The protection of your privacy is one of our fundamental objectives
1. Data Controller and Data Protection Officer
2. Personal data subject to processing
a. Browsing data
b. Data processed in connections to social networks
c. Data provided voluntarily by the owner.
d. Data records of domain names
e. Traffic data
3. Purpose of the processing
4. Legal basis and mandatory or voluntary processing
5. Receivers of personal data
6. Personal data protection
7. Retention of personal data
8. Owner’s rights
1. Data Controller and Data Protection Officer. The Data Controller role is carried out by the NOMINALIA website, as indicated above. The organisation of the Data Controller includes a Data Protection Officer (DPO). The DPO is available for any information relating to the processing of personal data by NOMINALIA, including the list of Data Controllers.
You can contact the DPO by writing to firstname.lastname@example.org
2. Personal Data subject to processing
"Processing of personal data" means any operation or set of operations carried out with or without the help of automated processes and applied to personal data or sets of personal data, such as collection, recording, organisation, structure, storage, adaptation or modification, removal, consultation, use, communication by transmission, dissemination or any other form of disposal, comparison or interconnection, limitation, cancellation or destruction.
The personal data processed - depending on how you intend to use the Services - may be in the form of an identifier such as name, an email address, an identification number, location data, an online ID, purchases made or other appropriate data to identify you or to make it possible to identify you, depending on the type of services requested (collectively, the "Personal Data").
Specifically, the personal data processed by NOMINALIA on its website are as follows:
a. Browsing Data:
The computer systems and software procedures used to operate the NOMINALIA website acquire, during normal operation, personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified or identifiable persons, but by its very nature it can, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the devices used by users who connect to the site, the addresses in the Uniform Resource Identifier (URI), the time of the request, the method used to send the request to the server, the size of the file obtained in response, the numerical code that indicates the status of the reply given by the server (success, error, etc.) and other parameters related to the operating system and the environment of the user device. These data are used for the sole purpose of obtaining anonymous statistical information about the use of the site and the sites of our clients and to verify its correct operation, to identify anomalies and/or abuse, and are deleted immediately after processing. The same data may be used to ascertain responsibility in case of hypothetical computer crimes against the site or against third parties: except for this possibility, the data on web contacts are not saved for more than 14 days, unless the user specifically requests otherwise (for example: access to the user's personal pages within NOMINALIA that reflects the services used, published information, etc.).
b. Data processing in the field of interaction with social networks:
In addition to completing the registration form when purchasing a service, you may alternatively register for Services, if you have a Facebook profile, simply by clicking – (and this implies EXPRESS CONSENT) - on the "Login with Facebook" button. In this case, Facebook will automatically send NOMINALIA some of your personal data, specifically in the pop-up window that is displayed during the application, and you need not fill out any other forms. If, however, you are already a registered user of NOMINALIA and also have a Facebook profile, you can opt for NOMINALIA to associate your account with your Facebook account by clicking on "Login with Facebook" and then "Account": Thereafter, your NOMINALIA ID will be associated with your Facebook user code. You may then click on "Login with Facebook" to sign into your control panel in NOMINALIA without needing to enter your username and password.
NOMINALIA also offers you the possibility to associate your NOMINALIA account with your Google, Twitter, or LinkedIn account, if any. Also, in these cases, the social networks sites involved send some of your personal data to NOMINALIA, specified in the "pop-up" window that is displayed at the time of the request.
c. Data provided voluntarily by the interested party:
When you use certain services (for example, NOMINALIA products or services that permit the assignment of domain names to third parties) information third party sent by you to the Service Manager may be processed. In this case, you are an independent Data Controller, assuming all the pertinent legal obligations and responsibilities.
In this regard, you undertake to hold NOMINALIA harmless, in the widest sense, in connection with any disputes, claims, requests for compensation for damage in connection with the data processing, etc. received by NOMINALIA from third parties whose personal data have been processed through the use that has been made of the services, in breach of the applicable rules on protection of personal data. In any case, if you provide or in any other way process personal data belonging to third parties by using the Service, you undertake that from now on - assuming all responsibility related - these specific cases of data processing are legal (for example, with the consent of the interested party) in accordance with Article 6 of the Regulation, which legitimises the processing of the information in question.
D. Data of the Domain Name Registration:
With regard to the processing of personal data carried out as part of the domain name registration service, it is hereby specified that NOMINALIA will only process the data as strictly necessary to provide the service, unless there is subsequent legal processing within the meaning of Article 6 of Regulation (for example, your express consent). The data collected by NOMINALIA as part of an application for registration of domain names are essential and are only those strictly necessary for the provision of the service, are listed in the Service Order. Since the data is voluntary; in the absence of such data NOMINALIA will not be able to provide the requested service.
It should be noted that the personal data of the domain name holder, with the strict purpose of provision of the service, may be communicated to third parties.
Specifically, to register domain names, the Internet Corporation for Assigned Names and Numbers ("ICANN") requires that NOMINALIA, as a registrar, deposit a copy of the data required for the registration of a domain name with an Authorised Agent under the authority of the ICANN itself as a guarantee.
This Service is provided to NOMINALIA by Iron Mountain Intellectual Property Management, Inc., by designation of ICANN.
Furthermore, data may be communicated to the national and foreign registration authorities that ask NOMINALIA to transmit technical and administrative documentation required by sector legislation, and for other matters concerning registration of domain names with extensions for which NOMINALIA does not act as a registrar or as a registry agent.
You must provide this information in order to use the Service, and therefore, in accordance with the privacy legislation in force, this is justified under Art. 6 (1) (b) of the Regulation. When you sign up for the Service, you agree and consent that some of your personal data will be communicated as described above.
If, instead, when applying for registration of domain names, you provide NOMINALIA with personal data of other third parties involved in the processing, you act as an Independent Data Controller, assuming all the obligations and responsibilities of the law.
In this regard, you undertake to hold NOMINALIA harmless, in the widest sense, in connection with any disputes, claims requests for compensation for damage in connection with the data processing, etc. received by NOMINALIA from third parties whose personal data have been processed through the use that you have of the services, in breach of the applicable rules on protection of personal data.
In any case, if you provide or in any other way process third-party personal data belonging to third parties by using the Service, you undertake that from now on - assuming all responsibility related - that these specific cases of data processing are legal (for example, with the consent of the interested party) in accordance with Article 6 of the Regulation, which legitimises the processing of the information in question.
In addition, to improve the provision of the service, the data will normally be published and, therefore, be disseminated in the public WHOIS database that contains personal data of domain name holders. With reference to this processing, it should be borne in mind that ICANN acts as an independent data controller and that NOMINALIA has no control over the activities of processing by ICANN. Icann's policies in this regard are currently being reviewed and developed and any new developments on the matter will be duly notified. In addition, domain names are published in the WHOIS database managed by the competent authorities, which are also updating their policies in the field of publication of personal data. We hereby make it clear that all these subjects are responsible for the independent processing and that NOMINALIA, in order to provide the domain registration service, must notify the data to these subjects (otherwise we could not provide the service), not does it exercise any control over how personal data is processed by these subjects. NOMINALIA, to the extent that is affected and as part of the domain registration service, shall not publish any personal data from you.
e. Traffic data:
As part of the e-mail service, NOMINALIA manages certain data in order to transmit communications through the electronic communications network. The specific data are:
- IP address and e-mail address and any other additional identification of the sender;
- IP address and domain name of the host's mail exchanger in the case of SMTP technology, or any other type of host related to a technology other than the above that is used for transmission of communications;
- Email address and any additional identification of the recipient of the communication;
- The IP address and domain name of the host's mail exchanger in the case of technology SMTP, or any other type of host related to another technology other than the previous one, which delivered the message;
- The IP address used to receive or to consult emails by the recipient, regardless of the technology or the protocol used;
- Date and time (GMT) of the connection and disconnection of the service user's e-mail on the Internet and the IP address that is used, regardless of the technology and the protocol used;
- The internet service used.
These data are processed and stored by NOMINALIA to provide the service and in addition and compliance with the applicable law, to detect and prevent crimes - by adopting strict security measures so that these data are accessible only to persons specifically authorised in writing and that access to such data requires a court order, accompanied, if necessary, by a reasoned decision of the prosecutor and, in any case, the authentication techniques provided by law.
Under the law, the data are retained and stored by NOMINALIA in order to detect and prosecute crimes by the retention period provided for by law. In addition, the data are also processed by NOMINALIA for ordinary commercial purposes related to the provision of the service (for example: as documentary evidence in case of a dispute involving invoices or payment of claims, for detection of fraud, and to perform analyses on behalf of clients), always in accordance with the law in force. In all cases, the data is stored, under the strict security measures applicable in accordance with the law, only during the legally established terms.
3. PURPOSE OF PROCESSING
Once you have obtained your express consent, we will process your data for the following purposes:
a. To provide the services requested by you and subsequent independent management by you in your Control Panel, which you will access by registering and creating your user profile when you start receiving the services, including the collection, storage and processing of data to establish and subsequently enable operational, technical and administrative management of the relationship resulting from the provision of services, as well a communications between us in connection with the service relationship;
b. To enable you to browse and consult NOMINALIA Websites;
c. Respond to requests for assistance and/or information that come to us via chat, or e-mail, or by telephone, or through the contact form available on the Site, or by means of the help form in your private area, as a customer, in the section "Client Area" particularly to respond to requests for assistance received by telephone, we inform you that calls may be recorded to ensure the quality of the service, for example, so that NOMINALIA can track that we have successfully processed the requests;
d. Comply with legal accounting and tax obligations;
e. To carry out direct e-mail marketing for similar services to that which you have signed up for out, unless you rejected this option initially or in subsequent communications, in order to achieve the legitimate interests of NOMINALIA to promote products and services in which you may be reasonably interested;
f. To conduct studies, surveys, gather market statistics; to send you promotional material, marketing information or surveys to improve the service ("customer satisfaction") via email or text message, and/or through the use of the telephone operator and/or through the official pages of NOMINALIA on social networks;
g. With respect to certain services, your data may be processed and disclosed to third parties for marketing purposes, i.e., to provide you with information and/or offers on products, services, or initiatives offered or promoted by other companies that belong to the Register Group and/or its related parties and/or subsidiaries, and/or other trading partners and subcontractors as independent data controllers;
h. To tailor business proposals to you based on previously purchased products or services, or in which you have shown interest while surfing our Website, or on the basis of the customer group to which you belong (profiling). This means, for example, that if you are a retailer will receive proposals for retailers; if you have browsed our site looking for information on certain services, you will receive offers related to such services; finally, if you are a service user, based on your use you will receive messages from NOMINALIA (for example, if the service capacity is close to its limit, you will be notified and invited to increase the capacity of the Service, or offered services that are additional and/or compatible with those purchased). This type of analysis is typically performed with data of purchases of both individuals and legal persons and decisions are not based only in automated processes.
This processing is necessary to achieve the legitimate purpose of the processing controller to customise commercial offers. You can always oppose the processing of your data by accessing your private area as a client in the section Client Area.
i. Solely for purposes of security and prevention of fraudulent behaviour, the Data controller installs an automatic control system to track and analyse user behaviour on the site, associated with the processing of personal data such as, for example, the IP address. The consequence of this, is that if someone tries to behave fraudulently on the NOMINALIA site, for example to benefit several times from a promotion when not entitled to do so, Nominalia reserves the right to exclude such persons from the promotion or to take other appropriate measures for its own protection.
4. Legal grounds for processing Personal Data and mandatory or optional nature of that processing
The legal grounds for processing your personal data for the purposes set out in Section 3 (paragraphs a, b, c) is Article 6 (1) (b) of the Regulation, because the processing is necessary for the provision of the services contracted. Providing your personal data for these purposes is optional, but the failure to provide the data will make it impossible to activate the Services requested.
The purpose of Section 3 (d) is to ensure legitimate processing of Personal Data in accordance with the Article 6 (1) (c) of the Regulation. Once you have provided Personal Data, the NOMINALIA must process the information in accordance with the applicable law.
Processing for trading purposes as described in Section 3 (f) and to communicate to third parties as described in Section 3 (g) are based on your consent in accordance with the Art. 6 (1) (a) of the Regulation. The provision of your personal data for these purposes is, therefore, entirely optional and does not affect the use of the Services. The processing activities pursuant to Section 3 (e) carried out with the purpose of e-marketing activities of products or services similar to those you have already acquired is legally permitted by Article 6.1.f of Regulation in the legitimate interest of NOMINALIA to promote your products and services in a context in which the applicant can reasonably expect this type of processing, which can be set at any time.
In fact, if you allow or refuse to allow your data to be processed for promotional purposes pursuant to Section 3 (e) and 3 (f), you may change this at any time by accessing your private management area as a client from the "Clients” section, or by using the link at the end of the email, and by changing the type of consent given. The development of profiles mentioned in Section 3 (h) is based on the legitimate interest of the person responsible for data processing to detect frauds and scams committed in accordance with Article 6 (1) (f) of the Regulation.
5. Recipients of personal data:
Your personal data may be shared, for the purposes specified in Section 3, above, with:
a. Subjects who typically act as data controllers that is to say: (i) persons, companies or professional firms that provide assistance and advice to NOMINALIA in accounting, administration, legal, tax, financial and debt collection with regard for disbursement of services; (ii) subjects with which it is necessary to interact to provide services (for example, the national and foreign registration authorities to transmit technical and administrative documentation and maintenance forms, authorities that manage the WHOIS database that contains personal data; assignees of domain names, subjects that provide the credit card payment service - for example, VISA, etc.) iii) or subject delegated to carry out technical maintenance activities (including maintenance of network equipment and communications networks); (iv) Register Group, Italian or foreign companies (all of them, together, the "Recipients");
b. Subjects, bodies or authorities to which it is mandatory to communicate your personal data in accordance with the provisions of the law or orders of the authorities (for example, in the course of criminal investigations, NOMINALIA may receive orders from the judicial authority to disclose logs);
c. Persons authorised by NOMINALIA to process personal data necessary to carry out activities strictly related to the provision of services, provided that they undertake to maintain confidentiality or have a legal obligation of confidentiality; for example, NOMINALIA employees;
d. Trading partners for their own purposes, only if you have given specific consent.
The full list of Data Controllers can be obtained by requesting this from customer services, from the Help form that you will find in your private client area that you can access from the Client Area.
6. Personal data transfer
Some of your personal data may be shared with recipients outside the European Economic Area. NOMINALIA ensures that the personal data by these recipients complies with the Regulations. Transfers can be based on a decision of appropriateness or standard contractual clauses approved by the European Commission. More information is available from the Processing Officer. Within domain name registration services, the data is communicated to the subjects listed in Section 2 (e) in this document: in some cases, processing involves transmission of the data in question outside the European Economic Area. You must provide this information in order to use the Service, and therefore, in accordance with the privacy legislation in force, this is justified under Art. 49 (1) (b) of the Regulation.
7. Conservation of personal data
Personal data processed for the purposes set out in Section 3 (a-b-c) will be kept for the time strictly necessary to achieve the purposes for which they were collected and processed. In any case, since the personal data will be processed to provide the services, NOMINALIA will retain the data for the period allowed by the Spanish law to protect their interests.
The personal data processed for the purposes set out in Section 3 (d) shall be retained for the specific period, or according to the applicable law. By way of example, there are regulations which stipulate that employment or social security data must be kept for four years; for accounting, tax, commercial purposes for six years and four for tax purposes; medical records must be kept for a minimum of five years and video surveillance files for no more than a month.
For the purposes described in paragraphs 3 (e) and (f) your personal data may, alternatively, be processed until you withdraw your consent or until ten years after you have ceased to be a client of NOMINALIA, or you have registered on the Site but have not bought a product or service.
In any case, Nominalia has the right to retain your personal data for the periods set out in the Spanish law to protect their interests. More information about the data retention periods and the criteria for defining such periods can be requested from the Data Protection Officer of NOMINALIA.
8. Rights of the Owner of the Personal Data
You have the right to request access to your personal data from NOMINALIA at any time, and to correct or delete them, as well as to object to the processing; you have the right to request a limitation on the processing in the case of Article 18 RGPD, and you have the right to obtain, in a commonly used, structured and readable format, the data relating to you, in accordance with article 20 RGPD.
Applications can be sent, either in writing in the section "Clients", or by sending an email to Iinfo@nominalia.com.
Portability. This right applies to both your personal data provided and automatically generated for each of the products and services of NOMINALIA.
The portability request will be dealt with within 30 days of its receipt (in exceptional cases, within a maximum period of 3 months, justifying the extension). You can ask NOMINALIA to forward the data directly; and you can also request it be sent to another service provider. In this case, NOMINALIA reserves the right to verify that this is technically possible. You are hereby informed that the new provider to which you want to forward your data does not have the legal obligation to receive them. The data will be accessible on a server via sFtp.
The portability does not automatically delete the data stored in NOMINALIA's system, nor does it affect the data retention period planned for the data transmitted; however, we recommend that you correctly carry out the portability before closing your account or withdrawing from the contract of service signed with NOMINALIA, so as not to run the risk that the data are no longer present in our systems. The data you provide will be that existing at the time of receipt of the request for portability. If the portability requested also includes third-party data and involves communication of data to a different holder, you guarantee to us, assuming sole and complete responsibility, that you have informed such third parties in advance and that you are in possession of the necessary consents.
In case of requests from owners related to abuse of the use of the Services or Spam, prohibited by contract as indicated in the General Conditions of Service, carried out by a customer of NOMINALIA (please consider that the client usually acts as Processing Controller in accordance with the RGPD) and, in the case of any subsequent application for the exercise of the rights referred to in article 15 RGPD and concordant, NOMINALIA, without going into the details of the application may, on the one hand, immediately inform the customer / processing controller, and on the other hand, give the owner of the contact details and details of the client / processing controller.
In any case, you always have the right to file a complaint with the competent supervisory authority - Spanish Data Protection Agency- (Guarantor for the Protection of Personal Data), in accordance with the Article 77 of the Regulation, if it considers that the processing of the data is against the law
If the amendments involve substantial changes to the processing activities or may have a significant impact on interested parties, NOMINALIA will duly notify the interested parties.
Most recent update: 30/10/2022