Privacy Policy

Last Updated: December 15, 2021

Totem (“Company”, “we”, or “us”) is committed to protecting your privacy. This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from totem.earth, xela.earth, and/or obtainable.io (the “Sites”).​​

This policy also explains your choices surrounding how we use information about you, which include how you can object to certain uses of information about you and how you can access and update certain information about you.  If you do not agree with this policy, do not access or use our Services or Sites or interact with any other aspect of our business.  

Personal information we collect 

When you visit the Sites, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Sites, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Sites, and information about how you interact with the Sites. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies: - “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. - “Log files” track actions occurring on the Sites, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. - “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Sites.

We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the links you click on; frequently used search terms; and how you interact with others on the Services.  We also collect information about the people you interact with and how you interact with them, like who you communicate with most frequently.  

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

Account and Profile Information

We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the Services. For example, you provide your contact information and, in some cases, billing information, when you register for the Services. You also have the option of adding a display name, profile photo, and other details to your profile information to be displayed in our Services.  We keep track of your preferences when you select settings within the Services.

Payment Information

We collect payment and billing information when you register for certain paid Services.  For example, we ask you to designate a billing representative, including name and contact information, upon registration.  You might also provide payment information, such as payment card details, which we collect via secure payment processing services or through third party data collection services.

Additionally when you make a purchase or attempt to make a purchase through the Sites, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number. We refer to this information as “Order Information”.

User Consent

By submitting Personal Information through our Sites or Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy. For conducting cryptocurrency transactions we use MetaMask and your interactions with MetaMask are governed by its privacy policy available at https://metamask.io/privacy.html.

How do we use your personal information? 

We use information about you to provide the Services to you, including to monitor transactions for  you, authenticate you when you log in and operate, maintain, and improve the Services.  We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful.  We use information and collective learnings (including feedback) about how people use our Services to troubleshoot, to identify trends, usage, activity patterns, and areas for integration and to improve our Services and to develop new products, features and technologies that benefit our users and the public. 

We use your contact information to send communications via email and within the Sites, including new updates, drops, and features. We also provide tailored communications based on your activity and interactions with Totem and other users. We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and through the Sites.

We use information about you and your Service to verify accounts and activity, to detect, prevent, and respond to potential or actual security incidents and to monitor and protect against other malicious, deceptive, fraudulent or illegal activity, including violations of Service policies. 

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Sites (for example, by generating analytics about how our customers browse and interact with the Sites, and to assess the success of our marketing and advertising campaigns).

Sharing your personal Information

We share your Personal Information with third parties to help us use your Personal Information, as described above We also use Google Analytics to help us understand how our customers use the Sites -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.


Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.


Behavioural Advertising 

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Do not track 

Please note that we do not alter our Sites’ data collection and use practices when we see a Do Not Track signal from your browser.

Third Party Websites

Our Sites may contain links to third party websites. When you click on a link to any other websites or location, you will leave our Sites and go to other sites, and another entity may collect Personal Information or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Information after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

Your rights 

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are an individual in the European Economic Area (EEA), we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Sites), or otherwise to pursue our legitimate business interests listed above under applicable EU laws. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

California Privacy Rights

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and third parties for marketing purposes, and providing contact information for such affiliates and third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: information@totem.earth.We will make every effort to promptly respond to your request.

Data retention 

We may retain your Personal Information as long as you continue to use the Service, have an account with us, or for as long as is necessary to fulfill the purposes outlined in this Privacy Policy. You can ask to close your account by contacting us as described above, and we will delete your Personal Information on request. We may, however, retain Personal Information for an additional period as is permitted or required under applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes. 

Data Protection

We care about the security of your information and use physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through our websites. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.​​

Deactivate your Account

If you no longer wish to use our Services, you can email us at information@totem.earth with your request to deactivate your account.  Please be aware that deactivating your account does not delete your information; your information remains visible to other Service users based on your past participation within the Services.  

Delete your Information


Our Services give you the ability to delete certain information about you from within the Service. Please email information@totem.earth to delete your information. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.   

Terms of Service

If you choose to use the Services, your visit and any dispute over privacy is subject to this Policy and our Terms of Service, including limitations on damages, resolution of disputes, and applicable law.

Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. The date the Privacy Policy was last revised is identified at the beginning of this Privacy Policy. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Sites and this Privacy Policy to check for any changes.

Minors

The Sites are not intended for individuals under the age of 18 years old. If a child under 18 submits Personal Information to Company and we learn that the Personal Information is the information of a user under 18, we will attempt to delete the information as soon as possible. If you believe we might have any Personal Information from a child under 18, please contact us at the address indicated below.

Opt out of communications

You may opt out of receiving promotional communications from us by using the unsubscribe link within each email or by contacting us as provided below to have your contact information removed from our promotional email list or registration database.  Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings. Please note, you will continue to receive generic ads.  

California Requirements: Exercising your rights

If you are a California resident, there are some additional rights that may be available to you under the California Consumer Protection Act (“CCPA”). This policy explains the tools that we have made available to you to exercise your data rights under the CCPA, such as the right to deletion and the right to request access to the categories of information we have collected about you. We encourage you to manage your information, and to make use of the privacy controls we have included in our Services. You will not be discriminated against for exercising any of your privacy rights under the CCPA. In order to protect your information from unauthorized access or deletion, we may require you to provide additional information for verification. If we cannot verify your identity, we will not provide or delete your information.

Processing your information

This policy describes the categories of personal information we may collect, the sources of that information, and our deletion and retention policies. We’ve also included information about how we may process your information, which includes for "business purposes" under the CCPA  - such as to protect against illegal activities, and for the development of new products, features, and technologies. 

If you have any questions or would like to exercise your rights under the CCPA, you can reach out to us at information@totem.earth.

Our policy towards children

The Services are not directed to individuals under 18. We do not knowingly collect personal information from children under 18. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact the appropriate support team or information@totem.earth.

Changes to our Privacy Policy

Totem may change this privacy policy from time to time. Totem will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice  by sending you an email notification.  We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this privacy policy, you will need to stop using the Services and deactivate your account(s), as outlined above. Contact us For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at information@totem.earth or by mail using the details provided below:

Totem Ecosystems Limited, Floor 4, Willow House, Cricket Square Grand Cayman  KY1-9010 Cayman Islands Attn: General Counsel