Totem VC, Inc. Privacy Policy
Last Updated: January 1, 2024
We at Totem know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways. Remember that your use of Totem's Services is at all times subject to the Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.
What does this Privacy Policy cover?
This Privacy Policy covers our treatment of personally identifiable information ("Personal Information") that we gather when you are accessing or using our Services, but not to the practices of companies we don't own or control, or people that we don't manage. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.
We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at support@totemvc.com.
Will Totem ever change this Privacy Policy?
We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice at totemvc.com, by sending you an email, and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
What Information does Totem Collect?
Information You Provide to Us: We receive and store any information you knowingly provide to us. For example, through the registration process and/or through your account settings, we may collect Personal Information such as your name, email address, employer, photo, job title, phone number, and third party account credentials (for example, your login credentials for Gmail, Outlook, or other third party sites). If you provide your third party account credentials to us, you understand some content and/or information in those accounts ("Third Party Account Information") will be transmitted into your account with us, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy; for example, if you link your Outlook or Gmail to your Totem account, certain information from those third party accounts will be transmitted to and displayed within your Totem account. Third Party Account Information may also include read-only access to your calendar, and explicitly forwarded emails to our system. Outside of Personal Information and Third Party Account Information, we also collect data given to us around a fund manager’s funds and investments ("Fund Information"). Fund Information can include investment details, fund performance, Limited Partners, cap tables, financial performance and company contacts. Certain information may be required to register with us or to take advantage of some of our features.
We may communicate with you if you've provided us the means to do so. For example, if you've given us your email address, we may email you about your use of the Services. If you do not want to receive communications from us, please indicate your preference by sending us an email at support@totemvc.com
Information Collected Automatically: Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, "cookie" information, the type of browser and/or device you're using to access our Services, and the page or feature you requested. "Cookies" are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device's acceptance of cookies, but this may prevent you from taking advantage of some of our features.
If you click on a link to a third party website or service, a third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren't responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor "Do Not Track" requests you have set using your browser or device. We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services -- for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
Information Collected From Other Websites and Do Not Track Policy: Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy. Your browser may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.
Information Collected from Third Parties:
Will Totem Share Any of the Personal Information it Receives? We do not rent or sell your Personal Information in personally identifiable form to anyone. We may share your Personal Information with third parties as described in this section:Information that's been deidentified. We may deidentify your Personal Information so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or deidentified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.
Affiliated Services: In certain situations, businesses or third party websites we're affiliated with may provide services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. One such service may include the ability for you to automatically transmit Third Party Account Information to your Services profile or to automatically transmit information in your Services profile to your third party account; for example, information may be regularly and automatically transferred to and from you Outlook account and your Services Account as a result of your use of the Services. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business' or websites' policies.
Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing company to receive and process your credit card transactions for us. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
User Profiles and Submissions: Certain user profile information, including your name, employer, job title, photo, location, and certain content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Your account privacy settings may allow you to limit the other users who can see the Personal Information in your user profile and/or what information in your user profile is visible to others. Please remember that any content you upload to your user profile, along with any Personal Information or content that you voluntarily disclose online in a manner other users can view (for example, by other users within your organization) becomes available to those other users, and can be collected and used by them.
Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
Protection of Totem and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order (including lawful requests by public authorities to meet national security or law enforcement requirements); enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Totem, our employees, our users, or others.
Is Personal Information about me secure?
Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
What Personal Information can I access?
Through your account, you may access, and, in some cases, edit or delete the following information you've provided to us:
Transfers of Personal Data:
The Services are hosted and operated in the United States ("U.S.") through Totem and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Information about you, regardless of whether provided by you or obtained from a third party, is being provided to Totem in the U.S. and will be hosted on U.S. servers, and you authorize Totem to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to EU-U.S. Privacy Shield Framework, the details of which are further set forth below.
Totem has certified to the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information transferred from the EU to the U.S., respectively. For more information about the Privacy Shield Program, and to view Totem’s certification, please visit www.privacyshield.gov. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. Totem is committed to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Information on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Totem’s compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Please contact us at support@totemvc.com with any questions or concerns relating to our Privacy Shield Certification. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through JAMS, an alternative dispute resolution provider located in the United States. You can visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.
What choices do I have?
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features. You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us at support@totemvc.com. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
Sub Processors
Totem uses the following sub processors and can provide DPA's for each of them upon request:
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to support@totemvc.com, and we will try to resolve your concerns.
Last Updated: January 1, 2024
We at Totem know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways. Remember that your use of Totem's Services is at all times subject to the Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.
What does this Privacy Policy cover?
This Privacy Policy covers our treatment of personally identifiable information ("Personal Information") that we gather when you are accessing or using our Services, but not to the practices of companies we don't own or control, or people that we don't manage. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.
We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at support@totemvc.com.
Will Totem ever change this Privacy Policy?
We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice at totemvc.com, by sending you an email, and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
What Information does Totem Collect?
Information You Provide to Us: We receive and store any information you knowingly provide to us. For example, through the registration process and/or through your account settings, we may collect Personal Information such as your name, email address, employer, photo, job title, phone number, and third party account credentials (for example, your login credentials for Gmail, Outlook, or other third party sites). If you provide your third party account credentials to us, you understand some content and/or information in those accounts ("Third Party Account Information") will be transmitted into your account with us, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy; for example, if you link your Outlook or Gmail to your Totem account, certain information from those third party accounts will be transmitted to and displayed within your Totem account. Third Party Account Information may also include read-only access to your calendar, and explicitly forwarded emails to our system. Outside of Personal Information and Third Party Account Information, we also collect data given to us around a fund manager’s funds and investments ("Fund Information"). Fund Information can include investment details, fund performance, Limited Partners, cap tables, financial performance and company contacts. Certain information may be required to register with us or to take advantage of some of our features.
We may communicate with you if you've provided us the means to do so. For example, if you've given us your email address, we may email you about your use of the Services. If you do not want to receive communications from us, please indicate your preference by sending us an email at support@totemvc.com
Information Collected Automatically: Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, "cookie" information, the type of browser and/or device you're using to access our Services, and the page or feature you requested. "Cookies" are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device's acceptance of cookies, but this may prevent you from taking advantage of some of our features.
If you click on a link to a third party website or service, a third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren't responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor "Do Not Track" requests you have set using your browser or device. We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services -- for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
Information Collected From Other Websites and Do Not Track Policy: Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy. Your browser may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.
Information Collected from Third Parties:
Will Totem Share Any of the Personal Information it Receives? We do not rent or sell your Personal Information in personally identifiable form to anyone. We may share your Personal Information with third parties as described in this section:Information that's been deidentified. We may deidentify your Personal Information so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or deidentified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.
Affiliated Services: In certain situations, businesses or third party websites we're affiliated with may provide services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. One such service may include the ability for you to automatically transmit Third Party Account Information to your Services profile or to automatically transmit information in your Services profile to your third party account; for example, information may be regularly and automatically transferred to and from you Outlook account and your Services Account as a result of your use of the Services. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business' or websites' policies.
Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing company to receive and process your credit card transactions for us. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
User Profiles and Submissions: Certain user profile information, including your name, employer, job title, photo, location, and certain content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Your account privacy settings may allow you to limit the other users who can see the Personal Information in your user profile and/or what information in your user profile is visible to others. Please remember that any content you upload to your user profile, along with any Personal Information or content that you voluntarily disclose online in a manner other users can view (for example, by other users within your organization) becomes available to those other users, and can be collected and used by them.
Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
Protection of Totem and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order (including lawful requests by public authorities to meet national security or law enforcement requirements); enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Totem, our employees, our users, or others.
Is Personal Information about me secure?
Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
What Personal Information can I access?
Through your account, you may access, and, in some cases, edit or delete the following information you've provided to us:
- Name
- Employer
- Job title
- Photo
- Email address
- Mailing address
- Phone number
Transfers of Personal Data:
The Services are hosted and operated in the United States ("U.S.") through Totem and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Information about you, regardless of whether provided by you or obtained from a third party, is being provided to Totem in the U.S. and will be hosted on U.S. servers, and you authorize Totem to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to EU-U.S. Privacy Shield Framework, the details of which are further set forth below.
Totem has certified to the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information transferred from the EU to the U.S., respectively. For more information about the Privacy Shield Program, and to view Totem’s certification, please visit www.privacyshield.gov. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. Totem is committed to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Information on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Totem’s compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Please contact us at support@totemvc.com with any questions or concerns relating to our Privacy Shield Certification. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through JAMS, an alternative dispute resolution provider located in the United States. You can visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.
What choices do I have?
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features. You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us at support@totemvc.com. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
Sub Processors
Totem uses the following sub processors and can provide DPA's for each of them upon request:
- Amazon Web Services
- MongoDB
- Mixpanel
- Postmark
- Clearbit
- UploadCare
- Rapid7
- OpenAI
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to support@totemvc.com, and we will try to resolve your concerns.