Privacy & Cookies

Totem Privacy and Cookies Policy:
Freemium Model

Introduction

Totem is an online platform created by Play Consulting Limited (Play) which comes in two flavours: 

  1. a paid-for version used by organisations to allow them to better connect, recognise and motivate their most important assets – their people;
  2. a free version, provided directly by Play, which allows individual users to create their own teams – whether in their workplace, in a sports team or club, in a university, or elsewhere

The free version of Totem – to which this privacy policy relates – consists of the Totem mobile application, the Totem TV web interface and the Totem management interface (together, the Service).

This Privacy Policy (Policy) relates to the free version of Totem and describes how personal information about you that you provide, or which is collected, when you use the Service is used and managed by Play.  All users are encouraged to act responsibly and with care when it comes to their personal information and that of others.

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.

About the service

The Service is provided by Play directly to users and is governed by this Privacy Policy and by the ‘Totem Terms of Use’ which you must accept in order to use the Service. 

To use the Service you will need to create a Totem account (Your Account) which Play will administer.  Play is the data controller and is responsible for the collection and use of any data that you submit or provide through the Service

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

Play may collect and process the following kinds of information when you, your teammates 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;
  • the name of the organisation or which you are a member and in respect of which you would like to use the Service
  • your work title, department information and other information related to your workplace or the organisation that you belong to;
  • 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; and
  • information that you provide when you contact or engage with Totem technical support regarding the Service.

The following kinds of information may also be automatically collected by Play 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.

Play will not collect special categories of data from you – such as personal data concerning your race, political opinions, religion, health or sexual orientation – unless you have chosen to provide that type of personal data when you use the Service (for example, when you provide you biographical information, or when you post information on Totem generally).


How does Play use this information

Play uses personal data collected through the Service only when it has a valid reason and the legal grounds to do so.  Play determines the legal grounds based on the purposes for which it has collected your personal data.

Legal grounds for using your personal data

The legal ground may be one of the following:

    Performance of a contract with you:  although there is no charge for the Service, your use of the Service, and Play’s agreement to allow you to use it, is a contract, and Play needs to use the personal data you provide in order to provide the Service to you.  Play is therefore fulfilling its contractual obligations.

    Compliance with law: In some cases, Play may have a legal obligation to use or keep your personal data.

    Play’s legitimate interests: Where it is necessary for Play to operate the Service efficiently through the Totem app, and generally.  Examples of when Play relies on its legitimate interests to use your personal data include:

  • for internal administrative purposes related to when you use the Service – such as Play’s records – and to make you aware of any changes to the Service
  • to collect and log IP addresses to improve the Service monitor usage of it
  • when responding to your queries and to resolve complaints
  • for security and fraud prevention, and to ensure that the Service is safe and secure and used in line with the Totem Terms of Use
  • identify and fix bugs that may be present
  • conduct data and system analytics to determine how the Service is functioning and to undertake research to improve the Service
  • associate activity on the Service across different devices operated by the same individual to improve the overall operation of the Service

Play does not rely on your consent for the processing of any of the personal data you provide.

Where Play relies on cookies to collect any personal data please see our cookie policy for more information and how to manage your cookie choices.

Access permissions when you are using the Totem app

When you use the Totem app, we ask for the following permissions to access particular functions of your mobile device: camera, photo library.


Sharing of your personal information

Play 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 a third party (such as the police or other law enforcement agency) where Play is under a duty to comply with any legal obligation, or in order to enforce or apply the Totem Terms of Use;
  • to protect the rights, property or safety of any person; and
  • to address fraud, security or technical issues.

Contact with organisations, employers etc identified by you

When you sign-up to use the Service, you must provide the details of the organisation that you belong to (this may be your employer, your university, a club or another type of organisation).

Play may from time to time contact these organisations in order to market the premium version of Totem to those organisations.  This may include the employer that you have identified in your profile.  

However, no personal data will be shared with those organisations – and no user of the Service will be identified or identifiable.  The only data that Play will be share with these organisations will be aggregated and anonymised – Play will simply use the fact that members of that organisation are using the Service as a means of persuading such those organisations to subscribe for and make the premium version available to its employees/members.  

In the event that one of those organisations decides to adopt the premium version of Totem, none of the personal information – or other content – that you have provided to Play and/or uploaded to the Service will be transferred to or shared with the organisation.

International Transfers

The information that Play 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 or by third parties providing hosting or other services to Play.

This processing of your personal information will involve a transfer of data outside the UK.  Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Play will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. 
  • where Play uses certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

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 Play without delay.

Play 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 / user generated content

Your personal information will be retained in respect of the Service until such time as Your Account is deleted.  For more information see “Account deactivation and Account closure” below.  In addition, your personal information may also be retained by Play 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 may remain on the Service and be accessible even after the deletion of Your Account.  Users can request for all content to be deleted by contacting support@totem.team.

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 support@totem.team 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 Play in respect of the Service:

  • you may request access to your personal data
  • you may request that Play rectifies personal data that is held about you in connection with the Service
  • you may request that Play 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 Play 
  • 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 support@totem.team

You also have a right to complain to the Information Commissioner’s Office.  You can find their contact details at www.ico.org.uk.  We would be grateful for the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.


Account deactivation and Account closure, Deletion of your Personal Information

If you would like to stop using the Services, you should contact support@totem.team 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.  

If you wish for your Account to be closed and your Personal Information deleted, you should contact support@totem.team. Some information may remain in backup copies for a reasonable period of time.

Cookies

This section sets out how cookies are used when you use the Service. By using the Service you are confirming your consent to the use of cookies as explained in this Policy.

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 Play 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 Play 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. 

Among the third party cookies that may be used are cookies provided by Google Analytics, which is one of the most widespread and trusted analytics solutions on the web that helps create an understanding of how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. The information generated by the Google Analytics cookies about your use of the Service (including your IP address) is anonymous (i.e. it does not identify you personally) and will be sent to Google and held on Google’s servers in the USA in accordance with Google’s privacy policy (available at http://www.google.co.uk/intl/en/privacy/). Please note that Google may also transfer Google-held information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. For more information on Google Analytics cookies, see the official Google Analytics page. Google offers an ‘opt-out’ browser which enables website users to prevent data from being used by Google Analytics.  To use this browser, please visit https://tools.google.com/dlpage/gaoptout/, however please read the paragraph below on disabling cookies before doing so.

Disabling cookies

If you object to the use of cookies on the Service, most browsers can be configured to alert you to their use or to enable you to reject browser-based cookies (see your browser help menu for how to do this). Third parties may use certain special types of cookies (such as flash cookies) that cannot be disabled by configuring browsers, although other methods of preventing or managing such cookies may be available to you (such as via the relevant third-party settings panel). You can also delete cookies already stored on your device.

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 Play does not control.  Play is not responsible for the privacy practices of these third parties, and you are recommended to view the privacy policies of each website that you visit.

Contacts

If you have any questions about this Policy, or thoughts about the privacy of your personal information, or the use of cookies, please contact support@totem.team

Changes to this Policy

This Policy may, from time to time, be updated or otherwise modified.

You will be notified about any changes by posting the modified Policy on the Service.  If you then continue to use the Service, you will be confirming your consent to the use of cookies or your information as set out in the modified Policy. You are encouraged to check the terms of this Policy whenever you use the Service.


This policy was last modified on Tuesday 27th April 2021.

Totem Privacy and Cookies Policy

Introduction

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).

This Privacy Policy (Policy) describes how personal information about you that you provide or which is collected when you use the Service is used and managed. All users are encouraged to act responsibly and with care when it comes to their personal information and that of others.

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.

Your Organisation

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).

The Service is provided by your Organisation and is governed by this Privacy Policy and by the 'Totem Terms of Use' which you must accept in order to use the Service. In addition, your Organisation may have its own policies in place regarding your use of the Service and the treatment of any information that you submit or provide through the Service.

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;
  • enhance the security and safety of the Service for your Organisation and other users, such as by investigating suspicious activity or breaches of the Totem Terms of Use;
  • 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 a third party (such as the police or other law enforcement agency) where under a duty to comply with any legal obligation, or in order to enforce or apply the Totem Terms of Use;
  • 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.

Data security

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.

Cookies

This section sets out how cookies are used when you use the Service. By using the Service you are confirming your consent to the use of cookies as explained in this Policy.

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.

Among the third party cookies that may be used are cookies provided by Google Analytics, which is one of the most widespread and trusted analytics solutions on the web that helps create an understanding of how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. The information generated by the Google Analytics cookies about your use of the Service (including your IP address) is anonymous (i.e. it does not identify you personally) and will be sent to Google and held on Google's servers in the USA in accordance with Google's privacy policy (available at http://www.google.co.uk/intl/en/privacy/). Please note that Google may also transfer Google-held information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. For more information on Google Analytics cookies, see the official Google Analytics page. Google offers an 'opt-out' browser which enables website users to prevent data from being used by Google Analytics. To use this browser, please visit https://tools.google.com/dlpage/gaoptout/, however please read the paragraph below on disabling cookies before doing so.

We use Hotjar in order to better understand our users' needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don't like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users' behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar's privacy policy by clicking on this link. You can opt-out to the creation of a user profile, Hotjar's storing of data about your usage of our site and Hotjar's use of tracking cookies on other websites by following this opt-out link.

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.

Disabling cookies

If you object to the use of cookies on the Service, most browsers can be configured to alert you to their use or to enable you to reject browser-based cookies (see your browser help menu for how to do this). Third parties may use certain special types of cookies (such as flash cookies) that cannot be disabled by configuring browsers, although other methods of preventing or managing such cookies may be available to you (such as via the relevant third-party settings panel). You can also delete cookies already stored on your device.

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.

Contacts

If you have any questions about this Policy, or thoughts about the privacy of your personal information, or the use of cookies, please contact your Organisation directly.

Changes to this Policy

This Policy may, from time to time, be updated or otherwise modified.

You will be notified about any changes by posting the modified Policy on the Service. If you then continue to use the Service, you will be confirming your consent to the use of cookies or your information as set out in the modified Policy. You are encouraged to check the terms of this Policy whenever you use the Service.

This policy was last modified on Monday 21st May 2018.

Totem Privacy and Cookies Policy

(PARENTAL CONSENT VERSION)

Introduction

Totem is an online platform created by Play Consulting Limited (Play) which allows organisations to better connect, recognise and motivate. The Totem platform consists of the Totem mobile application, the Totem TV web interface and the Totem management interface (together, the Service).

Your child's school (the School) has chosen to make Totem available for use by its students and this Privacy Policy (Policy) describes how personal information that students provide about themselves, or which is collected when they use the Service, is used and managed. All students are encouraged to act responsibly and with care when it comes to their personal information and that of others.

This Privacy Policy (Policy) describes how personal information about you that you provide or which is collected when you use the Service is used and managed. All users are encouraged to act responsibly and with care when it comes to their personal information and that of others.

Students may not use the Service or provide personal information through the Service without the consent of their parent or guardian.

The School

The Service is provided by your Organisation and is governed by this Privacy Policy and by the 'Totem Terms of Use' which you must accept in order to use the Service. In addition, your Organisation may have its own policies in place regarding your use of the Service and the treatment of any information that you submit or provide through the Service.

To use the Service all students will need to create a Totem account (Account) which the School will administer and for which the School is responsible. The School is also responsible for the collection and use of any data that students submit or provide through the Service - this means that the School is the data controller. Play is the data processor acting on the instructions of the School in respect of the Service.

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

The School may collect and process the following kinds of information when students access the Service:

  • the student's contact information, such as full name and email address;
  • the student's username and password (which is stored in a secured, hashed format);
  • the student's biographical information that they choose to give;
  • the student's title and other information related to the School;
  • all content that students create, upload, share or post in audio, video, text, images and other media or software files that students provide on or through the Service, or that are provided on students' behalf, including information in or about the content that students provide, such as the location of a photo or the date when a file was created;
  • information that other people provide about students when using the Service, including when they send a message to a student or upload information about a student;
  • all communications with other users of the Service;
  • user communications, feedback, suggestions and ideas sent to the School; and
  • information that students provide when they or the School contact or engage with technical support regarding the Service.

The following kinds of information may also be automatically collected by the School when students access the Service:

  • performance data such as the Internet Protocol (IP) address used to connect a student's 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 a student uses to access the Service, the number of times a student uses 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 the School use this information

The School will share the information that it collects and stores relating to students with Play in order to allow Play to provide, develop and improve the Service for the School and in accordance with any other instructions the School gives to Play. Examples of such use include to:

  • communicate with students and administrators regarding their use of the Service;
  • enhance the security and safety of the Service for the School and other users, such as by investigating suspicious activity or breaches of the Totem Terms of Use;
  • personalise students' and/or the School's experiences as part of Play's provision of the Service;
  • develop new tools, products or services for the School;
  • 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 student's personal information

The School 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 a third party (such as the police or other law enforcement agency) where under a duty to comply with any legal obligation, or in order to enforce or apply the Totem Terms of Use;
  • to protect the rights, property or safety of any person; and
  • to address fraud, security or technical issues.

Storing your information

The information that the School 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 the School's data processor) or third parties providing hosting or other services in respect of the Service.

Data security

Every reasonable precaution is taken to protect against the loss, misuse or alteration of students' 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 submitted by students cannot be absolutely guaranteed. You acknowledge and accept that there is a risk that others may try to intercept the personal information students provide. Transmission of students' information is entirely at their own risk. Strict procedures and security features are in place to try to prevent unauthorised access.

It is each student's responsibility to keep their username and password confidential. If a student loses the device which they use to access the Service you and/or they should notify the School without delay.

The School is responsible for dealing with any suspected personal data breach and will notify parents and students, and applicable regulator, of a breach where it is legally required to do so.

Retention of your personal information

Personal information relating to students will be retained in respect of the Service until such time as their Account is deleted (for example, after a student leaves the School, or after the School ceases using the Service). For more information see "Account deactivation and Account closure" below. In addition, student's personal information may also be retained by the School for as long as necessary to satisfy any legal, accounting, or reporting requirements to which it is subject.

In some circumstances students' personal data may be anonymised (so that it can no longer be associated with a student) for research or statistical purposes in which case this information may be used indefinitely without further notice to you.

Please note that any content which a student creates and shares through their use of the Service is owned by the School and may remain on the Service and be accessible even after the deletion of their Account.

Student's rights in relation to their personal information

Student's may access, correct or delete information that they have uploaded to the Service using the tools within the Service (for example, editing their profile information). If a student is not able to do so using the tools provided in the Service, they or you should contact the School directly to access or modify the student's information.

In addition, under certain circumstances, students have the following rights under data protection laws in relation to their personal data held by the School in respect of the Service:

  • students may request access to their personal data;
  • students may request that the School rectifies personal data that is held about them in connection with the Service;
  • students may request that the School erases personal data that is held about them in connection with the Service;
  • where student's personal data is processed based on their or your consent (as their parent/guardian), they or you may withdraw that consent at any time by contacting the School;
  • students may have other rights to restrict or object to the processing of their personal data;
  • students may request the transfer of their personal data;
  • students may request information about, or for human intervention into, any automated data processing that is undertaken in respect of the Service.

If students wish to exercise any of the rights set out above you should contact the School directly.

Account deactivation and Account closure

If a student (or their parent/guardian) would like to stop using the Services, they should contact the School and request that your Account is deactivated; this will mean that the student's Account is no longer live but their personal information will remain within the System. Similarly, if a pupil leaves the School, the School may request that that student's Account is deactivated.

If a student (or their parent/guardian) wishes for their Account to be closed, they should contact the School. Some information may remain in backup copies for a reasonable period of time as directed by the School.

Cookies

This section sets out how cookies are used when students use the Service. By approving your child's use of the Service you will be confirming your consent to the use of cookies as explained in this Policy.

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 the School through the Service, such as a student's IP address and other browser or device identifiers, browser type, operating system, crash data, Internet service provider, pages that they visit before and after using the Service, the date and time of their visit, information about their activities (such as the links that they click and pages that they view) within the Service and other standard server log information.

When a student creates their Account, cookies will be used for the management of the signup process and general administration. These cookies will usually be deleted when the student logs out (these are known as "session cookies"). However, in some cases they may remain afterwards to remember the student's site preferences when logged out (these long-term cookies are known as "persistent" cookies). Cookies are used when students are logged in so that this can be remembered. This prevents students from having to log in every single time they visit a new page.

The Service also utilises cookies to allow the School to customise and personalise student's experience of the Service, to maximise security and to help authenticate a student as a registered user of, and to give the student access to their user profile, on the Service.

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.

Among the third party cookies that may be used are cookies provided by Google Analytics, which is one of the most widespread and trusted analytics solutions on the web that helps create an understanding of how students use the site and ways that that Play can improve students' experience. These cookies may track things such as how long a student spends on the site and the pages that they visit so that Play can continue to produce engaging content. The information generated by the Google Analytics cookies about a student's use of the Service (including their IP address) is anonymous (i.e. it does not identify the student personally) and will be sent to Google and held on Google's servers in the USA in accordance with Google's privacy policy (available at http://www.google.co.uk/intl/en/privacy/). Please note that Google may also transfer Google-held information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. For more information on Google Analytics cookies, see the official Google Analytics page. Google offers an 'opt-out' browser which enables website users to prevent data from being used by Google Analytics. To use this browser, please visit https://tools.google.com/dlpage/gaoptout/, however please read the paragraph below on disabling cookies before doing so. The School may also elect to use social media buttons and/or plugins on the Service that allow students to connect with their 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 a student's profile on their site or contribute to the data those social media sites hold for various purposes outlined in their respective privacy policies (which will be available on their respective websites). The School is not, nor is Play, responsible for, and the School 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 such social media sites, please refer to their relevant privacy and cookies policies

We use Hotjar in order to better understand our users' needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don't like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users' behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar's privacy policy by clicking on this link. You can opt-out to the creation of a user profile, Hotjar's storing of data about your usage of our site and Hotjar's use of tracking cookies on other websites by following this opt-out link.

Disabling cookies

If a student (or their parent/guardian) objects to the use of cookies on the Service, most browsers can be configured to alert you to their use or to enable you to reject browser-based cookies (see your browser help menu for how to do this). Third parties may use certain special types of cookies (such as flash cookies) that cannot be disabled by configuring browsers, although other methods of preventing or managing such cookies may be available (such as via the relevant third-party settings panel). A student can also delete cookies already stored on their device.

Be aware that disabling cookies will affect the functionality of the Service and may mean that a student is 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 the School does not control. The School is not, nor is Play, responsible for the privacy practices of these third parties, and students (or their parent/guardian) are recommended to view the privacy policies of each website that the student visits

Contacts

If a student (or their parent/guardian) has any questions about this Policy, or thoughts about the privacy of the student's personal information, or the use of cookies, please contact the School directly.

Changes to this Policy

This Policy may, from time to time, be updated or otherwise modified.

Students will be notified about any changes by posting the modified Policy on the Service; parents/guardians will be notified by the School.

This policy was last modified on Tuesday 4 September 2018.

Totem Children's Privacy Notice

(CHILDREN'S VERSION)

Introduction

Totem is a mobile app created by a company called Play Consulting Limited (who we are going to call 'Play' from now on) that allows people to connect with each other, share information and celebrate successes. Your school has chosen to make Totem available for you and other students in your school to use, and this privacy notice explains what personal information your school receives and what it will do with it.

First things first: as you are using Totem in school, you need to have your mum, dad or other guardian's approval to use Totem.

And don't worry - the only people who will be able to use Totem are other pupils and teachers that your school has said should be allowed to use it.

To use Totem you will need to create an account and only other pupils in your school / class will be able to connect to each other. All accounts are managed by the school and you will need to ensure that you follow any other policies that your school has in place.

What kinds of information is collected

When you use Totem, there are a few different types of information your school might receive of yours, depending on how you use Totem. Your school might receive:

  • your name and email address
  • your username and password (when you create your account);
  • any other information that you provide about yourself;
  • all content that you create or share on, or upload to, Totem (this could include audio and video posts, questionnaire answers, as well as pictures and other images that you create or share);
  • information that other people provide about you on Totem;
  • technical information that your phone or tablet provides, like where you are and what kind of device (e.g. an iPhone, iPad or Android phone) you are using.

How does your school use your personal information

The school will use the information listed above because you have asked to use Totem and your mum, dad or other guardian have agreed that your personal information can be used in the way explained in this notice.

The school will use your information:

  • to make Totem available to you and to keep it useful and interesting;
  • to contact you about Totem;
  • to help keep Totem safe for you and other people using it;
  • to find and fix any bugs in Totem; and
  • to do its own homework about how Totem is being used in the school.

Who your school shares your information with

Your school may share your information with:

  • Play (the people who make Totem), or other people who help to make Totem work;
  • the police or other people like that if the law says that the school has to do this;
  • anybody who needs to be involved to keep you or other users of Totem safe, or to help keep Totem itself safe and secure, or for any other technical or security reason.

How does your school keep your personal information

Your school controls all of the information that is in Totem and this is will be stored for your school by Play (the people who make Totem) on their secure servers in the UK or in Ireland, or sometimes in other countries in Europe.

How does your school look after your personal information

Your school and Play (the people who make Totem) will try really hard to keep your personal information safe and secure.

You must make sure you don't tell anybody else what your username or password are (telling your mum, dad, or other guardian is ok). If you lose your phone or other device, tell your mum, dad, or other guardian straight away, and make sure somebody tells the school so that they can change your Totem password.

And remember, although everybody tries really hard to stop people who should not be allowed access to Totem from finding a way in, the internet is not always secure so you need to be careful about what you share and where you use Totem.

If any personal data is ever lost or taken from Totem (this is known as "personal data breach") your school will be responsible for dealing with this.

How long does your school keep your personal information for?

Your personal information will stay in Totem until your account is deleted (for example, after you leave the school, of if you ask to delete your account).

Some of your personal information may have to stay in Totem if the law (or other rules that apply to the school) requires the school to keep it.

Sometimes your personal information will be kept anonymously by the school, for example if it helps the school to better understand how Totem is being used. If this happens, nobody will be able to tell that the information is about you.

It you create or share things in Totem (perhaps a picture, or a video, or a story), this will actually belong to your school and may stay on Totem even after you have stopped using it.

Your rights to the information the school holds about you

You can access, correct or delete information that you have uploaded to Totem by using the tools within the app. If you need help with this, ask your teacher or your mum, dad or other guardian.

As well as this, you have the right at any time:

  • to find out what information the school holds about you in Totem;
  • to ask the school to stop doing anything with the information that it holds about you;
  • to request a detailed summary of that information.

You also have the right to:

  • complain to the person who protects your privacy rights in the UK, the Information Commissioner's Office (https://www.ico.org.uk);
  • change your mind about using Totem in the first place;
  • ask the school to correct, delete, limit or stop using any of your personal information stored in Totem.

If you want to do any of these things, you should ask your teacher or mum, dad or other guardian for help.

Stopping using Totem

If you (or your mum, dad or other guardian) want to stop using Totem, speak to your teacher who will be able to have your Totem account deactivated. If this happens, your personal information remains in Totem but your account will be hidden.

If you want your account and personal information to be deleted, speak to your teacher. The school will try to do this as quickly as possible but it may not be immediate, and some of your information may remain in back-ups of Totem for a little while.

Cookies

This section sets out how cookies are used when students use the Service. By approving your child's use of the Service you will be confirming your consent to the use of cookies as explained in this Policy.

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 the School through the Service, such as a student's IP address and other browser or device identifiers, browser type, operating system, crash data, Internet service provider, pages that they visit before and after using the Service, the date and time of their visit, information about their activities (such as the links that they click and pages that they view) within the Service and other standard server log information.

When a student creates their Account, cookies will be used for the management of the signup process and general administration. These cookies will usually be deleted when the student logs out (these are known as "session cookies"). However, in some cases they may remain afterwards to remember the student's site preferences when logged out (these long-term cookies are known as "persistent" cookies). Cookies are used when students are logged in so that this can be remembered. This prevents students from having to log in every single time they visit a new page.

The Service also utilises cookies to allow the School to customise and personalise student's experience of the Service, to maximise security and to help authenticate a student as a registered user of, and to give the student access to their user profile, on the Service.

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.

Among the third party cookies that may be used are cookies provided by Google Analytics, which is one of the most widespread and trusted analytics solutions on the web that helps create an understanding of how students use the site and ways that that Play can improve students' experience. These cookies may track things such as how long a student spends on the site and the pages that they visit so that Play can continue to produce engaging content. The information generated by the Google Analytics cookies about a student's use of the Service (including their IP address) is anonymous (i.e. it does not identify the student personally) and will be sent to Google and held on Google's servers in the USA in accordance with Google's privacy policy (available at http://www.google.co.uk/intl/en/privacy/). Please note that Google may also transfer Google-held information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. For more information on Google Analytics cookies, see the official Google Analytics page. Google offers an 'opt-out' browser which enables website users to prevent data from being used by Google Analytics. To use this browser, please visit https://tools.google.com/dlpage/gaoptout/, however please read the paragraph below on disabling cookies before doing so. The School may also elect to use social media buttons and/or plugins on the Service that allow students to connect with their 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 a student's profile on their site or contribute to the data those social media sites hold for various purposes outlined in their respective privacy policies (which will be available on their respective websites). The School is not, nor is Play, responsible for, and the School 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 such social media sites, please refer to their relevant privacy and cookies policies

We use Hotjar in order to better understand our users' needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don't like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users' behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar's privacy policy by clicking on this link. You can opt-out to the creation of a user profile, Hotjar's storing of data about your usage of our site and Hotjar's use of tracking cookies on other websites by following this opt-out link.

Disabling cookies

If a student (or their parent/guardian) objects to the use of cookies on the Service, most browsers can be configured to alert you to their use or to enable you to reject browser-based cookies (see your browser help menu for how to do this). Third parties may use certain special types of cookies (such as flash cookies) that cannot be disabled by configuring browsers, although other methods of preventing or managing such cookies may be available (such as via the relevant third-party settings panel). A student can also delete cookies already stored on their device.

Be aware that disabling cookies will affect the functionality of the Service and may mean that a student is 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 the School does not control. The School is not, nor is Play, responsible for the privacy practices of these third parties, and students (or their parent/guardian) are recommended to view the privacy policies of each website that the student visits

Changes to this information

If your school makes any changes to this policy they will let you know, and will also let your mum, dad or other guardian know.

The last time this information was changed was on 21st September 2018