At Authentic Web Inc. (“Authentic Web”, “we”, “our” and “us”) we are committed to protecting your privacy, and support a general policy of openness about how we collect, use and disclose your personal information.
Any questions regarding this policy and our privacy practices should be sent by email to firstname.lastname@example.org or by calling our privacy officer at: +1-416-583-3770 or writing our privacy officer at: 219 Dufferin Street, Suite 201C, Toronto, Ontario M6K 3J1.
WHO ARE WE?
We are a corporate domain registrar enabling enterprise brands to fully manage their domains, DNS, and brand registry on a single, integrated system.
HOW WE COLLECT PERSONAL INFORMATION
We obtain information about you in the following ways:
Information you give us directly – For example, we may obtain information about you when you register with us, sign up for a newsletter, contact us, or purchase one of our products and services.
Information you give us indirectly – We may obtain some of your personal information indirectly from third parties, which might include subcontractors acting on our behalf who provide us with technical, payment or delivery services, our business partners, advertising networks analytics providers, and search information providers.
When you visit the Websites – we, like many companies, automatically collect the following information: technical information, including the type of device you’re using, the IP address, browser and operating system being used to connect your computer to the internet. This information may be used to improve the Services we offer. We also collect information about your visit to the Websites, for example we collect personal information about pages you visit and how you navigate the Websites, i.e. length of visits to certain pages, products and services you viewed and searched for, referral sources (e.g. how you arrived at our Websites).
We collect and use your personal information by using cookies on our website – more information on cookies can be found in our Cookies Policy and the cookies section below.
Social Media – When you interact with us on social media platforms such as Facebook, LinkedIn, Instagram, YouTube, and Twitter we may obtain information about you (for example, when you publicly tag us in a photo). The information we receive will depend on the privacy preferences you have set on those types of platforms.
Public Information – We, sometimes, supplement information on our customers and prospective customers with information from publicly available sources such as annual reviews, corporate websites, and public social media accounts in order to create a fuller understanding of someone’s interests and support.
WHAT PERSONAL INFORMATION WE COLLECT
The personal information we may collect in the course of you accessing or using the Website or the Services (including through your initial registration for a subscription account and the subsequent administration of that account) may include, but is not limited to, the following:
- Your first and last names;
- Your contact information (such as your postal address, personal or work e-mail addresses, telephone numbers, or both);
- Your company name, job function and position in the company, thumbnail photograph (should you elect to upload one), location of work and other information as may be required from time to time to utilize our service;
- Your activity on our system once you are logged in;
- Any other personal information you have put on to the system; and
- Any other personal information you have shared with us directly such as emails, phone calls, letters, and employment applications.
Some data protection laws recognize certain categories of personal information as sensitive or special category and therefore require greater obligation on us to protect the personal information, such sensitive or special category of personal information is information about your health, ethnicity, and religion. We do not collect sensitive data about you, but if we ever were required to do so, you will be explicitly asked whether you consent to our collection and use of sensitive or special category of personal information.
HOW AND WHY WE USE YOUR PERSONAL INFORMATION
We use your personal information to:
- Provide you with Services, products or information you asked for;
- Provide you with personalized Services and a personalized experience on our Websites and interactive communication;
- Procssessing orders and instructions that you have submitted to us;
- Keeping a record of your relationship with us;
- Conducting analysis and market research so we can understand how we can improve our services, products or information;
- Seeking your views or comments on the Services we provide;
- Notify you of changes to our Services;
- Sending you communications which you have requested and that may be of interest to you;
- processing job applications;
- Provide you with timely and reliable Services;
- Do all the things necessary to administer those Services and the Website;
- Research, develop, manage, protect and improve those Services and the Website;
- Bill you for our Services; and
- Collect outstanding debts.
We will not sell, share, distribute, or reference any of your personal information except that we do share some of your personal information with service providers who support our Services which we explain in more detail in the next section.
WHEN WE DISCLOSE YOUR PERSONAL INFORMATION
We do not sell or rent your personal information to any third party.
We also do not share your personal information with third parties for their marketing purposes, but may, share your personal information with marketing agencies to market our own Services to you.
Third parties working on our behalf – We may pass your information to our third party service providers, suppliers, agents, subcontractors and other associated organizations for the purposes of completing tasks and providing services to you on our behalf (for example to process domain name registrations, send you email messages, process your payment, respond to support inquires). However, when we use these third parties, we disclose only the personal information that is necessary to deliver the Services and we have a contract in place that requires them to keep your information secure and prevents them from using it for any purpose other than to provide the service to us to support our Services to you. Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so.
Other Users – If you are using our Services as a registered user in connection with an enterprise-wide service arrangement, we also make certain personal information contained in your profile (such as your name, email address and any thumbnail photograph you choose to upload) available to other registered users within your organization.
KNOWLEDGE AND CONSENT
Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:
Specific Consent – Where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text and/or telephone marketing.
Performance of a contract – Where we are entering into a contract with you or performing our obligations under it like when you buy our Services.
Legal obligation – Where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example where we are ordered by a court or regulatory authority such as the Canadian Revenue Agency.
Vital interests – Where it is necessary to protect life or health (for example in the case of medical emergency suffered by an individual when visiting our offices) or a safeguarding issue which requires us to share your information with the emergency services.
Legitimate interests – Where it is reasonably necessary to achieve our or others’ legitimate interests (as long as what the information is used for is fair and does not duly impact your rights and is balanced).
We consider our legitimate interests to be offering our Services in pursuit of our aims and ideals. For example to:
- send postal communications which we think will be of interest to you;
- conduct research to better understand who our customers, prospective customers, visitors, prospective visitors, and prospective employees are;
- monitor who we deal with to protect the us against fraud, money laundering and other risks;
- enhance, modify, personalize or otherwise improve our services /communications for the benefit of our customers; and
- understand better how people interact with our Websites and Services in general.
When we legitimately process your personal information in this way, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information where our interests are overridden by the impact on you, for example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to do so by law).
USE FOR MARKETING PURPOSES
We may use your contact details to provide you with information about the products and services you can buy, if we think it may be of interest to you. We may contact you via:
Email/text/Phone – We will only send you marketing communications by email, text and telephone if you have explicitly provided your prior consent by signing up for our newsletter or have registered with us. You may opt out of our marketing communications at any time by clicking the unsubscribe link at the end of our marketing communications.
Post – We may send you marketing communications by post unless you have told us that you would prefer not to hear from us.
You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about the exciting products and services you can buy, then you can select your choices by contracting us directly by email, telephone or by post.
We’re committed to putting you in control of your personal data so you’re free to change your marketing preferences (including to tell us that you don’t want to be contacted for marketing purposes) at any time by contacting us by email: email@example.com, telephone: +1-416-583-3770 or post: 219 Dufferin Street, Suite 201C, Toronto, Ontario M6K 3J1.
We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted and will retain your details on a suppression list to help ensure that we do not continue to contact you. However, we may still need to contact you for administrative and technical purposes like such as an emergency maintenance, a confirmation of a domain name registration, a renewal reminder.
We may analyze your personal information to create a profile of your interests and preferences so that we can tailor and target our communications in a way that is timely and relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. This allows us to be more focused, efficient and cost effective with our resources and also reduces the risk of someone receiving information they may find inappropriate or irrelevant. But, as mentioned above, we are very committed to putting you in control of your data so you’re free to opt out of your information being used in this way at any time by contacting firstname.lastname@example.org
When you visit our website, we may place a text file called a “cookie” in the browser directory of your computer’s hard drive. A cookie is a small piece of information that a website can store on your web browser and later retrieve. The cookie cannot be read by any website other than the one that set up the cookies.
It is possible to switch off cookies by setting your browser preferences. For more information on how to switch off cookies on your computer, visit our full cookies policy. Turning cookies of may result in a loss of functionality when using our website.
Under UK data protection law, you have certain rights over the personal information that we hold about you. Here is a summary of the rights that we think apply:
Right of access – You have a right to request access to the personal information that we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply. If you want to access your personal information, please send a description of the personal information you want to see and proof of your identity via the contact details provided below.
Right to have your inaccurate personal information corrected – You have the right to have inaccurate or incomplete information we hold about you corrected. The accuracy of your information is important to us so we’re working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or if you believe any of the other information we hold is inaccurate or out of date, please contact us via the contact details provided below.
Right to restrict use – You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy or we’re not lawfully allowed to use it.
Right of erasure – You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions, we will do so as far as we are required to. In many cases, we will anonymize that information, rather than delete it.
Right for your personal information to be transferred to a third party – If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, you may ask us to provide it to you or another service provider in a machine-readable format.
Right to object – You have the right to object to processing where we using your personal information (1) based on legitimate interests or (3) for statistical/research purposes.
If you want to exercise any of the above rights, please email us at: email@example.com, telephone: +1-416-583-3770 or post: 219 Dufferin Street, Suite 201C, Toronto, Ontario M6K 3J1. We may ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.
Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We make commercially reasonable efforts to ensure that personal information collected in the course of you accessing or using the Websites or the Services is protected against loss, theft and unauthorized access. This protection applies in relation to information stored in both electronic and hard copy form. Access to such personal information is restricted to selected employees or representatives. In addition, we employ generally accepted information security techniques, such as firewalls, access control procedures and cryptography, to protect personal information against loss and unauthorized access.
LINKS TO THIRD PARTY SITES
We do not collect personal information of children which we consider to be 16 or under.
RETENTION AND STORAGE OF YOUR PERSONAL INFORMATION
As part of the services offered to you through this Website, the information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”) and Canada. By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA or Canada. You should be aware that these countries may not have similar data protection laws to the EEA or Canada. By submitting your personal information, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EEA or Canada in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy.
If you use our services while you are outside the EEA or Canada, your information may be transferred outside the EEA or Canada in order to provide you with those services. We undertake regular reviews of who has access to information that we hold to ensure that your personal information is only accessible by appropriately trained staff, volunteers, and contractors.
RETENTION AND STORAGE OF YOUR PERSONAL INFORMATION
Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:
- For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
- For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
Retention periods in line with legal and regulatory requirements or guidance.
Attention Privacy Officer, Peter LaMantia
If the Privacy Officer does not resolve the issue to your satisfaction, you may contact the Privacy Commissioner of Canada.
Office of the Privacy Commissioner of Canada
30 Victoria Street
Phone: 1 800 282-1376
Of, if you are based in Europe, any of the relevant European supervisory authorities who’s contact details you can obtain from this link: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm