GoDaddy - Conversations Privacy Notice

GoDaddy Conversations processes personally identifiable information (“PII”) consistent with the terms of GoDaddy’s Global Privacy Notice (set forth in Section B, below), which describes our core privacy practices and applies to all individuals regardless of where they live. We encourage you to review our Global Privacy Notice for a description of how we process personal information collected through GoDaddy Conversations.

A. GoDaddy Conversations App-Specific Processing of Contact Information

GoDaddy Conversations offers you the ability to share contact information stored in your mobile device to enhance the functionality of GoDaddy Conversations and improve its usefulness to you. We only process contact information with your affirmative opt-in consent. We do not use your contact information for our purposes.

B. GoDaddy Global Privacy Notice

GoDaddy empowers entrepreneurs everywhere, making opportunity more inclusive for all. We also empower you to manage your privacy preferences and exercise your privacy rights when visiting our website, using our services, and communicating with us. As described below,

• website visitors can manage their privacy preferences directly through this notice by visiting Manage Privacy Settings
• customers can manage their privacy preferences in their Account Settings page, and
• you can always reach us at privacy@godaddy.com or by mail at the addresses listed in the Contact Us section below to exercise your privacy rights.

This Global Privacy Notice describes our core privacy practices and applies to all individuals regardless of where they live. The laws in some places where we do business also require customized local privacy notices, which you can access through the following links:

• Europe (EEA/EU, UK, and Switzerland)
• United States (California and other States)

We encourage you to review your local customized notice if you live in one of these areas.

This global privacy notice covers personally identifiable information (PII) when we act as the data controller.

• PII identifies or could be used to identify a specific person, and any data about that person. For example, your name, address, and payment details are PII.
• We act as a controller when we process PII for our own use. For example, we act as a controller when you provide your PII to open an account.

This notice does not apply when you process PII for your own benefit. For example, when you send email for your business purposes that includes PII, you are acting as the “controller”. When you act as the controller, we act as the “processor” and process PII only in accordance with your instructions or as required by law.

This notice also does not apply to third-party applications offered through our services or linked through our website, such as Microsoft 365 and similar offerings. Please review the privacy notice of any third-party service or website before using it.

We recognize several core privacy rights:

• the right to know what PII we hold about you
• the right to access, correct, or delete your PII
• the right to transfer your PII (data portability)
• the right to set your marketing and advertising preferences

We promptly review requests to exercise privacy rights. If we need more information to process your request, we will contact you by email or, if we do not have an email address on file for you, by the same method you made your request.

If we do not honor your request for legal or other reasons, we will explain why we did not honor your request, your right to appeal, and your right to file a complaint (if available where you live).

1. PII You Provide
   
   We collect PII when you set up an account, use our services, or contact us. Examples of PII we may collect from you include your name, email, phone number, address, and payment method.
2. PII We Collect Automatically
   
   We collect PII automatically when you visit our websites, use our services, contact us, open our emails, or view our advertising. Examples of PII we may collect include your device ID, your IP address, information about web pages and other websites you visit, and other similar details.
3. PII from Other Sources
   
   We may collect PII about you from other sources. Examples of PII obtained from other sources include publicly available data, social media information, and information lawfully gathered by third party data providers.
4. PII We Generate
   
   We process data in connection with our business and services to generate inferences and insights that may be linked to you or your account.

We use PII to operate our business and provide services. Examples of how we use PII include:

• Managing accounts
• Processing purchase requests
• Registering domains you purchase
• Provisioning products and services you have requested or may be interested in using
• Providing customer support
• Securing, updating, and improving our services
• Detecting fraud and other illegal activity
• Customized marketing and personalized advertising of our services
• Contacting you by telephone, text or messaging applications to offer you services
• Website traffic measurement
• Other uses consistent with the purposes for which the PII was collected or that have been authorized by you

No Sale of PII

We do not sell PII.

We disclose PII:

• to processors to operate our business and deliver services, including but not limited to providing security services, payment processing and customer support; conducting contests and surveys; and performing other activities related to our business and services.
• to business partners to offer some services, such as email and payment processing.
• to marketers and advertisers who create personalized marketing and advertising messages.
• to comply with law enforcement and other legal requests, protect our legal rights, prevent harm to us or others, and enforce our policies and contracts.
• if we sell some or all of our assets or merge with a third-party we may transfer relevant PII to the buyer or new company.

We use three main “identifiers” on our website and in our services: cookies, web beacons, and scripts.

• Cookies are text files placed on your device when you visit our webpages or view messages from us. Some cookies are “session cookies” that expire at the end of your browser session, while others are “persistent cookies” that allow us to remember your preferences and settings over multiple visits and across other websites.
• Web Beacons are image files placed in our web pages and emails.
• Scripts are small pieces of computer code that power customer service tools, deliver video, and provide interactive experiences. We also use scripts for measuring service use.

We manage some identifiers directly. Other identifiers are managed by third parties. For example, we use Google Analytics to monitor site performance and visitor engagement.

We use identifiers to provide customized services, measure website performance, provide customer support, and deliver personalized advertising. Examples of how we use identifiers include, but are not limited to:

• Setting your service preferences
• Managing your shopping cart
• Guarding against fraud
• Delivering relevant advertisements
• Measuring website use
• Conducting research to improve our services

You can manage identifier settings by clicking on Manage Privacy Settings through the link in this notice. Customers can also manage their identifier settings for our website and our services through their customer account. We use optional and mandatory cookies and other identifiers. Optional cookies and other identifiers are used for support, website performance, and advertising. Mandatory cookies and other identifiers are used for account, verification, service continuity, security, and other functions necessary to provide our website and services.

In addition to our Manage Privacy Settings options, many web browsers allow users to block cookies (directly or through plugins and extensions). Some cookies, however, are essential for our website and services to function. If you set your browser to block all cookies, you may not be able to use our services.

Some web browsers provide a “Do Not Track” feature. There are no generally accepted standards for this feature and we do not respond to “Do Not Track” signals.

We also do not recognize any universal opt-out mechanism, such as the Global Privacy Control, which is still under development.

You can manage your marketing and advertising preferences, including whether you wish to receive customized marketing and advertising:

• Through this notice by clicking Manage Privacy Settings
• If you are a customer, through your Account Settings

We store PII on our own systems and with trusted service providers, including Amazon Web Services.

We transfer PII internationally to operate our business and provide services. We comply with applicable law when making international transfers.

For transfers of PII from the European Union/European Economic Area, Switzerland, and the United Kingdom, we have certified our compliance with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF), the Swiss-U.S. Data Privacy Framework, and the UK Extension to the EU-U.S. DPF, collectively (the “DPF”). Please see our Data Privacy Framework Notice for more information on our participation in the DPF Program.

Please see our European Data Protection Disclosures for more information pursuant to the DPF and other transfer mechanisms we use to transfer PII from the EU/EEA, Switzerland, and the UK.

We retain PII for our business needs and to comply with law. If we no longer need PII, we may delete it or de-identify it so that it no longer identifies a specific person. Factors we consider when deciding when to delete or de-identify your PII include: (1) if you still have an account, (2) if we are required to retain PII to comply with law, or (3) if the PII is needed for tax other business purposes.

We use risk-based measures to protect PII, including appropriate security controls and employee training. We also require that our service providers, business partners, and advertisers use appropriate risk-based controls to protect PII.

We do not knowingly collect PII about anyone under 18 without permission from their legal guardian. Please contact us at privacy@godaddy.com if you believe we have collected information from a child without permission from their legal guardian.

We process PII upon your request, with your consent, to fulfill our contract with you, based on our legitimate interest, or other lawful bases. The specific basis of processing depends on the services you are using, the data being processed, the place where the processing occurs, and the place where you live. If you have questions about our basis for processing your PII, please contact us at privacy@godaddy.com.

We will not discriminate against you for exercising your privacy rights.

No Financial Incentives

We do not provide any financial incentives for providing PII to us.

Policy Changes

We may revise this Global Privacy Notice by posting a revised statement at the same location as this Notice or on another location on our website. If we change this Notice, it will apply to personal data collected prior to adoption of the new statement only to the extent as the new statement does not reduce the rights of affected data subjects.

If you have any questions, you can contact us at privacy@godaddy.com or by mail at:

• United States: Attn: Office of the Data Privacy Officer, 100 S. Mill Ave, Tempe, AZ 85281 USA
• United Kingdom: Attn: Legal, Office of the Data Privacy Officer, 5th Floor, The Shipping Building, Old Vinyl Factory, 252-254 Blyth Road, Hayes, UB3 1HA.
• European Union (EEA) / Switzerland: Attn: Legal, Office of the Data Privacy Officer, GoDaddy c/o WeWork, Friesenplatz 4, 50672 Köln, Germany
• Asia: Attn: Office of the Data Privacy Officer, 80 Robinson Road #02-00 Singapore 068898

We respond to all questions or concerns within 30 days.