Totem - Privacy Policy

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Introduction

Totem, Inc.("Totem" or "we") respects your privacy and is committed to protecting it through compliance with this policy.

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This policy describes the types of information we may collect from you or that you may provide when you visit https://www.totemlabs.com/ or https://totemlabs.shop/ (collectively, the "Site") and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to information we collect:

• On the Site.
• In email, text, and other electronic messages between you and the Site.

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It does not apply to information collected by:

• Us offline or through any other means; or
• Any third party.

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Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Site. By accessing or using the Site, you agree to this privacy policy. This policy may change from time to time (see Changes toOur Privacy Policy). Your continued use of the Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

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Children Under the Age of 18

The Site is not intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Site or through any of its features, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 18without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at shop@totemlabs.com.

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Information We Collect About You and How We Collect It

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Use of Device and Consent to Geolocation Data Collection
By purchasing and using our products, including the Totem Compass, you acknowledge and agree that Totem may collect and use anonymous geolocation data generated during usage. This data is collected solely for the purpose of improving product functionality, user experience, and service delivery. It does not personally identify you and is handled in compliance with GDPR and other applicable privacy laws.

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We collect several types of information from and about users of the Site, including information:

• Personal information (e.g., name, postal address, email address, telephone number)
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• Non-identifying information (e.g., device type, browser, operating system)
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• Anonymous geolocation data to understand general usage patterns and improve our services

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.

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Information You Provide to Us

The information we collect on or through the Site may include:

• Information that you provide by filling in forms on the Site. This includes information provided when making any purchase or using any "contact us" feature available on the Site. We may also ask you for information when you report a problem with the Site.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through the Site.
• Information collected about you by third parties who collect information on our behalf, including companies who support the Site, such as Shopify, and payment processors who collect payment information to process your payment to fulfill your orders.

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Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to the Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

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The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. Data that we collect automatically helps us to improve the Site and to deliver a better and more personalized service, including by enabling us to understand usage and purchase patterns.

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The technologies we use for automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Site. Unless     you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Site. For     specific information about the cookies that we use related to powering our store with Shopify, see https://www.shopify.com/legal/cookies.
• Web Beacons. Pages of the Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Totem, for example, to count users who have visited certain webpages and for other related website statistics (for example, recording the popularity of certain website content and merchandise and verifying system and server     integrity).

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How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• Operate and improve the Site
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• Fulfill purchases and transactions
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• Respond to your inquiries
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• Customize your user experience
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• Provide updates, marketing communications, and promotions (with consent)
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• Analyze usage trends and optimize the Site and Products (including through geolocation analytics)

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For more information, see Choices About How We Use and Disclose Your Information.

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Legal Basis for Processing (GDPR)

Under the General Data Protection Regulation (GDPR), we rely on the following lawful bases:

• Consent: For sending marketing communications and placing non-essential cookies
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• Contractual necessity: To process transactions or provide services you requested
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• Legitimate interest: For analytics, fraud prevention, product improvement, and anonymous geolocation tracking
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• Legal obligation: To comply with applicable laws

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Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

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We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our affiliates.
• To contractors, service providers, and other third parties we use to support the Site.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With business and marketing partners, including Shopify, to provide services and advertise to you. (Our business and marketing partners will use your information in accordance with their own privacy notices).
• With your consent.

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We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use [INSERT AS LINK TO WEBSITE'S TERMS OF USE] and any other agreements you enter into with Totem, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Totem, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when     cookies are being sent. If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly.

• Promotional Offers and Advertisements. If you do not wish to have your contact information used by Totem to promote our own or     third parties' products or services, you can opt-out by sending us an email stating your request to shop@totemlabs.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided by Totem as a result of inquiries or requests submitted by you, or in connection with transactions carried out through the Site.

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Accessing and Correcting Your Information

You may also send us an email at shop@totemlabs.com to request access to, correct or delete any personal information that you have provided to us through the Site. We may not accommodate a request to change or delete information if we believe the change would violate any law or legal requirement, cause the information to be incorrect, or if such information is needed to fulfill any outstanding purchases.

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Data Security

The safety and security of your information also depends on you. Where we have given you(or where you have chosen) a password for access to certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

The transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on theSite.

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GDPR Notice

In compliance with the European Union (“EU”) General Data Protection Regulation (“GDPR”), we may rely upon one or more legal bases defined in the GDPR to collect, use, share and otherwise process the personal information of individuals located in theEU, including where:

• Necessary to perform a contract we have with you, such as our terms of engagement, and to provide the services;
• You have consented to the processing (in which case you may revoke your consent at any time);
• Necessary for us to comply with a legal obligation, or to establish, exercise or defend legal claims;
• Necessary to protect your vital interests or those of others;
• Necessary in the public interest; and
• Necessary for the purposes of Totem's or a third party’s legitimate interests, provided that those interests are not overridden by your interests or fundamental rights and freedoms.

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Where we collect, use, disclose and otherwise process your information based on legitimate interests, we may rely on the following interests:

• Marketing our products: We use your information as necessary to pursue our legitimate interests in marketing our products to you. For example, where permitted by digital marketing law, we may contact you by email to let you know of products or training you might be interested in.
• Providing, improving and developing our products: We use your information as necessary to pursue our legitimate interests in tailoring and improving our products. For example, we may send you a survey or questionnaire to understand your experience in purchasing from us.

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If you are located in the EU, under certain circumstances, you may have certain legal rights under the GDPR, including:

• To access the personal data we maintain about you
• To receive information about how we process your personal data
• To correct your personal data
• To have your personal data erased
• To object to or restrict how we process your personal data
• To request your personal data be transferred to a third party
• To withdraw any consent you may have given us to process your personal data

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If you are an EU resident, you have the right to object to our processing that is based on legitimate interests by contacting us at the address or number below. If you are located in the EU and you believe that we have infringed your rights under the GDPR, please contact us by sending an email to shop@totemlabs.com.

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Data Retention

We retain personal data only as long as necessary to fulfill the purposes outlined in this policy or comply with legal obligations. Anonymous geolocation data is retained only in aggregate form.

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Data Security

We implement industry-standard measures to protect your data. However, no method of transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your password.

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Changes to Our Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. Your continued use of the Site after any changes means you accept the new policy.

Last updated: April 29th, 2025

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Contact Information

To ask questions or comment about this privacy policy or our privacy practices, contact us via our contact page.

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