Last revised: May 25, 2018
Domains Holdings Group Limited (the "Company"), offers a global network of content-rich web, mobile and social sites, including user acquisition and media buying (including paid search, display, mobile and social advertising), content optimization (including key word search, off-page and on-page optimization), and affiliate program, both in the web and mobile ecosystem (including through websites or mobile apps operated by Company; collectively, the “Services”).
§ WHAT INFORMATION WE COLLECT?
§ HOW WE USE THE COLLECTED INFORMATION?
§ WITH WHOM WE SHARE INFORMATION?
§ INTERNATIONAL TRANSFER OF INFORMATION
§ THIRD PARTY TRACKING TECHNOLOGIES
§ THIRD PARTY SERVICES
§ RETENTION OF PERSONAL INFORMATION
§ YOUR RIGHTS
§ HOW WE KEEP YOUR INFORMATION SECURED
§ HOW TO CONTACT US
WHAT INFORMATION WE COLLECT?
We collect two types of information from our Users:
§ Personal Information
The first type of information is information that identifies or may reasonably identify an individual reasonable effort (“Personal Information”). Personal Information which is being gathered may consist of the following:
§ Contact details: you may voluntarily provide us with certain contact details, such as your full name and email address.
§ Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the chat feature and in games.
§ Device information: we collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device’s unique identifiers (e.g. UDID, IMEI, MAC address), browser fingerprinting, IP address and geo-location data.
§ Social networks: when you voluntarily decide to register through your social network account (such as your Facebook account), we will have access to basic information from your social network account, such as your name, birthdate, profile picture and friends' list, as well as information you made publicly available on such account.
§ Information we collect from third parties: We collect Personal Information from third party service providers, such as information about your credit history from credit agencies and other financial information which is relevant to the provision of the Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.
§ Non-Personal information
The second type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Services (“Non-Personal Information”).
Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User visited the Services and related time stamps, etc.
For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
Types of Non-Personal Information we collect from or about you:
§ Technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.). This information also includes anonymous online identifiers, such as the Google Advertising ID and the IDFA.
§ Device and app information – this category includes your device's type and model, system language, the device's operating system (such as Android or iOS), SDK version, mobile carrier name, mobile browsers installed on the device (such as Chrome or Safari), app history and usage information (such as information about running and installed apps on the device), information regarding downloads and installations of mobile applications and any information regarding in-app events (such as in-app purchases), and anonymous identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Google Advertising ID, or other types of device identifiers.
§ Location information – we collect information about your general location (such as city and country). For example, we may use the IP address to identify your general location. This information does not tell us where your device is precisely located. This information is sent as a normal part of internet traffic. In addition, we also collect implicit location information, which allows us to infer that you are either interested in a place or that you might be at the place – this information does not actually tell us where your device is precisely located.
§ Ad information – this category includes information about the online ads and personalized content we have served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, whether you viewed, clicked on or otherwise interacted with the ad, ad engagement history and whether you visited the advertiser’s website, downloaded an app or purchased the product or service advertised.
§ Log and analytics information: we collect information about your use of the Services, such as applications' usage, log files, user activity (e.g. referral URL, pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at firstname.lastname@example.org .
HOW WE USE THE COLLECTED INFORMATION?
We use your Personal Information for the purposes listed below:
§ To provide and operate the Services, such as to provide our clients with performance marketing, online user acquisition network, online promotions, and for the purposes of user attribution;
§ To communicate with you and to keep you informed of our latest updates to our Services and special offers;
§ To market our Services (see more below under “Marketing”), as well as to serve you advertisements, including behavioral advertising;
§ To conduct analytics, statistical and research purposes, in order to improve and customize the Services to your needs and interests (such as by compiling aggregated reports about the usage of certain features of our Services);
§ To support and troubleshoot the Services and to respond to your queries;
§ To enable us to further develop, customize and improve the Services based on Users’ common preferences and uses;
§ To identify and authenticate your access to certain features of the Services;
§ To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;
§ To investigate violations of our policies and User Agreement as well as enforce our policies and the User Agreement;
§ To investigate and resolve disputes in connection with your use of the Services; and
§ As required by law or regulation, or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request.
The Company will use your Personal Information, such as your name, home address, email address, telephone number etc., ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) other companies within the Company; or (ii) the Company's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
We may also share and disclose Personal Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.
You may at any time decline receiving further marketing offers from us or from our business partners and marketing affiliates by contacting us at to email@example.com . Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
WITH WHOM WE SHARE INFORMATION?
We share Personal Information with any of the following recipients:
§ Our clients that deploy our Services on their online properties (such as websites and mobile apps); this includes our clients whose websites or apps you have visited, as well as an advertiser whose site or app you have visited – we share information about how you have interacted with such websites or apps.
§ Companies within the Company and other affiliated companies;
§ Subcontractors and third party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;
§ Auditors, contractors or advisers of any of the Company’s business processes;