Data protection policy

(Last update on )

1

Data protection policy for visitors to the Totemus website, available at totemus.com

LUDIFICA SRL is committed to protecting and respecting your privacy.

You can visit our site, find out about our services and read our latest news without having to provide us with any personal information.

However, the use of certain cookies is necessary to browse our website. For further information in this regard, please refer to our cookie use policy, available at Cookie management.

You may also entrust us with personal data and generate such data on our website.

LUDIFICA SRL scrupulously complies with the applicable legislation in this area as in all others. Here’s how:

1.1.

Why do we process your data?

1.1.1.

Creating a user account

PurposesThe data you send us is processed to enable you to create an account on our website.
Legal basisThe data is processed on the basis of the performance of the contract relating to the creation of an online account (article 6.1.b) of the RGPD).
Categories of dataThis includes your surname, first name, e-mail address and postcode. All this data is essential for the performance of the agreement. Without it, we cannot allow you to create an account.

This data is collected when you create an account on our website.

DurationThe data is processed until you ask us to delete your online account. However, if you have placed an order via this account, certain data is retained in accordance with the section below entitled “Exchanging your toteez”.
RecipientsIt may be necessary to communicate your data to our subcontractors (IT service providers, payment services, etc.).
1.1.2.

Exchanging your toteez

PurposesThe data you send us is processed to enable us to exchange your toteez and to enable you to benefit from gift vouchers made available by our partners.
Legal basisThe personal data processed is essential for the performance of our contractual relationship (article 6.1.b) of the RGPD).
Categories of dataThis may include your surname, first name, e-mail address, postal address and telephone number. All this data is essential for the performance of the agreement. Without it, we cannot prepare your gift vouchers and send them to you.

This data may be collected when you create an account on our website or when you first connect to our application.

DurationThe data you entrust to us is kept for 10 years, in particular to comply with our tax and accounting obligations, as well as for reasons of contractual liability.
1.1.3.

Promoting our services

PurposesYour personal data is processed to promote our services. In this way, we can keep you informed about our services.
Legal basisIf you have a user account on our site, our legitimate interest in promoting our services justifies us carrying out information operations (on our news, events, etc.) or promoting our services (article 6.1.f) of the RGPD).
Categories of dataThis includes your surname, first name, e-mail address and postcode.

This data may be collected when you visit our website or our mobile application.

Recipients of the dataYour data will be sent to an electronic mailing service.
DurationWe keep your data for this purpose until you ask us to stop and for a maximum of 5 years after your last contact with us.
1.2.

Where is your data located?

In the European UnionIn principle, your data will only be stored on servers located within the EU.
1.3.

What are your rights?

InformationThis right is exercised by means of this document. If the data processed includes the data of your staff, you undertake to inform them of this document.
Access and rectificationYou have the right to access your data and have it rectified if necessary.

You have the right to consult your data at any time and free of charge, by sending an email to info@ludifica.be or a dated and signed letter to the registered office of the data controller. You also have the right to demand that incorrect data be corrected and that inappropriate or no longer necessary data be deleted by sending an email to info@ludifica.be or by sending us a dated and signed letter to the address of the registered office of the data controller.

ObjectionYou may object to the processing of your data by us on the basis of our legitimate interests. You can exercise your right to object either by using the unsubscribe links available in the e-mails sent to you.
Withdrawing your consentWhere data is processed on the basis of your consent, you may withdraw this decision at any time, without calling into question past processing.
DeletionYou may obtain the erasure of your data or the restriction of processing under the conditions set out in Articles 17 and 18 of the General Data Protection Regulation.
PortabilityThe data you have provided us with may be communicated or transmitted in electronic format.
1.4.

Who should you contact?

The person responsible for processing your data (SRL LUDIFICA, whose registered office is at 4053 Chaudfontaine, Voie de l’Ardenne, no. 134/6 and registered with the Crossroads Bank for Enterprises under number (BE) 0770.789.120) will be happy to answer any questions you may have at info@totemus.com and, subject to proof of identity, for any request relating to the rights set out above.

If you require any further information, or if you wish to lodge a complaint, you may contact the Data Protection Authority (Rue de la Presse, 35 – 1000 Brussels, Tel. + 32 2 274 48 00 – https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte).

2

Processing of personal data of users of the application made available by Ludifica SRL

LUDIFICA SRL is committed to protecting and respecting your privacy.

The data that you entrust to us and that you generate when you download and use our mobile application are essentially personal data.

LUDIFICA SRL scrupulously complies with the applicable legislation in this area as in all others. Here’s how:

2.1.

Why do we process your data?

2.1.1.

Creating a user account and accessing the application

PurposesThe data you send us is processed to enable you to create an account on our application and to communicate with you about it.
Legal basisThe personal data processed is essential for the performance of our contractual relationship (article 6.1.f) of the GDPR).
Categories of dataThis may include your surname, first name, e-mail address and postcode. All this data is essential for the performance of the agreement. Without it, we cannot allow you to access the application.

This data is collected when you first connect to our application.

DurationThe data is processed until you ask us to delete your online account. However, if you have placed an order via this account, certain data will be retained in accordance with the section “Exchanging your toteez” below.
2.1.2.

Range of courses

PurposesThe data you send us is processed to enable you to take part in the courses and to communicate with you on this subject.
Legal basisThe personal data processed is essential for the performance of our contractual relationship (article 6.1.f) of the GDPR).
Categories of dataThis may include your surname, first name, e-mail address, postcode and geolocation. All this data is essential for the performance of the agreement. Without it, we cannot allow you to benefit from our services.

This data may be collected when you first connect to our application and/or, in the case of geolocation data, when the application is active.

DurationThe data you entrust to us is kept for 10 years for reasons of contractual liability.

Geolocation data is not stored.

2.1.3.

Exchanging your toteez

PurposesThe data you send us is processed to enable us to exchange your toteez and to enable you to benefit from gift vouchers made available by our partners.
Legal basisThe personal data processed is essential for the performance of our contractual relationship (article 6.1.f) of the RGPD).
Categories of dataThis may include your surname, first name, e-mail address, postal address and telephone number. All this data is essential for the performance of the agreement. Without it, we cannot deliver your gift vouchers.

This data may be collected when you create an account on our website or when you first connect to our application.

DurationThe data you give us is kept for 10 years for contractual liability reasons.
2.1.4.

Promoting our services

PurposesYour personal data is processed to promote our services. In this way, we can keep you informed about our services.
Legal basisIf you have a user account on our site, our legitimate interest in promoting our services justifies us carrying out information operations (on our news, events, etc.) or promoting our services (article 6.1.f) of the RGPD).
Categories of dataThis includes your surname, first name, e-mail address and postcode.

This data is collected when you create your account via our website or our application.

Recipients of the dataYour data is sent to an electronic mailing service.
DurationWe keep your data for this purpose until you ask us to stop and for a maximum of 5 years after your last contact with us.
2.1.5.

Authorisations requested by the mobile application

In order for certain functions to work, our mobile application must be able to access certain interfaces and data on your device.

Depending on the operating system you are using, this may require your express authorisation. Our mobile application requires the following authorisations (if they are necessary for processing your data):

  • Your geographical position (geolocation): this authorisation is required so that the mobile application can access the geographical position determined by your device. If you do not authorise this access, you will not have access to the route;
  • Your geographical position in the background: this authorisation is required while using the application in order to access the geographical position when the application is minimised so that the user can continue to be tracked on the routes; – Your geographical position in the background: this authorisation is required while using the application in order to access the geographical position when the application is minimised so that the user can continue to be tracked on the routes;
  • Notifications: this authorisation is required to activate the mobile application’s notification service;
  • Access to your device’s storage space: this authorisation is required to allow the mobile application to store data in your device’s memory or, if applicable, in an auxiliary memory, or to read it. The mobile application only reads data stored in connection with its use.

You can withdraw these authorisations at any time or change the authorisation settings in the system settings of your device.

2.1.6.

Improving our services and using Firebase Analytics

PurposesYour personal data is processed to improve our services.
Legal basisOur legitimate interest in improving our services justifies our processing of your data.
Categories of dataThis is your Log Data, which may include the IP address of your device, the name of the device, the time and date of your use of the service and other events/actions carried out via the application.
RecipientsThis data may be communicated to Google Analytics for Firebase.
2.1.7.

Statistics

PurposesYour personal data is processed to enable us to produce statistics on the use of our platform and services.
Legal basisOur legitimate interest in improving our services justifies our processing of your data.
Categories of dataThis may include your Log Data, which may include the IP address of your device, the name of the device, the time and date of your use of the service), the hunts in which you have participated and the frequency of your participation.
RecipientsThis data may be communicated to hunt organisers.
DurationThis data is kept for five years.
2.2.

Where is your data located?

In the European UnionIn principle, your data will only be stored on servers located within the EU.
2.3.

What are your rights?

InformationThis right is exercised by means of this document. If the data processed includes the data of your staff, you undertake to inform them of this document.
Access and rectificationYou have the right to access your data and have it rectified if necessary.

You have the right to consult your data at any time and free of charge, by sending an email to info@ludifica.be or a dated and signed letter to the registered office of the data controller. You also have the right to demand that incorrect data be corrected and that inappropriate or no longer necessary data be deleted by sending an email to info@ludifica.be or by sending us a dated and signed letter to the address of the registered office of the data controller.

ObjectionYou may object to the processing of your data by us on the basis of our legitimate interests. You can exercise your right to object either by using the unsubscribe links available in the e-mails sent to you.
Withdrawing your consentWhere data is processed on the basis of your consent, you may withdraw this decision at any time, without calling into question past processing.
DeletionYou may obtain the erasure of your data or the restriction of processing under the conditions set out in Articles 17 and 18 of the General Data Protection Regulation.
PortabilityThe data you have provided us with may be communicated or transmitted in electronic format.
2.4.

Who should you contact?

The person responsible for processing your data (SRL LUDIFICA, whose registered office is at 4053 Chaudfontaine, Voie de l’Ardenne, no. 134/6 and registered with the Crossroads Bank for Enterprises under number (BE) 0770.789.120) will be happy to answer any questions you may have at info@totemus.com and, subject to proof of identity, for any request relating to the rights set out above.

If you require any further information, or if you wish to lodge a complaint, you may contact the Data Protection Authority (Rue de la Presse, 35 – 1000 Brussels, Tel. + 32 2 274 48 00 – https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte).

3

Processing of personal data of visitors to our pages on social networks

LUDIFICA SRL is committed to protecting and respecting your privacy.

The data that you entrust to us and that you generate when you visit our pages on social networks are essentially personal data.

LUDIFICA SRL scrupulously complies with the applicable legislation in this area as in all others. Here’s how:

3.1.

Why do we process your data?

PurposesThe data you provide when visiting our pages on social networks is or may be processed jointly by the social network and the administrator of this page for the following purposes:

  • the collection of certain data by means of cookies ;
  • improvement by the social network of its advertising system;
  • to obtain audience statistics for the page.

The personal data use policies of each social network can be found by clicking on the following links:

The audience statistics established by the social network are only transmitted in an anonymised form to SRL LUDIFICA to administer the page.

Basis of lawfulnessThis data is processed on the basis of our legitimate interest in obtaining statistics on visitors to our pages in order to promote our page appropriately.
Categories of dataData linked to your account, data linked to the sharing of content or to your communications with other people.
DurationThis data is or may be processed for as long as the page exists and you visit it.
3.2.

Where your data is located

In the European UnionIn principle, your data will only be stored on servers located within the EU.
In the event of transfer outside the European UnionYour data will only be transferred to a country that does not offer an adequate level of protection if this is necessary.

In such cases, we naturally ensure that the recipients are obliged to comply with the same data protection standards as in the EU by means of appropriate contractual clauses. You can obtain a copy of these guarantees on request.

3.3.

What are your rights?

InformationThis right is exercised by means of this document. If the data processed includes the data of your staff, you undertake to inform them of this document.
Access and rectificationYou have the right to access your data and have it rectified if necessary.

You have the right to consult your data at any time and free of charge, by sending an email to info@ludifica.be or a dated and signed letter to the registered office of the data controller. You also have the right to demand that incorrect data be corrected and that inappropriate or no longer necessary data be deleted by sending an email to info@ludifica.be or by sending us a dated and signed letter to the address of the registered office of the data controller.

ObjectionYou may object to the processing of your data by us on the basis of our legitimate interests. You can exercise your right to object either by using the unsubscribe links available in the e-mails sent to you.
Withdrawing your consentWhere data is processed on the basis of your consent, you may withdraw this decision at any time, without calling into question past processing.
DeletionYou may obtain the erasure of your data or the restriction of processing under the conditions set out in Articles 17 and 18 of the General Data Protection Regulation. >>URL INVALID<<
PortabilityThe data you have provided us with may be communicated or transmitted in electronic format.
3.4.

Who should you contact?

The person responsible for processing your data (SRL LUDIFICA, whose registered office is at 4053 Chaudfontaine, Voie de l’Ardenne, no. 134/6 and registered with the Crossroads Bank for Enterprises under number (BE) 0770.789.120) will be happy to answer any questions you may have at info@totemus.com and, subject to proof of identity, for any request relating to the rights set out above.

If you require any further information, or if you wish to lodge a complaint, you may contact the Data Protection Authority (Rue de la Presse, 35 – 1000 Brussels, Tel. + 32 2 274 48 00 – https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte).

4

Data protection policy for members of organisations offering hunting via the totemus.com website

LUDIFICA SRL is committed to protecting and respecting your privacy.

The data that you give us when you suggest a hunt on our website are essentially personal data.

LUDIFICA SRL scrupulously complies with the legislation applicable in this area as in all others. Here’s how:

4.1.

Why do we process your data?

4.1.1.

Our services: hunting quotes

PurposesThe data you send us is processed to enable us to respond to your request for a hunting quote and to communicate with you about it.
Legal basisThe personal data processed is essential for the performance of pre-contractual measures taken at your request or that of your organisation.
Categories of dataThis may include your surname, first name, the name of your organisation, your e-mail address, telephone number and the town where the hunt will take place. All this data is essential for the execution of pre-contractual measures taken at your request or that of your organisation. Without it, we cannot allow you to benefit from our services.

This data may be collected during your visit to our site or when you contact us by e-mail.

DurationThe data you entrust to us is kept for 10 years, in particular to comply with our tax and accounting obligations, as well as for reasons of contractual liability.
4.1.2.

Managing our contractual relationship

PurposesThe data you send us is processed to enable us to organise the hunt and communicate with you about it, to notify you of any changes to the contract or to the data protection policy.
Legal basisThe personal data processed is essential for the performance of our contractual relationship.
Categories of dataThis may include the surnames, first names, e-mail addresses and telephone numbers of the members of your organisation. All this data is essential to the performance of the agreement. Without it, we cannot allow you to benefit from our services.

This data may be collected when you first request contact or as part of the performance of the agreement.

DurationThe data you entrust to us is kept for 10 years, in particular to comply with our tax and accounting obligations, and for reasons of contractual liability.
4.2.

Where is your data located?

In the European UnionIn principle, your data will only be stored on servers located within the EU.
4.3.

What are your rights?

InformationThis right is exercised by means of this document. If the data processed includes the data of your staff, you undertake to inform them of this document.
Access and rectificationYou have the right to access your data and have it rectified if necessary.

You have the right to consult your data at any time and free of charge, by sending an email to info@ludifica.be or a dated and signed letter to the registered office of the data controller. You also have the right to demand that incorrect data be corrected and that inappropriate or no longer necessary data be deleted by sending an email to info@ludifica.be or by sending us a dated and signed letter to the address of the registered office of the data controller.

ObjectionYou may object to the processing of your data by us on the basis of our legitimate interests. You can exercise your right to object either by using the unsubscribe links available in the e-mails sent to you.
Withdrawing your consentWhere data is processed on the basis of your consent, you may withdraw this decision at any time, without calling into question past processing.
DeletionYou may obtain the erasure of your data or the restriction of processing under the conditions set out in Articles 17 and 18 of the General Data Protection Regulation. >>URL INVALID<<
PortabilityThe data you have provided us with may be communicated or transmitted in electronic format.
4.4.

Who should you contact?

The person responsible for processing your data (SRL LUDIFICA, whose registered office is at 4053 Chaudfontaine, Voie de l’Ardenne, no. 134/6 and registered with the Crossroads Bank for Enterprises under number (BE) 0770.789.120) will be happy to answer any questions you may have at info@totemus.com and, subject to proof of identity, for any request relating to the rights set out above.

If you require any further information, or if you wish to lodge a complaint, you may contact the Data Protection Authority (Rue de la Presse, 35 – 1000 Brussels, Tel. + 32 2 274 48 00 – https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte).

5

Data protection policy for totemus.com partner members

LUDIFICA SRL is committed to protecting and respecting your privacy.

The data that you entrust to us when you make gift vouchers available to our customers are essentially personal data.

LUDIFICA SRL scrupulously complies with the applicable legislation in this area as in all others. Here’s how:

5.1.

Why do we process your data?

5.1.1.

Gift vouchers

PurposesThe data you send us is processed to enable us to make available the gift vouchers you have given us and to communicate with you on this subject, to notify you of any changes to the contract or to the data protection policy.
Legal basisThe personal data processed is essential for the performance of our contractual relationship.
Categories of dataThis may include the surnames, first names, e-mail addresses and telephone numbers of the members of your organisation. All this data is essential to the performance of the agreement. Without it, we cannot allow you to benefit from our services.

This data may be collected when you first request contact or as part of the performance of the agreement.

DurationThe data you entrust to us is kept for 10 years, in particular to comply with our tax and accounting obligations, and for reasons of contractual liability.
5.2.

Where is your data located?

In the European UnionIn principle, your data will only be stored on servers located within the EU.
5.3.

What are your rights?

InformationThis right is exercised by means of this document. If the data processed includes the data of your staff, you undertake to inform them of this document.
Access and rectificationYou have the right to access your data and have it rectified if necessary.

You have the right to consult your data at any time and free of charge, by sending an email to info@ludifica.be or a dated and signed letter to the registered office of the data controller. You also have the right to demand that incorrect data be corrected and that inappropriate or no longer necessary data be deleted by sending an email to info@ludifica.be or by sending us a dated and signed letter to the address of the registered office of the data controller.

ObjectionYou may object to the processing of your data by us on the basis of our legitimate interests. You can exercise your right to object either by using the unsubscribe links available in the e-mails sent to you.
Withdrawing your consentWhere data is processed on the basis of your consent, you may withdraw this decision at any time, without calling into question past processing.
DeletionYou may obtain the erasure of your data or the restriction of processing under the conditions set out in Articles 17 and 18 of the General Data Protection Regulation.
PortabilityThe data you have provided us with may be communicated or transmitted in electronic format.
5.4.

Who should you contact?

The person responsible for processing your data (SRL LUDIFICA, whose registered office is at 4053 Chaudfontaine, Voie de l’Ardenne, no. 134/6 and registered with the Crossroads Bank for Enterprises under number (BE) 0770.789.120) will be happy to answer any questions you may have at info@totemus.com and, subject to proof of identity, for any request relating to the rights set out above.

If you require any further information, or if you wish to lodge a complaint, you may contact the Data Protection Authority (Rue de la Presse, 35 – 1000 Brussels, Tel. + 32 2 274 48 00 – https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte).

6

Data protection policy for Premium users of the Totemus application

LUDIFICA SRL is committed to protecting and respecting your privacy.

The data that you entrust to us or that you generate by taking out a Premium subscription on our mobile application are essentially personal data.

LUDIFICA SRL scrupulously complies with the applicable legislation in this area as in all others. Here’s how:

6.1.

Why do we process your data?

Totemus offers an optional subscription package called the “Premium Account”, which can be accessed via the Totemus mobile application.

In this context, we collect and process certain personal data necessary for the management of the subscription, namely :

  • the subscription subscription date
  • the end date of any trial period,
  • the status of the subscription (active, expired, cancelled, etc.),
  • subscription history (duration, status, renewals),
  • unlocked content items associated with Premium status (e.g. exclusive badges),
  • and preferences linked to Premium features.

We also use this data to ensure the smooth operation of the Premium service (access to features, retention of benefits obtained, sending of subscription management-related emails such as reminders or renewal notifications, etc.).

6.2.

Where is your data located?

Subscriptions are managed technically and commercially via the Apple App Store and Google Play Store platforms, using the RevenueCat tool, which complies with current security standards. Totemus does not directly collect or store banking or payment information.

Premium subscription data is stored on our internal systems, located within the European Union, in accordance with our general data processing policy.

6.3.

What are your rights?

You have the following rights with regard to your personal data:

  • right of access,
  • right of rectification,
  • right to erasure,
  • the right to restrict processing,
  • right to data portability
  • and the right to object.

You can exercise these rights by contacting us (see point 6.4 below).

6.4.

Who should you contact?

The person responsible for processing your data (SRL LUDIFICA, whose registered office is at 4053 Chaudfontaine, Voie de l’Ardenne, no. 134/6 and registered with the Crossroads Bank for Enterprises under number (BE) 0770.789.120) will be happy to answer any questions you may have at info@totemus.com and, subject to proof of identity, for any request relating to the rights set out above.

If you require any further information, or if you wish to lodge a complaint, you may contact the Data Protection Authority (Rue de la Presse, 35 – 1000 Brussels, Tel. + 32 2 274 48 00 – https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte).