Last Updated: 30 July 2018
VeriSign, Inc. (“Verisign”) respects Consumers’ concerns about privacy. Verisign participates in the EU-U.S. and Swiss-U.S. Privacy Shield frameworks (collectively, the “Privacy Shield”) issued by the U.S. Department of Commerce. Verisign commits to comply with the Privacy Shield Principles with respect to Consumer Personal Data Verisign receives from the EU and Switzerland in reliance on the Privacy Shield. This Policy describes how Verisign implements the Privacy Shield Principles for Consumer Personal Data.
For purposes of this Policy:
"Consumer" means any natural person who is located in the EU or Switzerland, but excludes any individual acting in his or her capacity as an Employee.
“Controller" means a person or organisation which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
"Customer" means any entity for which Verisign provides products and/or services, such as without limitation, ICANN approved registry services, DDoS protection services or managed DNS services.
"Employee" means any current, former or prospective employee, contractor, intern or temporary worker of Verisign or any of its EU or Swiss affiliates, or any related individual whose Personal Data Verisign processes in connection with an employment relationship, who is located in the EU or Switzerland.
"EU" means the European Union and Iceland, Liechtenstein and Norway.
"Personal Data" means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by Verisign in the U.S. from the EU or Switzerland, and (iii) recorded in any form.
"Privacy Shield Principles" means the Principles and Supplemental Principles of the Privacy Shield.
"Processor" means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.
"Sensitive Data" means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (including trade union-related views or activities), sex life (including personal sexuality), information on social security measures, the commission or alleged commission of any offence, any proceedings for any offence committed or alleged to have been committed by the individual or the disposition of such proceedings or the sentence of any court in such proceedings (including administrative proceedings and criminal sanctions).
Verisign’s Privacy Shield certification, along with additional information about the Privacy Shield, can be found at https://www.privacyshield.gov/. For more information about Verisign’s processing of Consumer Personal Data collected by Verisign from Consumers’ when visiting Verisign’s websites, please visit Verisign’s Privacy Statement located at http://www.verisign.com/en_US/privacy/index.xhtml.
Types of Personal Data Verisign Collects
Verisign serves as both a Controller and a Processor with respect to the Consumer Personal Data it obtains and maintains.
As a Controller, Verisign obtains Personal Data about Consumers in various ways. For example, Verisign collects Personal Data from Consumers when they visit Verisign’s websites. Verisign may use Personal Data from Consumers collected when the Consumer visit Verisign’s websites for the purposes indicated in Verisign’s Privacy Statement located at http://www.verisign.com/en_US/privacy/index.xhtml. The Verisign Privacy Statement may be updated from time to time as Verisign changes the types of Personal Data that it collects from Consumers.
In addition, Verisign obtains Personal Data from representatives of current and prospective Customers, such as contact information and payment or financial account data. Verisign uses this information to manage its relationships with current and prospective Customers, process payments and carry out Verisign’s obligations under its contracts with Customers.
Verisign also obtains Personal Data of its vendors’ and service providers’ representatives. The information obtained may include contact information and payment or financial account data. Verisign uses this information to manage its relationships with its vendors and service providers, process payments and carry out Verisign’s obligations under its contracts with these parties.
Verisign also obtains and use Consumer Personal Data in other ways for which Verisign provides specific notice at the time of collection.
As a Processor, Verisign may receive Consumer Personal Data in connection with providing services to its Customers, including Personal Data of domain name registrants that may be contained in WHOIS information received from Customers, managed DNS requests and encrypted data flows that transit Verisign systems in connection with the provision of online security services to its Customers, such as during a DDoS attack.
Verisign’s privacy practices regarding the processing of Consumer Personal Data comply with the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security;
Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability, each as further described below.
Verisign provides information in this Policy and Verisign’s Privacy Statement located at http://www.verisign.com/en_US/privacy/index.xhtml about its Consumer Personal Data practices, including the types of Personal Data Verisign collects, the types of third parties to which Verisign discloses the Personal Data and the purposes for doing so, the rights and choices Consumers have for limiting the use and disclosure of their Personal Data and how to contact Verisign about its practices concerning Personal Data.
When Verisign acts as a Processor and Consumer Personal Data is transferred to Verisign in the U.S. by, or on behalf of, a Customer, the Customer is responsible for providing appropriate notice to its Consumers and ensuring it is collecting such the Personal Data under a lawful basis such as for example, obtaining the Customer’s requisite consent.
Relevant information also may be found in notices pertaining to specific data processing activities.
When Verisign collects Consumer Personal Data in its role as a Controller, Verisign generally offers the relevant Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorised by the relevant Consumer. To the extent required by the Privacy Shield Principles, Verisign shall obtain opt-in consent for certain uses and disclosures of Sensitive Data. These Consumers may contact Verisign as indicated below regarding Verisign’s use or disclosure of their Personal Data. Unless Verisign offers these Consumers an appropriate choice, Verisign uses Personal Data only for purposes that are materially the same as those indicated in this Policy.
When Verisign obtains Consumer Personal Data in its role as a Processor for its Customers, Verisign’s Customers are responsible for providing appropriate notice to its Consumers and ensuring it provides the relevant Consumers with certain choices with respect to the Customers’ use or disclosure of the Consumers’ Personal Data.
Verisign shares certain Consumer Personal Data with its affiliates and subsidiaries. Verisign may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data: (i) to third-party Processors Verisign has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from governmental authorities, including to meet national security, governmental interest or law enforcement requirements. Verisign also reserves the right to transfer Consumer Personal Data in the event of an audit or if Verisign sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganisation, dissolution or liquidation).
Accountability for Onward Transfer of Personal Data
This Policy and Verisign’s Privacy Statement http://www.verisign.com/en_US/privacy/index.xhtml describe Verisign’s sharing of Consumer Personal Data.
To the extent Verisign acts as a Controller, except as permitted or required by applicable law, Verisign shall provide Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. Verisign requires third-party Controllers to whom it discloses such Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and (iii) notify Verisign and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Privacy Shield Principles.
With respect to transfers of Consumer Personal Data to third-party Processors, Verisign (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the Privacy Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Verisign’s obligations under the Privacy Shield Principles, (v) requires the Processor to notify Verisign if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorised processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. Verisign remains liable under the Privacy Shield Principles if Verisign’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Verisign proves that it is not responsible for the event giving rise to the damage.
Verisign takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.
Data Integrity and Purpose Limitation
Verisign limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. Verisign does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorised by the relevant Consumer. In addition, to the extent necessary for these purposes and consistent with its role as a Controller or Processor, Verisign takes reasonable steps to ensure that the Personal Data Verisign processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, Verisign relies on its Consumers and Customers (with respect to Personal Data of Consumers with whom Verisign does not have a direct relationship) to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorised. Consumers (and Customers, as appropriate) may contact Verisign as indicated below to request that Verisign update or correct relevant Personal Data.
Subject to applicable law, Verisign retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorised by the Consumer.
Consumers generally have the right to access their Personal Data. Accordingly, to the extent Verisign acts as a Controller, where appropriate, Verisign provides Consumers with reasonable access to the Personal Data Verisign maintains about them. Verisign also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. Verisign may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer’s privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting Verisign as indicated below.
When Verisign obtains Consumer Personal Data in its role as a Processor for its Customers, Verisign’s Customers are responsible for providing Consumers with access to the Personal Data and the right to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. In such circumstances, Consumers should direct their questions to the appropriate Verisign Customer. When a Consumer is unable to contact the appropriate Customer, or does not obtain a response from the Customer, Verisign will provide reasonable assistance in forwarding the Consumer’s request to the Customer.
Recourse, Enforcement and Liability
Verisign has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. Verisign conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions Verisign makes about its Privacy Shield privacy practices are true and that Verisign’s privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.
Consumers may file a complaint with Verisign concerning Verisign’s processing of their Personal Data. Verisign will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Consumers may contact Verisign as specified below about complaints regarding Verisign’s Consumer Personal Data practices.
If a Consumer’s complaint cannot be resolved through Verisign’s internal processes, Verisign will cooperate with JAMS pursuant to the JAMS Privacy Shield Programmeich is described on the JAMS website at https://www.jamsadr.com/eu-us-privacy-shield. JAMS mediation may be commenced as provided for in the JAMS rules. Following the dispute resolution process, the mediator or the Consumer may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about Verisign’s compliance with the Privacy Shield Principles.
When Verisign obtains Consumer Personal Data in its role as a Processor for its Customers, Consumers may submit complaints concerning the processing of their Personal Data to the relevant Customer, in accordance with the Customer’s dispute resolution process. Verisign will participate in this process at the request of the Customer or the Consumer.
How to Contact Verisign
To contact Verisign with questions or concerns about this Policy or Verisign’s Consumer Personal Data practices or to file a complaint:
12061 Bluemont Way
Reston, VA 20176
Attn: Privacy Committee