DISCIPLINED. EFFICIENT. GRITTY. ™

Totem Asset Group, LLC is a Member of the National Futures Association and registered as a Commodity Trading Advisor and only provides services to Qualified Eligible Participants as defined in section 4.7 of the Commodity Exchange Act
updated May 31, 2018

Privacy Policy

In brief:
We respect your privacy and the confidentiality of all information that you give us.

About Us

Totem Asset Group, LLC. ('Totem Asset Group' or 'We' or 'Us' or 'TAG') is the sole owner of the totemasset.com website ('Website') and all of the information collected on it. Totem Asset Group collects information from users in several ways through the Website.

The following Privacy Policy discloses how we collect, process, store and share information including the following:

By using our Website, you consent to our Website's Privacy Policy.

We always ask users for a permission to collect and use personal data for purposes that are not listed in this Privacy Policy.

Children's privacy rights

We do not knowingly contact or collect personal information from children below the age of 16 years. If you believe we have inadvertently collected such information, please contact us so that we can either obtain parental consent or delete the information.

Online Privacy Policy Only

This Policy applies only to information collected through our Website and is not related to any information collected offline.

Policy Updates

We may update this Policy at our discretion from time to time by posting a new version on our Website. You should check our Website occasionally to ensure any changes made are suitable for you. You will be informed of any significant changes made to the Privacy Policy.

Current version of our Privacy Policy was modified on May 31, 2018.

Personal data that we collect

There is no need to request that an account be created for you or give consent to personal data processing when searching and viewing certain publicly available information on our website. Users will, however, need to attest to and confirm their status as a Qualified Eligible Participant as defined in section 4.7 of the Commodity Exchange Act in order to access this publicly available data or to request joining our monthly email distribution list.

If you do request that an account be created for you, or if you join our monthly email distribution list, then you will have to share some limited personal data with us so that we can provide you with access to our information.

During registration you will be required to provide us with:

We use your contact details such as email address or phone number to authenticate your account, ensure its security along with the security of our information and to prevent spam, fraud and abuse.

How personal information is collected

Profile

User information may be collected using either secure server-side forms on our site, or using a 3rd-party service provider.

3rd-Party Service Providers

Mailing list information may be collected using a 3rd-party service provider MailChimp

Scheduling information may be collected using a 3rd-party service provider Calendly

Video Communication information may be collected using 3rd-party service providers Join.me or Zoom

Cookies

We collect cookie files to gather and analyze statistical information as well as to ensure security, improve the user experience and to fight spam. More detailed information on the terms of use can be found in our Cookies Policy.

You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of the Website nor will you be able to access subscriber areas if cookies are disabled.

Log Files

Like most websites, We use web server log files. Records in our log files include internet protocol (IP) addresses, browser types, internet service providers (ISP's), referring pages, exit pages, platform types, and date/time stamps. We use web server log files to administer the site, to provide broad traffic information for site planning purposes, and to ensure that our terms of service agreement are being adhered to. IP addresses are not tied to personally identifiable information in our web server log files.

Device information

We collect the following information about the devices that you use to visit the site: IP-address of the device, operating system and browser version. We are collecting this information to prevent spam and abuse of our services.

Web beacons (Clear GIFs)

Web beacons are tiny graphics with a unique identifier that allow us to track usage patterns, count users who have visited a particular page, etc. Web beacons only collect limited information, including a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. These beacons do not carry any personally identifiable information and are only used to track the effectiveness of Website. We use web beacons in connection with Google Analytics service. The information generated related to our Website is used to create reports about the use of the Website. We use this information to develop, test and improve our services further.

Google will store this information. Please refer to Google's privacy policy to get more information.

Links to other sites

At our discretion We can add links (web links) to other websites from our Website. These websites can be run by third parties with separate and independent privacy policies. We, therefore, have no responsibility or liability for the content, activities or privacy policies of those linked sites. We suggest you read the privacy policy of each and every site that you visit. We remind you that this Privacy Policy applies only to information collected by our Website (totemasset.com).

Advertising

We do not display advertising on the website, but we do utilize Amazon.com to display our list of recommended reading material. Advertisers are able to see general statistics that include the amount of impressions and clicks.

Security

We use Secure Socket Layer (SSL) encryption technology in order to protect certain information that you submit. This type of technology protects you from having your information intercepted by anyone while it is being transmitted to Totem Asset Group. While on a secure page, such as our dashboard, the 'lock' icon in the browser window is displayed, confirming that a secure, encrypted connection has been established with the Website. We work hard to ensure that our Website is secure and that we meet industry standards. We also use other safeguards, such as firewalls, authentication systems (e.g., passwords and personal identification numbers), and access control mechanisms to control unauthorized access to systems and data.

We are constantly improving the ways we collect, store and process data which including physical security measures that help us counter unauthorized access to our systems.

We also do our best to protect user information offline. All of our users' personal information is restricted to our offices. Only employees who need to see the information to perform their jobs are allowed to access it. The servers that store personally identifiable information are located in a secure environment in a locked facility.

How personal information is used

Account Administration

We send all new users a welcome activation email to verify their email address.

Users cannot opt-out of these messages, though they can deactivate their account.

Announcements and Newsletters

On rare occasions it is necessary to send out service-related announcements or important newsletters. For instance, if our service is interrupted for a prolonged period or major functionality upgrade is released, we might send all users an email message. Also, we can sometimes use your email address to send marketing messages. Users can refuse to receive such messages in the future by clicking unsubscribe in one of the emails.

Document Retreival

To maintain the requirements of our regulatory authorities, the National Futures Association and Commodity Futures Trading Commission, we need to be very careful about the content of the information we are sharing and with whom we are sharing. Therefore, some sensitive documents retreived from our site's repository will requite an added layer of access approval and requests will be logged into a transaction file.

Customer Relationship Management

In the course of normal business activities and to better serve our user's best interests, certain records of activities such as but not limited to meetings, emails, phone calls and document retreival may be recorded into our secure 3rd-party CRM software PipeDrive.

Legal requirements

We can store and disclose your information to law enforcement authorities, state or government agencies if we establish that such disclosure is necessary to comply with the law. This includes responses to court orders or subpoenas, as well as other judicial or regulatory processes.

User rights

In accordance with the General Data Protection Regulation (GDPR), you have the right to access, correct, transfer and delete your data. You also have the right to object to certain ways your data is processed and to restrict such processing.

This includes your right to:

Viewing and correcting data

Each user can view and manage his/her personal data in their profile settings.

Each user can view and manage his/her mailing list information by following the settings link found in each email.

Deleting data

You have the right to refuse to use our website and to delete your account. You need to contact our support team to do so. We will respond to requests about this within a reasonable timeframe.

Contact Information

If you have any questions or suggestions regarding our Privacy Policy, please contact our support team.

If you disagree with this privacy policy, you will need to stop using our website and deactivate your account, as outlined above. You can also revoke your consent to personal data processing. Note that in such case you will have limited access to our site's features and your account will be deactivated.

Totem Asset Group, Inc.
2144 Ashland Ave.
Suite 7
Evanston, IL 60201

The risk of loss in trading commodities can be substantial. You should therefore carefully consider whether such trading is suitable for you in light of your financial condition.
PAST PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS.