Privacy Policy

Effective Date: January 1st, 2026

Last Updated: October 6, 2026

Totem Professional Development (“Totem PD”, “we”, “our”, or “us”) operates the website Totem PD. This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of personal data when you use our website, schedule consultations, or participate in our school behavior management and crisis intervention training programs, and the choices you have associated with that data.

1. Information We Collect

We collect several types of information from and about users of our website, primarily when you voluntarily submit information through our consultation forms or interact with our services.

  • Personal Identification Information: When you fill out our consultation or contact forms, we collect:

    • Full Name (First and Last Name)
    • Work Email Address
    • Phone Number
    • School District or Educational Organization
    • State of Residence/Operation
    • Professional Position or Role (e.g., School Administrator, Special Educator, School Psychologist, etc.)
  • Automatically Collected Data: As you navigate through our site, we may automatically collect standard technical information, including your IP address, browser type, operating system, pages viewed, and the dates and times of your visits, through cookies and similar tracking technologies.

2. How We Use Your Information

We use the information we collect for legitimate business and educational purposes, including:

  • Providing Consultations: To coordinate and conduct your requested free consultation sessions, offering customized training recommendations tailored to your school or district.
  • Service Delivery: To deliver our 2-day experiences, implementation plans, and ongoing professional development resources.
  • Communication: To respond to your inquiries, send administrative information, and provide updates regarding our training programs.
  • Website Improvement: To monitor website performance, analyze user behavior, and optimize our digital user experience.

3. Sharing and Disclosure of Information

We respect your privacy and do not sell, trade, or rent your personal identification information to third parties. We may share your information only under the following limited circumstances:

  • Service Providers: With trusted third-party vendors, hosting providers, or communication tools who assist us in operating our website, managing our CRM, or conducting our business operations, provided those parties agree to keep this information confidential.
  • Legal Requirements: When required to do so by law, court order, or governmental regulation, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

4. Data Security

We implement commercially reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

5. Your Choices and Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information, including:

  • Access and Update: You may request access to, correction of, or updating of your personal information by contacting us directly.
  • Opt-Out: You can opt out of receiving promotional communications from us by following the unsubscribe instructions included in those emails or contacting us directly.

6. Children’s Privacy

Our services are directed toward educators, school administrators, and school staff members. We do not knowingly collect personal information directly from children under the age of 13 through our website.

7. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will post any changes on this page and update the “Last Updated” date at the top. You are advised to review this Privacy Policy periodically for any changes.

8. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please reach out to us directly sending a request through our Get Support form on totempd.com

Turnstile Privacy Addendum

Last updated: JUNE 18, 2025


1. INTRODUCTION

Turnstile, developed by Cloudflare, Inc. (Cloudflare), is a pro-privacy website security tool that processes minimal Signals (as defined below) solely to protect web properties against malicious activity by distinguishing human users from bots and blocking bot traffic.

Cloudflare does not control whether a website chooses to use Turnstile; instead, we make Turnstile available to any website that is looking for a way to detect and block bot traffic.

2. SCOPE OF THIS ADDENDUM

This Turnstile Addendum is supplemental to Cloudflare’s main Privacy Policy. It provides additional information specific to your use and interaction with Turnstile. This Addendum also applies to the personal data processed using Cloudflare’s Challenge Platform, and any reference to “Turnstile” in this addendum applies equally to the Challenge Platform.

The Cloudflare Privacy Policy continues to apply to your use and interaction with Turnstile, except where this Turnstile Addendum provides more specific information. In those cases, the more specific information will apply instead.

3. INFORMATION WE COLLECT

Cloudflare Turnstile processes a variety of client-side signals (“Signals”) such as client IP address, TLS Fingerprint, User-Agent Header and Sitekey and associated origin. Cloudflare does not have the ability to directly identify any individuals from any of the Signals Turnstile collects, including IP addresses.

4. HOW WE USE INFORMATION WE COLLECT

(i) Bot detection and blocking

Turnstile is a tool to protect web properties by distinguishing human users from bots and blocking any detected bot traffic that could otherwise harm the safety and security of that property.

It does so by evaluating the Signals listed above specific to both the website visitor and the website visited. The purpose of collecting these Signals is not to identify, profile or target any individuals but solely to detect and block bots. The Signals collected by Turnstile are strictly necessary for this purpose (i.e. detecting and blocking bots to enable visitors to enjoy a safe and secure experience when visiting websites that have implemented Turnstile).

Cloudflare is a data processor of Signals that we process to provide the Turnstile service to our customers, that is, securing our customers’ websites. This means that we process Signals for this purpose on behalf of, and pursuant to instructions issued by, our website operator customers (who are the data controllers of any data processed for this purpose). If you have questions, or wish to exercise any data protection rights, regarding Cloudflare’s processing of Turnstile data to provide our service, please contact the relevant website operator.

(ii) Improving Turnstile’s bot detection capabilities


Cloudflare also processes the Signals described in this Privacy Notice to improve Turnstile. This is necessary to refine and improve our bot detection algorithms in order to respond to evolving bot threats, and to maintain the security of the web properties that website visitors choose to visit.

Cloudflare is a data controller of Signals that we process to improve Turnstile’s bot detection capabilities. This Turnstile Privacy Notice (in conjunction with Cloudflare’s main Privacy Policy) governs our processing of Signals for this purpose.

5. NOTICE TO EU AND UK RESIDENTS

To the extent that the data described in the Turnstile Privacy Notice qualifies as personal data, then:

  • When processing this personal data as a processor to protect our customers’ websites, our customers, as controllers, determine the lawful basis of this processing, and we process this data under their instruction and on their behalf; and

  • When processing this personal data as a controller, we rely on our legitimate interests in improving the effectiveness of Turnstile’s bot detection capabilities to process this Turnstile data.

6. COOKIES

The Signals collected by Turnstile are strictly necessary for the purpose of detecting and blocking bots to enable visitors to enjoy a safe and secure experience when visiting websites that have implemented Turnstile.

For more information about the cookies used by Cloudflare, please check our Cookie Policy and our Turnstile Developer Docs.

CONTACT FOR PRIVACY CONCERNS

If you have questions or concerns about this Turnstile Privacy Notice or your personal data processed through Turnstile, please contact Cloudflare’s Data Protection Officer at dpo@cloudflare.com.

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