Last modified: June 17, 2021
Last modified: June 17, 2021
Totogi LLC, a Delaware limited liability corporation, (“Totogi” or “Company”) respects your privacy and is committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the Totogi website (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
It does not apply to information collected by:
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at firstname.lastname@example.org.
We collect several types of information from and about users of our Website, directly from you when you provide it to us, and automatically when you use the Website, including information:
When you provide us information to schedule a demonstration of a Totogi product, we will store that information so our sales representatives can follow-up with you regarding your interest in Totogi. If at any point you do not want to be contacted by a Totogi sales representative, please email email@example.com.
We collect this information:
Information You Provide to Us
The information we collect on or through our Website may include:
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
Information about your computer and internet connection, including your IP address, operating system, and browser type.The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
Do Not Track: California law requires us to disclose to you how we respond to web browser Do Not Track (DNT) signals. Because there currently is no industry or legal standard for recognizing or complying with DNT signals, we do not respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.
We use information that we collect about you or that you provide to us, including any personal information:
We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, contact us at firstname.lastname@example.org. For more information, see Choices About How We Use and Disclose Your Information.
We may also use information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may also disclose your personal information:
California residents and EU residents may have additional personal information rights and choices. Please see Your California Privacy Rights and Your EU Privacy Rights below for more information.
If you are a California resident, California law provides you with additional rights regarding our use of your personal information, and this section applies to you.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
Right to Delete
You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either emailing us at email@example.com.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at firstname.lastname@example.org.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Required CCPA Disclosures
In the last twelve (12) months, we have collected the following categories of personal information through our Websites and App:
|A. Identifiers.||A real name, , Internet Protocol address, email address,||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, telephone number, Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
We do not sell your personal information. We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below:
|Personal Information Category||Category of Third-Party Recipients|
|Business Purpose Disclosures||Sales|
|A: Identifiers.||Performing Services||None|
|B: California Customer Records personal information categories.||Performing Services||None|
|C: Protected classification characteristics under California or federal law.||None||None|
|D: Commercial information.||Performing Services||None|
|E: Biometric information.||None||None|
|F: Internet or other similar network activity.||Security||None|
|G: Geolocation data.||None||None|
|H: Sensory data.||None||None|
|I: Professional or employment-related information.||None||None|
|J: Non-public education information.||None||None|
|K: Inferences drawn from other personal information.||None||None|
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
If you are a resident of the European Union (“EU”), you have additional rights under the General Data Protection Regulation (“GDPR”), and this section applies to you. Under GDPR, you have the following rights:
If you make a request under this section, we have one month to respond to you. If you would like to exercise any of these rights, our contact information is provided below.
We would like to send you information about products and services of ours we think you might like, as well as those of our partner companies.
If you have agreed to receive marketing, you may always opt out at a later date.
You have the right at any time to stop Totogi from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us at email@example.com.
If we transfer your personal data to the United States from the EU, we will do so pursuant to the EU Standard Contractual Clauses, exemplar text of which is available at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en, unless such transfer is internal to Totogi, in which case you hereby consent to such transfer, pursuant to Article 49(1) of the GDPR.
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Networking Advertising Initiative (“NAI”) on the NAI’s website.
You can review and change your information by sending us an email at firstname.lastname@example.org to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Totogi retains user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the category of user to whom the data relates, the type of data, and the purposes for which we collected the data.
You may request deletion of your account at any time. Totogi may retain user data after a deletion request due to legal or regulatory requirements or for the reasons stated in this policy.
Following an account deletion request, Totogi deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute.