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# Afternic Privacy Policy

Updated March 15, 2018

Your privacy is very important to Afternic. As part of the normal operation of our business services, we collect and, in some cases, disclose information about you. This Privacy Policy ("Policy") outlines the information that we collect about you and what may happen to that information. It also describes your choices regarding use, access and correction of your personal information. This Policy applies to www.afternic.com (hereafter, our "Site")owned and operated by Go Daddy Operating Company LLC.

As described below, some of your personally identifiable information is disclosed to third parties and used by us and third parties. By accepting the Membership Agreement, you expressly consent to our use and disclosure of your personally identifiable information. This Policy is incorporated into and subject to the terms of the AFTERNIC Membership Agreement.

EU-U.S. & Swiss-U.S. Privacy Shield

Our parent company, Go Daddy Operating Company, LLC (and our related entities, including GoDaddy.com, LLC, Wild West Domains, LLC, Blue Razor Domains, LLC, Starfield Technologies, LLC, Domains by Proxy, LLC, Outright, Inc., Locu, Inc., Media Temple, Inc. and Mad Mimi, Inc.) participates in and has certified its compliance with the EU-U.S. and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certifications, visit the U.S. Department of Commerce’s Privacy Shield List.

Go Daddy Operating Company, LLC is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

Afternic is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Afternic complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Afternic is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Afternic may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

1. Information we collect.
If you are merely visiting our Site, we collect and store only the following information about you:

- The IP address of the terminal from which you access the Internet
- The IP address of the website from which you linked directly to our Site
- The date and time you access our Site
- The browser you used to access our Site
- The operating system you used to access our Site

We store the aforementioned information in log files. We use this information to measure the number of visitors to the different sections of our Site, and to help us make our Site more useful to visitors.

We will not obtain any other personally identifying information about you when you visit our Site, unless you choose to provide such information to us.

As a Standard Member, Buyer Member or AfternicDLS Member, we collect and store additional information about you. To fully use our services, you will need to register using our online form. You will be required to provide us with your contact information and other personal information such as User ID, email address, and billing address. In addition, as a Buyer Member or AfternicDLS Member, you will be required to provide your credit card number and its expiration date. We use this credit card information to verify your name, address, and other personally identifying information as well as to process your transactions.

We use Google Analytics, a third-party tracking service, which uses cookies to track non-personally identifiable information about our visitors to our Site in the aggregate to capture usage and volume statistics. Some of our business partners (e.g., Google Analytics) use cookies on our Site.

They are used on certain pages of our Site. We offer certain features that are only available through the use of a cookie. Cookies are stored on your hard drive, not on our Site. If your browser permits, you are always free to decline our cookies, but you may not be able to use certain site features and will have to enter your personally identifying information manually more often. If you choose to buy, bid, sell, or appraise on our site, we collect information about these behaviors.

When you successfully buy or sell a domain name, we collect some additional information including name servers, administrative contacts, business identification, special registrar requirements, billing address, bank account number, and tracking information from checks and money orders. Bank account information is deleted when your transaction closes.

In addition to cookies, we and our partners use similar technologies to analyze trends, administer the website, tracking users’ movements around our Site, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include:

- Address information about you from third party sources, such as the U.S. Postal Service, to verify your address so we can properly ship your order to you and to prevent fraud.
- Purchased marketing data about our customers from third parties that is combined with information we already have about you, to create more tailored advertising and products.

2. How we use your information.
We use the information we collect from you to transmit administrative notices, buy/sell information and support, billing information, to send you specific information that you have requested, to process your credit card purchases, and to complete the paperwork necessary to transfer a domain name registration. We may also use it to send you information that is targeted to your interests, such as upcoming auctions and promotions. By accepting the Membership Agreement, receiving our newsletter is required as part of the service that we offer. If you wish to no longer receive our newsletters and promotional communications, you may opt-out of receiving them by either deactivating your account, by following the instructions included in each newsletter or communication, or by emailing us at privacy@afternic.com. We will respond within a reasonable timeframe. We offer an opportunity to opt-out of certain communications through an opt-out link provided through our marketing emails, or you may contact us at (781) 839-2800, or Afternic, Attn: Customer Service, 1 Main Street, Cambridge, MA 02142 to opt-out.

Additionally, on appropriate portions of our Site, we may display or archive your user name and system- and user-generated feedback, including the comments you submit and that others submit about you.

If you send us personal correspondence, such as emails or letters, or if third parties such as other users send us correspondence about your activities or postings on our Site, we may collect such information into a file with information specific to you. We use this information to support your customer inquiries, settle disputes, enforce our Membership Agreement, maintain our customer ranking system, troubleshoot problems, and to identify you as eligible for special user campaigns. On rare occasions, we may look across multiple users to identify problems, resolve disputes, and evaluate you for multiple usernames.

In general, we do not sell or rent any personally identifiable information about you to any third party. If you choose to use the optional services available on our Site, we will, by necessity, provide some of your personally identifiable information to these service providers. However, you can avoid these disclosures by choosing to not use these services. Because we do not control the privacy practices of these third parties, you should evaluate their practices before deciding to use their services.

To enhance the effectiveness of our exchange, Afternic has formed strategic partnerships with select organizations, mostly registrars. Upon request by such Partners, we disclose some of your personally identifiable information to the Partners for the Partners'' marketing purposes. To each Partner, we only disclose information for the members that were referred to Afternic from the Partner''s website. (Members can determine the Partner that referred them to Afternic by clicking "My Account" on our home page.) All Partners have agreed to post a privacy agreement on their own websites and protect your information accordingly. If you do not want us to share your personal information with these companies, contact us at privacy@afternic.com.

We may provide your personal information to companies that provide services to help us with our business activities such as shipping your order or offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.

Unfortunately, due to the existing regulatory environment, we cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Policy. As an example, without limiting the foregoing, Afternic will provide personal data records if required by the order of any court of competent jurisdiction. We may disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal and may expose us to legal liability. Therefore, although we use industry standard practices to protect your privacy, we cannot guarantee, and you should not expect, that your personally identifiable information or private communications will remain private.

We may also disclose your personal information

- as required by law, such as to comply with a subpoena, or similar legal process
- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request,
- • if Afternic is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information,
- to any other third party with your prior consent to do so.

3. Special note about children.
We do not knowingly collect personally identifiable information from anyone under the age of 13. If it is discovered that we have collected PII from someone under 13, we will delete that information immediately.

4. Your use of other users' information.
In order to facilitate community, our service allows you to access other users' personal information, such as (but not limited to) user name and listed auctions. Further, as a successful buyer or seller, you will be sent the other data subject's name, address, email address, phone number, fax number, title, DNS information, and registrar identity information.

By entering into our User Agreement, you agree that, with respect to other user's personally identifiable information, you obtain through our Site or through an Afternic -related communication or Afternic -facilitated transaction, Afternic hereby grants you license to use such information only for:

- Afternic -related communications that are not unsolicited commercial messages, and
- Any use that such user expressly opts into after adequate disclosure of the purpose(s).

Additionally, under no circumstances, except those defined in this section, can you disclose personally identifiable information about another user to any third party without our consent and the consent of such other user after adequate disclosure. Note that law enforcement personnel and other rights holders are given different information access rights.

Afternic and its users will not tolerate any spam. Without limiting the foregoing, you are not licensed to add any Afternic user, even one with whom you have transacted, to your mail (email or physical) or phone list without their express consent after adequate disclosure.

5. Control of your password.
Except as specifically permitted by this section, you may not disclose your Afternic password to any third parties nor share it with any third parties. If you lose control of your password, you will lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password.

The Afternic staff will never ask you for your password. If you receive a request from anyone claiming to represent us, do not reveal this information.
Instead, please contact AFTERNIC.

6. Reviewing and changing your information.
Following registration, you can review and/or request access to the information you submitted via your personal AFTERNIC account and/or process on behalf of a third party, including your username and encoded credit card information, by contacting us at privacy@afternic.com. We will respond to these requests within a reasonable timeframe.

Additionally, you can use your Afternic account to review, delete and modify other fields, including first and last name, address information, email address, and password. If you choose to change your email address, we will cross-match your new address in our database for relationship to any other data set. We will only allow unique email addresses to be used for registration.

At your discretion, you may review and change all fields in your personal domain name profile records at any time except username and legal name. With your consent we may post your testimonial along with your name. If you want your testimonial removed please contact us at privacy@afternic.com. We will respond to your request in a reasonable timeframe.

7. Information security.
The security of your personal information is important to us. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at privacy@afternic.com.

We will retain your information for as long as your account is active or as needed to provide you services. Please contact us if you wish to cancel your account or request that we no longer use your information to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. Privacy protection.
The data required by Afternic to activate your membership is used solely for the account you maintain with us. All real data you provide to Afternic is kept strictly confidential and will not be sold or released. Your username on Afternic can be any name of your own choosing, and identifies you as Standard Member or AfternicDLS Member. Prospective counterparties will be able to view your member profile, post comments about you, and view the auctions you are involved in, but in no way will have access to your true identity or your email address.

Our Site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. You can request the removal of your personally identifiable information from our blog or community forum, by contacting us at privacy@afternic.com. In some cases, we may not be able to remove your personally identifiable information, in which case we will let you know if we are unable to do so and why.

9. Links to Other Sites
Our Site includes links to other web sites whose privacy practices may differ from those of Afternic. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any web site you visit.

10. "Do Not Track" Signals
Note that your browser settings may allow you to automatically transmit a "Do Not Track" signal to websites and online services you visit. There is no consensus among industry participants as to what "Do Not Track" means in this context. Like many websites and online services, we currently do not alter our practices when we receive a "Do Not Track" signal from a visitor's browser. To find out more about "Do Not Track," you may wish to visit (www.allaboutdnt.com).

11. Notification of Privacy Policy Changes
We may update this Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

12. Contacting the Site
If you have any questions about this Policy or privacy practices on the Site, please contact us at the information listed below:

AFTERNIC.com
Attn: Customer Service
1 Main Street
Cambridge, MA 02142
Phone: 781-839-7990
Fax: +1 480-393-4544
Email: privacy@afternic.com

By submitting this form and clicking Get Price, you agree to our Privacy Policy.

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