DRAFT — this page is technical groundwork, not a finished legal document. It has not been reviewed by a lawyer and should not be published or relied upon until it has been.

TOTEM

Privacy Policy — draft

Last updated: [insert date once finalized]

This Privacy Policy explains what personal information Totem collects, why, how it's used and protected, and what rights you have — in line with South Africa's Protection of Personal Information Act (POPIA).

Who this applies to

Totem is used by clubs and schools ("the Organization") to manage sports team selection, fixtures, and results. The Organization is generally responsible for the personal information of its players, coaches, and staff entered into Totem, including obtaining any necessary consent — see "Children's information" below. Totem (operated by [Hyperianlabs — confirm exact registered entity name]) processes this information on the Organization's behalf.

What we collect

Totem does not collect payment card details directly — if your organization is on a paid plan, that's handled entirely by Stripe, who has their own privacy practices.

Why we process this information

Children's information

Much of the information in Totem relates to children (anyone under 18). POPIA requires a valid legal basis to process a child's personal information — generally, consent from a parent or guardian, unless another exception applies. Obtaining this consent is the Organization's responsibility, since players and parents do not use Totem directly. Organizations are asked to confirm this when creating their account, and a consent form template is provided to help.

Who we share information with

We use a small number of service providers ("sub-processors") to run Totem:

Cross-border transfer note: if data is hosted outside South Africa, POPIA has extra requirements for transferring children's personal information across borders — confirm with a lawyer whether additional steps (such as Information Regulator authorization) are needed.

How long we keep information

[Retention period to be confirmed — e.g. data is kept while the organization has an active account, and deleted within X days/months of account closure or a valid deletion request.]

Your rights

Parents/guardians, coaches, and staff can request access to, correction of, or deletion of personal information held about them or their child by contacting their Organization directly, who can action this within Totem, or by contacting us at [insert contact email].

Security

Access to each Organization's data is restricted to that Organization's own logged-in staff only, enforced at the database level. Data is transmitted over encrypted connections (HTTPS).

Information Officer

[Name and contact details of Totem's registered Information Officer, once appointed]

Contact us

Questions about this policy or your information can be directed to [insert contact email].