2. What "Personal Information" do we collect?
To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:
- Information you provide us. When you register for our Services, purchase and/or register domain names, use any of our Services; and/or when you contact us directly by any communication channel, you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with us and with other users on our Platform, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).
- Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc
- Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers , fraud detection and prevention providers for example to help us screen out users associated with fraud, ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.
Users of users ‘Personal Information’
We may also collect Personal Information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf (as further described in Section 6 below).
3. Why do we collect such "Personal Information"
We use your Personal Information for the following purposes:
- To provide and operate the Services;
- To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences and difficulties;
- To provide our Users with ongoing customer assistance and technical support;
- To be able to contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section 8 below);
- To help us to update, expand and analyze our records to identify new customers;
- To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;
- To analyze our performance and marketing activities;
- To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services;
- To provide you with professional assistance, only upon your request;
- To enhance our data security and fraud prevention capabilities; and
- To comply with any applicable laws and regulations.
We use your Personal Information for the purposes set out in this section where:
- Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g. to provide you with a website builder, to provide you with our customer assistance and technical support);
- Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or
- Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and the effectiveness of the Platform by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.
4. How we share your "Personal Information"
We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:
- Third Party Service Providers: NORTHWEB has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”). NORTHWEB may share the following categories of Personal Information with Third Party Service Providers for a business purpose:
- identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers
- commercial information, for example information regarding products or services purchased, obtained, or considered
- Law Enforcement, Legal Requests and Duties: NORTHWEB may disclose or otherwise allow access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.
- Protecting Rights and Safety: NORTHWEB may share your Personal Information if we believe in good faith that this will help protect the rights, property or personal safety of NORTHWEB, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.
- Social Media Features and Framed Pages: Our Services include certain Social Media features, widgets, and single sign on features, such as the “Facebook Connect,” “Google Sign-in,” “Facebook Like”, or “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect certain Personal Information such as your IP address or which page you are visiting on our Website and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours. In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third-Party Service Providers or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing are governed by those third parties’ policies and not ours.
- Connection With a Change in Corporate Control: In addition, should NORTHWEB undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.
- Upon Your Further Direction: NORTHWEB may also share your Personal Information with third parties for other purposes upon your further direction or with your explicit approval.
You are solely responsible for notifying your Users-of-Users of the collection, processing and use of their Information and informing them that their Information will be transferred to and processed by NORTHWEB on your behalf.
5. Where do we store your "Personal Information"?
Users’ and Users-of-Users’ Personal Information may be stored in data centers located in Germany. We may use other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law. NORTHWEB Ltd is based in Bulgaria, which is a member of the European Union, thus all General Data Protection Policies apply.
NORTHWEB Third-Party Service Providers that store or process your Personal Information on NORTHWEB’s behalf are contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
6. Users-of-users’ "Personal Information"
NORTHWEB may collect, store and process certain Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their e-mail contacts from third-party services like Gmail, or otherwise collect and manage contacts via their User Website. Such contacts are then stored with NORTHWEB, on the User’s behalf.
For such purposes, NORTHWEB serves and shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation (“GDPR”)) of such Users-of-Users Information.
The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.
You are responsible for the security, integrity and authorized usage of Personal Information about Users-of-Users’, and for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Personal Information.
NORTHWEB cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites in accordance with any applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they understand and, to the extent required by applicable law, consent to them.
For more information on how Users-of-Users Personal Information may be handled by NORTHWEB (which may be relevant for any specific notice you provide to and/or consent you obtain from your Users-of-Users), please see Sections 4, 12 and 13.
If you are a visitor, user or customer of any of our Users, please read the following: NORTHWEB has no direct relationship with Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to request to access, correct, amend, or delete inaccurate Personal Information processed by NORTHWEB on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If NORTHWEB is requested by our Users to remove any Users-of-Users’ Personal Information, we will respond to such requests in a timely manner upon verification and in accordance with applicable law (for example, thirty (30) days under the GDPR). Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set forth in Section 12 below.
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
8. Communications from NORTHWEB
We may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within our Platform, marketing calls and similar forms of communication from NORTHWEB or our partners (acting on NORTHWEB’s behalf) through such means.
If you do not wish to receive such promotional messages or calls, you may notify NORTHWEB at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
Service and billing messages
NORTHWEB may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.
It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a NORTHWEB User (which can be done by deleting or deactivating your account).
9. Your rights in relation to your ‘Personal Information’
NORTHWEB agrees that it is imperative that you have control over your Personal Information. Pursuant to privacy regulations worldwide, NORTHWEB is taking steps to enable you to request access to, receive a copy of, update, amend, delete, or limit the use of your Personal Information.
Before fulfilling your request, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g. if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
If you are a NORTHWEB User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please send us an email to firstname.lastname@example.org. We will make reasonable efforts to honor your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations.
Please note that permanently deleting your NORTHWEB account erases all of your Personal Information from NORTHWEB's databases. After completing this process, you can no longer use any of your NORTHWEB Services, your account and all its data will be removed permanently, and NORTHWEB will not be able to restore your account or retrieve your data in the future. If you contact our support channels in the future, the system will not recognize your account and support agents will not be able to locate the deleted account.
10. Questions and complaints
Our Data Protection Officer will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly and in accordance with applicable law.
You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.
11. Data retention
We may continue to retain your Personal Information after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
We maintain a data retention policy which we apply to Personal Information in our care.
NORTHWEB has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
All purchases on the Websites managed by NORTHWEB and our User's Websites are handled by a third party - PayPal.com, VivaWallet.com or other Banks, in which the transferred information thereof is encrypted. NORTHWEB does not arrange, save or transport any credit card numbers.
Regardless of the measures and efforts taken by NORTHWEB, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Personal Information or any other information you upload, publish or otherwise share with NORTHWEB or anyone else. We encourage you to set strong passwords for your User Account and User Website, and avoid providing us or anyone with any sensitive Personal Information of which you believe its disclosure could cause you substantial or irreparable harm.
Furthermore, because certain areas on our Services are less secure than others (for example, if you set your Support forum ticket to be “Public” instead of “Private”, or if you browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
If you have any questions regarding the security of our Services, you are welcome to contact us at email@example.com.
13. Third-party websites
14. Updates and interpretation
Any heading, caption or section title contained herein is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.
15. Contacting us