Privacy Policy

Welcome to Totem and our website at www.totemcg.org (our “website”). This Privacy Policy sets out the basis on which we will process any Personal Data that we may collect about you as a visitor to our website and user of our services. This policy further sets out how we protect your privacy and your rights in respect of our use of your Personal Data.

WHO IS THE DATA CONTROLLER?

A “data controller” is a person or organisation who alone or jointly determines the purposes for which and the manner in which any personal data is, or is likely to be, processed. In this sense, Totem Consulting Group of Quatro House, Lyon Way, Camberley, GU16 7ER, United Kingdom (“Totem”, “we”, “us”, “our”) is the data controller. If you have any questions about cookies or about data protection at Totem in general, please email us using info@totemcg.org.

WHAT IS PERSONAL DATA?

Personal Data is information that makes it possible to identify a natural person. This includes, in particular, your name, date of birth, address, telephone number, and e-mail address, but also your IP address. Anonymous data exists if no personal reference to the user can be made.

WHAT IS PROCESSING?

“Processing” means and covers virtually any handling of data.

WHAT LAW APPLIES?

We will only use your Personal Data in accordance with the UK’s Data Protection Act 2018 (“DPA”), the EU’s General Data Protection Regulation (“GDPR”), and, of course, only as described in this Privacy Policy.

WHAT ARE THE LEGAL BASES FOR PROCESSING PERSONAL DATA

We have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent; b) the data is necessary for the fulfilment of a contract/pre-contractual measures; c) the data is necessary for the fulfilment of a legal obligation; or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

We may collect and process the following Personal Data about you:

a) Personal Data that you give us:
This is information about you that you give to us by filling in forms on our website, requesting information, or corresponding with us by telephone, email, or otherwise. It may include, for example, your name, address, email address, and telephone number; information about your business relationship with us; and information about your requirements.

When you go ahead and download our resources and publications, your IP address is requested and logged for documentation purposes. This is a mere technical process and required to make our resources and publications available for download to your device or, depending on your browser, available for viewing. The basis for this storage is the provision of a contract and our legitimate interest.

We also process the Personal Data involved in your use of our services (your contact information such as full name, email, postal address and phone number and the data related to your use of our services and the contract between us) in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, and fulfilment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of your consent, fulfilling our contractual obligations and our legal obligations.

b) Personal Data that our website and other systems collect about you:
If you visit our website, it will automatically collect some information about you and your visit, including the Internet Protocol (IP) address used to connect your device to the Internet and some other information, such as the pages on our site that you visit. This is used to monitor the performance of the website and improve the experience of visitors to the website.

We use the hosting services of Hostinger for the purpose of hosting and displaying our website. Hostinger does so on the basis of processing on our behalf, and that also means that all data collected on our website and shop is processed on Hostinger’s servers. The basis for processing is our legitimate interest and the initiation and/or fulfilment of a contract.

We use the open-source Content Management System (CMS) of WordPress.org to publish and maintain the created and edited content and texts on our website. This means that all content, texts, and contact data submitted to us are transferred to and stored on our Hostinger servers. The legal basis for this processing is our legitimate interest.

We use Google Fonts by Google and Font Awesome of Fonticons on our website to display external fonts. To enable the display of certain fonts on our website, a connection to a Google/Font Awesome server is established when our website is accessed. The connection to Google/Font Awesome established when you call up our website enables Google/Font Awesome to determine which website sent your request and to which IP address the display of the font is to be transmitted. This represents a legitimate interest.

Our website uses Google Maps to visually display geographical information. When using Google Maps, Google LLC also collects, processes and uses data about visitors’ use of the map functions (You can find more information about data processing by Google in the Google privacy policy). The integration of Google Maps represents a legitimate interest.

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. As set out in the UK’s Privacy and Electronic Communications Regulations (“PECR”) and the EU’s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of non-essential cookies. For further information on the cookies we use, please refer to our Cookie Policy.

OTHER USES OF YOUR PERSONAL DATA

We may also collect, store, and use your Personal Data for the following purposes:

• to operate, manage, develop, and promote our business and, in particular, our relationship with you and related transactions, including, for example:
  • marketing purposes (when we have either gathered prior opt-in consent and/or have a legitimate interest to send you communications which we believe to be relevant and of use to you);
  • to operate, administer, and improve our website and other aspects of the way in which we conduct our business;
  • to offer you our services;
  • to provide you with services or information that you may have requested; and
  • to keep you informed and updated on relevant topics or services you may be interested in. 
• to protect our business from fraud, money laundering, breach of confidence, theft of proprietary materials, and other financial or business crimes;
• to comply with our legal and regulatory obligations, bring and defend legal claims and assert legal rights; and
• if the purpose is directly connected with an assigned purpose previously made known to you.

We will only process your Personal Data as necessary so that we can pursue the purposes described above and where we have a legal basis for such processing. Where our lawful basis for processing is that such processing is necessary to pursue our legitimate interests, we will only process your Personal Data where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest. In exceptional circumstances, we may also be required by law to disclose or otherwise process your Personal Data.

CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it as detailed above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 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.

DATA SHARING

In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.

Internal

If necessary, we transfer your Personal Data within Totem. Access to your Personal Data is only granted to authorised employees who need access to the data due to their job, e.g., to provide our products or services or to contact you in case of queries.

External bodies

Personal Data is transferred to our service providers in the following instances:

• in the context of fulfilling our contract with you,
• to use marketing services and to advertise our products and services online,
• to communicate with you,
• to provide our website, and
• to state authorities and institutions as far as this is required or necessary.

International transfers

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements, including non-disclosure agreements, data processing agreements, and standard contractual clauses regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will delete your Personal Data when we no longer need such Personal Data, for instance, where:

it is no longer necessary for us to retain your Personal Data to fulfil the purposes for which we had collected it;
we believe that your Personal Data that we hold is inaccurate; or
in certain cases where you have informed us that you no longer consent to our processing of your Personal Data.

Sometimes, however, there are legal or regulatory requirements which may require us to retain your Personal Data for a specified period, and in such cases we will retain your Personal Data for such specified period; and we may need to retain your Personal Data for certain longer periods in relation to legal disputes, and in such cases we will retain it for such longer periods to the extent required.

DATA SECURITY

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”), for example, encryption or need-to-know access, to ensure the most complete protection of Personal Data processed through our website.

SOCIAL MEDIA

We are present on social media based on our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint responsibility agreement. The Personal Data collected when you contact us is used to process your request, and the basis for this is both your consent and our legitimate interest.

 MARKETING

Insofar as you have given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to. Our marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.

LINKED SITES

For your convenience, there may be hyperlinks on our website that link to other websites. We are not responsible for, and this Privacy Policy does not apply to the privacy practices of any linked websites or of any companies that we do not own or control. The website links may collect information in addition to the information we collect.

We do not endorse any of these linked websites, their products, services, or any of the content on their websites. We encourage you to seek and read the Privacy Policy of each linked website that you visit to understand how the information that is collected about you is used and protected.

YOUR RIGHTS AND PRIVILEGES

Privacy rights
You can exercise the following rights:

• The right to access;
• The right to rectification;
• The right to erasure;
• The right to restrict processing;
• The right to object to processing;
• The right to data portability;

Update your information and withdraw your consent

If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, or withdraw your consent, please do so by contacting us.

Access Request

In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

What we do not do

• We do not request Personal Data from minors and children;
• We do not process special category data without obtaining prior express consent;
• We do not use automated decision-making, including profiling; and
• We do not sell your Personal Data.

Who is the competent data protection authority?
The supervisory authority for data protection in the UK is the Information Commissioner’s Office (ICO) (www.ico.org.uk). However, we would appreciate the opportunity to address your concerns before you contact the ICO.

Data Breaches and Notification
Databases or records containing Personal Data may be breached accidentally or through unlawful intrusion. As soon as we become aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notification will be accompanied by a description of the measures that will be taken to repair the damage caused by the data breach. Notifications will be sent as soon as possible after the violation is discovered.

HELP AND COMPLAINTS

If you have any questions about data protection at Totem, you can contact us by email using info@totemcg.org.

CHANGES

The first version of this policy was issued on Monday, 2nd of June, 2025, and is the current version. Any prior versions are invalid, and if we make changes to this policy, we will revise the effective date.