December 17th, 2020
GoDaddy Media Temple, Inc. d/b/a Sucuri cares about your privacy. For this reason, we collect and use personal information only as needed to deliver our products, services, websites and mobile applications, and to communicate with you about the same, or as you have requested (collectively, our “Services”). Your personal information includes information such as:
- Telephone number
- Date of birth
- Email address
- Billing and payment information
- Candidate information (for job applicants)
- Other data collected that could directly or indirectly identify you.
If at any time you have questions about our practices or any of your rights described below, you may reach our Data Protection Officer(“DPO”) and our dedicated team that supports this office by contacting us at email@example.com. This inbox is actively monitored and managed so that we can deliver an experience that you can confidently trust.
What information we collect, how we collect it, and why.
Much of what you likely consider personal data is collected directly from you when you:
(1) create an account or purchase any of our Services (ex: billing information, including name, address, credit card number, government identification);
(2) request assistance from our award-winning customer support team (ex: phone number);
(3) complete contact forms or request newsletters or other information from us (ex: email); or
(4) participate in contests and surveys, apply for a job, or otherwise participate in activities we promote that might require information about you.
However, we also collect additional information when delivering our Services to you to ensure necessary and optimal performance.These methods of collection may not be as obvious to you, so we thought we’ d highlight and explain a bit more about what these might be(as they vary from time to time):
Supplemented Data may be received about you from other sources, including publicly available databases or third parties from whom we have purchased data, in which case we may combine this data with information we already have about you so that we can update, expand and analyze the accuracy of our records, assess the qualifications of a candidate for employment, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
How we utilize information.
We strongly believe in both minimizing the data we collect and limiting its use and purpose to only that (1) for which we have been given permission, (2) as necessary to deliver the Services you purchase or interact with, or(3) as we might be required or permitted for legal compliance or other lawful purposes:
Delivering, improving, updating and enhancing our Services.
We collect various information relating to your purchase, use and / or interactions with our Services.We utilize this information to:
Improve and optimize the operation and performance of our Services (again, including our websites and mobile applications)
Diagnose problems with and identify any security and compliance risks, errors, or needed enhancements to the Services
Detect and prevent fraud and abuse of our Services and systems
Collecting aggregate statistics about use of the Services
Understand and analyze how you use our Services and what products and services are most relevant to you.
Much of the data collected is aggregated or statistical data about how individuals use our Services, and is not linked to any personal information.
Sharing with trusted third parties.
We may share your personal information with affiliated companies within our corporate family, with third parties with which we have partnered to allow you to integrate their services into our own Services, and with trusted third party service providers as necessary for them to perform services on our behalf, such as:
- Processing credit card payments
- Serving advertisements
- Conducting contests or surveys
- Performing analysis of our Services and customers demographics
- Communicating with you, such as by way email or survey delivery
- Customer relationship management
- Security, risk management and compliance
- Recruiting support and related services.
These third parties (and any subcontractors they may be permitted to use) have agreed not to share, use or retain your personal information for any purpose other than as necessary for the provision of Services.
We will also disclose your information to third parties:
- in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
- if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, your information may be among the transferred assets.
Communicating with you.
We may contact you directly or through a third party service provider regarding products or services you have signed up or purchased from us, such as necessary to deliver transactional or service related communications. We may also contact you with offers for additional services we think you’ll find valuable if you give us consent, or where allowed based upon legitimate interests. You don’t need to provide consent as a condition to purchase our goods or services. These contacts may include:
- Text (SMS) messages
- Telephone calls
- Messenger applications (e.g. WhatsApp, etc.)
- Automated phone calls or text messages.
You may also update your subscription preferences with respect to receiving communications from us and/or our partners by signing into your account and visiting “Account Settings” page.
If you make use of a service that allows you to import contacts (ex. using email marketing services to send emails on your behalf), we will only use the contacts and any other personal information for the requested service. If you believe that anyone has provided us with your personal information and you would like to request that it be removed from our database, please contact us at firstname.lastname@example.org.
Transfer of personal information abroad.
If you utilize our Services from a country other than the country where our servers are located, your personal information may be transferred across international borders, which will only be done when necessary for the performance of our contract with you, when we have your consent to do so, or when the appropriate standard contractual clauses are in place. Also, when you call us or initiate a chat, we may provide you with support from one of our global locations outside your country of origin.
Compliance with legal, regulatory and law enforcement requests.
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoena requests), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical.
To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.
How we secure, store and retain your data.
We follow generally accepted standards to store and protect the personal information we collect, both during transmission and once received and stored, including utilization of encryption where appropriate.
We retain personal information only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:
mandated by law, contract or similar obligations applicable to our business operations;
for preserving, resolving, defending or enforcing our legal/contractual rights; or
needed to maintain adequate and accurate business and financial records.
If you have any questions about the security or retention of your personal information, you can contact us at email@example.com.
How you can access, update or delete your data.
To easily access, view, update, delete or port your personal information, or to update your subscription preferences, please sign into your Account and visit “Account Settings.”
If you make a request to delete your personal information and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.
If you are unable for any reason to access your Account Settings, you may also contact us by one of the methods described in the “Contact Us” section below.
The E.U-U.S and Swiss-U.S. Privacy Shield Frameworks.
On July 16, 2020, the Court of Justice of the European Union issued a judgment declaring as “invalid” the European Commission’s Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of the protection provided by the EU-U.S. Privacy Shield. As a result of that decision, the EU-U.S. Privacy Shield Framework is no longer a valid mechanism to comply with EU data protection requirements when transferring personal data from the European Union to the United States.
Nonetheless, the U.S. Department of Commerce continues to administer the Privacy Shield program, and our parent company, GoDaddy Operating Company, LLC is committed to subjecting all personal information received from the EU or Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
GoDaddy Media Temple, Inc. is responsible for the processing of personal information it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. GoDaddy Media Temple, Inc. complies with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal information received or transferred pursuant to each Privacy Shield Framework, GoDaddy Media Temple, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, GoDaddy Media Temple, Inc. may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
GoDaddy Media Temple, Inc. has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.
‘Do Not Track’ notifications.
Some browsers allow you to automatically notify websites you visit not to track you using a “Do Not Track” signal. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.
Our Services are available for purchase only for those over the age of 18. Our Services are not targeted to, intended to be consumed by or designed to entice individuals under the age of 18. If you know of or have reason to believe anyone under the age of 18 has provided us with any personal information, please contact us.
We will not discriminate against you for exercising any of your privacy rights. Unless permitted under applicable laws, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to this policy.
By Mail: Attn: Office of the Data Protection Officer, 14455 North Hayden Road, Suite 219, Scottsdale, AZ 85260 USA, or for customers established in the EEA, Attn: Legal, Office of the DPO, 5th Floor, The Shipping Building, Old Vinyl Factory, 252-254 Blyth Road, Hayes, UB3 1HA.
By Phone: 1-888-873-0817
We will respond to all requests, inquiries or concerns within thirty (30) days.
If you are not satisfied with our response, you may direct privacy complaints to your local data protection authority. GoDaddy Media Temple, Inc. is the data controller for www.sucuri.net.