1. INTRODUCTION

VWH group entity, the details of which are indicated in the VWH’s Terms of Service, ("VWH") provides you web-hosting, domain name registration, and related products and service.

VWH seeks to ensure the highest level of data privacy when offering its variety of quality products and services to VWH customers and subscribers ("Subscribers") (collectively, “You”, or "Users").

At VWH, the privacy and security of our Users is of paramount importance. VWH is committed to protecting the data you share with us.

When this Policy mentions "VWH", "we," "us", or "our", it refers to VWH that is responsible for protection of your personal information in line with this Privacy Policy ("Data Controller").

This Privacy Policy ("Policy") explains how VWH processes information that can be used to directly or indirectly identify an individual ("Personal Data") collected on our Site, our services (“Service”), forums and our mobile applications ("Platform").

All personal data are processed in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

For any questions regarding this Policy or any requests regarding the processing of personal data, please contact us at gdpr@VWH.com.

2. GENERAL PRINCIPLES. CONFIDENTIALITY

VWH shall process all Personal Data adhering to the general data processing principles:

  • lawfully, fairly and in a transparent manner in relation to the data subject (lawfulness, fairness, and transparency);
  • collect and process Personal Data only for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (purpose limitation);
  • ensure that Personal Data is adequate, relevant and limited to what is necessary for relation to the purposes for which they are processed (data minimization);
  • ensure that Personal Data is accurate and, where necessary, kept up to date (accuracy);
  • ensure that Personal Data is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (storage limitation);
  • process Personal Data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (integrity and confidentiality).

All and any information stored on VWH's Platform is treated as strictly confidential. All information is stored securely and is accessed by qualified and authorized personnel only.

3. INFORMATION WE COLLECT

3.1. Information You provide to us.

Information that is necessary for the use of the VWH Platform

We ask for and collect the following personal information about you when you use the VWH Platform. This information is necessary for the adequate performance of the contractual arrangement which is in place between you and us and to allow us to comply with our legal obligations. Failing to provide any of this data or decision to delete or object to the processing of any of such data may result in de-activation of your VWH Account.

  • Account Signup Information. When you sign up to VWH, we require you to provide minimum information - email address and password. In some particular cases we ask you to provide more information - such as your first and last name, identity verification, contact details. Such information is required when you are applying for a registration of domain name and indicated as the WHOIS information.
  • Login information. We collect Login scope and Email scope from Google, please see https://developers.google.com/identity/protocols/oauth2/scopes?hl=en and email from Facebook.
  • Identity Verification. To comply with the rules set forth by the Internet Corporation for Assigned Names and Numbers ("ICANN") before the registration of the new domain name, VWH may collect identity verification information (such as images of your passport, national ID card, valid driving license or other documents as required or permitted by applicable laws).
  • Payment Information. To order and use features of the VWH Platform (such as web-hosting, domain name registration), we may require you to provide certain financial information in order to facilitate the processing of payments. We use 3rd party (payment processor) services, so we do not collect and store credit card information (we receive information about the payment status and store only last 4 credit card digits).
  • Communications, Chats, Messaging. When you communicate with VWH (using general inquiries window), we collect information about your communication and any information you choose to provide or disclose. In order to respond to your request, we may access information provided in your VWH Account, purchase history, etc.
  • Job applicants' information. We also collect information that you provided to us by applying to any of the open career positions published at https://www.VWH.com/career, by e-mail or otherwise. For more details see Section 5 below.
  • Visitors and users of our User’s websites or services. We may also collect information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf.

You may also choose to provide us information when you fill in a form, conduct a search, update or add information to your VWH Account, respond to surveys, post to community forums, participate in promotions, or use other features of the VWH Platform. We advise against posting any information you don’t wish to make public on the VWH Platform. If you upload any content to your account or post it on your Website and provide it in any other way as part of the use of any Service, you do so at your own risk.

VWH processes information you provide to us on the legal basis of:

  • Your consent, expressed when voluntarily submitting and filling your Personal Data details in sign-up forms, by e-mail, request or inquiries window, etc.; and
  • Conclusion and performance of contractual arrangements and obligations between VWH and the User;
  • Pursuance of legitimate interests of VWH, as Data Controller and manager of VWH platform;
  • Compliance with a legal obligation to which VWH is subject, including, but not limited to, ICANN rules: https://www.icann.org/resources/pages/approved-with-specs-2013-09-17-en#whois.

Disclaimer

Please always take care and observe at least the following minimum requirements for the protection of your personal information:

  • please omit using your name, address, telephone number, e-mail, personal identification number, date of birth, bank Account number, card number, other special (sensitive) data, etc. in the subject of the request or file name;
  • please omit using your personal code, payment card number, and other financial information and details, health, family member details, or other specific (sensitive) data, in the texts of requests, e-mails or similar communication to us, and
  • please make sure that the remaining personal data is only indicated to the extent necessary for the purposes for which the letter, request or inquiry is sent.

Right to delete your data

You may at any time access and edit, update or delete your contact details by logging into your VWH's platform Account.

Please note that you will only be able to delete your email during de-activation of your VWH Account. To deactivate your Account, please send your request to gdpr@VWH.com, and you will be provided with further guidance.

3.2. Information We Collect when You use the Platform

When you use the VWH Platform or contact us directly by any communication channel, we may collect information, including personal information, about the services you use and how you use them.

This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the VWH Platform.

Automatic collection of data

  • Log data and Device information. We automatically collect log data and device information when you access and use the VWH Platform, even if you have not created an VWH Account or logged in. That information includes, among other things: Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and/or clickstream data.
  • Tracking technologies and Cookies. We use cookies, beacons, tags, scripts and other similar technologies, such as CI codes (click tracking), ISC (source tracking), and ITC (item tracking codes). We also automatically collect information about device's operating system, phone model, device ID and customer number. For more detail information on the use of these technologies, see our Cookies Policy.
  • Usage information. We use a tool called "Google Analytics" to collect information about your interactions with the VWH Platform (what pages you visit, such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the VWH Platform. In consequence, Google, Inc. plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this Site). For more information please visit Google.
  • Geo-location data. We collect information about your approximate location as determined by data such as your IP address to offer you an improved user experience and comply with applicable legal requirements, such as taxes, pricing, etc. Such data may be collected only when you access VWH platform using your device.

VWH processes this information on the legal basis of:

  • Your consent;
  • Conclusion and performance of contractual arrangements and obligations between VWH and the User;
  • Pursuance of legitimate interests of VWH, as Data Controller and manager of VWH platform.

4. HOW WE USE YOUR DATA?

We use, store, combine and process information, including personal information, about you to provide, understand, improve, and develop the VWH Platform, create and maintain a trusted and safer environment and comply with our legal obligations.

  • To Identify. Personal identification information is collected and processed for the purposes of User identification as well use of services and domain name registration. Additionally, this information may be used to provide Users with support, letting them know about upcoming updates or improvements, providing information regarding changes of any Terms of Use (including changes to this Policy) as well as other important information.
  • To Create and Maintain Trusted Environment. We verify or authenticate information or identifications provided by you (such as ID number, email or phone numbers). We also use collected information to detect and prevent fraud, spam, abuse, security incidents, and other illegal and harmful activities.
  • To Create Aggregated Statistical Data, to Carry out Market Research and Analysis necessary for running out our business, to improve our services we use aggregated and/or inferred non-personal information enabling us to evaluate our customers’ needs, sales and other trends of our activities.
  • To Stay Connected. We use information about data usage, devices, operating systems to diagnose problems with our servers, to administer our Platform, adopt decision when to retire SDK's/OS versions, to identify characteristics of major users so that we may optimize our applications and services and make your browsing and purchasing experience more enjoyable.
  • To Customize Marketing. To provide more customized offers to our Users, we may conduct data analysis based on information you provide to us, your interactions with the VWH Platform and its Users.
  • To Send Service and Billing Messages. VWH may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the communication channels available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your hosting plan; or notify you of material changes in our Services. Such kind of communication is essential, for this reason, no opt-out possibilities are given to avoid receiving such Service and Billing Messages unless you are no longer a VWH User (which can be done by deactivating your Account).
  • To Register Domain. In certain jurisdictions or pursuant to the rules of the ICANN or certain registries, domain name registration information has to be made available and accessible to the public through a "WHOIS" search. The WHOIS database is a publicly accessible database that lists the domain name registration information for a particular domain name, the name server(s) to which the domain name points, and the domain name's creation and expiration date. The domain name registration information you provide is stored by VWH and is made available to the public through WHOIS searches. VWH may deposit your domain name registration information with a third-party escrow provider to comply with ICANN requirements. At times, Users may receive solicitations that result from searches of the publicly available WHOIS database by other companies or individuals. Any such solicitations or e-mail communications do not come from VWH and VWH is not responsible for the use of WHOIS information by third parties. VWH acts only on the basis of ICANN rules and requirements. For more information see: https://www.icann.org/resources/pages/approved-with-specs-2013-09-17-en#whois.
  • To contact you. In order to notify you regarding your Account, to troubleshoot problems with your Account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, to send updates about our company, or as otherwise necessary to contact you to enforce our User Agreement, applicable national laws, and any agreement we may have with you. For these purposes, we may contact you via email, telephone, text messages, and portal.
  • To get feedback. We may contact you via email to invite you to review any services and/or products you received from us in order to collect your feedback and improve our services. We might use an external company, to collect your feedback which means that we will share your name, email address and reference number for this purpose.
  • To provide, operate and improve the Services.
  • To enhance data security and to prevent fraud.
  • To comply with applicable laws and regulations.

5. JOB APPLICATIONS

VWH welcomes all qualified Applicants to apply to any of the open positions published at https://www.VWH.com/career, by sending us their contact details and CV ("Applicants Information") via the relevant Position Application Form on our Website, or through any other means provided by us.

We understand that privacy and discreteness are crucial to our Applicants and are committed to keep Applicants Information private and use it solely for VWH's internal and group companies’ recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).

VWH may retain Applicants Information submitted to it for no longer than one year after the applied position has been filled or closed. We collect this information to re-consider Applicants for other positions and opportunities at VWH; we can use their Applicants Information as reference for future applications submitted by them; and if the Applicant is hired, for additional employment and business purposes related to his/her work at VWH.

If you previously submitted your Applicants Information to VWH, but now wish to access it, update it or have it deleted from our systems, please contact us at gdpr@VWH.com .

 

6. INFORMATION PERTAINING TO VISITORS AND USERS OF OUR USER’S WEBSITES OR SERVICES 

We may collect, store and process certain information pertaining to visitors and users of our User’s websites or services, solely on our Users’ behalf and at their direction. Each of our Users is able to collect and manage information, including personal data, via their website. Such information and personal data are then stored with VWH. For such purposes, within the meaning of the GDPR, VWH may in certain limited cases, as specified in the Terms of Service, be considered as a “data processor” of such information pertaining to visitors and users of their websites or services. The Users controlling and operating such User websites, shall be considered as the “data controllers” of such information, and shall be solely, completely and fully responsible and liable for complying with all laws and regulations that may apply to the collection and control thereof, including all privacy and data protection laws of all relevant jurisdictions.

User shall be solely, completely and fully responsible for the security, integrity and authorized usage of information related to visitors and users of their websites or services, and for obtaining consents, permissions and providing any fair processing notices required for the collection and usage of such information.

VWH has no direct relationship with the individual visitors and users of our User’s websites or services whose personal data it processes. If you are a customer of any of our Users, and would like to make any requests regarding your personal data, please contact such User(s) directly.

For more information about data processing arrangement between us and our Users, please see our Terms of Service. 

7. DIRECT MARKETING AND SERVICE EXPIRATION NOTICES/RENEWAL REMINDERS

When creating an Account at our Platform, subject to the available preferences, you are free to give consent and/or opt-out from receiving various offers and/or notices directly to your e-mail, phone (SMS and/or Whatsapp messages) or in your Account. We use provided contact details and your preferences for direct marketing (by sending various offers or newsletters) and/or Service expiration notices / renewal reminders.

This communication, depending on your preferences, may be personalized taking into account any other information which you have provided to us (e.g. location, social media profile information, purchase history etc.) or we have collected or generated from other sources as described below.

Please note that in case you subscribe to service expiration notices / renewal reminders via SMS/WhatsApp, it is our right, but not an obligation, to send such notices / reminders for each Service.

Right to object / revoke consent 

If a User wishes to change their preferences communication (revoke consent or object), they are free to exercise such option at any time they wish by (1) following the instructions to unsubscribe in the received email (usually, by clicking on a link for that purpose at the bottom of our e-mail) / text message; (2) visiting and adjusting User’s personal account settings (communication preferences).

You may also at any time refuse to receive information from us by sending an email to gdpr@VWH.com.

8. OTHER USES OF YOUR PERSONAL DATA

  • Developing Platform. We use data, including public feedback, to conduct research and development for the further development of our platform in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth.
  • Customer Support. We use data to help you and fix problems. We use the data (which can include your communications) to investigate, respond to and resolve complaints and issues (e.g., bugs).
  • Aggregate Insights. We use data to generate aggregate insights. We use your data to produce and share aggregated insights that do not identify you.
  • Security and Investigations. We use data for security, fraud prevention and investigations. We use your data (including your communications) if we think it's necessary for security purposes or to investigate possible fraud or other violations of our Terms of User or this Policy and/or attempts to harm our Users.

9. SOURCES OF PERSONAL DATA

We collect and receive your Personal data from yourself (including your device) as well as from the following sources:

  • Social network operators (such as Facebook, Google, etc.);
  • Third-party service providers, suppliers and our partners;
  • Other legal sources.

10. RETENTION AND DELETION

We generally retain your personal information for as long as is necessary to provide our services and to comply with our legal obligations. Where your personal information is no longer required we will ensure it is securely deleted.

If you would like to stop us using your personal information, you shall request that we erase your personal information and close your VWH Account.

After de-activation of Account, we will still retain the following data for the purposes of compliance with applicable legal requirements (such as tax, accounting, legal reporting, AML, other), for as long as we are legally required by virtue of such legal requirements:

  • profile with de-personalised information (we will change your email into user@deleted.com, erase you name, surname and contact information) like purchased services, login information, payment information, etc.

Please also note that we may further retain some of your personal information in such cases (i.e., after closure of your VWH Account):

  • as long as it is necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. If VWH suspends your VWH Account for safety reasons, we may retain certain information from that VWH Account to prevent that User from opening a new VWH Account in the future;
  • the extent necessary to comply with our legal obligations. VWH may keep some of your information for tax, legal reporting and auditing obligations;
  • forum posts or other publicly visible information may continue to be publicly available on the VWH Platform, even after your VWH Account is deactivated. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers;
  • to resolve disputes;
  • to enforce our agreements and/or pursue or protect our legitimate interests;
  • as we protect VWH Platform from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time;
  • domain name registration data - at the moment of writing this Policy, in order to register domain, we are requested to provide personal information about the owner of domain; this information is shown in WHOIS directory and is public. For more information, please visit https://www.icann.org/registrants.

11. DATA TRANSFERS AND USE OF THIRD-PARTY SERVICES

While collecting and processing your Personal Data, we may perform data transfers to various third parties.

11.1. With your consent

We will share your Personal Data with companies, organizations or individuals outside our group of companies when we have your consent to do so.

11.2. Where do we process your personal data?

  • Users' Personal Information may be maintained, processed and stored by VWH and our authorized affiliates and service providers in the United Kingdom, Netherlands, Lithuania or Cyprus, and in other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below).
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