General Privacy Conditions – All Users
Each section details important information regarding the use and disclosure of your Personal Information in conjunction with how you’ve chosen to interact with us, as well as options we make available to you to update, access, or otherwise take control of the Personal Information you provide to Clicklo.
INFORMATION WE COLLECT
We collect information you provide to Clicklo when choosing to participate in various activities on the Website. Such information may, or may not, include Personal Information.
WEBSITE USERS INFORMATION
If you submit Personal Information to us through the Website, then we may use it to operate, maintain, and provide to you the features and functionality of the Website, including, when applicable, sending you information.
Personal Information or other content that you voluntarily disclose online (on discussion boards, in messages and chat areas) may become publicly available and can be collected and used by others, including Clicklo, without any additional permission. We may use your email address to send commercial, marketing, or other messages regarding the Website or our Services 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. Clicklo reserves the right to disclose Personal Information and/or non-personally-identifiable information that Clicklo believes, 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, to protect the rights, property, or personal safety of Clicklo, our users or others, and to protect the rights, property, or personal safety of Clicklo, our users or others.
COOKIES / LOG FILES
We may use both your Personal 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. We may use and disclose to trusted third parties cookies and log file information to: (a) monitor the effectiveness of our marketing campaigns; and (b) monitor aggregate metrics such as total number of visitors, pages viewed, etc.
For a list of the Cookies we currently use, please visit https://donuts.domains/policies/cookies/
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. Our cookies are set to expire after 30 days unless indicated. Should you wish to manage cookies from within your browser, the following links will aid you to make the necessary settings changes to some of the most widely used browsers:
DATA SUBJECT REQUESTS
Should you, as a Website user, believe the data provided through the Website, and held by us, is inaccurate and requires rectification, Clicklo shall, when notified, make all necessary and timely attempts to update and correct such an identified inaccuracy.
Clicklo Service Users / Account Holders
GENERAL ACCOUNT INFORMATION
Clicklo ordinarily asks that you to provide us with information required for the proper maintenance and administration of your user account(s) with us. Such information is necessary for ensuring the proper administration of your account(s) (including contact email and telephone number) and for ease of contacting you in relation to your account(s) and Services.
BILLING INFORMATION / PAYMENT DETAILS
Information necessary for collecting payment for the Services and products that you purchase or obtain from us is also collected and processed. Clicklo does not directly process any payments; we use a 3rd party providers to process any payments on our behalf.
DATA NECESSARY FOR THE SPECIFIC PRODUCT/SERVICE OBTAINED BY YOU
Depending on the Service you obtain, we may need additional information, or to use your data in another manner specific and necessary to that Service. Please refer to the individual product/Service sections below.
2) Clicklo SERVICE USERS / ACCOUNT HOLDERS
Clicklo, acting as Data Controller, collects information necessary to provide Services to our customers, including email address and contact details. We collect and store your email address when you sign up and use this to communicate with you about account services, updates, and news from Clicklo.
CUSTOMER USE OF Clicklo SERVICES
At the core of Clicklo’s services is the creation of a shortened link to websites (“Links”), as specified by You. When you create such a Link, on your instructions, we collect and store the following:
The original URL and the shortened URL.
Your IP address
The time and date on which you shortened the original URL
Which user (as per your account) carried out the action.
When you share your shortened URL via the platform, we also shall store the information on the channels (such as Facebook and Twitter) through which the Clicklo Link was shared.
METRICS AND ANALYTICS
Clicklo collects information about accesses (such as clicks) of every shortened link created through our services. This information includes, but is not limited to:
the IP address and corresponding registered location of the devices accessing the created Link (limited to country and city only);
any referring websites or services; and
the time and date of each access and the browers and language preferences.
This information is used by Clicklo and its partners to provide your chosen Services. We also use this information to further improve Service and products available to you.
INFORMATION COLLECTED FROM THIRD PARTY SERVICES
Some features of the Services allow you to share your content and created Links through your accounts with other companies such as Facebook and Twitter. If you choose to connect Clicklo to such third party services, we may collect information related to your use of those third party services, such as authentication tokens that allow us to connect to your third party services accounts. We will ask you for permission before you authorize our collection of this information. We will only use that information for the specific reason for which it was provided to us. We may also collect information about how you are using the Services to interact with connected third party services. Note that third party services may have the ability to restrict the information that is provided to us based on your privacy settings of that account.
INFORMATION COLLECTED AUTOMATICALLY
Clicklo automatically receives and records information from your web browser when you interact with the Services (including creating or clicking on Links), such as your IP address, browser type, your general location and cookie information. This information may be used to help us understand how users transit a website, to fight spam/malware, to facilitate collection of data concerning your interaction with the Services (e.g., what Clicklo Links you have clicked on) and for other similar purposes.
Clicklo also automatically receives and records information that your mobile device transmits when you access the Services, like a device identifier, device settings, and operating system. This information is used to facilitate your access and use of the Services, to access and use other Third Party Services, and for other similar purposes.
Generally, the Services automatically collect website usage information, such as the number and frequency of visitors to the Site. Clicklo may use this data in aggregate form, that is, as a statistical measure. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the website so that we can analyze and improve them.
We will collect information about your general location (such as your city and state, which is derived from your IP address) when you visit the Website or use the Services, such as by clicking a Link and we may use various technologies to determine your location (if you enable this feature), when you access and use the Services through a mobile device.
We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service.
COOKIES INCLUDED IN Clicklo PROVIDED LINKS
Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. If you disable cookies, you will not be able to use some features of the Services. Clicklo cookies are set to automatically expire after 6 months from when they are set.
You may also ask Clicklo not to place cookies on your web browser. When cookies are disabled in this manner, clicks on Clicklo Links are not tied back to or associated with your web browser. However, we will still automatically collect the IP addresses of computers or mobile devices that click on or create Clicklo Links.
DOMAIN NAME REGISTRATION SERVICES
ROLES OF THE INVOLVED PARTIES
In the domain registration process, a number of parties, are necessarily involved to register your chose domain:
We collect and processes Registrant Data (defined below) to enable you to register a domain. In this instance, Clicklo is acting as a data processor, 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
With specific reference to the registration of a domain name, Clicklo has entered into an agreement with Name.com to act as the registrar, the data controller, which is responsible for escrowing your Registrant Data and passing your Registrant Data to the registry as required by its contracts with ICANN and the applicable registry.
A registry operator, as a joint data controller, will receive your Registrant Data from the registrar and is responsible for the processing of data necessary for the registration and maintenance of domains within one of their top-level domains (“TLD”). This includes escrowing of your Registrant Data as required by ICANN.
The Internet Corporation for Assigned Names and Numbers (“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. ICANN is also considered to be a joint data controller with regards to the collection, processing and publication of Registrant Data.
DOMAIN REGISTRANT DATA
Clicklo is a reseller of Name.com is required by contract, to collect data relating to the registration of domain names (“Registrant Data”) and then share such data with Name.com, who in turn shares it with the relevant registry operator (depending on the TLD you wish to register). The sharing and use of this data is required by our Reseller Agreement with Name.com and in turn as per the terms of their Registrar Accreditation Agreement with ICANN, and for each TLD’s Registry Agreement with ICANN, for the proper registration of your domain name.
To provide you with domain name registration Services, we typically require the following registrant data (“Registrant Data”):
Registrant Phone number
Administrative Contact Organization
Administrative Contact Address
Administrative Contact Email
Administrative Contact Fax
Administrative Contact Telephone Number
Technical Contact Organization
Technical Contact Address
Technical Contact Email
Technical Contact Fax
Technical Contact Telephone Number
Billing Contact Organization
Billing Contact Address
Billing Contact Email
Billing Contact Fax
Billing Contact Telephone Number
NOTE: Specific data collections may vary based on the TLD’s specific requirements as promulgated by its registry operator.
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 our system is held in a form that is easily transferable from one registrar to another (following stated transfer processes dictated by ICANN).
PURPOSE / LEGAL BASIS FOR PROCESSING
We use your Registrant Data for the following purposes:
to register the domain name;
to enable Name.com to provide the applicable registry with authoritative data to ensure the ongoing continuity, stability and resiliency of the DNS;
to enable our ongoing mitigation of DNS abuse, including but not limited to the investigation and mitigation of reported instances of abuse to Clicklo as a reseller of Name.com, and as are considered to be contrary to the terms of Name.com’s Acceptable Use Policy and the Acceptable Use policy of the relevant Registry Operator;
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, Clicklo uses your Registration Data to arrange your registration and supported functionality of your domain(s) with the Registrar and Registry operator. Additionally, Clicklo 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.
DISCLOSURE OF DATA
There are instances where Clicklo may have to disclose your Personal Information. At all times however, such disclosure shall be limited and subject to the required safeguards.
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 poses a threat to your safety;
required by ICANN;
required by law or necessary to respond to legal process;
in circumstances in which Clicklo believes that its 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 Clicklo service, 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.
Registrant Data required to register a domain will be provided to Name.com, who as registrar in turn is required by its contracts with ICANN, to make certain data available to the public via an interactive webpage and via a “port 43” WHOIS service (together, “WHOIS”). Similarly, Name.com as the registrar may pass your Registrant Data on to the applicable registry which may be required by its contracts with ICANN, to make certain data available to the public via their WHOIS service.
THIRD PARTIES PROCESSING DATA ON OUR BEHALF
3) GENERAL PRIVACY CONDITIONS ALL USERS
FAMILY OF COMPANIES
Clicklo is a part of the Donuts Inc. family of companies (the “Family of Companies”). As part of the Family of Companies, we may share information we have about you within the Family of Companies. Such sharing however shall be strictly limited in use. We will only share information about you to such members of the Family of Companies to facilitate, support and integrate their activities in a manner that is consistent with, and related to, the original stated use of the information, as explained to you upon collection, and to improve the provision of our services to you.
The Family of Companies includes the following companies: Dozen Donuts, LLC; Rightside Group, Ltd; Nametrust, LLC; Rightside Operating Co.; Domain Protection Services, Inc. Name.com, Inc.; Name.net, Inc.; Name104, Inc.; Name105, Inc.; Name106, Inc.; Name107, Inc.; Name108, Inc.; Name109, Inc.; Name110, Inc.; Name111, Inc.; Name112, Inc.; Name113, Inc.; Name114, Inc.; Name115, Inc.; Name116, Inc.; Name117; Name118, Inc.; Name119, Inc.; Name120, Inc.; Mobile Name Services Incorporated; Sipence, Incorporated; Vedacore.com, Inc.; Binky Moon, LLC; Corn Lake, LLC; Dog Beach, LLC; John Island, LLC; Pixie North, LLC; Clicklo Global LLC. The Family of Companies also includes the following non-U.S. based companies: Clicklo (HK) Limited; Capable Network Technology (Shanghai) Co., Ltd.; Rightside Domains Europe Limited; Name.com Canada Corp; Hot Media Inc, Acquire This Name, Inc.; and Rightside Canada Inc.
Clicklo has physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your Personal and non‑personal 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, Clicklo shall, upon discovering such a breach, ensure that our obligations are met under applicable data privacy requirements, and with specific acknowledgement of Articles 33 and 34 of the GDPR, where applicable.
RETENTION OF DATA
Clicklo does not retain any Personal Information for longer than is necessary.
CREATED LINK DATA
At all times Clicklo service users have the ability to delete the data associated with the Link that they have created. Where the service user does not delete that data, Clicklo shall delete account data after a reasonable period (generally 6 years after the closure of the account, so as to protect or prepare Clicklo against any legal action)
Where the registry is investigating or has taken action relating to a specific domain or domains, which have been flagged or confirmed as engaged in abusive behaviors (as per Clicklo Acceptable Use Policy) 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.
See Section on Website 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. Clicklo does not ordinarily or knowingly require or collect Sensitive Personal information. Where such collecting is required, we will not disclose such information with third parties without your 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 Services to individuals under eighteen (18) years of age.
DATA SUBJECT RIGHTS
ACCESS TO PERSONAL INFORMATION
Where applicable, you have the right to obtain from us a confirmation as to whether or not Personal Information concerning you is processed by us. In addition, where such processing is confirmed, and you request it, we will arrange access to the Personal Information along with the following information:
the categories of Personal Information collected and processed;
the recipients or categories of recipients to whom the Personal Information has been or will be disclosed, in particular recipients in third countries (outside of the European Economic Area (“EEA”) or international organizations;
the period for which the Personal Information will be stored, or, if not possible to be determined, the criteria used to determine that period;
the existence of the right to request from us, 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 Personal Information was not collected directly from the you, any available information as to its source;
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 Information 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
Clicklo may 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 as disclosed to us by you. 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 the erasure of your Personal Information, Clicklo will fulfill your 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 Clicklo is unable to demonstrate proper reliance on an exception under 17 (3) of the GDPR.
RIGHT TO BE FORGOTTEN
Where Clicklo has publicly disclosed your data and where you have made a valid request to erase your Personal Information, Clicklo 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.
Clicklo shall provide an ability for any client to obtain a copy of all data within their account regarding any created Links, save such data which has been erased by you as a Service user.
SPECIAL NOTES FOR INTERNATIONAL USERS
FOR EUROPEAN UNION, SWISS & UNITED KINGDOM CITIZENS
Transfer of data outside of the European Economic Area (“EEA”) – Clicklo is a US registered entity, and all our primary servers are located within the USA. Your choice to use of our Services may involve the transfer of data outside of the EEA.
PRIVACY SHIELD FRAMEWORKS
As a member of the Donuts Family of Companies, Clicklo complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States in reliance on Privacy Shield. We have certified that we adhere to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this Policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
Note that you have the right to access, correct, delete, and limit the use and disclosure of your Personal Information processed by us. For assistance with accessing, correcting, or deleting your personal data, please contact us at firstname.lastname@example.org. Please be aware that deleting your Personal Information may result in termination of the services you receive through us.
Clicklo’s accountability for the personal data that it receives under the Privacy Shield, and subsequently transfers to a third party, is described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Clicklo proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, We commit to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals, or those persons resident in the United Kingdom, with inquiries or complaints regarding this Policy should first contact our Legal Department at email@example.com or by certified mail (return receipt requested) at:
Clicklo Inc., c/o Donuts Inc., Attn: Legal Department, 10500 NE 8th Street Suite 750 Bellevue, WA 98004 USA.
We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Note that the US Federal Trade Commission has enforcement authority over our compliance with this Policy.
If you are a resident of the EEA and believe we maintain your personal data subject to the General Data Protection Regulation, you may direct questions or complaints to our lead supervisory authority, the Office of the Data Protection Commissioner, as noted below:
Last Updated: 03 February 2020