Privacy Policy

YOUR PRIVACY IS IMPORTANT TO US

WHO WE ARE

OneVoice Digital Limited (registered in England under number 10842253) whose registered office is at Jactin House, 24 Hood Street, Manchester, M4 6WX (“we”) is committed to protecting and respecting your privacy.

We are the operator of a number of websites, platforms, apps and services including but not limited to:

www.totum.com

www.onevoicedigital.com

the TOTUM Platform

collaborate.totum.com

isic.totum.com

cashback.totum.com

This policy applies to those websites, platforms and services.

We are an ID, member benefits and discount platform. We offer ID and discounts and deals online and in-store to students, apprentices and professional people. Our ID, offers and discounts are available via our websites and apps and in the main are only available to signed-up members who have completed our registration and verification processes. We may communicate with you about the ID, discount and money saving services you have registered for via email and other forms of electronic communication.

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 apps 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, or request the previous privacy policy version, please contact us using the details set out below:

on dpc@onevoicedigital.com

2. INFORMATION WE MAY COLLECT ABOUT YOU

When you register as a TOTUM member and engage with our websites, apps and our other platform in general we collect personal data and information about you so that we can provide you with the services you have signed up for.

You may also provide personal data and information to us when you search for products or services, compile your favourites and preferences, communicate with us by phone, social media, e-mail, etc., complete a questionnaire, a support ticket, or a contest entry form, upload images, videos or other files to your account and compile wish lists or participate in competitions and gifting promotions

If you’re signed in we’ll also know how you use our platforms and this will enable us to give you a better, more personalised service and to check we’re ensuring verified access only to exclusive student discounts.

If you choose not to provide certain data and information you might not be able to take advantage of many of our Services.

Examples of the sort of personal data and information we may collect and process about you include:

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.

Email interaction data: Our emails have a tracking pixel. When you download images or interact with the email by clicking this pixel will track that you have opened an email. Our email service provider will also track what you have clicked on.

Device location data: the location of your device or computer; Through our app we may also find out your location, however you can turn this feature off through your device’s settings.

Device metrics data: device metrics such as when a device is in use, application usage, connectivity data, and any errors or event failures.

Profile data: includes usernames and passwords, purchases or orders made, preferences, feedback and survey responses.

Marketing and communications data: includes preferences in receiving marketing communications and communication preferences and information arising from interactions with our platforms and those of third-parties whom you have consented we share your data with.

Employment data: includes current and past employment, experience, qualifications, skills, interests, professional association memberships and any other information disclosed by you.

URL information: the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); cookie number; products and/ or content you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs),

Phone number information: phone numbers used to call our customer service number.

Other tracking information: We may also use device identifiers, cookies, and other technologies on devices, applications and our web pages to collect browsing, usage or other technical information for fraud prevention purposes.

Information From Other Sources: we might receive information about you from other sources. Such as account information, purchase or redemption information and page-view information from brands with which we operate co-branded businesses or for which we provide technical, fulfilment, advertising or other services.

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.

We may also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

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;

Use the TOTUM App;

Subscribe to our publications, newsletters or push messages;

Request information about our services and platforms or other information or for materials to be sent to you;

Respond to a survey;

Make a complaint or give us some feedback;

Complete TOTUM PASS ID verification using the TOTUM App. This systems uses the GBG IDscan technology to verify your identity and ID document validity;

Through the use of tracking software such as Hotjar and Lead Forensics.

Automated technologies or interactions.

A ‘cookie’ is a small piece of information which is sent to your browser and stored on your computer’s hard drive. We use Cookies on our website pages to collect technical data about equipment, IP address, browsing actions and patterns. We may also receive technical data if you visit other websites employing our cookies. Our use of cookies is governed by our Cookies Policy, a copy of which can be found here: TOTUM Cookie Policy. You can find more about how cookies are used and how to opt out of them in 'Cookie Settings' linked in the footer of our website.

Third parties and publicly available sources.

We may receive personal data from various third parties as set out below:

Personal information from your Specified Place of Study or Membership Organisation; and

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; and

employment, identity and contact data from recruitment agencies, previous employers, etc.

4. HOW WE USE PERSONAL DATA

We use your data to make our products and services better for you and our other members. Your data and information helps us to operate, improve and maintain our business whilst at the same time enhances your user experience. This allows us to do things like:

Recommend to you things we think that you will like;

Notify you about things you have shown us you like, for example, a brand you like getting discounts from; and

Personalising our products and services to your tastes, including, for example, any newsletters, emails or other communications.

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. (Not applicable to biometric/PASS verification data)

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 via Cognito forms, Digioh, Type Forms or gleam.io via any of the TOTUM marketing channels and using a variety of entry techniques, including liking or following TOTUM across third-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” or “ISIC ID”), we necessarily pass the information printed on that card to ISIC Global Office B.V.

Generally, we rely on legitimate interest rather than consent as a legal basis for processing personal data and information, however we do rely on consent to share your data with third parties for their marketing processes. These third parties are only passed your data for this purpose where you have consented to this. Third parties will only use this data for the agreed purpose that you have consented to. Your consent can be withdrawn at any time by contacting our Customer Success team.

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 fulfil 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.

Newsletters and marketing communications via the Iterable or TOTUM platform.

We will send you newsletters, app pushes, web pushes, updates, news and information about discounts we offer and other money-saving offers and about our services in general.

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 also use your data for business, regulatory and legal purposes, such as verifying your identity and student, apprentice or professional status, getting in touch if we need to tell you about something, like a change to our policies or issues with a service; and contacting you to re-verify your student status so you can keep receiving discounts.

We may use certain information about you (such as purchase history with us or interactions with our website) to customise our emails and communications to you. Some emails and communications may contain technology that customises 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 postcode or the IP address that your computer or device sends when it loads the email, and it may provide email content customised 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 dpc@onevoicedigital.com.

Our website uses cookies and similar technologies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our website. You can set your browser to refuse all or some browser cookies. For more information about the cookies we use, please see our cookie policy.

Third-party links and services

Third-party plug-ins also may collect information about your use of the site. As an example, when you load a page on totum.com that has a social plug-in from a third-party site or service, such as a “Like” or “Send” button, you are also loading content from that third-party site. That site may request cookies directly from your browser. These interactions are subject to the privacy policy of the third-party site. In addition, certain cookies and other similar technologies on the site are used by third parties for targeted online marketing and other purposes. These technologies allow a partner to recognise your computer or mobile device each time you use the services. Please be aware that when you use third-party sites or services, their own terms and privacy policies will govern your use of those sites or services. TOTUM chooses and manages these third-party technologies placed on its sites. However, these are third-party technologies, and they are subject to that third party's privacy policy.

Children

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.

Reviews

We may contact you via email to invite you to review any services and/or products you received from us in order to collect your feedback and improve our services (The TOTUM membership, app, customer service and experience) (the “Purpose”). We may use an external company to collect your feedback which means that we will share your name, email address and reference number with them for that purpose. If you want to read more about how they might process your data, you can contact our Customer Services team.

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 Colony Jactin House, Suite 1.02, 24 Hood Street, Manchester, M4 6WX) and its subsidiary and group companies..

The National Union of Students

National Union of Students (United Kingdom) registered in England under number 08015198 whose registered office is at Merseyway Innovation Centre, 21-23 Merseyway, Stockport, SK1 1PN (“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. If you do not wish to receive this information from NUS you can use the unsubscribe function at any time.

Students’ Unions

If you are a student, we may pass your information to your local students’ union so that they can provide you with personalised customer service. If you do not wish to receive this information from Students’ Unions you can use the unsubscribe function at any time.

Employment Agencies and Opportunities

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.

GTI Futures Limited, trading as Target Jobs, registered in England under company number 2347472 whose registered office is The Fountain Building, Howbery Park, Benson Lane, Wallingford, Oxfordshire, OX10 8BA, UK. Target Jobs 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 Target Jobs so that they can provide you with relevant information about jobs, placements, career events and training.

Other

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.

We require third parties to respect the security and confidentiality of personal data and to treat it in accordance with the law. We do not allow third-party service providers to use personal data for their own purposes and only permit them to process personal data for specified purposes and in accordance with our instructions.

Where we disclose personal data with our group companies, we undertake that this privacy policy applies to each of those companies.

We will disclose personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to:

comply with legislation or legal process served on us; and

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.

Your right to limit our processing

Where we process your personal data and information on the basis of a legitimate interest you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

9. DATA RETENTION

Except if required otherwise by law, we retain your personal data for as long as necessary to fulfil the purposes for which we collect it and also where we have a legitimate interest in doing so, such as:

To enable us to respond effectively to grievances that may arise after you cease to engage with us; or

Where you sign up to receive e-mail marketing from us we will retain your e-mail address after you ‘opt-out’ of receiving e-mails in order to ensure that we continue to honour and respect that request.

We may also anonymise your data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. ANALYTIC SUPPLIERS

In common with comparable companies we use your personal data to help Analytic Suppliers match relevant ads to you using the data analytics of those Analytic Suppliers. However, we only use the data in that way where you are a subscriber to the services of Analytic Suppliers and have therefore agreed to this service by acceding to the relevant Agreements of those Analytic Suppliers. Accordingly, we do not control the countries in which those Analytic Suppliers process data. We mean by Analytic Suppliers companies such as: Facebook; Google; LinkedIn; Twitter and Microsoft. Analytic Suppliers supply us with statistical information on how users interact with our website to help us improve our user experience. You can find further details of our interaction with Analytic Suppliers in our cookie policy a copy of which can be found here: TOTUM Cookie Policy

11. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page. Where we make any material change to this privacy policy, we will notify you that it has been changed.