Introduction

At TOTAM (“we,” “our,” “us”), we understand the importance of protecting and properly managing the personal information we collect and process. This Privacy Policy aims to help you understand the types of information we may collect from users (“you”) of our website (the “Site”), how that information may be used, with whom it may be shared, and the rights you have regarding the protection of your personal data.

This Privacy Policy does not apply to information collected through our talent management services.

Who We Are

TOTAM acts as the controller for the processing of your data. Our company is located at 285 Davidson Ave, Somerset, NJ 08073

How to Contact Us

For all data privacy matters, please contact us at info@totam.biz

How We Collect Your Information

We collect personal data about you in the following instances:

  1. When you voluntarily give it to us: We may collect information when you contact or request information through our email address. We may also collect information when you submit your CV for possible job opportunities and when you engage in a commercial relationship with us. We will also collect your personal information when you fill in our online form to schedule a demo.
  2. When other people give it to us: We may collect information from advertising and marketing partners in order to monitor, manage and measure ad campaigns. We also may collect information that is publicly available.
  3. We may collect browsing data automatically when You visit our Site.

Which Information We Collect About You

We may collect the following information from You:

When you contact us to request information or when you are interested in the services we offer, we may collect information contact information such as first name and surname, email address and telephone number(s).

When you contact us interested in working with us, we may collect information such as contact information, employment history, professional qualifications, and any other information provided through the CV.

We do not knowingly collect data from children. If a parent or legal guardian learns that a child provided us with personal information, please contact us, and we will make commercially reasonable attempts to delete such personal information.

For Which Purposes We Collect Your Information

We use the information we hold about you for the following purposes and on the following legal bases:

  1. Reply to your inquiries and respond to your requests - Justified based on our legitimate interest in offering You our services.
  2. Provide You with our services and administer and manage our relationship with you - Performance of a contract with you.
  3. Gather statistical information from Site users and analyze for trends. This is justified based on our legitimate interest to improve your experience when navigating through our Site and to improve our services.
  4. Provide you with news and information related to our services and products that we believe may interest you. This is justified based on our legitimate interest in offering you our services.
  5. Evaluate your candidacy when you submit your CV to us - Performance of a contract with you.
  6. Provide government agencies with information when required by law - It is necessary for us to comply with our legal obligations.
  7. We may also collect your information in our legitimate interest to prevent fraud or harm to us or to any third party and ensure the security of our network and services.

Who We Share Your Information With

We commit not to sell any personal information to third parties. However, we may disclose personal data to third parties if you consent to us doing so, as well in the following circumstances:

  1. Our third-party services providers, suppliers and partners that assist in providing our Services, such as system hosting, management, support, and data analysis;
  2. Credit or reference providers or debt collection companies;
  3. Our professional advisors, including lawyers, consultants, accountants, auditors and insurers;
  4. Possible acquirers or investors (and our and their advisors) in the context of facilitating or implementing a business reconfiguration or reorganization or a transfer or sale of all or part of our assets or business, including, but not limited to a divestiture, acquisition or business reconfiguration. Alternatively, we may seek to acquire other businesses or merge with them;
  5. Competent governmental and public authorities, in each case, to comply with legal or regulatory obligations or requests.

Some of the service providers mentioned above may be located abroad, and, in this case, we adopt additional safeguards to guarantee an adequate level of protection for your personal data.

Transfer of Your Information

TOTAM takes all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

In accordance with the GDPR, when we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that we use specific controls approved by the European Commission, which give personal data the same protection it has in Europe.

How We Protect Your Information

To ensure that your personal information is secure, we communicate our privacy and security guidelines to all our employees and business partners and strictly follow precautionary measures regarding privacy within the company.

We strive to protect your personal information through physical, technical and organizational measures aimed at reducing the risks of loss, misuse, unauthorized access, disclosure and improper alteration of this data.

We make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical technical or managerial safeguards. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice on our Site or through other forms of communication.

How Long We Retain Your Information

We have determined retention periods based on the purpose of the processing and the rules set forth within the GDPR, as well as the legal and business requirements. For example, the GDPR requires us to remove data when it has served its purpose and is no longer of use. We review the personal data we regularly collect to ensure that the personal data we have is up-to-date and is not retained longer than needed or required by the regulation.

If you wish to have more detailed information about our retention times, please contact us at info@totam.biz.

Opt-Out of Sale of Personal Information or Sharing or Processing of Personal Information for Targeted Advertising (California, Colorado, Connecticut, Utah and Virginia Residents Only).

If you live in California, Colorado, Connecticut, Utah, or Virginia, you have the right to opt-out of certain processing of your personal information, including selling of your data and targeted advertising, as per the applicable law. Targeted advertising is when we or our partners show you ads based on the personal information collected from different businesses.

Nevada Residents

If you are a Nevada consumer, you have the option to opt out of the sale of your "covered information" as per Nevada law. We don't engage in such practices, but if you have any queries regarding this, please feel free to email us at info@totam.biz

California Privacy Rights

This section applies only to California residents. The California Consumer Privacy Act (CCPA) is a data protection law that ensures you have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.

  • Right of Access: you have the right to request that we disclose what Personal Information we have collected, used, and disclosed about you in the past 12 months.
  • Right of Deletion: you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
  • Right to Non-Discrimination: You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA.

You also have the right to opt out of the sale of personal information. In the preceding 12 months, we have not disclosed your personal information to any third party in a manner that would be considered a sale under the CCPA.

For more details on the personal information collected in the preceding 12 months, see our sections above How We Collect Your Information and Which Information We Collect About You. We collect this information for business and commercial purposes as described above in the How We Use Your Data section. Information about which categories of third parties we share this information with is described above in How We Disclose Personal Data.

Your Rights Under the GDPR (If You Are a Data Subject in the European Union)

Under the law, you are granted six fundamental rights when data about you is being processed. We will ensure to reach out without undue delay (no more than 30 days) when you submit a request related to exercising your data subject rights. Although uncommon, when applicable for official or legal reasons we may be unable to address the specific request you make related to your rights.

Also, if a request is manifestly unfounded or excessive, in particular, because of its repetitive character, we may either:

  • charge a reasonable fee considering the administrative costs of providing the information or communication or taking the action requested; or
  • refuse to act on the request.

In this scenario will we inform you of the reasons we believe your request is manifestly unfounded or excessive character of the request.

As a data subject, you have the right to:
  1. The right to request confirmation of whether we process Personal Data relating to you and if so, to request a copy of that Personal Data;
  2. The right to request that we update your Personal Data that is inaccurate, incomplete, or outdated;
  3. The right to request that we erase your Personal Data in certain circumstances provided by law;
  4. The right to request that we restrict the use of your Personal Data in certain circumstances;
  5. The right to request that we export your Personal Data that we hold to another company, where technically feasible;

Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; and/or:

  • In some cases, you may also have the right to object to the processing of your Personal Data.

We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may have the right under applicable laws to consult with the data protection authority in your country.

If you wish to exercise your rights, or if you have any other questions relating to your rights or this privacy statement, please contact us at info@totam.biz

You may also make such a request by writing to us at: 285 Davidson Ave, Somerset, NJ 08073

You also have the right to lodge a complaint with a supervisory authority.

You can find a list of Supervisory Authorities here.

Modifications to This Privacy Policy

We reserve the right to change this Privacy Policy anytime by posting revisions on this web page. Such changes will be effective upon posting and the current version published on our website shall apply.

Please revisit this page to stay aware of any changes. If the Privacy Policy is part of an agreement with you.