Privacy policy

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.


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


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.

You can revoke your consent at any time by contacting us below, through a contact page on the website service or, if applicable, through the unsubscribe link in the email from the service you wish to unsubscribe from. Such revocation may occur in whole or in part and applies only to the service in question, unless the request explicitly regards all of the user’s data across some or all of our services.

You should be aware that if you revoke your consent in part or in full, for any or all services, it may result in us being unable to provide the best possible user experience during the use of our service, or providing access to a service at all.

We use cookies and similar tracking technologies to track the activity on our service, and store certain information. Tracking technologies used are beacons, tags and scripts to collect and track information and to improve and analyse our service.

This service will provide you with a consent form on your initial visit. The form gives you the option to accept or reject different groups of cookies, except for the ones deemed ‘necessary’ for basic functions.

Note! In the next update we will improve this consent form so the user can accept or reject, any or all cookies. We anticipate that this update will be rolled out in November 2020 at the latest.

Cookies can be of types ‘persistent’ or ‘session’. Persistent cookies contain an expiration date and will remain stored on your device until that time, even if you leave our service. Session cookies are only stored in your device’s memory and never written to disk. They are deleted as soon as you close your web browser.

You can instruct most modern web browsers to refuse all cookies or to indicate when a cookie is being sent. For more information about the cookies we use and your current choices regarding cookies, please see the dedicated cookie settings page on the site in question.

You can learn more about cookies in general here: All About Cookies.

When registering for our services, such as accepting cookies, receiving newsletters or participating in one of our events, you will always be informed about this privacy policy. If at any time you don’t accept parts, or the whole, of this privacy policy you should not go through with the registration process or accepting any cookies.

If you change your mind after the fact of accepting or not accepting cookies you can change your consent on the site’s cookie settings page.

If you change your mind after the fact of registering for a service you should immediately contact the company’s data processors through any of the contact details at the end of this document.

Some of our services use javascript to detect the use of adblocking software. This script is implemented into source code of the service. It simulates the display of an ad and confirms whether or not the ad appears on the user’s device. We do not store any information on the user’s device and do not process the user’s personal information when using this script.

If we detect the use of adblocking software we may interact with the user about the use of such software and/or customize the content that the user accesses.

HKM/Totally is the copyright holder for all content, regardless of the type, on any website or service owned by HKM/Totally, except where otherwise stated (usually concerning third party material such as press images or embedded videos).

This means that all content in the form of – for example – texts, movies, articles, reports, audio tracks, radio, brands, graphics and illustrations are legally protected by copyright and trademark laws if nothing else is specified. This in turn means that when you visit our websites, and/or use our services, you do not own the right to copy, distribute, transmit or otherwise make any of the material available without the written consent of HKM/Totally.

If you have any questions related to this privacy policy or want to contact us for any other reason stated in this privacy policy, you can reach us at:

or at the below address or phone:

Personal Information
73 Leeson Street Lower
Dublin 2, Ireland

Tel: +353 1 676 6686

We strive to respond to you within 3 working days.

HKM/Totally will not be held liable for any damage caused directly or indirectly by your usage of our services. HKM/Totally makes no absolute guarantees regarding availability or functionality of our services.

HKM/Totally cannot be held responsible for the legality of the content of the web pages we link to from our services. Nor can we guarantee that published links work forever.

HKM/Totally cannot be held liable for any loss, both direct and indirect, including losses caused by malfunctions, unavailability of the sites and the like.

HKM/Totally is not responsible for personal data being accessed by unauthorised people in case of; sabotage/data breach, other external impact beyond our reasonable control or events that are considered to be ‘force majeure’.

We may update this privacy policy from time to time and any changes are effective at the time they are posted on this page. You are advised to review this privacy policy periodically for any changes so you always know the terms of the services you use.