Your visit to this site and all sites operated by HKM Media Ltd/Totally Partner Ltd is subject to the terms below. The same applies to all websites, applications, and services where there is a reference or link to this privacy policy.

This privacy policy describes our policies and procedures on the collection, use and disclosure of your information when you use our websites, apps or services. It also informs you about your privacy rights and how the law protects you.

We use your personal data to provide the best possible user experience.

Interpretation

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this privacy policy) refers to Totally Partner Ltd/HKM Media Ltd, 73 Leeson Street Lower, Dublin 2.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: Ireland
• Data controller is the person, company or other entity that decides the purpose of any data collected. In this case Totally Partner Ltd or HKM Media Ltd, as applicable.
• Data processor is a person (usually an employee) who decides how and when data is collected as well as handling said data.
• Device means any device that can access the service such as a computer, a cellphone or a digital tablet.
• HKM/Totally is Totally Partner Ltd or HKM Media Ltd, as applicable.
• Personal data is any information that relates to an identified or identifiable individual.
• Service refers to the website, app or other service (e.g. a newsletter).
• Service provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Third-party social media service refers to any website or any social network website through which a user can log in or create an account to use the Service.
• Usage data refers to data collected automatically, either generated by the use of the service or from the service infrastructure itself (for example, the duration of a page visit).
• Website refers to any site owned by HKM/Totally that refers to this document as its privacy policy.
• You means the individual accessing or using the website, app or service, or the company, or other legal entity on behalf of which such individual is accessing or using the website, app or service, as applicable.

HKM/Totally will always strive to protect your personal data and comply with all laws and regulations regarding the privacy of individuals. (You can read more about this below under the ‘Personal Information’ section).

Some of our services make use of cookies from, or links to, different service providers. We are obligated to inform you that they are recieving data from our services. For information about their intentions and use of said data we refer to the privacy policy for each of these service providers.

You can at any time request information about which personal data we have registered regarding you, and how this data is used, after a written request has been submitted to us in accordance with the contact details towards the end of this document.

In the same manner, you are always entitled to access, correct, delete and limit processing of personal data. You are also entitled to request and receive your personal data stored by us so that it can be used by another processor.

In order to protect your privacy and your personal information we may require you to identify yourself before we can comply with your request.

If at any time you feel that we do not live up to, meet or exceed requirements set by law, you have the right to lodge a complaint with a supervisory authority.

Personal Data

While using our services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Usage data

Usage Data

Usage data is collected automatically when using the service.

Usage data may include information such as your device’s Internet Protocol address (e.g. IP address), browser type, browser version, model, the device’s unique MAC address, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our services.

The company may use personal data for the following purposes:

• To provide and maintain our services, including to monitor the usage of our service.
• To manage your submitted personal information, for instance your registration as a recipient of any of our newsletters. The personal data you provide can give you access to different functionalities of the service that are available to you as a registered user.
• To contact you by email, telephone calls, SMS or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including security updates, when necessary or reasonable for their implementation.
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, unless you have opted not to receive such information.
• To manage your requests to us.

We may share your personal information in the following situations:

• With service providers to monitor and analyze the use of our services.
• For business transfers where we may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.
• With affiliates in which case we will require those affiliates to honor this privacy policy. Affiliates include any parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• With other users if you have registered with a third-party social media service. Other users on that third-party social media service may see your name, profile, pictures and description of your activity.

We will retain your personal data only for as long as is necessary for the purposes set out in this privacy policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our services, or if we are legally obligated to retain this data for longer time periods.

Your information, including personal data, is processed at the company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this privacy policy, followed by your submission of such information, represents your agreement to that transfer.

The company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and no transfer of your personal data will be to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Business transactions

If the company is involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different privacy policy.

Law enforcement

Under certain circumstances, the company may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The company may disclose your personal data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the company
• Prevent or investigate possible wrongdoing in connection with a service
• Protect the personal safety of users of the service or the public
• Protect against legal liability

The security of your personal data is important to us, but ultimately, no method of transmission over the internet, or method of electronic storage, is 100 per cent secure. While we strive to use commercially acceptable means to protect your personal data, we can never guarantee its absolute security.