assigns thereof, referred to hereinafter collectively as “CTRwow”, "we", "our" and/or "us"), our
websites, products and services. CTRwow knows that you care how information about you is used and
shared, and we appreciate your expectation that we will do so carefully and sensibly. By visiting this or another
“Websites”), or by otherwise interacting with CTRwow, you agree to accept the practices described
agreements related to the CTRwow services or products you utilize or purchase.
CTRwow values your privacy and is dedicated to protecting your
information and providing you with notice about what personally identifiable information we collect and how it is
used, what choices you have regarding the collection, use and distribution of that information, the security
procedures we implement to protect that information and what access you may have to correct any inaccuracies in
the information we have collected from you.
We receive and store any information you enter on our Websites or give us in any other way, such as via telephone,
electronic mail, online or otherwise. For example, this information may be collected when you register a domain
name or when you contact us for customer support. Here are the types of information we gather:
Contact Information: We collect and retain personal contact information that you submit to us
voluntarily and this
includes, but is not limited to, your name, mailing address, web address, telephone number, and e-mail
address. For any domain name registrars owned and/or operated by CTRwow, we are required by the
Corporation for Assigned Names and Numbers ("ICANN"), the organization which assumes responsibility for domain
name allocation, to collect certain information about you during the domain name registration process and to
maintain a copy of such information with a third-party escrow service. This information may include your full
name, mailing address, phone number, email address, and, where provided, your fax number. Such contact information
may be used, for example, to communicate with you when necessary with respect to
transactions. Additionally, we may collect contact information provided to us during any correspondence
relating to customer support, as well as in connection with products and services offered on our Websites.
Financial Information: We collect and retain certain financial information when you order our
services. For example, when you apply to register a domain name or sign up for any other product or service
through CTRwow, we require you to provide a credit card number and billing address before we will
application. We will not sell, share or rent any financial information collected from you except as disclosed in
Demographic Information: We may collect and store anonymous demographic information (such as your
zip code, gender
and age), and use this data to tailor your experience on our Websites, provide content that we think you might be
interested in, perform general improvements to the Websites, and display the content
according to your preferences. Such demographic information may be shared with partners, market
researchers and other third parties on an aggregate, non-personally identifiable basis. No personally
identifiable information will be linked to such aggregated demographic information that is shared with third
Other Information: We collect and store certain types of information whenever you interact with
example, our servers track the type of web browser you are using and the page from which you link.
Additionally, we log IP addresses (a unique number assigned to every computer on the Internet) in order to
improve security, analyze trends and administer the Websites. We may track your movement within the
Websites, the third-party website pages from which you were referred, access times and browser types. We use this
information to gauge the effectiveness of our Websites, track information for statistical purposes and to improve
the products and services we provide. We collect this information to better develop a sense of what services our
customers need and identify areas of improvement to the Websites. We may use such information for marketing
purposes, and only to the extent allowed by law, to send information to you that we believe might be of interest.
In addition, such information may be shared with partners, market researchers and other third parties on an
aggregate, non-personally identifiable basis. No personally identifiable information will be linked to such
aggregated information shared with third parties.
We may supplement the information you provide us by acquiring publicly or commercially available information as
available in the public domain or from third parties, for instance, to verify your address or to update your
information and to create a profile of your preferences. We tie your personally identifiable information to
information in the profile, in order to improve the content of the Websites for you or to inform you about
products or services that we think will be of interest to you. In addition, we may obtain non-sensitive contact
information from third parties, including via bulk access licenses from other registrars. From time to time, we
may also ask you to participate in surveys or other communications conducted by us or third parties designed to
help us improve the Websites or the products or services we provide.
Cookies: The Websites may use "cookie" technology for such purposes as enhancing your online
experience by making
it easier for you to navigate through the Websites and making certain features work better. Cookies are text files
which are commonly deposited by websites on a user's hard drive when the user visits a website. The file
identifies a user's computer and can record the user's preferences and other data about the user's website visit.
We do not extract information about individual users during this process. Your web browser may enable you to
disable cookies, but please note that certain services may not function correctly without it and your
experience on our Websites may be hindered.
Third Party Cookies: We may use third-party advertising companies to serve ads on our behalf
Internet. These companies may collect and use information about your visits to this and other websites and your
interaction with our products and services in order to provide advertisements about goods and services of interest
to you. However, no personally identifiable information (such as your name, address, email address or telephone
number) will be connected with such information. They may use information about your visits to this and other
websites to target advertisements for goods and services and may be used to keep track of user
response to each advertisement. These targeted advertisements may appear on our Websites or on other sites that
you visit. The anonymous information is collected through the use of a pixel tag or cookies, which are
industry standard technologies used by most major websites. If you do not want such companies to collect
information you may opt-out.
To learn more about the use of this information or choose not to have this information used by certain third-party
advertising partners, please visit the Network Advertising Initiative at
. Please note
that if you delete your cookies, use a different browser,
or buy a new computer, you will need to renew your opt-out choice.
Web Beacons: The Websites may contain electronic images (called a "single-pixel GIF" or a "web
beacon") that allow
a website to track the effectiveness of marketing campaigns. No personally identifiable information will be
transmitted via web beacons.
Telephone Recording and Monitoring: To ensure CTRwow customers receive quality
service, CTRwow selects phone calls
for recording and/or monitoring. These calls, between CTRwow customers (or potential customers)
and employees, are
evaluated by supervisors or other CTRwow representatives. This is to guarantee that prompt,
and accurate information is delivered in a professional manner. In contacting CTRwow, creating an
CTRwow, or by otherwise utilizing any VERVE products or services, you hereby consent to any such
call recording or
We receive and store any personal information you enter on our Websites or give to us
voluntarily in any
other way and may use it to contact you from time to time. By registering on a Website and providing your
telephone number, you agree that this action constitutes an established business relationship, purchase,
inquiry or application for purposes of telemarketing laws. Regardless of the fact that your telephone and/or cell
number may be listed with the Federal Do-Not-Call Registry or your local State Do-Not-Call List, you are
providing your express written consent to receive future information (including telemarketing) about products and
services from us or our affiliates, and you hereby agree and consent to our contacting you using the
information you have provided and will provide to us. This means that within the time limits allowed by law, we
may contact you by e-mail, phone or cell number (including use of automated dialing equipment and/or
pre-recorded calls), text (SMS) message, social networks or any other means of communication that your
wireless or other telecommunications device may be capable of receiving (i.e. video, etc.). You further
acknowledge that you are not required to agree directly or indirectly or enter into an agreement regarding our
telemarketing efforts as a condition of purchasing any goods or services from us or our affiliates. If you do not
want to receive marketing calls, please let us know via phone call. You can also opt out by sending email to our
Customer Support at email@example.com
certain cases, separate consent is not required, including:
- For the performance of our contractual obligations to you;
- To meet legal obligations or compliance with laws, regulations, court orders, or other legal obligations or
assist in an investigation; or
- For legitimate interests or to operate our business and provide the services or products, other than in
performing our contractual obligations to you for VERVE’s "legitimate interests" for the purposes of
applicable law - except where overridden by the interests or fundamental rights and freedoms that
require protection of personal data.
Electronic Mail: To the extent allowed by law, from time to time, CTRwow may use
your personal information to contact you by electronic mail concerning our services or products. These
communications are often
intended to inform you of important information regarding your account, or about general services or products
provided by CTRwow or its affiliates. If you do not want to receive email from us or our
affiliates regarding new services or products, please click the "unsubscribe" link which is included at the bottom
of any email you receive
from us. However, in order to fulfill our service obligations to you, we will continue to send you emails
regarding your account administration, as well as any necessary information, such as renewal notices and
instructions. By providing us with your email address you consent to receiving communications from us
electronically and all notices, disclosures and other communications that we provide to you electronically satisfy
any legal requirement that such communications be in writing.
Email marketing (if applicable and when legally allowed): With your permission and provided it is
legal in your
jurisdiction, we may, within time limits allowed by law, send you emails about our new products and
services, and other updates. By “permission” we mean express and provable permission granted by you. A
permission to send commercial or marketing emails may be through any of the following instances which we deem as
existing business relationship with or inquiry from you:
- Entering your email address on our Websites with no indication that you would not like to be emailed.
- Entering your email address as part of attempting to order or ordering a product or service from us with no
indication that you would not like to be emailed.
- Entering your email address as part of an abandoned cart with no indication that you would not like to be
- Entering your email address as part of participation in any contest, event or survey conducted by us and we
have informed you that we will be sending you marketing emails.
- Subscribing to an email newsletter by filling-out a form on our Website.
- Any instance where in completing a form, you have checked an opt-in checkbox indicating your willingness to
be contacted through email provided the checkbox is unchecked by default and we have informed you that the
nature of the emails will be commercial.
All marketing emails shall conspicuously contain a notice that at no cost to you, you can opt out of
receiving more marketing emails from us. All marketing emails shall prominently display a one-click
unsubscribe or opt-out option. Once you have opted out or unsubscribed, we shall immediately refrain from sending
marketing emails to you.
We may use your personal information, including but not limited to your name, address, telephone, email
address and other relevant data, to conduct our business, improve our Websites, develop new products and
servictes, provide information and support, to better understand your needs and interests, personalize
communications and advertising, meet contractual obligations, and generally promote a quality experience for you.
For example, we may use your personal information, including your email address, to:
- Communicate, interact and build our relationship with you;
- Customize the content, products and services that are offered to you;
- Contact you with information about us and affiliated third parties;
- Process, fulfill and follow up on transactions and requests for products, services, support, and
- Verify your authority to enter and use our services;
- Engage in market research and analysis;
- Measure, analyze and improve our products and services, the effectiveness of our websites, and our
advertising and marketing;
- Comply with legal requirements;
- Provide targeting advertising, including the use of re-targeting technology;
- Send you marketing materials, for example, via email, including our newsletter, and to notify you about
and services that we believe would be of interest to you;
- Deter, detect, and prevent fraud and other prohibited or illegal activities; or
- Inform you regarding new services, releases, upcoming events and changes in our terms and conditions or
You may manage your receipt of marketing and non-transactional emails by clicking on the “unsubscribe”
located on the bottom of our marketing and non-transactional emails. If at any point you choose not to
emails or newsletters, you can also opt-out or unsubscribe by emailing our Customer Support at
firstname.lastname@example.org or by following the opt-out instructions in the email or newsletter.
The request to opt-out from the mailing list shall be honored immediately. You may not be able to opt out of all
information sharing, however, such as information sharing with credit card processors in connection with
products or services that you order from us. While we offer you some control over marketing communication, certain
transactional, relationship, and legally required communications will not be affected by the choices you have made
about marketing communications.
WHOIS Information: For any domain name registrars owned or operated by CTRwow,
ICANN requires us to make certain
information, collected in connection with the registration of a domain name, available to the public via an
interactive web page and a "port 43" WHOIS service. This public information includes your full name, mailing
address, phone number, email address, and, where provided, your fax number, as well as the creation and expiration
dates of your domain name registration and the name server information associated with your domain name, but does
refer to this information collectively as your "WHOIS Information." Please note that we do not control how members
of the public may use the WHOIS Information.
From time to time we may share personally identifiable information with third
parties in order to
have them send you special offers and promotions or other information we think you might find of interest. We
ourselves will also occasionally send youinformation on products, services, special deals, promotions, or
information which we have found that may be of interest to our users and subscribers. If you do not want us to use
the information you provide in order to inform you of products and services we think might interest you, or
provide your information to third party companies, you can opt-out or let us know by contacting our Customer
Support at email@example.com
Agents and Service Providers: We engage other companies, individuals, and affiliates of
CTRwow to perform certain
functions or services to our customers. Examples may include processing credit card payments,
providing marketing assistance and removing repetitive information from customer lists, as well as offering
electronic mail services and making available digital certificates. Additionally, if you register a domain name
through a registrar owned or operated by CTRwow, we may forward certain information you provide
appropriate registry handling the administration of your chosen domain name. Your contact and financial i
nformation may either be collected by or shared with such third parties as necessary, and in some cases, your
information may be retained or used by such third parties.
We may contract with service providers to provide us with data collection and reporting services. When you visit
our Websites, those service providers may collect information on our behalf about you in order to provide us with
aggregated data about our customers to assist us in conducting our business and delivering the more
relevant products and services to our customers. If you would like to opt-out of the gathering of such i
nformation, you can disable your cookies that assist in the gathering of that data, but please note that certain
services and functions of our Websites may not function correctly without cookies.
Service Related Uses: We may use your personal information to contact you about the goods or
services you have
purchased from us, or for other purposes in which you have expressed an interest, for example, if you have
contacted customer service or made an inquiry. We will also provide you with service and account related
announcements. For instance, if the delivery of a service or product is delayed, we might send you an email, or
other message, or if there is some service issue with something you might have ordered. Generally, you may not
opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have
the option to cancel your services with us.
Partner Websites and Pages: CTRwow sometimes enters into agreements in which we jointly develop
operate websites with third parties (each a "Partner Site"). Any information collected via a Partner Site, with
your consent, may be jointly owned by CTRwow and the applicable third-party partner, or,
parties before submitting any personal information to a Partner Site.
Business Transfers: If CTRwow is acquired or merged with another company, we may
information with our prospective or actual purchasers, investors, or successor entities in connection with a
contemplated reorganization or an actual reorganization of our business, in connection with financing,
investment, support or funding, a sale, or other transaction involving the disposal of all or part of our business
or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a
transaction, pursuant to assurances of sufficient data handling practices and safeguards.
- Residents of the European Economic Area: Our disclosure is limited to situations where we are permitted to
under applicable European and national data protection laws and regulations.
Protection of VERVE and Others: We may release account and other personal information when we are
required to do so by law, court order, subpoena or other government or law enforcement authority or
regulatory agency, including ICANN, in order to enforce or apply our Services Agreement or other agreements, or
when we believe in good faith that disclosing this information is necessary or advisable, including for
example, to protect the rights, property, or safety of CTRwow, our users, or others. This
information with other companies and organizations for fraud protection, credit risk reduction or other similar
CTRwow has no control over and is not responsible for the privacy policies or information
gathering practices of
other websites, including those to which we may link and those which may link to us. We provide these links merely
for your convenience and we have no control over, do not review, and are not responsible for their
content, or any goods or services available through said links. We strongly recommend that you review the
privacy policies of every online service you use before submitting any personal information and direct any
concerns to the site administrator of that website.
CTRwow ASSUMES NO RESPONSIBILITY OR LIABILITY WITH REGARD TO ANY THEFT, LOSS, ALTERATION OR
MISUSE OF PERSONAL OR
OTHER INFORMATION LAWFULLY PROVIDED BY CTRwow TO THIRD PARTIES, OR WITH REGARD TO THE FAILURE OF
ANY THIRD PARTY
The Websites comply with the EU-U.S. Privacy Shield Framework
the Swiss-U.S. Privacy Shield Framework
regarding the collection, use, and retention of personal
information from European Union member
countries and Switzerland. VERVE has certified that in conjunction with those Websites it adheres to the privacy
shield's principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To
learn more, please visit https://www.privacyshield.gov/welcome
We have further committed to participate in the dispute resolution procedures of the
panel established by the EU
data protection authorities (DPAs) to resolve disputes pursuant to the Safe Harbor Privacy Principles, as well as
to cooperate and comply with the Federal Data Protection and Information Commissioner (FDPIC) of
Switzerland. If your inquiry has not been satisfactorily addressed and you are located in the EU, you may contact
the EU DPAs panel firstname.lastname@example.org or individual EU DPAs directly using the information provided at
. If your inquiry
has not been satisfactorily addressed and
you are in
Switzerland, you may contact the Swiss FDPIC using the information provided at
You may opt-out of marketing communications from us by contacting Customer Support at email@example.com
out from the opt-out link in any marketing email we send to you.
We work to protect the security of your financial information during transmission by using Secure Sockets Layer
("SSL") software, which
encrypts the information you input on the Website. Keep in mind however, that no method of transmission over the
Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially
acceptable means to protect your personal information, we cannot guarantee its absolute security. You can
further help to ensure your security by taking a few simple precautions. For instance, it is important to protect
against unauthorized access to your computer and to any CTRwow username and password, and to be
sure to sign off
when you are finished using a shared computer.
CTRwow gives you the ability to access the information you have provided for the limited purpose
of viewing and,
in certain cases, updating that information. To view or change this information, CTRwow customers may contact
Customer Support or log in to your online account manager, if applicable. We may retain your
information in our files after you terminate all your services with us to resolve disputes, enforce our relevant
Service Agreement, and to adhere to the technical and legal requirements and constraints related to the
security, integrity and operation of the Websites. Past customers may request this information by emailing or
calling Customer Support. Please note, however, that no financial information will be provided over the phone, and
in no event will such information be provided without verification.
You must be at least eighteen (18) years old or the age of majority in your state or province of residence to
register online or purchase our goods or services. CTRwow does not knowingly collect information
children or minors.
By choosing to visit the Websites or utilize any CTRwow services, you agree that any dispute you
laws of Hong Kong,
without regard to conflict of laws principles, as if the Agreement was a contract wholly entered into and wholly
performed within Hong Kong. You further agree that any judicial proceeding relating to or arising out of this
state court of
competent jurisdiction in Hong Kong. You consent to the personal jurisdiction of such court and waive the right to
challenge the jurisdiction of such court on grounds of lack of personal jurisdiction or forum non
conveniens, or to otherwise seek a change of venue. Please note that if you enter into other agreements with
privacy at CTRwow, please contact Customer Support, and we will attempt to resolve it.
Processing Requirements: In the course of providing our services to you, CTRwow
personal data on your
behalf where such personal data is subject to applicable privacy laws. To this end, CTRwow
represents and warrants
that it shall process such personal data only as may be required and necessary to provide the
services and as may subsequently be agreed between the Parties in writing. CTRwow shall maintain
appropriate processes and technical measures that will ensure that reasonable and lawful instructions can be
complied with upon your written request, including the following: updating, amending or correcting the
personal data of any individual, cancelling or blocking access to any personal data and providing a written record
of the processing of personal data. CTRwow shall, promptly following receipt of written notice,
data from its records and, upon completion of the services, comply with all reasonable instructions with respect
to the deletion of any remaining personal data. CTRwow shall comply with all applicable privacy
laws to the extent
applicable to the provision of the services.
CTRwow shall co-operate and comply with the directions or decisions of relevant privacy
authorities, in each case
(a) solely to the extent applicable to CTRwow’s provision of the services, and (b) within such
reasonable time as
would enable it to meet any time limit imposed by the privacy authority. CTRwow shall ensure the
reliability of any employee who has access to your personal data and that such personnel is under an
appropriate obligation of confidentiality (whether a contractual or statutory duty). CTRwow will
remain liable for
any disclosure of personal data by each such employee as if it had made such disclosure itself.
appoint a data protection officer in compliance with Regulation (EU) 2016/679.
Legitimate Interests: In most cases, CTRwow will ask for your consent to process
however, notwithstanding anything to the contrary herein, you acknowledge that CTRwow will have a
right to use and
disclose data relating to the operation, support or use of the services for its legitimate business p
urposes, such as, but not limited to, billing, account management, technical support, product development and
sales and marketing in accordance with applicable privacy law.
Breach Notification: Unless otherwise prohibited by applicable law, CTRwow shall
notify you, as
soon as is
reasonably possible but in any event no later than within seventy-two (72) hours after becoming aware, of any
security breach of personal data. Such notification shall include detailed description, likely consequences,
proposed measures and contact details of CTRwow’s Data Protection Officer and any other
information you may
reasonably request relating to the security breach. CTRwow shall take prompt action to
security breach and shall use industry standard, commercially reasonable, efforts to mitigate the effects and to
carry out any action necessary to remedy the security breach. Unless required to do so under applicable privacy
law, CTRwow shall not release or publish any filing, communication, notice, press release, or
any security breach.
Privacy Impact Assessment: CTRwow shall, promptly upon receipt of your written
request, at your
available to you such information as is reasonably necessary to demonstrate CTRwow’s compliance
applicable privacy law. CTRwow shall reasonably cooperate with a partner to implement such
actions as are reasonably required to address privacy risks identified. However, unless pursuant to a security
breach, or is otherwise required by applicable privacy law, you shall not make any such request more than once in
any 24-month period.
Third-Party Disclosure Requests: Unless prohibited by applicable law, CTRwow
shall, inform you
promptly of any
inquiry or complaint from any governmental, regulatory or supervisory authority and shall provide all
reasonable assistance, to enable you to respond and to meet applicable statutory or regulatory deadlines.
shall ensure that any sub-processor shall, not disclose personal data unless it is legally required to do so and
has otherwise complied with the obligations in this Addendum. Unless prohibited by applicable law, in the event
that CTRwow or any sub-processor is required by law to disclose any personal data,
CTRwow shall and shall ensure
that any sub-processor shall, notify you promptly and shall provide all reasonable assistance to you, at your
cost, to enable you to respond to any such demands and to meet applicable statutory or regulatory deadlines.
CTRwow shall ensure that any sub-processor shall not disclose personal data pursuant to a legal
request unless it is required to do so and has otherwise complied with the obligations in this Addendum.
Transfers of Personal Data Outside of the European Economic Area: Where personal data originating
in the European
Economic Area is processed by CTRwow outside the European Economic Area, in a territory that has
designated by the European Commission as ensuring an adequate level of protection pursuant to
applicable privacy law, we agree that the transfer shall be undertaken pursuant to CTRwow’s
certification, which CTRwow shall maintain in full force and effect during the term of the
Deletion of Data: Following expiration or termination of the parties agreement,
delete, or return to
you upon request, all personal data in its possession as provided in the Agreement except to the extent
required by applicable privacy law to retain some or all of the personal data (in which case
CTRwow will archive
the data and implement reasonable measures to prevent the personal data from any further
processing). The terms of this Addendum will continue to apply to such personal data.
Order of Precedence: In the event of inconsistencies between the provisions of this Addendum and
privacy-related provisions herein or any other agreements between the Parties, the provisions of this
Addendum shall prevail.
Due to the constantly changing nature of our business, we reserve the right to change, update or modify this
update or modification will be effective immediately upon posting on our Website. You are responsible for checking
our Websites frequently to keep apprised of recent changes. Continued use of our Websites or utilizing our
by its terms.
We have a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This
Data Protection Officer can be reached at the following address: firstname.lastname@example.org