Generally speaking, we receive and store any information you enter on our website or give us in any other way. We use the information that you provide for such purposes as responding to your requests, providing our services (e.g., domain name registration, DNS hosting, privacy services, etc, together “Services”), and communicating with you.
- Website Users
- VirtualNIC Inc. Service Users (Domain Name Registrations etc.)
- General Privacy Conditions – All Users
Each section details important information regarding the use and disclosure of your data in conjunction with the Service you have chosen to use.
INFORMATION WE COLLECT
User Provided Information: We collect information you provide when choosing to participate in various activities on the website, or in obtaining a VirtualNIC Inc. Service. Such information may include Personal Information. Personal Information includes data such as: your name, address, telephone number, email address, and other data collected that could directly or indirectly identify you.
Log File Information: When you use our website, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser.
Analytics: We may share non-personally-identifiable information (such as anonymous user usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to assist us in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality on the website.
THE WAY WE USE INFORMATION
WEBSITE USERS INFORMATION
If you submit personally identifiable information to us through the website, then we may use such information to operate, maintain, and provide to you the features and functionality of the website, including, when applicable, sending you information.
Any personal information or other content that you voluntarily disclose online (on discussion boards, in messages and chat areas, etc.) becomes publicly available and can be collected and used by others, including us, without any additional permission. We may use your email address or other personally identifiable information to send commercial, marketing, or other messages without additional consent. We may share non-personally-identifiable information (such as anonymous user usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with third parties to assist us in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality on the website. We may disclose Personal Information and/or non-personally-identifiable information if required to do so by law, or in the good faith belief that such action is necessary to comply with state and federal laws or respond to a court order, subpoena, or search warrant. We reserve the right to disclose Personal Information and/or non-personally-identifiable information that we believe, in good faith, is appropriate or necessary to take precautions against liability, to investigate and defend itself against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of our website, and to protect the rights, property, or personal safety of us, our users or others, and to protect the rights, property, or personal safety of us, our users or others.
We may use both your personally identifiable information and certain non-personally-identifiable information (such as anonymous user usage data, cookies, IP addresses, browser type, click stream data, etc.) to improve the quality and design of the website and to create new features, promotions, functionality, and services by storing, tracking, and analyzing user preferences and trends.
Within your browser you can choose whether you wish to accept cookies or not. Different browsers make different controls available to you and so we provide links below to popular manufacturers' instructions on how you can do this. Generally, your browser will offer you the choice to accept, refuse or delete cookies at all times, or those from providers that website owners use ("third party cookies"), or those from specific websites.
VirtualNIC Inc. SERVICES
Before purchasing a VirtualNIC Inc. service or product, you must familiarize yourself with this policy and we urge you to raise any queries with us prior to proceeding with your registration(s) or purchase.
INFORMATION WE HOLDS
GENERAL ACCOUNT INFORMATION
We ordinarily require you to provide us with that information that is required for the proper maintenance and administration of your user account with us.
Information necessary for ensuring the proper administration of your account. (including contact details such as email and telephone number, for ease of contacting you in relation to your account and services)
Billing information / Payment Details
Information necessary for collecting payment for the services and products that you have purchased or obtained from us.
Data necessary for the specific Product/service obtained by you
Depending on the product or service you obtain, we may need additional information, or to use your data in another manner specific and necessary to that product or service. (See individual product/service sections below).
DO WE SHARE THE INFORMATION WE RECEIVE?
DOMAIN NAME REGISTRATIONS
DOMAIN REGISTRATION DATA
We are required to collect data relating to the registration of domain names (“Registration Data”) and then share such data with the relevant registry operator (depending on the top-level domain (“TLD") you wish to register). The sharing and use of this data is required by our Registrar Accreditation Agreement with ICANN and is a requirement of each TLD’s Registry Agreement with ICANN, to effect the proper registration of your domain name.
In order to provide you with domain name registration services, we typically require the following registrant data:
- Domain Name (your choice of domain e.g. “example.ai” )
- Nameservers (your choice of hosting provider or equivalent)
- Registration Data (Data required to enter the domain into our registry)
- Registrant Name
- Registrant Organization (where applicable)
- Registrant Address
- Registrant Email
- Registrant Fax (where applicable)
- Registrant Phone number
- Administrative Contact
- Administrative Contact Organization (where applicable)
- Administrative Contact Address
- Administrative Contact Email
- Administrative Contact Fax (where applicable)
- Administrative Contact Telephone Number
- Technical Contact
- Technical Contact Organization (where applicable)
- Technical Contact Address
- Technical Contact Email
- Technical Contact Fax (where applicable)
- Technical Contact Telephone Number
- Billing Contact
- Billing Contact Organization (where applicable)
- Billing Contact Address
- Billing Contact Email
- Billing Contact Fax (where applicable)
- Billing Contact Telephone Number
NOTE: Specific data collections may vary based on the TLD’s specific requirements as promulgated by its registry operator.
PURPOSE / LEGAL BASIS FOR PROCESSING
We use your registration data for the following purposes:
- to register the domain name;
- to provide the applicable registry with authoritative data to ensure the ongoing continuity, stability and resiliency of the DNS;
- mitigation of DNS abuse, including but not limited to the investigation and mitigation of reported instances of abuse. We consider to be contrary to the terms of its Acceptable Use Policy;
- maintained integrity of the current dual failsafe system at the registrar and registry levels;
- verification of registrant eligibility, where applicable; and
- to update and improve our Services, systems and ability to provide you with a secure and stable Service experience.
OTHER WAYS WE USE YOUR INFORMATION
First and foremost, we use your Registration Data to arrange your registration and supported functionality of your domain(s) with the registry operator. Additionally, we may use Registrant Data to (i) improve our Services, promotions and functionality, (ii) develop and collect aggregate statistics (ensuring appropriate anonymization) regarding our systems and Services,; and (iii) communicate with you regarding your registration or related Services.
DATA CONTROLLER ROLES
We collect and processes your Registrant Data to carry out the registration of your domain, to ensure that your registration functions as expected, and that registrations do not affect the security of our registrar. In order to enter your chosen domain name into our system, we are required to process your data in a manner obligated in our contracts with Internet Corporation for Assigned Names and Numbers (“ICANN”). In this respect, it is our understanding under applicable law that we act as a joint data controller of your Registrant Data, working in conjunction with the TLD registry and ICANN, as herein described.
With specific reference to the registration of a domain name, as Registrar, we are responsible for the following:
- collection of registration data;
- providing you with adequate information and a means by which you may exercise your individual privacy rights, such as data access, deletion, and rectification; and
A registry operator, retains the responsibility for the processing of data necessary for the registration and maintenance of domains within one of their TLDs.
ICANN is the private-sector body responsible for coordinating the global Internet's systems of unique identifiers. The mission of ICANN is to coordinate the stable operation of the Internet's unique identifier systems. More information about ICANN can be found here: www.icann.org. ICANN is responsible for identifying and requiring, by contract, both registry operators and registrars to provide to them registration data. Registrant Data we collect and process is data which ICANN deems necessary to ensure the ongoing security and stability of the DNS.
Depending on applicable law, where necessary, Registration Data shall be made available to the public via an interactive webpage (https://whoisdog.com/). It is important that you review your registry operators’ individual WHOIS publication policy also prior to entering into a registration agreement.
In the event you elect to utilize a privacy service, the information of that service, rather than your personal WHOIS Information, will be made available to the public. Please note that we are not able to control how members of the public may use the WHOIS Information.
Where the disclosure of personal data, such as is envisaged by WHOIS, is considered to be incompatible with applicable law, we will, to the best of its ability and wholly dependent on the accuracy of the data provided by you, ensure that such personal data is not unnecessarily disclosed.
LIMITED DISCLOSURE WHERE NECESSARY
We may continue disclose elements of this data, but will only do so in a manner as outlined under the Exceptions To Disclosure section below. It is important that you also review your registry operators’ individual WHOIS publication policy also prior to entering into a registration agreement to ensure you are aware of the extent to which your personal data may be subject to disclosure.
THIRD PARTIES PROCESSING DATA ON OUR BEHALF
DATA ESCROW (DOMAIN NAME REGISTRATIONS ONLY)
We, as Registrar, is required by ICANN to provide a copy of all registration data (including PI and non PI) to a secure third party who shall hold the data securely in Escrow (“Escrow Provider”). We utilize the services of ‘Iron Mountain Inc.’, a US Corporation, with servers in the United States, as its Escrow Provider. Data held by the Escrow Provider can be used to restore a registry in the event of a catastrophic event, or a failure of the registry’s systems. In this case, the data may be securely transferred to another registry to ensure the ongoing security and stability of the DNS and to prevent any interruption to the proper functioning of registered domains.
EMAIL PROVIDER/CLOUD STORAGE
We use the third party services of Google Inc.’s G-Suite for both email and associated cloud services. Your data may be stored on Google’s servers, subject to industry standard encryption and security protections.
CLIENT RELATIONSHIP MANAGEMENT SYSTEM
We use the third party services to ensure the proper management of our client and customer service queries. Your data may be stored on each of our vendor’s servers; subject to industry standard encryption and security protections
We use the third party services to track reports, and actions relating to abusive use of our domains or the detection and mitigation of fraudulent activity on our platforms. Your data may be stored on each of these vendor’s servers, subject to industry standard encryption and security protections.
We may share aggregated demographic information with our partners and advertisers. This is not linked to any personal information that can identify any individual person.
We engage other companies and individuals to perform enhanced services on our behalf. In addition, certain of our enhanced services require that we contact Internet directories and various search engines on your behalf. Many of our service providers have access to personal information needed to perform their services. These parties are not allowed to use personally identifiable information except for the purpose of providing these services.
We engage other companies and individuals to perform functions on our behalf. Examples include processing credit card payments, providing marketing assistance, providing customer services, sending postal mail and email to you, removing repetitive information from customer lists, and analyzing data. These persons have access to personal information needed to perform their functions. These companies do not retain, share, store or use personally identifiable information that you provide to us for any secondary purposes.
As we continue to develop our business, we might sell or buy businesses or their assets. In such transactions, customer information generally is one of the transferred business assets. Also, if we or all or substantially all of our assets were ever to be acquired, customer information will of course be one of the transferred assets.
EXCEPTIONS TO DISCLOSURE LIMITATIONS
- necessary to fulfill a transaction or provide information you have requested;
- in your vital interests or in the vital interests of another person, including events of an emergency that pose a threat to your safety;
- required by ICANN;
- required by law or necessary to respond to legal process;
- in circumstances in which we believe that its registrar system, websites, domain names, or Services are being used in the commission of a crime;
- necessary to enforce our Acceptable Use Policy, and to protect the security or integrity of the DNS or our Website;
- as necessary to establish, assert, defend, or protect our rights or property; or
- as necessary to meet the requirements of requests, lawfully made by public authorities, including requests to meet national security or law enforcement requirements.
GENERAL PRIVACY CONDITIONS - ALL USERS
NOTE REGARDING SENSITIVE PERSONAL INFORMATION
“Sensitive Personal Information” refers to personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying sex life of the individual.
We do not ordinarily or knowingly require or collect Sensitive Personal information, nor do we use or disclose such information with third parties without your explicit consent.
NOTE REGARDING CHILDREN (under 18 years of age)
Please note that we do not knowingly permit or solicit information from individuals under eighteen (18) years of age. In addition we do not knowingly market our products or services to individuals under eighteen (18) years of age. You may use our services only with involvement and permission of a parent or guardian.
HOW SECURE IS INFORMATION ABOUT ME?
We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input and the information we may send to our agents.
We have gone to great lengths to ensure your information is securely obtained and held in compliance with the Payment Card Industry Data Security Standard. For example, we encrypt your credit card number before it is stored in our database. This helps ensure that no one may access your credit card from our system.
It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer.
We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. To that extent, we employ security measures that are deemed commensurate to the quality of data held, with due regard to the state of the art and cost of the available security measures, and the risk to the privacy rights of you, as data subject. We do not, nor can we, guarantee security. Neither people nor security systems are foolproof, including encryption systems.
Where a breach occurs, we shall, upon discovering such a breach, ensure that our obligations under applicable data privacy requirements, and with specific acknowledgement of Articles 33 and 34 of the GDPR, are complied with where applicable.
RETENTION OF DATA
We do not retain any Personal Information for longer than is necessary.
REGISTRANT DATA – REPORTS OF DNS ABUSE
Where we have specifically investigated or has taken action relating to a specific domain or domains, which have been flagged or confirmed as engaged in abusive behaviors (as per our acceptable use) we will ordinarily retain such data until such a time that such data is no longer necessary to defend against current or possible future suit(s). This period depends on limitation periods applicable, however should ordinarily be no longer than six (6) years.
WHAT INFORMATION CAN I ACCESS?
To access, update or delete your personal information, we will provide you with access to certain information about you for the limited purpose of viewing and, in certain cases, updating that information. To view or change this information, log in to your account. When you update information, we usually keep a copy of the prior version for our records.
FOR EUROPEAN UNION CITIZENS OR SWISS CITIZENS
ACCESS TO PERSONAL DATA
Where applicable, you have the right to obtain from us a confirmation as to whether or not your personal data is being processed. In addition, where such processing is confirmed, and you request it, we shall arrange access to the personal data and the following information;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the registrar, rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data was not collected from the you by us, any available information as to its source (e.g. referral program etc.); and
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Where your personal data is transferred to a third country you also have the right to be informed of the appropriate safeguards we have put in place pursuant to Article 46 of the GDPR relating to the transfer.
Copies of the Data: We, shall be happy to provide, where requested, a copy of that data, relating to you, which are being processed. Subject to the restrictions as noted in Article 23 of the GDPR.
All personal information held by us is that information which you have provided to us. To view or change this information, you should log in to your account. When you update information, we usually keep a copy of the prior version for our records. If this is deemed insufficient, or you are experiencing any difficulties in making the required updates, please contact us.
Where you as, the data subject, wish to erase personal data concerning you, we will fulfil this request should one of the following grounds apply:
- the personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed, e.g. the provision of our Services;
- where processing is based solely upon your required consent, and you withdraw this consent on which the processing is based;
- where you object to the processing, and where there are no overriding legitimate grounds for the processing;
- where you can demonstrate that the Personal Information has been unlawfully processed;
- where you provide notice that the Personal Information must be erased for compliance with a legal obligation as contained in a stated Union or Member State law to which the controller is subject; or
- where we are unable to demonstrate proper reliance on an exception under 17 (3) of the GDPR.
RIGHT TO BE FORGOTTEN
Where we have publically disclosed your data and where you have made a valid request to erase your personal data, we will, taking into account the available technology and the cost of implementation, take reasonable steps, including technical measures, to inform any controllers which are processing that personal data, of your request for erasure.
For clarity, Registration Data are in the format as specified by ICANN (compatible with the relevant technical standards as stated in the IETFs RFCs). This ensures that all Registration Data, in the our system is held in a form that is easily transferable from one registrar to another (following stated transfer processes dictated by ICANN).
Last Updated: 1 Jan 2020