Privacy Policy

This Privacy Policy applies to VERVE DIRECT LIMITED (along with all subsidiaries, affiliates, successors and assigns thereof, referred to hereinafter collectively as “VERVE”, "we", "our" and/or "us"), our websites, products and services. VERVE 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 VERVE website displaying this Privacy Policy or a link thereto (a "Website", or collectively the “Websites”), or by otherwise interacting with VERVE, you agree to accept the practices described in this Privacy Policy. This Privacy Policy is further subject to the Master Services Agreement and other agreements related to the VERVE services or products you utilize or purchase.

VERVE values your privacy and is dedicated to protecting your personal 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.


What Information Is Collected

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 VERVE, we are required by the Internet 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 products and services. For example, when you apply to register a domain name or sign up for any other product or service through VERVE, we require you to provide a credit card number and billing address before we will process that application. We will not sell, share or rent any financial information collected from you except as disclosed in this Privacy Policy or as necessary to fulfill any order for our products or services.

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 parties.

Other Information: We collect and store certain types of information whenever you interact with us. For 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 across the 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 this 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 http://www.networkadvertising.org/choices. 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 VERVE customers receive quality service, VERVE selects phone calls for recording and/or monitoring. These calls, between VERVE customers (or potential customers) and employees, are evaluated by supervisors or other VERVE representatives. This is to guarantee that prompt, consistent assistance and accurate information is delivered in a professional manner. In contacting VERVE, creating an account with VERVE, or by otherwise utilizing any VERVE products or services, you hereby consent to any such call recording or monitoring.


How Personal Information Is Used

Our Use: 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 info@dfo.global.

We collect and process your personal information for a variety of purposes outlined in this Privacy Policy. In certain cases, separate consent is not required, including:

1. For the performance of our contractual obligations to you;
2. To meet legal obligations or compliance with laws, regulations, court orders, or other legal obligations or to assist in an investigation; or
3. 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, VERVE 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 VERVE 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 emailed.
• 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 services, 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 information;
• 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 products 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 privacy policy.

You may manage your receipt of marketing and non-transactional emails by clicking on the “unsubscribe” link located on the bottom of our marketing and non-transactional emails. If at any point you choose not to receive our emails or newsletters, you can also opt-out or unsubscribe by emailing our Customer Support at info@dfo.global 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 VERVE, 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 not include demographic, financial or Internet usage information. For the purposes of this Privacy Policy we will 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.

Third Parties: 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 you information 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 info@dfo.global.

Agents and Service Providers: We engage other companies, individuals, and affiliates of VERVE 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 VERVE, we may forward certain information you provide to the appropriate registry handling the administration of your chosen domain name. Your contact and financial information 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 information, 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: VERVE sometimes enters into agreements in which we jointly develop or operate websites with third parties (each a "Partner Site"). Any information collected via a Partner Site, with your consent, may be jointly owned by VERVE and the applicable third-party partner, or, alternatively, owned solely by us or the third-party partner. It is your responsibility to check the privacy policy of such third parties before submitting any personal information to a Partner Site.

Business Transfers: If VERVE is acquired or merged with another company, we may disclose your 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 do so 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 VERVE, our users, or others. This includes exchanging information with other companies and organizations for fraud protection, credit risk reduction or other similar purposes.


Sites Other Than VERVE

VERVE 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.


Limitation of Liability

VERVE ASSUMES NO RESPONSIBILITY OR LIABILITY WITH REGARD TO ANY THEFT, LOSS, ALTERATION OR MISUSE OF PERSONAL OR OTHER INFORMATION LAWFULLY PROVIDED BY VERVE TO THIRD PARTIES, OR WITH REGARD TO THE FAILURE OF ANY THIRD PARTY TO ABIDE BY THIS PRIVACY POLICY OR SUCH THIRD PARTY'S PRIVACY POLICY OR ANY AGREEMENT BETWEEN THAT THIRD PARTY AND VERVE.


Privacy Shield Framework

The Websites comply with the EU-U.S. Privacy Shield Framework and 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 ec-dppanel-secr@ec.europa.eu or individual EU DPAs directly using the information provided at https://ec.europa.eu/commission/index_en. If your inquiry has not been satisfactorily addressed and you are in Switzerland, you may contact the Swiss FDPIC using the information provided at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/task.html.


Choice and Opt-Out

You may opt-out of marketing communications from us by contacting Customer Support at info@dfo.global or opting out from the opt-out link in any marketing email we send to you.


Procedures Used to Protect Personal Information

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 VERVE username and password, and to be sure to sign off when you are finished using a shared computer.


Access to Personal Information

VERVE 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, VERVE 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.


Age of Consent

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. VERVE does not knowingly collect information from children or minors.

Disputes

By choosing to visit the Websites or utilize any VERVE services, you agree that any dispute you may have regarding this Privacy Policy, the use of your information by VERVE shall be governed by the 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 Privacy Policy or the use of your information by VERVE shall be instituted only in a federal or 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 VERVE, such other agreements may supersede this Privacy Policy. If you have any concerns about your privacy at VERVE, please contact Customer Support, and we will attempt to resolve it.


Data Processing Addendum

Processing Requirements: In the course of providing our services to you, VERVE may process personal data on your behalf where such personal data is subject to applicable privacy laws. To this end, VERVE 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. VERVE shall maintain reasonable and 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. VERVE shall, promptly following receipt of written notice, delete personal 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. VERVE shall comply with all applicable privacy laws to the extent applicable to the provision of the services.

VERVE shall co-operate and comply with the directions or decisions of relevant privacy authorities, in each case (a) solely to the extent applicable to VERVE’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. VERVE 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). VERVE will remain liable for any disclosure of personal data by each such employee as if it had made such disclosure itself. VERVE shall appoint a data protection officer in compliance with Regulation (EU) 2016/679.

Legitimate Interests: In most cases, VERVE will ask for your consent to process your personal data, however, notwithstanding anything to the contrary herein, you acknowledge that VERVE will have a right to use and disclose data relating to the operation, support or use of the services for its legitimate business purposes, 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, VERVE 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 VERVE’s Data Protection Officer and any other information you may reasonably request relating to the security breach. VERVE shall take prompt action to investigate the 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, VERVE shall not release or publish any filing, communication, notice, press release, or report concerning any security breach.

Privacy Impact Assessment: VERVE shall, promptly upon receipt of your written request, at your cost, make available to you such information as is reasonably necessary to demonstrate VERVE’s compliance with applicable privacy law. VERVE shall reasonably cooperate with a partner to implement such mitigation 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, VERVE 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. VERVE 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 VERVE or any sub-processor is required by law to disclose any personal data, VERVE 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. VERVE 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 VERVE outside the European Economic Area, in a territory that has not been 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 VERVE’s Privacy Shield certification, which VERVE shall maintain in full force and effect during the term of the parties agreement.

Deletion of Data: Following expiration or termination of the parties agreement, VERVE will delete, or return to you upon request, all personal data in its possession as provided in the Agreement except to the extent VERVE is required by applicable privacy law to retain some or all of the personal data (in which case VERVE 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 any privacy-related provisions herein or any other agreements between the Parties, the provisions of this Addendum shall prevail.


Effective Date

Due to the constantly changing nature of our business, we reserve the right to change, update or modify this Privacy Policy at any time at our sole discretion, and will post any new Privacy Policy here. Any such change, 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 services or products after the Effective Date implies acceptance of the revised Privacy Policy and will be bound by its terms.


How to Contact Us

For questions about this Privacy Policy please contact Customer Support.

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: info@dfo.global.