Effective Date: August 10, 2023
We value your privacy. Regarding your personal data, we prioritize transparency over surprises. Therefore, we outline here the types of personal data we gather, our uses for it, and your options and rights.
By using our Services, you affirm that you have agreed to the Terms of Service and have read and understood this Privacy Policy and our Cookie Policy.
Certain jurisdictions mandate us to provide specific additional details. Refer to this page for such information if you are located in: (I) California; or (II) Virginia, Colorado, Connecticut, or Utah.
**1. Key Definitions**
In this Privacy Policy, “Users” refers to customers who use our Services, including site visitors. The term “End Users” applies to users, visitors, and customers of our Users’ sites. Other capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Service.
**2. Scope of this Privacy Policy**
This Privacy Policy explains our practices regarding personal information that we collect and use for our purposes (i.e., where we are a controller), including account information, details on how you interact with our Services, and customer support interactions, as well as certain information about your End Users, such as, if applicable, data provided for Payments Services. This policy does not cover the personal data of our employees or job applicants (except when they are Users). It also includes your right to object to specific processing activities we perform (see Section 7 for details).
We utilize cookies and similar technologies, as detailed in our Cookie Policy.
Regarding personal data we control, we assume different roles under global data privacy laws. Understanding the distinction between Controlled PI and User Controlled PI is crucial to comprehend your obligations and ours.
**“Controlled PI”** refers to personal data for which we determine the purposes and processing methods. This Privacy Policy and the additional U.S. state information page cover only Controlled PI.
**“User Controlled PI”** pertains to personal data for which a User decides the purposes and processing methods. For User Controlled PI, we act as a data processor, service provider, or similar role under applicable laws. User Controlled PI includes User Content and End Users’ personal information described in Section 12, which we host and process on behalf of our Users. Our Users dictate how we handle User Controlled PI based on their instructions. Users are responsible for ensuring their collection and processing of User Controlled PI complies with the law. Users seeking contractual terms regarding our treatment and security of User Controlled PI should refer to our Data Processing Addendum.
Below, we explain how we gather and use Controlled PI and outline your rights. If you are an End User of a User’s site, check that site’s privacy policy to understand how your information is managed.
**3. Types of Personal Information Collected**
We gather various personal information about you or your device, including:
– Data you provide to create an Account, such as your email address, first name, and last name.
– Information you provide when signing up for Paid Services, including your billing address and parts of your payment details provided by our payment processor (like the last four digits, issuing country, and expiration date).
– Communications you send us or contribute, such as customer support inquiries or posts on our forums. Note that information on public parts of our sites is accessible to others.
– If you use the Payments Services via our Services, additional details for setting up, managing, and providing the Payments Services, such as bank account information, name, address, phone number, date of birth, social security number, tax ID (EIN), photo ID, and nationality.
– Information from surveys, contests, or promotions you participate in.
– Usage data from our Services or Users’ sites, including IP addresses, preferences, web pages visited before accessing our sites, browser details, network or device information (e.g., browser type and version, operating system, ISP, preferences, unique device IDs, language and regional settings), and interaction details (e.g., timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and issues like loading errors).
– Data from our partners to support marketing, improve Services, and monitor and measure ad campaigns, such as when a partner shows you our ad on their platform.
– Other data you submit directly or through Third Party Services when creating an Account.
**4. Methods of Collecting Personal Information**
We obtain personal information through several methods:
– **Direct Submission:** You provide information directly, such as when registering for an Account.
– **Automated Recording:** We automatically record some data when you use our Services or Users’ sites, including through cookies.
– **Third-Party Sources:** We receive information from third parties, like when you register using a Third Party Service, purchase products from an authorized reseller, or make payments via our processor or a mobile app store.
Detailed descriptions are provided below.
**a. Direct Submission of Personal Information**
Using our Services involves providing data in various ways. For example, we ask for your name and email to register and manage your Account. We also keep records of your marketing preferences and communications, such as customer support inquiries or forum posts. Additional data may be provided through surveys, forms, contests, or promotions.
Certain information is required for legal or contractual reasons. For instance, when registering or transferring a domain name, we collect domain registration data to comply with ICANN, registry, ccTLD, or registrar policies. For Paid Services, we may ask for a mailing address or jurisdiction to determine tax obligations. Using the Payments Services requires additional data to fulfill legal and contractual duties, such as bank account details and personal identification information. We typically notify you when data is mandatory and the consequences of not providing it. Failure to provide required data may prevent you from using our Services if necessary to deliver the service or comply with legal obligations.
**b. Information from Usage of Our Services**
We collect data on your activities and interactions with our Services, such as IP addresses, device and browser types, the web page visited before ours, pages visited on our sites, visit durations, and device identifiers. If permitted through your device settings, we may also collect location information via our mobile apps.
For End Users of our Users’ sites, we obtain interaction data, typically in anonymous, aggregated, or pseudonymized forms that do not directly identify you. This data helps us evaluate, provide, protect, or improve our Services, including developing new products and services.
Some data is collected automatically using cookies and similar technologies. Our Users control what cookies and technologies are used on their sites, except those essential for performance or security. For more information, refer to our Cookie Policy.
**c. Information from Other Sources**
When you use a Third Party Service (like Google) to register for an Account, the service may share your account information, such as your name and email, based on your privacy settings. Review their privacy policies to understand what they share and adjust your settings if necessary.
If you sign up for Paid Services via an authorized reseller, they may share account information and data necessary for service activation.
When signing up directly with us, we obtain limited payment card details from our processor, like the last four digits, issuing country, and expiration date. Currently, Stripe processes this information following their privacy policy. This does not apply to in-app purchases through a mobile app store, where the store’s privacy policy governs. See Google’s and Apple’s privacy policies for details on how they handle payment information. Similarly, if you sign up via a Third Party Service reseller, refer to their privacy policy.
**5. Utilization of Personal Information**
We use your personal information for several purposes:
– **Service Provision:** Create and manage your Account, provide personalized Services, register or transfer domain names, process payments, and respond to inquiries. For Payments Services, manage and provide the service, integrate with Processor Services, and initiate Transactions.
– **Communication:** Send transaction-related emails and Service announcements.
– **Surveys and Contests:** Administer surveys, contests, and promotions.
– **Marketing:** Promote Services, send tailored marketing communications about products, services, offers, and measure campaign success. Marketing efforts may vary based on your subscription plan and interests inferred from other data.
– **Advertising:** Analyze interactions to tailor advertising. For example, avoid advertising to existing Paid Service users on social media or customize ads based on your subscription plan.
– **Customization:** Provide customized services, such as language preferences and accurate date and time displays. Use cookies for personalization, like remembering recently edited sites.
– **Service Improvement:** Analyze usage to improve Services, develop new products, manage communications, and measure ad effectiveness, typically using anonymized, pseudonymized, or aggregated data.
– **Security:** Ensure service security and integrity, conduct fraud and risk monitoring, verify identities, and investigate fraud, especially for Payments Services.
– **Vendor and Partner Management:** Manage relationships with vendors and partners.
– **Policy Enforcement:** Enforce Terms of Service and other legal terms.
– **Protection:** Protect interests, rights, and property.
– **Legal Compliance:** Comply with legal requirements, such as tax regulations, industry standards, and law enforcement requests. For Payments Services, meet legal obligations like anti-money laundering laws.
We process personal information based on:
– **Consent:** When you have consented to a specific use, which can be withdrawn at any time.
– **Contract Performance:** When necessary to provide requested services or respond to inquiries.
– **Legal Obligations:** To comply with legal requirements.
– **Legitimate Interests:** When necessary to pursue our legitimate interests, balanced against your rights. Examples include operating our business, tailoring advertising and communications, ensuring security, providing personalized services, and sharing data with affiliates for service improvement.
**6. Sharing Personal Information**
We share personal information in the following ways:
– **Affiliates:** Share data with affiliates as needed for service provision and improvement.
– **Users:** Provide Users with data on End Users’ interactions with their sites for analysis and service enhancement.
– **Payments Services
Providers:** Share data with third-party providers (e.g., Stripe, Sift, Plaid) for operating Payments Services, identity verification, and fraud prevention.
– **Domain Registration Partners:** Share domain registration data to comply with ICANN and registrar policies.
– **Business Partners:** Share data with partners when Services integrate with their Third Party Services, with prior notification.
– **Plugins and Social Networks:** Share data with website plugins, social media platforms, or similar services to enhance user experience.
– **Service Providers:** Share data with providers performing services on our behalf, such as customer support, marketing, and data storage.
– **Payment Processors:** Transmit payment data to processors securely.
– **Legal Compliance:** Disclose data to comply with laws, protect rights, and prevent fraud, including responding to lawful requests from authorities.
– **Advertising Partners:** Share data for tailored advertising and campaign measurement.
– **Business Transfers:** Transfer data during reorganization, merger, acquisition, or asset sale negotiations.
**7. Your Rights and Choices**
Depending on applicable laws, you may have the right to access, update, change, or delete personal information.
You can manage personal information through your Account. To delete your account, follow the support guide instructions. We may need to verify your identity for such requests, potentially requiring additional information if you lack Account access. If verification is unsuccessful, we may be unable to fulfill your request. Contact us at privacy@2Mindsmarketing.com for access, update, change, or deletion requests.
You can opt out of marketing communications via Account preferences or unsubscribe instructions in emails.
Please note, data deletion from our systems may take time due to technical reasons. We retain personal information to comply with legal obligations, protect rights, resolve disputes, or enforce policies, as permitted by law.
You may have rights to restrict or object to data processing or request data portability, depending on the law. Complaints can be lodged with a supervisory authority, such as the Irish Data Protection Commissioner for EU residents or the UK’s Information Commissioner’s Office for UK residents.
For processing based on consent, you can withdraw consent anytime, without affecting the lawfulness of prior processing.
Our Cookie Policy details managing cookies and similar technologies.
End Users should contact site owners to exercise rights over information controlled by those Users.
**8. Data Protection Measures**
We implement various security measures to safeguard personal information against accidental or unlawful destruction, loss, alteration, unauthorized access, misuse, and other unlawful processing. These include firewalls, network redundancies, and vulnerability testing.
**9. Data Retention**
We retain personal information for as long as necessary to provide active Accounts or as required to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, protect our interests, resolve disputes, and enforce agreements.
Retention periods vary based on data nature and purpose. Factors include legal requirements, best practices, claim periods, aggregation or pseudonymization status, and other criteria. For instance, email addresses are retained while Accounts are active, while support messages depend on the last submission date.
Inactive Accounts or canceled Paid Services are not immediately deleted, allowing for data retention for potential reactivation.
You can delete your Account via the support guide or by contacting us at privacy@2Mindsmarketing.com, leading to the deletion of held personal information unless retention is required by this Privacy Policy.
We may indefinitely retain aggregated, anonymized, or de-personalized data collected during Service provision.
**10. International Data Transfers**
Personal information submitted through our Services may be transferred to countries other than where you reside, including our U.S. servers. We also store data locally on your access devices.
Data may be transferred to countries with different data protection laws, making it accessible to law enforcement and national security authorities under certain conditions.
We rely on several mechanisms to transfer personal information under GDPR and UK data privacy laws, including:
– **Standard Data Protection Clauses:** Transfer data to recipients under European Commission-approved contracts for data transfer outside the EEA or UK ICO-approved agreements.
– **Other Means:** Transfer data to recipients in countries with adequate data protection levels or through approved certification mechanisms or binding corporate rules.
– **Data Privacy Frameworks:** Transfer data to the US under the EU-U.S., Swiss-U.S., and UK Extensions to the EU-U.S. Data Privacy Frameworks, based on adequacy decisions.
Additional information on these mechanisms is available upon request.
**11. Data Privacy Frameworks Compliance**
We comply with Data Privacy Frameworks for legal data transfers to the US from the EEA, Switzerland, and the UK. Our certification covers personal data processing for the purposes described in this Privacy Policy.
We adhere to the DPF Principles for personal information received from the EEA, Switzerland, and the UK, ensuring proper use and disclosure, including responding to legal requests. Certification details are available on the Data Privacy Frameworks website.
We remain accountable for third-party data processing under the DPF Principles, unless proven otherwise.
For DPF-related complaints, contact us first at privacy@2Mindsmarketing.com. Unresolved complaints can be addressed to JAMS, an independent dispute resolution provider. Further unresolved issues may be subject to binding arbitration under DPF Principles. The U.S. Federal Trade Commission enforces compliance.
This Privacy Policy aligns with DPF Principles, governing any conflicts.
**12. End Users’ Data Handling**
Users creating sites with our services are responsible for their handling of End Users’ personal data, including collection, usage, and legal compliance. This section is for those Users.
**a. User-End User Relationships**
Users collect End Users’ data, like name, address, email, and payment information during checkout, and use cookies for trend analysis.
Users must comply with relevant laws and regulations regarding End Users’ data. We and Users may be independent controllers for some data, such as IP addresses, device/browser details, and browsing activity on User sites. Users should publish and adhere to their own privacy and cookie policies.
We are not liable for Users’ data practices and do not provide legal advice on such matters.
**b. End User Payment Data**
For Payments Services, Users accept that we, the Processor, and certain third-party service providers (like Sift and Plaid) can access, use, and transmit End Users’ payment and transaction data for Payments Services, identity verification, and fraud prevention.
For third-party eCommerce Payment Processors integrated with User sites, End Users’ payment data is processed according to those processors’ terms and policies. We only transmit payment information to the processors and do not store it.
**13. Privacy Policy Updates**
We periodically update this Privacy Policy to reflect changes in technology, law, business operations, or other reasons. Changes are posted with an updated “Effective Date” and may include prominent notices or direct notifications for significant changes.
We encourage periodic reviews of this Privacy Policy to stay informed about how we process personal information.
**14. Our Company Information**
References to “we”, “us”, or “our company” mean: (a) Our Company, Inc. for U.S. residents or principal business entities; or (b) Our Company Ireland Limited for residents or principal businesses outside the U.S.
The controlling entity changes based on your location.
**15. Contact Information**
For questions, comments, or complaints about this Privacy Policy or our privacy practices, or to exercise your rights, email us at fm(a.d..)2Mindsmarketing.com