This Privacy Policy Notice (including family policy requirement)

Date of last revision: 26 November 2023

This Privacy Policy Notice explains how Miway Joint Stock Company (“Miway”), the owner of Totta app collect, use and disclose personal data online and offline in connection with the services we provide. The Notice also sets out how Totta meets Family Policy Requirements.

The terms “Totta”, “we”, “our”, and “us” are used in this Privacy Policy Notice to refer to Totta and Miway Corporation collectively. Miway is a data controller.

In this Privacy Policy Notice we refer to the individuals whose personal data we process as “you”. Please read this Privacy Policy Notice carefully therefore if any of the following applies to you:

1) If you use our app on your smart phone, tablet and/or other device.

2) If you visit our website totta.me (“Website”); or

3) If you use any of our services (whether as a child, parent or third party (such as a relative of a cardholder wishing to send money to someone via our services));

In this Privacy Policy Notice, we refer to all of the above as our “Services”.

At Totta, our mission is to help every kid be smart with money in a safe and secure environment. This means that your and your family’s privacy is important to us. This Privacy Policy Notice is an opportunity for us to be transparent with you about the personal data we collect, why we collect it, how we use it and how we protect it.

1) Who are we?

1.1 Totta is owned by Miway Joint Stock Company, is a company established in Vietnam with Business Registration Certificate No. 0108995103.

1.2 Please read this Privacy Policy Notice carefully so that you understand your rights in relation to your personal data. This Privacy Policy Notice supplements any other privacy related notices and policies we may provide to you from time to time and is not intended to override them. If you do not agree with this Privacy Policy Notice in general or any part of it, you should not access the Website, App, use our Services or otherwise provide your information to us.

1.3 If after reading this Privacy Policy Notice you still have questions, please don’t hesitate to contact us on totta@totta.me.

1.4 We will post any changes to this Privacy Policy Notice on our Website, so please check it from time to time.

2) The personal data we collect

2.1 Personal data means any information that can be used directly or indirectly to identify you.

2.2 The personal data we collect about you depends on whether you are a parent/guardian (and customer of Totta), a child who uses our Services or a visitor to our Website or prospective customer. The types of personal data will also vary depending on the context of your interactions with our Services and the choices you make.

Parents/guardians (who are customers of Totta)

Information you give to us

You may provide some or all of the following personal data to us by registering with us, using our Services or contacting us:

Personal Data	How we use it
Contact and identification information such as your name, phone number, email address, postal address, date of birth, photograph.	We each use this information to:  – process and grant your access to our respective Services, – investigate account activities, and – communicate with you. We use your photographs with your consent to give you the ability to add a personal touch when engaging with our Services.
Security information such as passwords, password hints, security questions and answers and other similar security information	We each use this information to process your account application and grant your access to our respective Services. This is necessary for us to provide the Services to you.
Any other information you directly provide to us when filling out forms, corresponding with us, filling out surveys, providing us with feedback and product reviews and other similar information.	We each use this information to provide you with our respective Services at your request, to communicate with you, to help you with any services issues. We also use this information to conduct research into the use of our respective Services, also for the purposes of our legitimate interests in improving our Services.

Information we collect automatically

When you use our Services, we automatically collect certain information that is sent to us by your computer, mobile phone or other device

Personal Data

How we use it

Usage information such as the full uniform resource locators (URLs), information about page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), error reports and performance data (i.e. details of the software or hardware related to an error, content of files you were using when an error occurred), troubleshooting and help data plus other similar usage information.

We each use this information for the purposes of our respective legitimate interests in providing and improving our Services and the security of them.

Children who use our Services
Information you or your parent/guardian give to us

You or your parent/guardian may provide us with some or all of the following personal data relating to you by registering with us, using our Services or contacting us:

Personal Data	How we use it and the Legal Basis for doing so
Contact and identification information such as your name, phone number, email address, postal address, date of birth, photograph.	We use this information to process and grant your access to our Services, to communicate with you. This is necessary for the purposes of our respective legitimate interests in providing our Services to you. We use your photographs with you or your Parent/Guardians consent to give you the ability to add a personal touch when engaging with our Services.
Security information such as passwords, password hints and other similar security information.	We each use this information to process your account application and grant your access to our respective Services. This is necessary for the purposes of our respective legitimate interests in providing our Services to you.
Any other information you directly provide to us when filling out forms, corresponding with us, filling out surveys, providing us with feedback and product reviews and other similar information.	We each use this information to provide you with our respective Services at your request, to communicate with you, to help you with any services issues. We also use this information to conduct research into the use of our respective Services, also for the purposes of our legitimate interests in improving our Services.

Information we collect automatically

When you use Totta’s Services, Totta automatically collects certain information that is sent by your computer, mobile phone or other device.

Personal Data

How we use it and the Legal Basis for doing so

Usage information such as the full uniform resource locators (URLs), information about page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), error reports and performance data (i.e. details of the software or hardware related to an error, content of files you were using when an error occurred), troubleshooting and help data plus other similar usage information

We each use this information for the purposes of our legitimate interests in providing and improving our respective Services and the security of them.

Visitors to our Website or Prospective Customers
Information you give to us

You may provide some or all of the following personal data to Totta when you visit our website or app:

Personal Data	How we use it and the Legal Basis for doing so
Any information you directly provide to Totta and Miway when filling out forms, filling out surveys, providing us with feedback and product reviews and other similar information.	Totta and Miway uses this information for the purposes of its legitimate interests in communicating with you, helping you investigate and resolve complaints and services issues and conducting research into the use of our Services.

3) Families Policy Requirements

One of the target audiences for our app is children from six years old. Our policy to comply with Families Policy Requirements are follows:

3.1. App content: We ensure our app’s content in particular money lessons for children are appropriate for children in Vietnam.

3.2. App functionality: We ensure our app does not merely provide a webview of a website or have a primary purpose of driving affiliate traffic to a website without permission from the website owner or administrator.

3.3. Data practices: We have fully disclosed in this Notice the collection of any personal and sensitive information from children in our app, including through APIs and SDKs called or used in our app. Sensitive information from children includes, but is not limited to, authentication information, microphone and camera sensor data, device data, Android ID, and ad usage data. We also ensure that our app follows the data practices below:

     (i) Our app does not transmit Android advertising identifier (AAID), SIM Serial, Build Serial, BSSID, MAC, SSID, IMEI, and/or IMSI. Our apps does not request AD_ID permission when targeting Android API 33 or higher.

     (ii) Our app does not transmit AAID, SIM Serial, Build Serial, BSSID, MAC, SSID, IMEI, and/or IMSI from children or users of unknown age.

     (iii) Device phone number is not requested from Telephony Manager of the Android API.

     (iv) Our apps does not request location permission, or collect, use, and transmit precise location of children.

     (v) Our apps use the Companion Device Manager (CDM)when requesting Bluetooth, unless Our app is only targeting device Operating System (OS) versions that are not compatible with CDM.

4) Cookies

4.1 We may use cookies and other similar technologies to collect information about your browsing activities over time and across different websites following your use of our Services. Cookies allow us to recognise and count the number of users and to see how users move around our website when they are using it. This helps us to improve our Services and the way our website works.

5) How we share your personal data

5.1 We do not use or share your personal data with others except as described in this Privacy Policy Notice. However, in certain circumstances, we will share your information with third parties. Specifically, we share your personal data (i) when the disclosure is requested by you, with consent or to perform a contract with you or (2) for legal and security reasons and to protect our services and business, in our legitimate interests or as required by law.

6) Where we store your personal data

6.1 The personal data that we collect from you will be stored in Vietnam. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy Notice.

7) How long do we store your personal data?

7.1 Your personal data will not be retained by us for longer than necessary in relation to the purposes for which it was originally collected, or for which it was further processed. We will retain your personal data as follows:

     (i) If you choose to close your account, your personal data will generally stop being visible on our Services within 24 hours.

     (ii) We retain your personal data after you have closed your account for the purposes for which it was originally collected, or for which it was further processed, but we will not retain any of your personal data for more than 12 months year after the closure of your account.

8) Security

8.1 We know that security is a major concern for you and your family. To give you peace of mind we have advanced security systems in place. Please know however that although we do our best to protect your personal data, we cannot guarantee the security of your data during transmission of information via the internet, as any such transmission is at your own risk.

8.2 To protect your and your family’s personal data, we make an effort to:

     (i) Use secure server software to store your personal data;

     (ii) Use full login and security question controls on our systems;

     (iii) Maintain physical, electronic and procedural safeguards to protect your personal data from unauthorised access;

     (iv) Continuously monitor our systems for possible vulnerabilities and attacks; and

     (v) Regularly review and update our privacy controls and policy.

9. Your rights

9.1 Your personal data is yours and you therefore have certain rights in relation to it:

     (i) Access: You have the right to access personal data we hold about you, how we use it, and who we share it with.

     (ii) Correction: You have the right to correct any of your personal data we hold that is inaccurate.

     (iii) Erasure: In certain circumstance, you have the right to delete the personal data we hold about you.

     (iv) Restriction of processing to storage only: You have the right to require us to stop processing the personal data we hold about you, other than for storage purposes, in certain circumstances.

     (v) Objection: You have the right to object to our processing of your personal data.

     (vi) Withdrawal of consent: Where we rely on consent to process your personal data, you have the right to withdraw this consent at any time.

If you wish to exercise any of your rights please contact us via totta@totta.me.

10. Third party links

10.1 Our Website, App and Services may contain links to other websites or other applications operated by third parties. We do not control such other sites or applications, and are not responsible for their content, their privacy policies, or their use of your information.

10.2 Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Website/Services. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal data by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

11. Complaints

11.1 If you have a complaint about how we use your personal data please don’t hesitate to contact us via totta@totta.me.

12. Contact

12.1 We welcome your questions, comments, and concerns about this Privacy Policy or your personal data. Please send us any feedback to totta@totta.me