Effective date: 7 April 2025

Totem Learning Ltd. is committed to safeguarding your personal data and respecting your privacy. This notice outlines what to expect when we collect and process your personal information. It applies to:

  • Visitors to our websites

  • Complainants and individuals making data protection or freedom of information enquiries

  • People who use our services

  • Job applicants and current or former employees

  • Individuals whose data is submitted via our platforms

1. What Information We Collect and Why

Website Analytics

When you visit our website, we collect data such as:

  • Browser, network, and device details

  • IP address and general location

  • Pages viewed and time spent on each

  • Clicks, scrolls, searches, and timestamps

  • Referring and exit web pages

This is processed under our legitimate interests to improve user experience, monitor performance, and ensure security.

Our site is hosted on Squarespace, which collects and processes this data in accordance with their own privacy terms. Some analytics may be handled via Google Analytics or similar tools, anonymised where possible.

Cookies

We use cookies and similar technologies to deliver, secure, and improve our website.

  • Essential cookies: Required for core site functionality and security

  • Analytics cookies: Used to understand traffic and usage (only activated with your explicit consent)

We use a cookie banner to manage your consent preferences in accordance with the UK Privacy and Electronic Communications Regulations (PECR) and UK GDPR.

For more details, see: The Cookies Squarespace Uses

For Customers

All payments are processed through PayPal. Totem Learning Ltd. does not store any payment or financial data. PayPal acts as the data controller for payment information, processing data in accordance with their own privacy policy.

For Webform Submissions

If you submit a form through our website, we collect the information you provide (e.g., name, email, message).

This data is shared with:

  • Squarespace (hosting platform)

  • Mailchimp (email provider)

  • Zapier (data integration tool)

We use this data only to respond to your enquiry or request. Lawful basis: consent or legitimate interest, depending on context.

Marketing Emails

With your consent, we may send you newsletters or updates. You may unsubscribe at any time via the link in any email.

We use Mailchimp to manage and send marketing communications. Mailchimp may process data outside the UK; appropriate safeguards (e.g., Standard Contractual Clauses) are in place.

Fonts

We use fonts from Google Fonts and Adobe Fonts. These services may process your IP address and browser metadata to deliver font files.

2. Your Rights (UK, EU, and US Visitors)

If you're based in the UK or EU, under the UK GDPR or EU GDPR, you have the right to:

  • Access your personal data

  • Correct inaccurate data

  • Request deletion

  • Restrict or object to processing

  • Data portability

  • Not be subject to automated decision-making or profiling

If you're based in the US, you may have additional rights under laws such as the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). These include the right to:

  • Know what personal information is being collected

  • Request access or deletion of your data

  • Opt-out of the sale of personal data (Totem does not sell your data)

You can exercise your rights at any time by emailing: info@totemlearning.com

3. Complaints and Enquiries

If you make a complaint, we’ll create a secure file containing details of the issue and the people involved. This is used only to manage and resolve the complaint.

We may need to share the identity of the complainant with the subject of the complaint to fully address the matter.

Complaints are retained for two years from closure and securely deleted thereafter, in line with our retention policy.

4. Service Users

If you use our services, we collect only the data necessary to deliver what you’ve requested. This may include your contact details, preferences, or service history.

We never use this information for unrelated marketing or share it with third parties without your consent.

5. Job Applicants and Employees

  • Applicant data is used only for recruitment and monitoring

  • Data from unsuccessful applicants is deleted after 12 months

  • Successful candidates will have a secure employment file, used only for HR purposes

  • Ex-employee data is retained and deleted in accordance with our retention policy

We will never share candidate or employee information without consent, unless legally required to do so.

6. Data Transfers

Some of our third-party providers (e.g. Squarespace, Mailchimp) may process data outside the UK/EEA (e.g., in the US). Where this occurs, we ensure:

  • Standard Contractual Clauses (SCCs) are in place

  • Transfers are covered by adequacy decisions or other legal mechanisms

We carefully select providers with strong data protection standards.

7. No Children’s Data

We do not knowingly collect data from individuals under the age of 18. If we become aware of such data being submitted, we will delete it promptly.

8. No Automated Decision-Making

Totem Learning Ltd. does not use any automated systems that make legal or similarly significant decisions about individuals based solely on personal data.

9. External Websites

Our website may link to external sites. This privacy notice does not apply to them. We encourage you to read their privacy notices before submitting any personal data.

10. Changes to This Privacy Notice

We review our privacy policy regularly and will update it when necessary. This version was published on 7 April 2025.

11. Contact Us

If you have any questions, requests, or concerns about this privacy notice or how we handle your data, you can contact us at:

📧 info@totemlearning.com
📮 Totem Learning Ltd, 3 & 4 Pegasus House, Pegasus Court, Olympus Avenue, Warwick, CV34 6LW

You also have the right to contact the Information Commissioner’s Office (ICO) if you are unhappy with how we’ve handled your data.