WORLDWIDE DOMAIN SERVICES LTD  T/A NAMELYNX

PRIVACY & COOKIE POLICY

 

Last Updated : 14 December 2021

 

  • INTRODUCTION
    • The Company known as Worldwide Domain Services Ltd t/a Namelynx (company number 12361684) take privacy, and the security of personal data, very seriously, and We are committed to ensuring that We safeguard the privacy and personal data of Our Website visitors and those with whom We communicate through that Website, whether by email or electronically, at all times and in the best way possible.
    • This privacy policy contains important information for You. It explains:
  • Who We are;
  • Our Website;
  • What personal information We collect about You;
  • How, when and why We collect, store, use and share Your personal data;
  • How We keep Your personal data secure;
  • For how long We keep Your personal data;
  • Your rights in relation to Your personal data;
  • Issues relating to marketing; and
  • How to contact Us or the relevant supervisory authorities should You have a complaint.
    • This privacy policy aims to give You information on how We collect and process Your personal information through Your use of this Website, including data You may provide through this Website when You buy a product or service, take part in a competition or sign up to a newsletter. This privacy policy supplements other privacy notices and policies and is not intended to override them.
    • Children. Please note that Our Website is not intended for use by children under the age of 18 years of age, and We do not knowingly collect or use personal information relating to children
    • Worldwide Domain Services Ltd t/a Namelynx is a company registered in England and Wales and Our registered office is at 71-75 Shelton Street, London, Greater London, United Kingdom WC2H 9JQ.  We own and operate the Website You can find at www.namelynx.com (the “Website”).   Our principal contact for data protection purposes is Vicky Grobbelaar, who may be contacted at +44 (0)1908 738 750 or vicky@namelynx.com.
    • Controller.When We collect, use and process personal data We are subject to the provisions of the United Kingdom General Data Protection Regulation (UK GDPR), and the Data Protection Act 2018, and We are responsible as what is described as a ‘controller’ of that personal information for the purposes of those laws. In other words, We are primarily responsible for that data and are the ‘natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data’. We may also be subject to the EU GDPR legislation from time to time if You are a citizen and/or accessing these services within the EEA.
    • DPO. If You have any questions about the use to which We put Your data, please contact Our Data Protection Officer, whose details are set out in paragraph 5 above.
    • Your Use. This policy relates to Your use of Our Website and electronic communications. Please note that Our Website may link to other third-party websites, plug-ins and applications (“Third-party Links”), that may also gather information about You. Third-party Links will operate in accordance with their own separate privacy policies, and We have no control over any personal data that they may acquire, store and use. When You leave Our Website, We encourage You to read the privacy policy of every Website You visit.
    • We are committed to preserving the privacy of Your data so that We can:
  • deliver service of a high quality to clients;
  • at all times comply with the law and the various regulations that We are subject to;
  • meet the expectations of clients, employees and third parties; and
  • protect Our reputation.
    • In this policy, please note the use of the following terms:
      • comply with a legal obligation means processing Your personal data where it is necessary for compliance with a legal obligation that We are subject to.
      • external third parties means Service providers acting as processors based who provide IT and system administration services and is based in the UK and South Africa; Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in England and Wales who provide consultancy, banking, legal, insurance and accounting services; HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
      • internal third parties means other companies in the group and who act as joint controllers or processors and provide services to Us.
      • legitimate interest means the interest of Our business in conducting and managing Our business to enable Us to give You the best service/product and the best and most secure experience. We make sure We consider and balance any potential impact on You (both positive and negative) and Your rights before We process Your personal data for Our legitimate interests. We do not use Your personal data for activities where Our interests are overridden by the impact on You (unless We have Your consent or are otherwise required or permitted to by law). You can obtain further information about how We assess Our legitimate interests against any potential impact on You in respect of specific activities by contacting Us.
      • performance of contract means processing Your data where it is necessary for the performance of a contract to which You are a party or to take steps at Your request before entering into such a contract.
      • personal data has the meaning given to it by the UK GDPR and means any information relating to an identified or identifiable individual (known as a data subject);
      • processing means any operation or actions performed on personal data; for example collection, recording, organisation, structuring, storing, altering, deleting or otherwise using personal data.
      • We, Us and Our refers to Worldwide Domain Services Ltd t/a Namelynx and its directors;
      • You and Your refers to the person who is accessing Our Website and whose data is processed;

 

  • WHAT PERSONAL DATA WE COLLECT
    • Personal data is collected about You whenever You access Our Website, register with Us, contact Us, send Us feedback, purchase services via Our Website, post material to Our Website, complete forms on Our Website, take part in customer surveys, participate in competitions via Our Website, submit reviews to or via Our Website.
    • Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
    • We may collect, use, store and transfer different kinds of personal data about You which We have grouped together as follows:
  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from You and other details of products and services You have purchased from Us.
  • Technical Data includes internet protocol (IP) address, Your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices You use to access this website.
  • Profile Data includes Your username and password, purchases or orders made by You, Your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how You use Our website, products and services.
  • Marketing and Communications Data includes Your preferences in receiving marketing from Us and Our third parties and Your communication preferences

where these are applicable to You.

  • We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from Your personal data but is not considered personal data in law as this data will not directly or indirectly reveal Your identity. For example, We may aggregate Your Usage Data to calculate the percentage of users accessing a specific website feature. However, if We combine or connect Aggregated Data with Your personal data so that it can directly or indirectly identify You, We treat the combined data as personal data which will be used in accordance with this privacy policy.
  • We do not collect any Special Categories of Personal Data about You (this includes details about Your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about Your health, and genetic and biometric data). Nor do We collect any information about criminal convictions and offences.
  • HOW IS YOUR PERSONAL DATA COLLECTED?
    • We use different methods to collect data from and about You including through:
  • Direct interactions. You may give Us Your Identity, Contact and Financial Data by filling in forms or by corresponding with Us by post, phone, email or otherwise. This includes personal data You provide when You
    1. apply for Our products or services;
    2. create an account on Our website;
    3. subscribe to Our service or publications;
    4. request marketing to be sent to You;
    5. enter a competition, promotion or survey; or
    6. give Us feedback or contact Us;
    7. buy a product from Us;
    8. provide details for delivery of a purchase.
  • Automated technologies or interactions. As You interact with Our website, We will automatically collect Technical Data about Your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and/or other similar technologies.
  • Third parties or publicly available sources. We will receive personal data about You from various third parties and public sources as set out below:

Technical Data from the following parties:

  1. analytics providers such as Google based outside the UK and domain name Registrars;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe and Paypal based inside and outside the UK.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

 

  • The personal data We receive and process is dependent on how You access Our Website, what You do while You are accessing it, and what You perceive the end result of accessing Our Website will be.
    •  
  • HOW WE USE THE PERSONAL DATA
    • In general terms, We may use this personal data to:
    • Please note that it is important that the personal data We hold about You is accurate and current. Please keep Us informed if Your personal details change during Your relationship with Us.
    • We will only use Your personal data when the law allows Us to. Most commonly, We will use Your personal data in the following circumstances:
  • Where We need to perform the contract We are about to enter into or have entered into with You.
  • Where it is necessary for Our legitimate interests (or those of a third party) and Your interests and fundamental rights do not override those interests.
  • Where We need to comply with a legal obligation.
    • Generally, We do not rely on consent as a legal basis for processing Your personal data although We will get Your consent before sending third party direct marketing communications to You via email or text message. You have the right to withdraw consent to marketing at any time by contacting Us.
      •  
    • PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways We plan to use Your personal data, and which of the legal bases We rely on to do so. We have also identified what Our legitimate interests are where appropriate.

Note that We may process Your personal data for more than one lawful ground depending on the specific purpose for which We are using Your data. Please contact Us if You need details about the specific legal ground We are relying on to process Your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register You as a new customer

(a) Identity

(b) Contact

Performance of a contract with You

To process and deliver Your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to Us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with You

(b) Necessary for Our legitimate interests (to recover debts due to Us)

To manage Our relationship with You which will include:

(a) Notifying You about changes to Our terms or privacy policy

(b) Asking You to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with You

(b) Necessary to comply with a legal obligation

(c) Necessary for Our legitimate interests (to keep Our records updated and to study how customers use Our products/services)

To enable You to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with You

(b) Necessary for Our legitimate interests (to study how customers use Our products/services, to develop them and grow Our business)

To administer and protect Our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for Our legitimate interests (for running Our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to You and measure or understand the effectiveness of the advertising We serve to You

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for Our legitimate interests (to study how customers use Our products/services, to develop them, to grow Our business and to inform Our marketing strategy)

To use data analytics to improve Our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for Our legitimate interests (to define types of customers for Our products and services, to keep Our website updated and relevant, to develop Our business and to inform Our marketing strategy)

To make suggestions and recommendations to You about goods or services that may be of interest to You

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for Our legitimate interests (to develop Our products/services and grow Our business)

  • Marketing. We strive to provide You with choices regarding certain personal data uses, particularly around marketing and advertising. [We have established the following personal data control mechanisms:
  • Promotional offers from Us. We may use Your Identity, Contact, Technical, Usage and Profile Data to form a view on what We think You may want or need, or what may be of interest to You. This is how We decide which products, services and offers may be relevant for You (We call this marketing). You will receive marketing communications from Us if You have requested information from Us or purchased goods or services from Us and You have not opted out of receiving that marketing.
  • Third-party marketing. We will get Your express opt-in consent before We share Your personal data with any third party for marketing purposes.
  • Opting out. You can ask Us or third parties to stop sending You marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust Your marketing preferences, by following the opt-out links on any marketing message sent to You or by contacting Us at any time. Where You opt out of receiving these marketing messages, this will not apply to personal data provided to Us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
  • Cookies. You can set Your browser to refuse all or some browser cookies, or to alert You when websites set or access cookies. If You disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies We use, please see Our Cookie section below.
  • Change of purpose. We will only use Your personal data for the purposes for which We collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. If You wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Us. If We need to use Your personal data for an unrelated purpose, We will notify You and We will explain the legal basis which allows Us to do so.Please note that We may process Your personal data without Your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
    •  
  • CONTACTING YOU
    • In addition to the general matters dealt with above, We may also need to send You updates concerning Our services, and about relevant developments in relation to You, Our services, or other related matters which might concern You, or be of interest to You. This may be by post, telephone, email or text, and may include information about the services We offer and information relating to changes in those services.
    • We regard ourselves as having a legitimate interest in processing Your personal data for these purposes, and We take the view that We do not require Your consent in order to do so. From time to time We undertake what are known as ‘legitimate interest assessments’ in order to balance Our interests in contacting You with Your interests in relation to Your data. Where We believe that consent is required, We will contact You specifically for this, and will do so in a clear and transparent manner.
    • Where You have agreed to Us doing so, We may also send You information about third party services in which You have expressed an interest, or which are relevant to any services that We have supplied.
    • Be assured that We treat Your personal data with the utmost respect and will never share it with others for marketing or promotional purposes. You have, at all times, the right to request that We do not contact You for any purpose other than providing Our services. We may, however, require that You confirm Your marketing preferences from time to time so that We can be sure that Your views remain the same, especially in relation to issues such as legal and regulatory updates.
      •  
    • SHARING YOUR DATA WITH OTHERS
      • Despite the fact that We will not share Your personal data for marketing purposes, it may be necessary for Us to share Your personal data with others in order to perform Our services for You, to comply with Our contractual obligations to You, to comply with Our legal or regulatory obligations to You, or to comply with any contractual, legal or regulatory obligations that We are subject to. These may include Service Providers in the United Kingdom, and South Africa; professional advisors, HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
      • When sharing Your personal data, We will ensure at all times that those with who it is shared, process it in an appropriate manner and take all necessary measures in order to protect it. In doing so We impose contractual obligations on all providers of services to ensure that Your personal data is kept secure. We will only ever allow others to handle Your personal data if We are satisfied that the measures which they take to protect that personal data are satisfactory.
      • We may also need to share some personal information with other parties, such as potential buyers of some or all of Our business or during a re-structuring or sale. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
      • From time to time it may be necessary for Us to share data for statistical purposes. We will always take steps to try to ensure that information shared is anonymised but, where this is not possible, We will require that the recipient of the information keeps it confidential at all times.
      • Other than as set out above, We will not share Your personal data with any other third party.
        •  
      • DATA SECURITY & RETENTION
        • We have put in place appropriate security measures to prevent Your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to Your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process Your personal data on Our instructions and they are subject to a duty of confidentiality.
        • We have put in place procedures to deal with any suspected personal data breach and will notify You and any applicable regulator of a breach where We are legally required to do so.
        • We will only retain Your personal data for as long as reasonably necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain Your personal data for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect to Our relationship with You.
        • To determine the appropriate retention period for personal data, We consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of Your personal data, the purposes for which We process Your personal data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
        • In some circumstances We will anonymise Your personal data (so that it can no longer be associated with You) for research or statistical purposes, in which case We may use this information indefinitely without further notice to You.
      • INTERNATIONAL TRANSFERS
        • From time to time, it may be necessary for Us to transfer Your personal data outside the UK where, for example, those with who We need to make contact on Your behalf have offices outside the UK, where electronic services and resources are based outside the UK, or where there is an international element to Your matter. Where this is the case, special rules apply to the protection of Your data.
        • Many of Our external third parties are based outside the UK so their processing of Your personal data will involve a transfer of data outside the UK, such as Paypal USA located in the USA and the Stripe payment portal.
        • Whenever We transfer Your personal data out of the UK, We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
      • We will only transfer Your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
      • Where We use certain service providers, We may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
        • For further information please contact Our Data Manager.
          •  
        • YOUR RIGHTS IN RELATION TO YOUR DATA
          • Data protection legislation gives You, the data subject, various rights in relation to Your personal data that We hold and process. They are as follows:
            • Right to request access—the right to obtain from Us confirmation as to whether or not personal data concerning You is being processed, and, where that is the case, access to that personal data and various other information, including the purpose for the processing, with who the data is shared, how long the data will be retained, and the existence of various other rights (see below).
            • Right to request correction—the right to obtain from Us, correction of inaccurate personal data concerning You, though We may need to verify the accuracy of the new data You provide Us.
            • Right to request erasure—sometimes referred to as the ‘right to be forgotten’, this is the right for You to request that, in certain circumstances, We delete data relating to You, where there is no good reason for Us to conintue processing it. You also have the right to ask Us to delete or remove Your personal data where You have successfully exercised Your right to object to processing (see below), where We may have processed Your information unlawfully or where We are required to erase Your personal data to comply with local law. Note, however, that We may not always be able to comply with Your request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of Your request.
            • Right to object to processing—the right, in certain circumstances, to object to personal data being processed by Us where it is in relation to direct marketing, or in relation to processing where We are relying on a legitimate interest (or those of a third party) and there is something about Your particular situation which makes You want to object to processing on this ground as You feel it impacts on Your fundamental rights and freedoms. You also have the right to object where We are processing Your personal data for direct marketing purposes. In some cases, We may demonstrate that We have compelling legitimate grounds to process Your information which override Your rights and freedoms.
            • Right not to be subject to automated decision making—the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning You or similarly significantly affects You.
            • Right to restrict processing—the right to request that, in certain circumstances, We restrict the processing of Your data. This enables You to ask Us to suspend the processing of Your personal data in the following scenarios:
          • If You want Us to establish the data’s accuracy.
          • Where Our use of the data is unlawful but You do not want Us to erase it.
          • Where You need Us to hold the data even if We no longer require it as You need it to establish, exercise or defend legal claims.
          • You have objected to Our use of Your data but We need to verify whether We have overriding legitimate grounds to use it.
            • Right to request the transfer of Your data —the right, in certain circumstances, to receive that personal data which You have provided to Us in a structured, commonly used and machine-readable format, and the right to have that personal data transmitted to another controller. Note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
            • Right to withdraw consent – You may withdraw Your consent for Us to process Your data at any time where We are relying on consent to process Your personal data. However, this will not affect the lawfulness of any processing carried out before You withdraw Your consent. If You withdraw Your consent, We may not be able to provide certain products or services to You. We will advise You if this is the case at the time You withdraw Your consent.
          • Full details of these rights can be found in the UK GDPR or by reference to guidance produced by the Information Commissioner’s Office (ico.org.uk );
          • In the event that You wish to exercise any of these rights You may do so by:
        • contacting Us using any medium You wish, including in writing, by telephone, by text, electronically, or using such social media as We employ for communication purposes;
        • by completing a form which We can supply to You for this purpose; or
        • through a third-party who You have authorised for this purpose.

 

  • ABOUT COOKIES
    • We use cookies in connection with the operation of Our Website. A cookie is a small file that is sent by a web server (where We host Our Website) to a web browser (from where You view Our Website) and which is then stored by the browser. The cookie contains an identifier which is stored in Your browser and then sent back to Our server each time Your browser accesses Our Website. These cookies may either be ‘persistent cookies’ (in which case they will continue to be held by Your browser until they are deleted, or until a specified event/date) or they will be ‘session cookies’ which expire when You close Your browser.
    • Usually, cookies do not hold any data by which You can be identified, although if We do hold personal data about You (for example, because You have subscribed to a service that We offer) the cookie may be linked to that data.
    • In addition to cookies used by Us, Our service providers may also use cookies, and those cookies may also be stored in Your browser when You visit Our Website.
    • We use Google Analytics. This uses cookies to gather data about how users use Our Website. This data is used to create reports about that use. Further information about Google’s use of data may be obtained from Google’s Website.
    • If You wish to do so then, usually, You can prevent cookies from being downloaded to Your browser and can delete those that have already been downloaded. How this may be achieved varies between different browsers. Consult the Website of Your browser provider for more details.
    • However, You should be aware that if You block or delete cookies this may have a detrimental impact on Your ability to access Our Website, and the services that We provide. It may mean that not all of the facilities on Our Website will be accessible by You. We regret that We cannot, for technical reasons, supply services unless Your browser is set to accept cookies.
    • For further information about the cookies We use, please contact our DPO, Vicky Grobbelaar at vicky@namelynx.com.
      •  
    • KEEPING YOUR DATA SECURE
      • In order to ensure that Your personal data is kept secure, and to prevent there being any breach of confidentiality, We have put in place security measures which are intended to prevent Your personal data from being accidentally lost or used, or accessed unlawfully. Access to Your personal data is restricted to those with a need to access it, and regard will be had to the need for confidentiality when that personal data is processed.
      • In the event that there is a suspected data security breach You will be notified. Where relevant We will also inform the appropriate regulator (including the Information Commissioner’s Office) of a suspected data security breach where We are legally required to do so.
        •  
      • MAKING A COMPLAINT
        • If You have any queries as to the acquisition, use, storage or disposal of any personal data relating to You please contact our DPO, Vicky Grobbelaar at vicky@namelynx.com.
        • Despite Our best efforts, inevitably sometimes things do sometimes go wrong. Although You always have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues, We would appreciate the chance to deal with Your concerns before You approach the ICO, so please contact Us in the first instance. If You are still unhappy with any aspect of the use and/or protection of Your personal data, You have the right to make a complaint to the Information Commissioner’s Office, who may be contacted in writing at the Information Commissioner’s Office (ICO), the UK regulator for data protection issues, at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; by telephone on 0303 123 1113; by fax on 01625 524510; or online at ico.org.uk.
          •  
        • THIS POLICY
          • This privacy policy was published/updated in December and is reviewed regularly.
          • The terms and provisions of this privacy policy may be changed, updated and amended from time to time. If We do so during the time when We are providing You with services We will inform You of those changes.

 

  • Schedule A

CATEGORY OF PERSONAL DATA

 

RETENTION PERIOD

 

Name and contact details address, phone number

2 Years from last log-on to the Website

Information collected through cookies and similar technologies

2 Years from last log-on to the Website

Contact history

2 Years from last log-on to the Website

Browser, device and Website usage information

2 Years from last log-on to the Website

Information from linked accounts

2 Years from last log-on to the Website

Responses to surveys, competitions and promotions

2 Years from last log-on to the Website

Customer comments and product reviews

2 Years from last log-on to the Website

Technical, Audit, Transaction and Profile Data

5 years from closure of account

  •