Totem Privacy and Cookies Policy
Totem is an online platform created by Play Consulting Limited (Play) which allows organisations to better connect, recognise and motivate their most important assets - their people. The Totem platform consists of the Totem mobile application, the Totem TV web interface and the Totem management interface (together, the Service).
The Service is only intended to be offered to users aged at least 16 (or the age of majority in your territory of residence). If you are under such age, please do not use the Service or provide personal information through the Service without the consent of your parent or guardian.
The Service is intended for use by organisations and is provided to you by your employer or other company, organisation or institution (e.g. a club, university, charity, or a public body) which has chosen to use the Service and to authorise your access to it (your Organisation).
To use the Service you will need to create a Totem account (Your Account) which your Organisation will administer and for which your Organisation is responsible. Your Organisation is also responsible for the collection and use of any data that you submit or provide through the Service - this means that your Organisation is the data controller. Play is the data processor acting on the instructions of your Organisation in respect of the Service.
For all users outside of the EU
By using the Service, you expressly consent to the processing of your personal information by your Organisation.
As the Services are hosted by Play in the Republic of Ireland, your personal information will be transferred by your Organisation from your country of residence to Play and to third parties located in the Republic of Ireland or elsewhere in the EU. By using the Service from outside the EU, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence, with the understanding that personal information collected from the Service may be collected, stored and used in a country whose privacy laws may be different and less protective than those of your country of residence.
Reasonable steps will be taken to prevent third parties outside your country of residence using your personal data in any way that's not set out in this Policy.
What kinds of information is collected
Your Organisation may collect and process the following kinds of information when you, your colleagues or others access the Service:
- your contact information, such as your full name and email address;
- your username and password (which is stored in a secured, hashed format);
- your biographical information that you choose to give;
- your work title, department information and other information related to your work or Organisation;
- all content that you create, upload, share or post in audio, video, text, images and other media or software files that you provide on or through the Service, or that are provided on your behalf, including information in or about the content that you provide, such as the location of a photo or the date when a file was created;
- information that other people provide about you when using the Service, including when they send a message to you or upload information about you;
- all communications with other users of the Service;
- user communications, feedback, suggestions and ideas sent to your Organisation; and
- information that you provide when you or your Organisation contact or engage with technical support regarding the Service.
The following kinds of information may also be automatically collected by your Organisation when you access the Service:
- performance data such as the Internet Protocol (IP) address used to connect your device to the internet, traffic data, location data and interaction data (such as scrolling and clicks);
- anonymous analytics data such as such details of the device and/or browser you use to access the Service, the number of times you use the Totem websites, apps and related online services and the duration of such use as well as the particular pages visited during such use
How does your Organisation use this information
Your Organisation will share the information that it collects and stores relating to you with Play in order to allow Play to provide, develop and improve the Service for your Organisation and in accordance with any other instructions your Organisation gives to Play. Examples of such use include to:
- communicate with users and administrators regarding their use of the Service;
- personalise your and/or your Organisation's experiences as part of our provision of the Service;
- develop new tools, products or services for your Organisation;
- associate activity on the Services across different devices operated by the same individual to improve the overall operation of the Service;
- identify and fix bugs that may be present; and
- conduct data and system analytics to determine how the Service is functioning and to undertake research to improve the Service.
Sharing of your personal information
Your Organisation may disclose the information that it collects in the following circumstances:
- to third-party service providers where such service providers assist in providing the Service or part of the Service;
- to third-party apps, websites or other services that you can connect to through the Service;
- to protect the rights, property or safety of any person; and
- to address fraud, security or technical issues.
Storing your information
The information that your Organisation collects is stored and processed within the Republic of Ireland or other parts of the European Economic Area (EEA) on secure servers hosted by Play (acting as data processor) or third parties providing hosting or other services in respect of the Service.
Every reasonable precaution is taken to protect against the loss, misuse or alteration of your personal information and to ensure that it will be processed in accordance with this Policy. Unfortunately, the transmission of information via the internet is not completely secure and therefore the security of data you submit cannot be absolutely guaranteed. You acknowledge and accept that there is a risk that others may try to intercept the personal information you provide. Transmission of your information is entirely at your own risk. Strict procedures and security features are in place to try to prevent unauthorised access.
It is your responsibility to keep your user name and password confidential. If you lose the device which you use to access the Service you should notify Your Organisation without delay.
Your Organisation is responsible for dealing with any suspected personal data breach and will notify you and applicable regulator or a breach where it is legally required to do so.
Retention of your personal information
Your personal information will be retained in respect of the Service until such time as Your Account is deleted (for example, after you leave Your Organisation, or after Your Organisation ceases using the Service). For more information see "Account deactivation and Account closure" below. In addition, your personal information may also be retained by your Organisation for as long as necessary to satisfy any legal, accounting, or reporting requirements to which it is subject.
In some circumstances your personal data may be anonymised (so that it can no longer be associated with you) for research or statistical purposes in which case this information may be used indefinitely without further notice to you.
Please note that any content you create and share through your use of the Service is owned by your Organisation and may remain on the Service and be accessible even after the deletion of Your Account.
Your rights in relation to your personal information
You may access, correct or delete information that you have uploaded to the Service using the tools within the Service (for example, editing your profile information). If you are not able to do so using the tools provided in the Service, you should contact your Organisation directly to access or modify your information.
In addition, under certain circumstances, you have the following rights under data protection laws in relation to your personal data held by your Organisation in respect of the Service:
- you may request access to your personal data;
- you may request that your Organisation rectifies personal data that is held about you in connection with the Service;
- you may request that your Organisation erases personal data that is held about you in connection with the Service;
- where your personal data is processed based on your consent, you may withdraw that consent at any time by contacting your Organisation;
- you may have other rights to restrict or object to the processing of your personal data;
- you may request the transfer of your personal data;
- you may request information about, or for human intervention into, any automated data processing that is undertaken in respect of the Service.
If you wish to exercise any of the rights set out above you should contact your Organisation directly.
Account deactivation and Account closure
If you would like to stop using the Services, you should contact your Organisation and request that your Account is deactivated; this will mean that your Account is no longer live but your personal information will remain within the System. Similarly, if you stop working for or with the Organisation, the Organisation may request that Your Account is deactivated. If you wish for your Account to be closed, you should contact your Organisation. Some information may remain in backup copies for a reasonable period of time as directed by your Organisation.
What are cookies?
Cookies are widely used to allow online and mobile sites to function efficiently and are often small data files that (depending on your browser settings) are deposited on your computer, mobile phone, tablet or other device when you visit a site. The cookies may be sent back to that site when you visit again, and may then be used by the server to identify and track your use of the Service.
Certain information is automatically collected by your Organisation through the Service, such as your IP address and other browser or device identifiers, browser type, operating system, crash data, Internet service provider, pages that you visit before and after using the Service, the date and time of your visit, information about your activities (such as the links that you click and pages that you view) within the Service and other standard server log information.
When you create Your Account, cookies will be used for the management of the signup process and general administration. These cookies will usually be deleted when you log out (these are known as "session cookies"). However, in some cases they may remain afterwards to remember your site preferences when logged out (these long-term cookies are known as "persistent" cookies). Cookies are used when you are logged in so that this can be remembered. This prevents you from having to log in every single time you visit a new page.
The Service also utilises cookies to allow your Organisation to customise and personalise your experience of the Service, to maximise security and to help authenticate you as a registered user of and to give you access to your user profile on the Service.
Third party cookies
In some special cases cookies are also provided by trusted third parties.
Your Organisation may also elect to use social media buttons and/or plugins on the Service that allow you to connect with your social network in various ways. For these to work the following social media sites, including Google+, Facebook, Twitter, will set cookies through the site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies (which will be available on their respective websites). Your Organisation is not, nor is Play, responsible for, and Your Organisation does not, nor does Play, accept any liability for such third party services' content or their operators' privacy practices (including any tracking technologies that they may use). Before providing any personal information to them, please refer to their relevant privacy and cookies policies.
Be aware that disabling cookies will affect the functionality of the Service and may mean that you are unable to access all or parts of the Service.
Further information on rejection and deletion of cookies is provided at www.aboutcookies.org.
Third-party links and content
The Service may contain links to content maintained by third parties that your Organisation does not control. Your Organisation is not, nor is Play, responsible for the privacy practices of these third parties, and you are recommended to view the privacy policies of each website that you visit.
Changes to this Policy
This Policy may, from time to time, be updated or otherwise modified.
This policy was last modified on Monday 21st May 2018.