter into with our third-party partners. We will always get your consent to transfer any Personal Data to any third party whom you enter into an agreement with for the provision of their services to you. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties