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Last Updated: May 14, 2025

This Privacy Policy describes how Identity Digital Inc. and our subsidiaries and affiliated companies (collectively, “Identity Digital,” “we,” or “us”) collect, use, disclose, and otherwise process information about you if you:

• Visit our websites and other online products and services that link to this Privacy Policy (collectively, our “Websites”);
• Work with a registrar that relies on our internet registration products, including Domain Name Registration, Domains Protected Marks List, or Domain Engine (collectively the “Products”);  and
• Otherwise interact with us in a business or professional context, such as if you are a registrar who has an account with us, communicate with us via email, or provide us your contact information at a conference.

This Privacy Policy does not apply in all circumstances. For example, Identity Digital may operate as a “data processor” for certain third-party registry operators. In those instances, we handle domain name registrant personal information on behalf of such registry operators, subject to the terms of our agreements with them.  Please carefully review the terms associated with registry operators you work with. In addition, Identity Digital may also provide different or additional notices of our privacy practices for certain offerings, in which case those notices will supplement or replace the disclosures in this Privacy Policy.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by notifying your registrar, adding a statement to our Websites, or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

CONTENTS

COLLECTION OF INFORMATION

The information we collect about you depends on which Products you use and how you use our Websites or otherwise interact with us. In this section, we describe the categories of information we collect and the sources of this information.

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information directly from you when you fill out a form on one of our Websites, create an account with us, request customer support, connect with us via email, or otherwise communicate with us. The types of information that we collect directly from you include your name, email address, postal address, phone number, and any other information you choose to provide. If you are a registrar or other party making a payment to us, we work with a third-party payment processor to process your payment information.

Information We Collect Automatically

We automatically collect information about your interactions with us, including:

• Device, Usage, and Activity Information: We collect information about how you access our Websites and how you use our Domain Engine Product, which certain registrars may make available to you. The information we may collect includes data about the device and network you use (such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, and browser type), and data about your interactions with our Websites and Domain Engine Product, such as access dates and times, browsing behavior (such as pages viewed and links clicked), terms you search for, and information about your activity on specific pages.
• Chat and Audio Content: If you contact our support team through email or by phone or video conference, we may monitor and retain those conversations, including for training purposes.
• Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as cookies and pixels, to collect information about your interactions with our Websites and our marketing communications. These technologies help us improve our offerings and marketing communications, personalize your experience, and analyze your interactions with us, including to count visits and understand popularity of different features. For more information about the cookies and similar tracking technologies we use, and the choices available to you, see the Targeted Advertising and Analytics and the Your Choices sections below.

Information We Collect from Other Sources

We obtain information from other sources. For example, you may purchase one of our registration products from your registrar, in which case they may provide us with certain information including your registrant name, organization, address, email, fax, phone number, and contact information for various stakeholders, including administrative, technical, and billing contacts. We may also collect information from entities that gather and license business contact information, industry partners, and advertising networks.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, if you use our Domain Engine Product or visit our Websites, we may make inferences about your approximate location based on your IP address.

USE OF INFORMATION

We use the information we collect in the following ways:

• Domain Name Registration: If you purchase our Domain Name Registration Product from your registrar, we process the associated information 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 registry. We also process it to centralize authoritative registrant data at the registry level to ensure the ongoing continuity, security, stability and resiliency of the domain name system (“DNS”). To enter your chosen domain name into our registry system, we are required to process your data in accordance with our contracts with the Internet Corporation for Assigned Names and Numbers (“ICANN”). In these instances, each of our top-level domain registries acts as a “joint controller” of your information, working together with your registrar and ICANN.
• Domains Protected Marks List: If you purchase our Domains Protected Marks List (“DPML”) Product from your registrar, we process the associated information to enable the DPML block across our top-level domains at your registrar’s request.
• Domain Engine: If you use our Domain Engine Product on a registrar’s website, we use the search terms you enter and your IP address to help identify relevant and high-performing domain names for you.
• Other Uses of Information: We also use the personal information we collect pursuant to this Privacy Policy to:
  
  • Process and fulfill purchases;
  • Maintain and improve our Products and Websites, including but not limited to maintaining the integrity of the current dual failsafe system at the registrar and registry levels;
  • Mitigate DNS abuse, including but not limited to the investigation and mitigation of reported instances of abuse Identity Digital considers to be contrary to the terms of its Acceptable Use Policy;
  • Detect, investigate, respond to, prosecute, and help protect against security incidents and other malicious, deceptive, fraudulent, or illegal activity, and help protect the rights and property of Identity Digital and others;
  • Send you technical notices, security alerts, support messages, and other transactional or relationship messages;
  • Send you marketing communications (see the Your Choices section below for information about how to opt out of these communications at any time);
  • Monitor and analyze trends, usage, and activities in connection with our Websites and Products;
  • Target advertisements to you on third-party platforms and websites (for more information and to opt out, see the Targeted Advertising and Analytics section below);
  • Develop new products and services; and
  • Comply with our legal and financial obligations.

TARGETED ADVERTISING AND ANALYTICS

We engage others to provide analytics services, advertise Identity Digital and our Products to you on third-party sites and services, and perform related services across the web and in mobile applications. To do this, Identity Digital and these partners may use cookies, web beacons pixels, SDKs, and similar technologies to collect information about your use of our Websites and third-party services, including your device identifiers, IP address, web browser and mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information is used to deliver advertising targeted to you on other companies’ websites and mobile apps, understand the effectiveness of this advertising, analyze and track data, and better understand your activity. When you arrive on our site, you will be presented with consent options upon arriving at our websites and can subsequently change those choices using the “Your Privacy Choices” link. Your choice will be linked to your browser only; therefore, you will need to renew your selections if you visit our website from a new device or browser, or if you clear your browser’s cookies.

In addition to ad targeting activities that rely on cookies and similar technologies, we work with advertising partners to translate other identifiers, such as your email address or phone number, into a unique identifier (called a hashed value) that such partners can then use to show ads that are more relevant to you across the web and in mobile apps. You may opt out of these disclosures by contacting us at privacy@identity.digital.

The activities described in this section may constitute “sharing,” or “selling” under the California Consumer Privacy Act. See the Additional Information for California Residents section below for details.

You can also learn more about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices or www.youronlinechoices.eu (if you reside in Europe) or https://youradchoices.ca (if you reside in Canada). Your device may also include a feature that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.

DISCLOSURE OF INFORMATION

We disclose information about you as described in the Targeted Advertising and Analytics section above and in the following scenarios:

• Vendors and Service Providers. We make personal information available to our vendors, service providers, contractors and consultants who perform services on our behalf, such as companies that assist us with payment processing, cloud storage, marketing, analytics, mitigating abuse and customer service.
• ICANN. 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. In connection with providing our Domain Name Registration Product, we may provide certain personal information to ICANN or to others as required by ICANN.
• Domain Name Registration Organizations. If you purchase our Domain Name Registration Products, we may disclose certain personal information escrow providers to effectuate the proper registration of your domain name and in accordance with ICANN requirements. 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.
• Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We disclose personal information in response to a request for information if we believe that disclosure is in accordance with, or required by, any applicable law, regulation, or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• To Protect the Rights of Identity Digital and Others. We may disclose personal information if we believe that your actions are inconsistent with our policies (including our Acceptable Use Policy), if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Identity Digital or others.
• Professional Advisors. We disclose personal information to our legal, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• Corporate Transactions. We disclose personal information in connection with, or during negotiations of, certain corporate transactions, including a merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Corporate Subsidiaries. Personal information may be disclosed between and among Identity Digital and certain of our subsidiaries under common control and ownership.
• With Your Consent or at Your Direction. We make personal information available to third parties when we have your consent or you intentionally direct us to do so.

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you. We maintain and use this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

YOUR CHOICES

Account Information

You can update certain information stored within your account with us at any time by logging in and navigating to the settings menu.

Cookies and Similar Tracking Technologies

Identity Digital uses cookies and similar tracking technologies on our Websites, as described above. You can usually adjust your browser settings to remove or reject browser cookies. In addition, if you are in the United States, you may opt out of cookie-based ad targeting on our website by clicking the link titled “Your Privacy Choices ” on the footer of our Websites. If you are outside of the United States, you will be presented with consent options upon arriving at our Websites and can subsequently change those choices using the “Cookies Settings” link.

Communications Preferences

You may opt out of receiving promotional emails from us by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your orders with us or our ongoing business relationship. Depending upon where you live, we may only send you promotional emails where we have your consent to do so.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

California has enacted the California Consumer Privacy Act (“CCPA”), which grants California residents certain rights and requires specific disclosures. If you reside in California, this section applies to you and also serves as our California notice at collection.

In the preceding sections, we explain how we collect, use, and disclose information about you, as well as our targeted advertising and analytics practices. As required by the CCPA, we use the tables below to explain this same information.  

Use and Disclosure of Personal Information for Business Purposes

We do not collect information that is deemed “sensitive” under the CCPA.

As described in the Collection of Information section above, we collect personal information from various sources, including directly from you, automatically when you access or use our Websites or Domain Engine Product, from registrars and from other third-party sources.

We retain personal information for as long as necessary to carry out the purposes for which we originally collected it and for other purposes described in this Privacy Policy.

Sales and Sharing Activities

We also disclose certain categories of personal information to show you targeted ads on third-party properties and for related purposes. These disclosures may be considered “sales” or “sharing” under the CCPA, and the table below provides more information about our practices.

We do not engage in sales, sharing, or targeted advertising using personal information about consumers we know to be under the age of 18.

Your Rights

Opt Out of Sales and Sharing

You may opt out of activities that we engage in that constitute “sharing” or “sales” of personal information under the CCPA by:

• Cookies and Similar Technologies: Clicking the “Your Privacy Choices ” link on the footer of our Websites and following the instructions that appear. Your opt-out choice will be linked to your browser only; therefore, you will need to renew your opt-out choice if you visit our website from a new device or browser, or if you clear your browser’s cookies; and
• Other Identifiers: Emailing us at privacy@identity.digital to opt out of “sharing,” and “sales” based on your email address and other non-cookie identifiers.

If you reside in California, you can also opt out by visiting our website with a legally recognized universal opt-out signal enabled, such as the Global Privacy Control.

Access, Correction, and Deletion

If you are a California resident, you have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information.

To request access, correction, or deletion of your personal information, please contact us at privacy@identity.digital. To authenticate your request, we may ask you to provide some additional information, such as about previous interactions with us.

Nondiscrimination

You have the right not to be discriminated against for exercising any of your privacy rights.

Authorized Agents

You may also designate an authorized agent to submit rights requests on your behalf. For access, correction, or deletion requests, we may ask authorized agents to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the consumer who is the subject of the request. In some cases, we may contact the individual who is the subject of the request to verify their own identity or confirm the authorized agent has permission to submit the request. If you are an authorized agent seeking to make a rights request on behalf of a California resident, please email us at privacy@identity.digital.

ADDITIONAL INFORMATION FOR INDIVIDUALS OUTSIDE OF THE UNITED STATES

International Transfers

Identity Digital is based in the United States, and we and our service providers process and store personal information on servers located in the United States and other countries. Whenever we make restricted international transfers of personal information, we take steps to ensure that your personal information receives an adequate level of protection (by putting in place appropriate safeguards, such as contractual clauses) or ensure that we can rely on an appropriate derogation under data protection laws. Where relevant, you may request access to any safeguard which we use to transfer your personal information outside of the European Economic Area, the United Kingdom, or Switzerland (although we may need to redact data transfer agreements for confidentiality reasons).

For personal information about EEA, Swiss, and UK individuals, Identity Digital complies with the EU-U.S. and Swiss-U.S. Data Privacy Frameworks and the UK Extension to the EU-U.S. Data Privacy Framework (collectively, the “Frameworks”), each as set forth by the U.S. Department of Commerce.  As described in our Frameworks certification, Identity Digital has certified that it adheres to the Frameworks Principles with regard to the processing of personal information received from the EEA, Switzerland, and the UK in reliance on the Frameworks.  In accordance with the Frameworks, we remain responsible under the Onward Transfer Principle for personal information that we disclose to third parties for processing on our behalf.  To learn more about the Frameworks or to view our certification, please visit the Frameworks website.  The Federal Trade Commission has jurisdiction over Identity Digital’s compliance with the Frameworks.

Identity Digital commits to resolve Frameworks Principles-related inquiries and complaints about our processing of personal data under the Frameworks. Individuals located in the EEA, UK, and Switzerland can contact us with inquiries or complaints at privacy@identity.digital.  If we are unable to resolve the complaint, such individuals may refer the complaint to your local data protection authority, and we will work with them to resolve the issue. Contact details for the relevant data protection authorities can be found using the links below:

• For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
• For individuals in the UK: https://ico.org.uk/global/contact-us/
• For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

In certain circumstances, the DPF provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Framework Principles.

The following US-based Identity Digital affiliates adhere to the Frameworks: Afilias Inc.; Afilias USA, Inc.; Binky Moon, LLC; Covered TLD, LLC.; Dog Beach, LLC; Domain Protection Services, Inc.; Domainsite, Inc.; Dozen Donuts, LLC; DTLD Holdings, LLC; DTLD Parent, Inc.; Identity Digital Capital LLC; Identity Digital Inc.; Identity Digital Ventures LLC; Monolith Registry, LLC; Name.com, Inc.; Name.net, Inc.; Name105, Inc.; Name106, Inc.; Name117, Inc.; Nametrust, LLC; Ruby Glen, LLC; Spring McCook, LLC.

The Identity Digital family of companies also includes the following non-U.S. based companies: Afilias (Shanghai) Information Technology Co., Ltd.; Afilias India Pvt. Ltd.; Afilias Resolution Services Ltd.; Capable Network Technology (Shanghai) Co., Ltd.; Domain Registry Services Ltd.;  doMEn d.o.o.; Donuts (HK) Limited; Dot Global Domain Registry Ltd.; Global Website Asia Ltd.; Global Website TLD Asia Ltd; HOTEL Top-Level-Domain S.a.r.l.; Identity Digital Australia Pty Ltd.; Identity Digital Canada Corp.; Identity Digital Domains Ltd.; Identity Digital Holdings Ltd.; Identity Digital Limited; and Internet Computer Bureau Ltd..

Legal Basis for Processing

If you are located in Europe or another jurisdiction that requires a lawful basis for processing personal information, please note that when we process your personal data as described in this Privacy Policy, we do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., processing payments for and providing the Products you requested);
• When we have a legitimate interest in processing your personal information to operate our business or protect our interests (e.g., to coordinate with ICANN, provide, maintain, and improve our products and services, conduct data analytics, and communicate with you);
• To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications); or
• When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing of your personal information, you may withdraw such consent at any time.

Data Subject Requests

If you are located in Europe or another jurisdiction that grants you data subject rights, you have the right to (1) access your personal data, including in a portable format, (2) request erasure of your personal data, and (3) request correction of inaccurate personal data. In addition, you may have the right to object to certain processing or request we restrict certain processing. To exercise any of these rights, please email us at privacy@identity.digital.

If you have a concern about our processing of personal data, we encourage you to contact us in the first instance. However, if we are not able to resolve it, you may have the right to lodge a complaint with the Data Protection Authority where you reside (if you live in the EEA, UK, or Switzerland, see links in the International Data Transfers section for contact information).

Individuals in Canada

If you are a Canadian resident, this section applies to you.

Consent

By submitting personal information to Identity Digital, our service providers, or our agents, you consent to the collection, use, disclosure, and transfer of your personal information in accordance with this Privacy Policy and as permitted or required by law.

You may withdraw your consent at any time to the collection, use, disclosure, or transfer of your personal information by contacting Identity Digital as set forth in the Contact Us section below. If you withdraw your consent (or if you decide not to provide certain personal information), you acknowledge that Identity Digital may not be able to provide you, or continue to provide you, with certain products, services, or information that may be of value to you.

Canada’s Anti Spam Law

Identity Digital will only send you commercial electronic messages (“CEMs”) where we have your express or implied consent to do so. Your consent to receive CEMs is implied where we have an existing business relationship with you, or you have reached out to us and made an inquiry within a certain time frame. You may unsubscribe from receiving CEMs at any time, by clicking the unsubscribe button on an email. If you opt out, we may still send you non-promotional messages, such as those about your account or our ongoing business relations.

CONTACT US

If you have questions about this Privacy Policy, please contact us at privacy@identity.digital.