WHO WE ARE
OneVoice Digital Limited (registered in England under number 10842253) whose registered office is at Ian King House, Snape Road, Macclesfield, Cheshire, SK10 2NZ) (“we”) is committed to protecting and respecting your privacy.
We are the operator of the following websites, platforms and services:
the TOTUM Platform
the EduClick Photo verification service.
This policy applies to those websites, platforms and services.
We gather and process data in accordance with the prevailing data protection legislation, including the General Data Protection Regulation 2016 (the “GDPR”) and the Data Protection Act 2018.
When you interact with us by email, phone or other means of communication or visit our website or sign up for use of one of our services or platforms you provide, and we collect, data about you. This policy sets out the basis on which we will process personal data we collect about you, or that you provide to us. Please read the following carefully to understand our views and practices regarding your data.
If you have any questions about this policy including any requests to exercise your legal rights, please contact us using the details set out below:
2. INFORMATION WE MAY COLLECT ABOUT YOU
We may collect and process the following data about you:
Identity data: includes first name, last name, username or similar identifier, title, date of birth, gender, social media accounts, photograph, academic achievements, course and level of study, university or further education establishment, club membership and personal interests and preferences.
Contact data: includes billing address, delivery address, email address and telephone numbers.
Financial data: includes bank account and payment card details.
Transaction data: includes details about payments made and other details of goods and/or services purchased. These may include purchase or redemption information arising out of interactions related to access to discounts or offers from partners for which we provide technical, fulfilment, advertising or other services.
Technical data: includes information about use of a website, internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology used to access websites.
Profile data: includes usernames and passwords, purchases or orders made, preferences, feedback and survey responses.
Marketing and communications data: includes preferences in receiving marketing from us and third parties and communication preferences and information arising from interactions with our communication platforms.
Employment data: includes current and past employment, experience, qualifications, skills, interests and any other information disclosed by you.
Special categories of personal data: includes political opinions, religious or philosophical beliefs, information about health, biometric data, data concerning a person’s sex life or sexual orientation and racial or ethnic origin.
3. HOW IS PERSONAL DATA COLLECTED?
We use different methods to collect data including through:
Direct interactions. You may give us details such as a name, photograph, email address and other contact details in person, or by filling in forms on our website or by corresponding with us by post, phone, email, social media and/or otherwise. This includes personal data provided when you:
participate in an event which we have attended or organised
contact us via our website;
subscribe to our publications or newsletters
request information about our services and platforms or other information or for materials to be sent to you
sign up to the TOTUM Platform or the EduClick ID Verification Service or one of our other services;
respond to a survey
contact us about a role within OneVoice Digital;
make a complaint or give us some feedback.
Third parties and publicly available sources.
We may receive personal data from various third parties as set out below:
technical data from analytics providers and/or search information providers; and
account information, purchase or redemption information and page-view information from partners for which we provide technical, fulfilment, advertising or other services and affiliate networks.
employment, identity and contact data from recruitment agencies, previous employers, etc.
4. HOW WE USE PERSONAL DATA
We will only use personal data as permitted by law. Most commonly, we will use personal data in the following circumstances:
Where we need to respond to your requests and fulfil our contractual obligations with you.
Where it is in our legitimate interest to do so (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation
Where you have given your consent to our use or transfer of your personal data.
Entering a giveaway via totum.com or gleam.io via any of the TOTUM marketing channels and using a variety of entry techniques, including liking or following TOTUM across 3rd party platforms
We also use the services of the following companies based in the European Union: Where you apply for an International Student Identity Card (an “ISIC Card”), we necessarily pass the information printed on that card to ISIC Global Office B.V. Generally, we do not rely on consent as a legal basis for processing personal data, however we do rely on Consent to share your data with third parties for their marketing processes. These named third parties are only passed your data for this purpose where you have actively, positively opt-in to provide your consent. Third parties will only use this data for the agreed purpose that you have consented for. Your consent can be withdrawn at anytime by accessing your account through our app or by contacting our customer service team or emailing [email protected] with the relevant information. You can also unsubscribe from any marketing mailing lists by using the Unsubscribe link in each email. You have the right to withdraw consent to us contacting you like this at any time by responding to the person that contacts you and/or by contacting us via the details given above. We have set out below the ways we use personal data and the legal basis for doing so. We have also identified what our legitimate interest is, where appropriate.
We may process personal data for more than one lawful ground depending on the specific purpose for which we are using data. Please contact us if you want further details about the specific legal ground we are relying on to process your personal data. Where we need to collect personal data by law, or under the terms of a contract and you do not provide that data when requested, we may not be able to perform the contract. In this case, we may have to cancel a service you have with us but we will notify you of this at the time. We also use some of the data you provide such as first name to derive some demographics like gender where we haven’t asked you for this specifically. Where you have told us what gender you identify as or indicated ‘other’ or ‘prefer not to say’ we do not include you in this process and simply use the preferences you have given. You can get in touch with us to update this at any time.
Newsletters and marketing communications
You may receive newsletters, updates, news and information about our services and/or other marketing communications from us if you have requested such information from us, purchased our services or if you provided us with your details when you contacted or registered with us unless you told us you did not want to receive such information.
We may also inform you of products or services available from carefully selected partners.
We may also contact you via surveys to conduct research about your opinion of our services.
We do not give or provide in any other way newsletter and marketing communication customer lists to third parties.
We may use certain information about you (such as purchase history with us or interactions with our website) to customize our emails to you. Some emails may contain technology that customizes the email content based on your general location when the email is opened. That technology doesn’t know your precise geolocation. It makes a guess about your general area based on your zip code or the IP address that your computer or device sends when it loads the email, and it may provide email content customized to that general area.
Opt-out or unsubscribe
We are committed to responsible email practices. We only send email to individuals whose data has been lawfully and fairly obtained. If at any time you do not wish to receive emails from us, please use the unsubscribe functionality contained in our communications. Alternatively, please contact us on [email protected]
Third-party links and services
This website and our services are not intended for children and we do not knowingly collect data relating to children. Please be aware that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data when transmitted via the internet between us: any such transmission is at your own risk.
5. SHARING YOUR INFORMATION
We may disclose relevant personal information with the parties set out below for the purposes set out in Section 4 (‘How we use personal data’):
Company group members
These are Arrk Limited (registered in England under number 03574335 whose registered office is at 11 Wimborne Avenue, Urmston, Manchester, M41 0RT), OneVoice Digital Limited and Arrk Solutions Private Limited, a private limited company duly incorporated with registration number U72900MH2002FTC135091 under the laws of India, having its registered office at Unit No. 1 & 2, Building No. 5, Sector-2, Millennium Business Park, Mahape, Navi Mumbai, PIN 400710.
The National Union of Students
National Union of Students (United Kingdom) registered in England under number 08015198 whose registered office is at Ian King House, Snape Road, Macclesfield, Cheshire, SK10 2NZ (“NUS”). NUS is one of the oldest student organisations in the world, and it works hard every day to help to make your experience as a student the best it can be. NUS works to influence national and local policies in areas that are important to you, such as accommodation, fees and the right to study. NUS also run ground breaking programmes to drive change, such as improving environmental impact and reducing alcohol abuse. We pass your information to NUS so that they can better provide you with their services and help manage your data. NUS is an English company. Where you opt in to doing so, we also pass information to NUS so that NUS can use the information to provide you with their latest information, offers and competitions. If you do not wish to receive this information from NUS you can use the unsubscribe function at any time.
We pass your information to your local students’ union so that they can provide you with personalised customer service. Where you opt in to doing so, we also pass information to your local Students’ Unions so that they can use the information to provide you with their latest information, offers and competitions. If you do not wish to receive this information from Student Unions you can use the unsubscribe function at any time.
Graduate Recruitment Bureau, registered in England under 03640983, whose registered office is Atlas Chambers 33 West Street Brighton East Sussex BN1 2RE. Graduate Recruitment Bureau is a graduate recruitment agency representing many graduate employers, and offering advice and guidance to students and graduates looking for graduate jobs. Where you opt in to us doing so, we pass your contact details to Graduate Recruitment Bureau so that they can provide you with relevant information about jobs, placements, career events and training.
We may also share personal data with third parties as per below for the purposes set out in the table in section 4 above:
Service providers who perform services and functions on our behalf in connection with the operation of our business such as software and application service providers, third parties who host, store and manage data or provide programming or technical support and providers of identity cards and gourmet cards.
Third party identity verification service providers, such as GBG
Professional advisers including our accountants, insurers and brokers, etc.
Analytics partners to analyse website traffic and understand customer needs and trends.
Marketing service providers to help us to communicate with you.
If we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our websites or customers.
Those to whom we may sell, transfer, or merge parts of our business with, or where we acquire other businesses or merge with them. If such a change happens then any new owners may use your personal data in the same way as set out in this policy.
comply with legislation or legal process served on us;
protect and defend our rights and/or property; and
to protect personal safety.
6. INTERNATIONAL TRANSFERS
Our third-party service providers may be based outside the European Economic Area (EEA) and when they are their processing of personal data will involve a transfer of data outside the EEA. Whenever we transfer personal data out of the EEA or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
7. SECURITY OF PERSONAL DATA
We implement appropriate security measures to protect your personal data from accidental loss, misuse, incorrect alteration or disclosure. Our security systems include limiting access to staff and third parties on a need to know basis and password authenticated access to internal databases. We also encrypt and anonymise data wherever it is appropriate to do so. We regularly take back-ups of our data. We regularly review overall web security and audit procedures. Our security measures include the following Information Security Management (“ISMS”) policies; Acceptable Usage Policy, Antivirus Policy, Cloud Computing Policy, Data Security Breach Policy, Incident Management Policy, Information Handling Policy, Information Security Policy, Logical Access Control Policy, Mobile Computing Policy, Network and System Security Policy, Password protection Policy, Patch Management, Physical Security Policy, Vendor Management Policy. In conforming with data protection laws, we endeavour to implement appropriate procedures to protect your personal data and to prevent any unauthorised access or misuse of it.
8. YOUR RIGHTS
The data protection legislation gives you a number of rights. These rights include:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. It is unlikely, but in some cases we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who does not have a right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests as soon as reasonably practicable and at least within one month. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. DATA RETENTION
We will retain your data for as long as we need in order to fulfil the purposes we collected it for and in order to satisfy any legal, accounting or reporting requirements.
We normally hold and process your data in accordance with the following criteria and duration:
Source criteria of the data: Data collected when you initially register on our app or one of our websites including free membership.
Relevant Event date: Register date, Interaction date.
Maximum duration of processing: 36 months after the last interaction with TOTUM app, TOTUM.com or our email correspondence.
Source criteria of the data: Data collected for TOTUM paid membership purposes
Relevant Event date: Membership expiry, Interaction date
Maximum duration of processing: 24 months after the date of expiry of paid-for membership, or if user continues to use our free membership products 24 months after the last interaction with TOTUM app, TOTUM.com or our email correspondence.
Source criteria of the data: Data collected when you sign up for the EduClick ID Verification Service or one of our other services
Relevant Event date: Completion of the service
Maximum duration of processing: 24 months after completion of the service
Source criteria of the data: Data collected when you correspond or similarly interact with us
Relevant Event date: The last date of such correspondence or interaction with us
Maximum duration of processing: 36 months after your last interaction with us
We regularly review the personal data we hold and we may regularly purge personal data subject records which are not relevant on earlier occasions.
In any event we will stop the processing of your data where you ask us to do so by contacting us at [email protected] The only circumstances in which we will not do so or where we may keep data for a longer period are where we have a legal obligation or a legitimate interest to continue processing your data.
10. ANALYTIC SUPPLIERS