Recently updated: July 2018
Welcome to Totem Time, by 424RL Ltd. (“Totem Time”, “we”, “us” or “our”, as applicable). We care about your Privacy and are committed to your right to privacy.
- You are not required by law to provide us with any Personal Data. Sharing Personal Data with us or other users on the App is entirely voluntary.
- Our Services are intended for Users over the age of 16 or equivalent minimum age for providing consent to processing of Personal Data in the relevant jurisdiction. Children under such age are not permitted to register to or use the Services. If you are under such age you should cease to use the Services immediately, and uninstall the App from your device.
- You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the App and the Services may be restricted or disabled.
- We do not sell, trade, or rent Users’ Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Services to our Users, or other limited circumstances specified herein.
- If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Notice, please send us an email to: firstname.lastname@example.org
- What is Personal Data, and what data is collected about me by Totem Time?
“Personal Data”, means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, billing information, etc.
We collect non-Personal Data regarding Users concerning their use of the App and Services, such as the scope, frequency, latency, pages accessed, what and when a User views or interacts with content and materials displayed through our Services, device identifiers, and other technical information regarding the device used to access the Services, such as model, operating system, etc.
2. 1 In order to use certain Services, such as creating or participating in a Game, you will be asked to register to the App and create an account by providing certain Personal Data, such as your name, email address and a password of your choice (the “Account”). When connecting to the App from your Facebook account, Google account we collect certain Personal Data from your Facebook account, in order to provide you with the App and the Services, such as your full name.
2.2. We collect and Process User Content posted on the App. For example, when you create a Game on the App, and upload certain content in connection with your Game, or when you upload pictures or comments to the App.
2.3 We also may use and collect your real time location, among others, in the form of GPS signals and other information sent by your mobile device on which the App is installed, or by identifying the wireless networks available for your device at certain times. You may program your device to block our access to your location data but be aware that such blocking may prevent us from providing you some of the Services.
2.4 We do not knowingly collect or Process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been posted to the App or collected by us, please inform us immediately.
2.5 In the event you post any Personal Data included in Special Categories of Personal Data, such as information on health or medical state, sexual life or orientation, religious belief, etc., you explicitly acknowledge and agree that such data may be Processed by us.
2.6 Please note, that the App may contain links to other apps or websites maintained by third parties, which may not be governed by this Privacy Notice. This Privacy Notice does not apply to the practices of entities which are not controlled by Totem Time.
3. What will Totem Time do with my Personal Data?
3.1 Non-Personal Data. Non-Personal Data is used mainly for click stream analysis in order to constantly improve and maintain our App, Website or/and Services, including among others, in order to measure and understand the level of engagement to our services, for general business analytics and in order to provide a more personalized experience and tailored content, for ensuring the technical functioning of our network, to help prevent fraudulent use of our Services and for developing new services and features.
3.2 Personal Data. Personal Data is used only for the following limited purposes:
3.2.1To provide you with the Services.
3.2.3 For the purposes of our legitimate interests, to the extent not overridden by the rights and freedoms of natural persons, and as permitted under applicable law.
3.2.4 To protect the security or integrity of our databases and the Services, and to take precautions against legal liability.
3.2.5 To improve the Services, and to develop new features, products and services.
3.2.6To improve your experience on the App and customize our Services to your interests.
- What can I do to control my Personal Data?
5.1 Reviewing and amending your Personal Data. You may review the information included in your Account on the App. You may also send us a request in connection with your Personal Data to:email@example.com In the event any Personal Data is incorrect or outdated, you may update and correct such data by providing us with appropriate notification or correcting the data directly on the App.
5.2 Right of erasure and restriction. You may also be entitled request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
5.3 Portability of Personal Data. To the extent relevant to you and to the Services, you may be entitled to request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
5.4 Retention of Data We reserve the right to retain any Personal Data for as long as reasonably necessary in order to: (i) fulfill the purposes described herein; (ii) in the defense or assertion of legal claims and liability; (iii) for the analysis and development of the Services; and (iv) to comply with applicable law. Non-Personal Data and statistical anonymized data may be retained by us without limitation.
6. Will Totem Time Share my Personal Data?
6.1 Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and services for our Users and partners.
6.2. We share Personal Data only under the following limited circumstances:
6.2.1 With other users on the App, in order to provide you and our users with the App and the Services. For example, when you participate in a Game, other users may view your full name, score on the Game, and pictures you upload to public Game walls. Organizers of Games may also see the locations of Game participants on an interactive map. Organizers also receive additional information, such as number of participants, and data concerning the participation of participants in their Game (for example, how many participants finished the Game, how long did it take participants to complete each challenge, etc.).
6.2.2 With trusted third parties who assist us in operating the Services, conducting our business, and for personalizing your experience of the App.
6.2.3 To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.
- What is the lawful basis under which Totem Time processes Personal Data?
7.1 Certain processing activities conducted by us are based on the necessity of such activities for the performance of the understandings between us and our Users.
7.2 Other processing activities are based on the grounds that they are necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of natural persons which require protection of Personal Data.
7.3 There may be certain processing activities based on your consent to this Privacy Notice. In connection with such activities, you may rescind your consent, by sending us an email to: firstname.lastname@example.org. Please note that in the event you rescind your consent to the processing of Personal Data, we may not be able to provide you with some or all of the Services.
8. Will Totem Time transfer my Personal Data internationally?
Our databases are currently located in Frankfurt, Germany. We may transfer our databases from time to time to centers located in other jurisdictions, in accordance with applicable law. Some of our processing activities are made in Israel. The European Commission has decided that the State of Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data from the EU to Israel is lawful and does not require any specific authorization.
Any other transfer of Personal Data originating from the EU to a third country (other than Israel) shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our Users’ rights.
- Will I receive SPAM from Totem Time?
We currently do not send Users any commercial or promotional information via direct mailing such as emails or SMS messaging. We will not send any User such promotional mailing without obtaining the User’s explicit prior consent. We may however send our Users notifications to their mobile devices (“push notifications”), containing offers which may be of interest to them. If you wish not to receive such notifications, you may change the settings of your device at any time to block such notifications.
- Applicable Laws
The provisions included in this Notice relating to matters regulated under the GDPR will apply only to the processing of Personal Data which is subject to the GDPR in accordance with the applicability provisions contained therein. If the GDPR does not apply to the processing of your Personal Data, some of the provisions above may not apply to you.
- Persons under 16
. Our App is a general audience App, which is not directed to persons under 16 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 16 years old. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. If we become aware that a person under years 13 old has provided us with Personal Data, please contact us quickly as possible and we will delete such data from our databases.
- Questions or concerns regarding privacy
If you have any questions or concerns regarding privacy issues, please send us a message to email@example.com, and we will make every effort to resolve your concerns without delay.
We may, at any time and from time to time, modify this Privacy Notice. Modifications to this Privacy Notice we will notify you by email (sent to the e-mail address specified in your account) or by posted on the App or our Website, and shall be effective as of the date in which they are posted on the App.
You are also entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy and Personal Data.