Art. 13 of EU Regulation 2016/679

General Data Protection Regulation


With this policy, Totem Esports S.r.l., as the data controller, wishes to inform users of the website (the “Website “) of the policy adopted on the protection of personal data, underlining its commitment and attention with reference to the protection of the privacy of users of the Website (the “Users ”).
We invite you to carefully read our Privacy Policy, which applies both in the case of simple navigation within the Website and related services.

Navigation within the Website is free and does not require any registration, with the exception of some areas where the User can freely and expressly provide a series of data concerning him to access specifically identified services (e.g. to complete the purchase process). Where the visitor intends to provide his personal data to access such additional services, he can find in this document all the information relating to the processing of his personal data pursuant to of Regulation (EU) 2016/679 — General Data Protection Regulation (the “Regulation”) and Legislative Decree no. 196 of 30 June 2003 – Code regarding the protection of personal data (the “Code”), with indication (by way of example) of the purposes and methods of using the data from Totem Esports S.r.l., as well as the right to request the deletion of data or updating them at any time.

We remind Users that personal data means “any information concerning an identified or identifiable natural person”; for processing “any operation o set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination, or any other form of making available, comparison or interconnection, limitation, erasure or destruction”.

By accessing the Website, the User declares to have read and understood this Privacy Policy.

Information on the processing of personal data
Pursuant to and for the purposes of art. 13 of the Regulation, Totem Esports S.r.l. provides the following information.

  1. 1. Identity and contact details of the Data Controller
  2. 2. Joint Ownership
  3. 3. Type of personal data processed
  4. 4. Optional provision of personal data
  5. 5. Purpose and legal basis of the processing
  6. 6. Methods of treatment
  7. 7. Recipients of personal data
  8. 8. Non-EU transfers
  9. 9. Retention period
  10. 10. Links to other sites
  11. 11. Analysis tools
  12. 12. Rights of the interested parties
  13. 13. Complaint to the Supervisory Authority
  14. 14. Review clause


1. Identity and contact details of the Data Controller
The owner of the processing of personal data collected through the Website is Totem Esports S.r.l., with headquarters in Zona Industriale San Zeno, Strada F 31, 52100 Arezzo, VAT number and CF 02388020519, registered in the Register Companies in Arezzo, tel. 3334239820, e-mail (“Totem” or the “Company”).


2. Joint Ownership
Totem Esports will be joined as a joint controller by the company Totem Esports ASD, with headquarters in Arezzo (Italy), MONTE SAN SAVINO ( AR), Tax Code, VAT Number and Arezzo Business Register No. 02354020519 (“ASD Totem Esports”), in order to carry out some specific treatments identified in paragraph 5 below.
Totem Esports S.r.l. and Totem Esports ASD (the “Joint Data Controllers”) have entered into a joint ownership agreement, in compliance with art. 26 of the Regulation, with which they jointly established their respective obligations and respective responsibilities under current legislation on personal data (e.g. with regard to the management of requests from interested parties). The essential content of the agreement is available by sending a communication to
The Joint Controllers have jointly defined the contents of this information, with regard to the parties of common interest.


3. Type of personal data processed
To access the Website, it is not necessary to register. However, there are sections that require a registration or the use of an username and password (e.g. to register on the Website); in addition, the Website offers some services for the use of which is essential provide your data (e.g. to subscribe to the newsletter or to complete the purchase process). Where necessary, the Joint Controllers will acquire the User’s specific consent to the relative use of the data.
Here is a summary of the type of information that is collected through the Website:
• Personal information: name, surname, address, etc.; 
• Contact details: residential address, e-mail address, telephone number, postal code; 
• Data relating to interests and preferences: data relating to your purchases (e.g. number, value and types of purchases), products placed in the shopping cart, etc.; 
• Transactional data: credit card number, tax code, VAT, etc.; 
• Connection data: IP address, number of devices/ID, data relating to your internet connection and your service provider, the equipment you use to access the Website, your browsing history and other details technical and usage. 
With reference to the data relating to navigation within the Website collected through the use of “cookies”, see also the following paragraph 11 regarding the Analysis and Profiling Tools;


4. Optional provision of personal data
Some of the personal data requested on the Website, such as first and last name, telephone number, e-mail address, shipping address, may be marked as “mandatory” [for example, indicated with an (*)] as they are necessary to access the services offered by the Company through the Website you want to use (for example, if you make a purchase).
Failure to provide the data marked as “mandatory” will make it impossible for Totem Esports (and the Joint Data Controllers) to provide the requested service (for example, if the User does not provide their e-mail address, the Company will not be able to proceed with the sending of a reply when filling out the form). Failure to provide data marked as “optional” will not have any consequences.
Users are required to indicate on the Website only the personal data concerning them. If personal data of third parties are indicated, Users must expressly declare and acknowledge that they have obtained the consent of third parties for the processing of the corresponding personal data by the Companies, or other data controllers.


5. Purpose and legal basis of the processing
Users’ data are collected and processed for purposes strictly related to the use, management and updating of the Website, the services offered within the framework of the same and their presentation to Users. The specific purposes of using the data are indicated in detail in this paragraph.

(a) Registration on the Website, creation of a personal account, use of services
Users’ personal data will be processed by the Company for:
• allow registration on the Website, 
• proceed to the creation of a personal account, and 
• guarantee access to areas and any benefits reserved for members (e.g. making purchases faster, checking order history, etc.). 
The Users’ e-mail address may also be used for
• sending any communications relating to how to use the functions of the Website (e.g. confirmation of registration, invitation to renew credentials, etc.). 
We will also use some personal data of Users relating to the connection and navigation within the Website to
• allow a normal and efficient navigation and use of the Website, and 
• improve performance and operation. 
The processing of data connected to the provision of the services and the operation of the website does not require the consent of the Users, as it is necessary for the execution of a contract between Users and Totem Esports (art. 6, paragraph 1, letter b) of the Regulation).
Likewise, the processing of data for purposes of analysis and improvement of the functioning of the Website does not require the consent of the Users, as it is necessary for the pursuit of the legitimate interest of the Companies and Users to provide a high quality service (art. 6, paragraph 1, letter f) of the Regulation).


(b) E-commerce
If the User makes a purchase on the Website, his personal data will be processed by Totem Esports for:
• completing the sales process and execute the contract in place between the parties (e.g. payment management and processing, completion of the delivery and/or return process, etc.); 
• fulfill legal obligations (e.g. in tax, accounting for billing, keeping records and accounting records) inherent to the contract concluded with the User; 
• manage any services strictly related to the sale (e.g. request for information about products, use of customer service, sending order confirmation, etc.); 
• protect the rights deriving from the contract concluded with the User, even by means of agents, in court or out of court. 
The processing of data for this purpose does not require the consent of the Users, as it is necessary for the execution of the sales contract concluded with the User and for the execution of pre-contractual measures adopted at the request of the User, as well as to correctly fulfill the legal obligations to which the Company is subject (art. 6, paragraph 1, letters b) and c) of the Regulation) and — in the event of disputes — for the pursuit of Totem Esports’ legitimate interest in protecting its rights (art. 6, paragraph 1, letter f) of the Regulation).
Furthermore, subject to the collection of appropriate and specific consent, Users’ data will be processed for:


(c) Marketing and soft spam
Allow you to subscribe to the update service on promotions, sales and initiatives — through the use of automated and non-automated means, such as newsletters, e-mail, telephone contact, text messages, instant messages, posts, communications and posts on social networks, etc. -, related to the Totem Esports world and its Esports team. In case of subscription to the “Newsletter”, the User will only receive commercial communications on the e-mail address indicated during registration.
If the User has consented to the analysis of preferences, communications may be personalized on the basis of the interests and additional information available relating to the individual User (e.g. example, indicating only the promotions active in the region to which the data subject belongs).
If the User has consented to the analysis of preferences, communications may be personalized on the basis of the interests and additional information available relating to the individual User (e.g. example, indicating only the promotions active in the region to which the data subject belongs).
In the event that the User has made a purchase on the Website, Totem Esports may also proceed, in compliance with art. 130, c.4 of the Privacy Code, when sending e-mail communications for the purpose of direct sales of products similar to those purchased by the User (so-called “soft spam”), subject to the possibility of canceling such “e-mail subscription” from that moment in time and in any subsequent communication, in the manner described in the box below and/or in paragraph 12.
The processing of data for marketing purposes requires the consent of the Users (art. 6, paragraph 1, letter a) of the Regulation), while the processing for “soft spam” purposes is based on the legitimate interest of the Company as identified by art. 130, c.4 of the Privacy Code.


(d) Preference Analysis
Analyze your data (including, where available, your browsing data) to learn about the purchase preferences and tastes of Users and allow the Joint Controllers to improve the linked commercial offer to the Totem Esports world and personalize communications addressed to Users.
The processing of data for this purpose requires the consent of the Users (art. 6, paragraph 1, letter a) of the Regulation).
Totem Esports S.r.l. and Totem Esports ASD will act as joint controllers of the processing of User data for marketing and preference analysis purposes.
The Joint Controllers jointly manage:
• marketing operations connected to the Totem Esports team, both at the level of content creation and operational management; and 
• analysis and profiling of User data. 
We remind Users that any consents provided may be revoked at any time, against both the Joint Data Controller (s) by accessing their personal area on the Website and changing the relevant settings, (ii) (as regards the Newsletters) by clicking on the appropriate link in all communications; (iii) by sending a specific communication at the address In case of revocation of consent related to the Totem Esports S.r.l. and Totem Esports ASD update service, the User will no longer receive any kind of communication, in any way. It is always possible to revoke consent, limited to the receipt of communications using electronic tools (eg e-mail, sms, phone call, instant messages), while continuing to receive commercial communications only by paper mail or telephone contact with an operator.
It is understood that failure to provide consent for the purposes (c) and (d) will not in any way affect the possibility of registering on the Website, making a purchase or contact Totem Esports S.r.l. and Totem Esports ASD for any kind of complaint or information.


6. Methods of treatment
The processing of Users’ personal data is carried out by archiving on electronic and/or telematic media, in compliance with current legislation and, in any case, in order to guarantee security and confidentiality of data and prevent its unauthorized disclosure or use, alteration or destruction. All the information collected is transmitted in a secure connection so as to prevent it from being intercepted by strangers.
If the User allows the processing for analysis purposes, the Joint Controllers will use the data collected (e.g. postal code, residential address and purchases made) to examine the interests and preferences of the interested party, in order to improve its offer and personalize its communications. All data and preference analysis activities will not take place in exclusively automated ways but will always involve the intervention and evaluation of individuals duly to this authorized.


7. Recipients of personal data
Users’ data will be made known (limited to their respective field of competence) of the personnel expressly authorized by the Joint Controllers, pursuant to art. 29 of the Regulation. As part of the purposes indicated in the diagram below, the personal data of Users may become aware of the following third parties:

PurposeTarget Audience

(i) Public authorities, public and administrative bodies, state and community control bodies (even in the case of health alert situations); (ii) banks and institutions credit; (iii) legal, tax and accounting consultants; (iv) companies in charge of managing the services functional to the payment of purchases; (v) companies in charge of shipping and delivery of products; (vi) companies that provide services instrumental to the management of the contractual relationship (e.g. suppliers of the e- commerce, management, CRM).


(i) companies that provide services instrumental to the management of the contractual relationship (e.g. suppliers of the e-commerce platform and CRM); (ii) companies that provide services instrumental to marketing activities (e.g. providers of commercial communications sending platforms) and analysis (e.g. dedicated software providers).


Where necessary, Totem Esports S.r.l. and Totem Esports ASD have appointed the recipients of Users’ personal data as data processors, pursuant to art. 28 of the Rules. A list of all data processors can be requested by means of a communication to be sent to the addresses indicated in this Privacy Policy. Users’ personal data will never be disseminated.


8. Non-EU transfers:
In order to allow a correct and efficient management of the Website, the personal data of Users may be transferred to countries outside the European Union, including the United States.
The data will be transferred in full compliance with the guarantees, measures and rights provided for by the privacy legislation, usually on the basis of standard contractual clauses approved by the Commission of the European Union. By simple request, the User can receive more information on the transfer of his data and the guarantees provided for their protection.
Where expressly provided for by the relevant agreements, the data processors referred to in paragraph 7 above may also transfer the personal data of Users to countries outside the Union European in the context of the execution of the activities carried out in favor of the Company, while in strict compliance with the purposes indicated in this statement and the guarantees, measures and rights envisaged by the Regulation.


9. Retention period
Users’ data will be kept for the time strictly necessary to achieve the purposes indicated in paragraph 5 of the Privacy Policy and in compliance with any consent provided. At the end of the retention period, the data will be destroyed or made anonymous.
Specifically, the data will be stored according to the criteria indicated in the following table.


The data will be kept for the entire duration of the registration on the Website. After a period of 3 years of total account inactivity, the data will be deleted.


The data will be kept for the time necessary for the management and completion of the sales process, and subsequently in compliance with the legal obligations related to the contractual relationship. However, Users’ personal data will not be kept for a period longer than 10 years from the termination of the contractual relationship (without prejudice to any further retention in the event of litigation relating to the contract between the parties).



The data will be processed for the entire duration of the subscription to the update and/or newsletter service, in full compliance with the consent provided by the User, without prejudice to the possibility of revoking consent at any time.
In particular, data relating to the details of Users’ purchases will be processed for direct marketing or analysis purposes for a maximum period of 24 and 12 months, respectively, from registration of the same, in compliance with regulatory requests and with the General Provision of the Guarantor for the Protection of Personal Data adopted on 24 February 2015 relating to the loyalty.


10. Links to other sites
This Privacy Policy is provided only for the Website and not for other websites that may be consulted by the User through links. The Company cannot be held responsible for the personal data provided by Users to external parties or to any websites linked to the Website.


11. “Profiling” and/or personalization tools
The Joint Controllers do not carry out any promotional and/or advertising communication activities without the User’s prior express consent.
The Website uses “cookies”, both technical (that is, to facilitate navigation and use), and profiling (that is, to analyze Users and their behaviors and preferences, and to make them have advertising customized).
For a detailed explanation of the cookies used and how to disable them, we invite Users to read our Cookie Policy.


12. Rights of the interested parties
By sending a communication to the address, the User may at any time exercise the rights referred to in articles 15 to 22 of the Regulation against both Joint Data Controllers, including know what data we are processing, how and for what purposes we use it, modify the data you have provided us or delete it, ask us to limit the use of data, request to receive or transmit data, without prejudice to the possibility of revoking and/or modifying any consent to the processing provided.
Furthermore, the User can always object to the processing of his data carried out for marketing purposes or preference analysis.
In case of exercising one of the rights provided for by the Regulation, Totem Esports S.r.l., also in the context of the joint ownership relationship with Totem Esports ASD reserves the right to verify the identity of the User requesting to send a photocopy of an identity document that certifies the legitimacy of the request. Once the identity is confirmed, the photocopy received will be immediately destroyed.


13. Complaint to the Supervisory Authority
If a User considers that the processing that concerns him violates the provisions of the Regulation, he can always lodge a complaint with the Guarantor authority for the protection of personal data (, or to the Guarantor Authority of the country in which you usually reside, work or the place where the alleged violation occurred.


14. Review clause
The Company reserves the right to review, modify or simply update, in whole or in part, at its sole discretion, in any way and/or at any time, without notice, this Privacy Policy , also in consideration of changes in laws or regulations on the protection of personal data. Changes and updates to the Privacy Policy will be notified to Users as soon as they are adopted and will be binding as soon as they are published on the Website. We therefore ask Users to regularly access the “Privacy” section to check the publication of the most recent and updated Privacy Policy.
Such as, for example, the addresses in URI-Uniform Resource Identifier notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters related to the operating system and the User’s IT environment). These data are collected for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Website: with the exception of this possibility, the data will be deleted after the useful time for the provision of the services illustrated on the Website.
The personalization of communications can take place, by way of example and not exhaustive, through:
• sending promotional offers to Users identified on the basis of products usually purchased (or not purchased); 
• the offer of promotions that may be of interest to Users based on (i) their address of residence and/or postal code, (ii) the preferences expressed, (iii) the use of previous promotions; 
• the invitation to participate in events that may be of interest to Users based on (i) their residence address and/or postal code, (ii) the preferences expressed, (iii) participation to previous events. 
The applicable privacy legislation provides that a specific consent to the transfer to third countries is not necessary when the data transfer is made to a country that guarantees a level of adequate protection (art. 45 of the Regulation) or on the basis of the adoption of adequate guarantees (Articles 46 and 47 of the Regulation), and in particular on the basis of the adoption of binding rules for groups of companies, the adoption of clauses contracts approved by the European Commission.
The transfer of Users’ data to third countries will therefore take place in full compliance with the guarantees, measures and rights as provided for in the acts listed above (and in particular in application of the contractual clauses approved by the European Commission). In any case, by simple request to, the User may receive information on the existence of an adequacy decision or the appropriate guarantees adopted to allow the transfer of your data, as well as the means to obtain such data or the place where it was made available.
Articles 15 to 22 of the Regulation recognize specific rights including:


Right to object to processing

The User has the right to object to certain types of processing of personal data, including processing based on the legitimate interest of the Company or the processing carried out for the purposes of direct marketing.

Right to be informed

The User has the right to receive clear, transparent and easily understandable information on how to use his personal data and exercise his rights.

Right to access personal data

The User has the right to access their personal data (to the extent that they are processed by the Company) and to request, at any time, further information regarding the processing (e.g. which data concerning him is processed, the purpose of the processing, the categories of data in question, the recipients or categories of recipients to whom the data is transmitted, the retention period or the criteria used to determine that period). In this way, the User will become aware and can check whether the Company is using his personal data in compliance with current legislation on the protection of personal data.

Right to update and modify

The User has the right to obtain the rectification of his personal data, if these are inaccurate or incomplete. If the User is registered on the Website, he will have the opportunity to modify, correct or update his personal data at any time by accessing his account.

Right to erasure

Also known as the “right to be forgotten”, it allows the User to request the deletion or removal of his personal data where there are no binding reasons that determine the need for the Company to preserve them. There is no absolute right to erasure, which will therefore be balanced with the needs of the Company (e.g. the deletion of data that the Company is obliged to keep to fulfill a legal obligation or for the purposes of ascertaining, exercising or defending a right in court).

Right to restriction of processing

The User has the right to “block” or restrict the further use of their personal data. If the processing has been restricted, the Company may still keep the User’s personal data, but it will not be able to process them further. In case of exercise of the right, the Company will prepare special lists containing the details of the subjects who have asked to limit the processing of their personal data, in order to ensure that the restriction is respected.

Right to portability

The User has the right to obtain their data in a structured format, commonly used and readable by an automatic device, and to use them for their own purposes in the context of various services. This right is to be understood as limited to data collected as part of the conclusion or execution of a contract with the User or on the basis of the consent of the User.


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