[The English version of the legal agreements and policies is considered the only
current and valid version of this document. Any translated version(s) is provided for
your convenience only and is not legally binding and cannot replace the English
versions. In the event of disagreement or conflict, the English language legal
agreements and policies shall prevail.]
- INTRODUCTION
Truehost Cloud Ltd. (“Truehost”, “Truehost Cloud”) provides you with web-hosting,
domain name registration, and other related online products and services
(“Services”).
We strive to offer the highest level of data privacy to you when offering these
services. We are committed to protecting the data you share with us at all times.
This Privacy Policy (“Policy”) explains how Truehost processes information that can be
used to directly or indirectly identify an individual (“Personal Data”) collected on our
sites.
We collect your personal information with your knowledge and consent, and we use
your personal information that we collect to access, update, or otherwise take
control of your services with us.
We do not onboard minors (any person under 18 years of age) except where you
additionally register on their behalf as their parent and/ or legal guardian. If you
allow a child to use our services, you should be aware that their personal information
could be collected as described in this statement.
All personal data is processed in accordance with the Data Protection Regulations of
the markets we operate in, notably Kenya, South Africa, India, United States, Nigeria,
among others.
This policy can be amended at anytime. It is your obligation to always be on the
lookout for any material updates. However, if major amendments are made, we will
strive to update you via email.
For any questions concerning this policy or requests regarding the processing of
personal data, please contact us at [email protected]. - DATA PROCESSING PRINCIPLES
Truehost processes all personal data with strict adherence to general data processing
principles. We process personal data in a manner that ensures appropriate security of
the personal data, including protection against unauthorized or unlawful processing
and against accidental loss, destruction, or damage, using appropriate technical or
organizational measures.
All and any information in our possession is treated as strictly confidential. All
information is stored securely and is accessed by qualified and authorized personnel
only. - WHAT INFORMATION DO WE COLLECT?
3.1. Necessary information to enable you to use our platforms.
Such information is necessary for the adequate performance of the contractual
obligations that are in place between you and us and to allow us to comply with our
legal obligations. Failing to provide any of this data or a decision to delete or object to
the processing of any of such data may result in the de-activation of your Truehost
Account and/or our inability to meet our legal and contractual obligations to you and
legal establishments.
● Account Signup Information. Upon sign-up, you need to provide the minimum
information – email address, password, first and last name, identity
verification, contact details, etc. This information is necessary when you are
registering a domain. It is called WHOIS information. We do not store account
sign-up passwords on our platforms as this is exclusively known to you.
However, should you lose or forget your account signup password, we are able
to send you a password reset link to your registrant email.
● Login information We collect login and email scope from Google and email
from Facebook.
● Payment Information When paying for services, we may require you to
provide certain financial information in order to facilitate the processing of
payments. We do not collect or store credit card information. We use third
party payment gateways to process payments and, as such, we do not collect
or store such information. Extra caution is taken by us so that you are able to
make payments to us securely. However, it is your obligation to ensure that
you take care and precaution when making payments online.
● Calls, chats, messaging, and emails, among other communication channels.
When you make enquiries with us, we collect information about your
communication and any information you choose to provide or disclose. In
order to respond to your request, we may access information provided in your
Truehost Account, purchase history, or any other platform.
● Visitors- We may also collect information pertaining to our websites’ visitors
solely for our own use.
You may choose to provide us with information when you fill in a form, conduct a
search, update or add information to your Truehost account, respond to surveys, post
to community forums, participate in promotions, or use other features of our
platforms. We strongly recommend that you do not post/share information you
deem private on public platforms. If you do so, it is at your own risk.
Disclaimer
To protect your personal information, please observe the following at the bare
minimum:
● avoid using your name, address, telephone number, e-mail, personal
identification number, date of birth, bank account number, card number, other
special (sensitive) data, etc. in the subject of the request or file name;
● omit using your personal code, payment card number, and other financial
information and details, health, family member details, or other specific
(sensitive) data, in the texts of requests, e-mails or similar communication to
us, and
● please make sure that the remaining personal data is only indicated to the
extent necessary for the purposes for which the letter, request or inquiry is
sent.
Right to delete/amend your data.
You may at any time access and edit, update or delete your contact details by logging
into your Truehost Account.
To delete your account, please send an email request to [email protected] for
further advice.
3.2. Information We Collect When You Use Our Platforms
When you use the Truehost platforms or contact us directly through any
communication channel, we may collect information, including personal information,
about the services you use and how you use them.
This information is necessary for the adequate performance of the contract between
you and us, to enable us to comply with legal obligations and given our legitimate
interest in being able to provide and improve the functionalities of our services.
Data is collected automatically.
● Log data and device information. We automatically collect log data and device
information when you access and use the Truehost Platform, even if you have
not created a Truehost Account or logged in. That information includes, but is
not limited to: Internet Protocol (IP) addresses, browser type, Internet Service
Provider (ISP), referring/exit pages, operating system, date/time stamp and/or
clickstream data.
● Tracking technologies and cookies We use cookies, beacons, tags, scripts, and
other similar technologies, such as CI codes (click tracking), ISC (source
tracking), and ITC (item tracking codes). We also automatically collect
information about the device’s operating system, phone model, device ID and
customer number.
● Usage information. We use a tool called “Google Analytics” to collect
information about your interactions with the Truehost Platform (what pages
you visit, such as the pages or content you view, your searches for listings,
bookings you have made, and other actions on the Truehost Platform). As a
consequence, Google, Inc. plants a permanent cookie on your web browser to
identify you as a unique user the next time you visit this site.
● Geo-location data. We collect information about your approximate location as
determined by data such as your IP address to offer you an improved user
experience and comply with applicable legal requirements, such as taxes,
pricing, etc. Such data may be collected only when you access the TrueHost
platform using your device.
We process this information on the legal basis of:
● Your consent;
● Conclusion and performance of contractual arrangements and obligations
between Truehost and the User;
● Pursuance of legitimate interests of Truehost, as Data Controller and manager
of Truehost platform.
- HOW DO WE USE YOUR DATA?
We use, store, combine, and process information, including personal information,
about you to provide, understand, improve, and develop the Truehost Platform,
create and maintain a trusted and safer environment, and comply with our legal
obligations.
● User identification- the information collected is for user identification
purposes only.
● To create and maintain a trusted environment. We verify or authenticate
information or identification provided by you (such as ID numbers, email or
phone numbers). We also use collected information to detect and prevent
fraud, spam, abuse, security incidents, and other illegal and harmful activities.
● To create aggregated statistical data, to carry out market research and
analysis necessary for running our business, and to improve our services, we
use aggregated and/or inferred non-personal information, enabling us to
evaluate our customers’ needs, sales, and other trends in our activities.
● To stay connected and improve your experience. We use information about
data usage, devices, operating systems to diagnose problems with our servers,
to administer our Platform, adopt decision when to retire SDK’s/OS versions,
to identify characteristics of major users so that we may optimize our
applications and services and make your browsing and purchasing experience
more enjoyable.
● To Customize Marketing. To provide more customized offers to our users, we
may conduct data analysis based on information you provide to us and your
interactions with the Truehost Platform and its users.
● To Send Service and Billing Messages. Truehost may also contact you with
important information regarding our services or your use thereof.
● To Register a Domain. In certain jurisdictions or pursuant to the rules of the
ICANN or certain registries, domain name registration information has to be
made available and accessible to the public through a “WHOIS” search. See
more about WHOIS here. Truehost may deposit your domain name
registration information with a third-party escrow provider to comply with
ICANN requirements.
● To contact you. In order to notify you regarding your account, to troubleshoot
problems with your account, to resolve a dispute, to collect fees or money
owed, etc. We may contact you via email, telephone, text messages, and
portal.
● To get feedback. We may contact you via email to invite you to review any
services and/or products you may have received from us in order to collect
your feedback and improve our services. We might use an external company
to collect your feedback which means that we will share your name, email
address and reference number for this purpose.
● To provide, operate and improve the services.
● To enhance data security and to prevent fraud.
● To comply with applicable laws and regulations.
- DIRECT MARKETING
When creating an Account with us, you are free to opt-out from receiving various
offers directly to your email, phone or in your Account. We use the provided contact
details and your preferences for direct marketing by sending various offers or
newsletters.
These direct marketing offers, depending on your preferences, may be personalized
on the basis of any other information that you have provided to us (location, social
media profile information, purchase history, etc.) or that we have collected or
generated from other sources.
Right to object
You may change your preferences for direct marketing at any time by following the
instructions to unsubscribe in the received email.
You are free to opt out of our newsletters at any time. You can do this by clicking on a
link for that purpose at the bottom of our e-mail with the newsletters.
You may at any time refuse to receive information from us by sending an email to
[email protected] or by visiting and adjusting your personal account settings.
- OTHER USES OF YOUR PERSONAL DATA
● Developing Platform. We use data, including public feedback, to conduct
research and development for the further development of our platform in
order to provide you and others with a better, more intuitive, and personalized
experience and drive membership growth.
● Customer Support. We use data to help you and fix problems. We use the data
(which can include your communications) to investigate, respond to and
resolve complaints and issues (e.g., bugs).
● Aggregate Insights. We use data to generate aggregate insights. We use your
data to produce and share aggregated insights that do not identify you.
● Security and Investigations. We use data for security, fraud prevention, and
investigations. We use your data (including your communications) if we think
it’s necessary for security purposes or to investigate possible fraud or other
violations of our Terms of User or this Policy and/or attempts to harm our
users. - SOURCES OF PERSONAL DATA
We collect and receive your personal data from you (including your device) as well as
from the following sources:
● Social network operators (such as Facebook, Google, etc.);
● Third-party service providers, suppliers and our partners;
● Other legal sources. - RETENTION AND DELETION
Generally, we retain your personal information for as long as is necessary to provide
our services and to comply with our legal obligations. Where your personal
information is no longer required, we will ensure it is securely deleted.
If you would like to stop us using your personal information, you may request that we
erase your personal information and close your TrueHost account.
After deactivation of Account, we will still retain the following data for the purposes
of compliance with applicable legal requirements (such as tax, accounting, legal
reporting, Anti-Money Laundering (AML), other), for as long as we are legally
required by virtue of such legal requirements.
Please also note that we may further retain some of your personal information in
such cases (i.e., after the closure of your Truehost Account):
● as long as it is necessary for our legitimate business interests, such as fraud
detection and prevention and enhancing safety. If Truehost suspends your
Truehost Account for safety reasons, we may retain certain information from
that Truehost Account to prevent that user from opening a new Truehost
Account in the future;
● the extent necessary to comply with our legal obligations. Truehost may keep
some of your information for tax, legal reporting, and auditing obligations;
● forum posts or other publicly visible information may continue to be publicly
available on the Truehost Platform, even after your Truehost Account is
deactivated. However, attribution of such information to you will be removed.
Additionally, some copies of your information (e.g., log records) may remain in
our database but are disassociated from personal identifiers;
● to resolve disputes;
● to enforce our agreements and/or pursue or protect our legitimate interests;
● as we protect the Truehost Platform from accidental or malicious loss and
destruction, residual copies of your personal information may not be removed
from our backup systems for a limited period of time;
● domain name registration data – in order to register a domain, we are asked to
provide personal information about the owner of the domain; this information
is shown in the WHOIS directory and is public. For more information, please
see here. - DATA TRANSFERS AND USE OF THIRD-PARTY SERVICES
While collecting and processing your personal data, we may perform data transfers to
various third parties.
9.1. With your consent.
We will share your personal data with companies, organizations, or individuals
outside our group of companies when we have your consent to do so.
9.2. Where do we process your personal data?
● Users’ personal information may be maintained, processed, and stored by
Truehost and our authorized affiliates and service providers in different
jurisdictions as necessary for the proper delivery of our services and/or as may
be required by law (as further explained below).
● Truehost affiliates and service providers (such as third-party data centres,
servers, website design, administration services, online traffic and website
analysis, statistics, direct marketing services, mailers, messengers, etc.), that
store or process your personal data as well as personal data of your users on
Truehost’s behalf are each contractually committed to keep it protected and
secured, in accordance with industry standards and regardless of any lesser
legal requirements which may apply in their jurisdiction (see below).
● Domain name registration data and identification data are shared with third
parties in accordance with ICANN rules. For more information see here.
We may share non-personally identifiable information publicly as well as with our
partners – publishers, advertisers. For example, we may share information publicly to
show trends about the general use of our platform.
If we are involved in a merger, reorganization, acquisition, or sale, we will continue to
ensure the confidentiality of any personal data and give all affected users appropriate
notice.
Some of our servers are located in different jurisdictions, such as the EU, US, Kenya,
Nigeria, South Africa, etc. Therefore, depending on your choice or the services, your
personal data as well as the personal data of your users might be transferred to
processors, sub-processors or other data recipients established in such third
countries. However, we will ensure that the said personal data will be transferred
only if there is a sufficient basis for this under the GDPR and other applicable legal
acts.
9.3. Targeting, advertising,
We also use Facebook, Google, and other advertising and marketing tools. You should
carefully read the privacy policies of these service providers. For more information on
targeted advertising, as well as your opt-out rights and other rights, see Facebook
and Google.
9.4. Social Media Features
Our Services include certain Social Media features and widgets, single sign on
features, such as the “Facebook Connect” or “Google Sign-in”, the “Facebook Like”
button, the “Share this” button or other interactive mini-programs (“Social Media
Features”). These social media features may collect information such as your IP
address or which page you are visiting on our website, and may set a cookie to
enable them to function properly. Social Media Features are either hosted by a third
party or hosted directly on our Services. Your interactions with these third parties’
social media features are governed by their respective policies.
9.5. Our Legal Obligation to Use or Disclose Personal Data
We will disclose your personal data to state and public authorities without your prior
permission only when we are legally required to provide information, including taking
legal action to defend our rights, as well as in cases, where we have a belief (in good
faith) that access, use, preservation, or disclosure of the information is reasonably
necessary to meet any applicable law, regulation, legal process, or enforceable
governmental request, enforce applicable Terms of Services, including investigation
of potential violations, detect, prevent, or otherwise address fraud, security, or
technical issues.
9.6. Other
We may share your personal data in ways other than as described above, pursuant to
your explicit consent or if we are legally obligated to do so.
- SECURITY MEASURES TO PROTECT YOUR INFORMATION
Truehost has implemented security measures designed to protect the personal
information you share with us, including physical, electronic, and procedural
measures. Among other things, we offer HTTPS secure access to most areas of our
services. We also regularly monitor our systems for possible vulnerabilities and
attacks and regularly seek new ways and Third-Party Services for further enhance the
security of our services and protect our visitors’ and users’ privacy.
Regardless of the measures and efforts taken by Truehost, we cannot and do not
guarantee the absolute protection and security of your personal information or any
other user content you upload, publish, or otherwise share with Truehost or anyone
else.
We therefore encourage you to set strong passwords for your user account and avoid
providing us or anyone with any sensitive information about which you believe its
disclosure could cause you substantial or irreparable harm.
If you have any questions regarding the security of our services, you are welcome to
contact us at [email protected]. - YOUR RIGHTS
You are entitled to a range of rights regarding the protection of your personal data,
which are subject to limitations, restrictions, and conditions.
When you object to the processing of your personal data when processing is carried
out on the basis of legitimate interest, we will carefully consider such a request,
which may result in your account closure or deactivation.
Users have the right to lodge a complaint with the national data protection agency in
their country of residence in the event that their rights may have been infringed.
However, we recommend attempting to reach a peaceful resolution of the possible
dispute by contacting us first. - ACCEPTANCE OF THIS POLICY
We assume that all users of Truehost Services have carefully read this document and
agree with its contents. If someone does not agree with this policy, they should
refrain from using our website and other platforms. We reserve the right to change
this. policy at any time. Continued use of Truehost’s website and services we offer
implies acceptance of the revised policy.
This policy is an integral part of TrueHost’s terms and conditions.
We will ask for your consent before using information for a purpose other than those
set out in this policy.
- CONTACTS
For all your requests or comments concerning this Privacy Policy, please contact:
[email protected] - APPLICATION OF POLICY
Our Policy applies to all of the services offered by us and our affiliates, including but
not limited to, Truehost Kenya, Truehost Nigeria, Truehost South Africa, Truehost US,
and Truehost India.
Our policy does not apply to services offered by other companies or individuals,
including products or sites that may be displayed to you in search results, sites that
may include our services or other sites linked from our services. - AMENDMENTS
Our policy may change from time to time. We will post any policy changes on our
website and, if the changes are significant, we may consider providing a more explicit
notice (including, for certain services, email notification of policy changes).
FREQUENTLY ASKED QUESTIONS.
- Why expose client information/domain on WHOIS?
Client information is mandatory for all domains from the registry. This is the industry
standard globally. However, we also offer WHOIS Privacy/ID Protection. Note that,
depending on your market, this may be a billed service. You may need to consult our
Support Team on this. Please see this link on why client information is shared. - Should client details be accurate?
Yes, for communication purposes regarding your account management and general
communication purposes. - Can I delete my account at any time?
Yes, you are at liberty to delete your account. To do so, you need to send an email
request to [email protected]. Note that even after the account is deleted, we may
retain some of your details in our records for different reasons, as explained in
Section 8 above. - Can I change my client area account details?
You can always update/amend your account details at any time. You can do this by
logging into your account. See this guide. - Should the client’s information be factual?
Your client area details need to be correct and factual. We use this information to
identify, verify, and communicate with you. Also, the WHOIS information may also be
obtained from such details. - If I contracted someone and they registered/bought domain and/or hosting on
my behalf, can Truehost transfer the services to me?
Scenario: I am the owner of a business and I contracted a developer (employee) to
design and manage my website/emails. I paid the developer to purchase the domain
and/or hosting, which he did under his account. After some time, the developer and I
parted ways (or the employee is no longer with us) and I now need the services
under my account.
How do I go about it according to your policies?
The developer (employee) needs to request the transfer of the service to your email
address. He/she has to do it using their registered email address. However, if they are
not agreeing to do so, you can send the request email yourself, but you will have to
copy the developer and explain everything that is happening so that it’s transparent
to all 3 parties (you, the developer, and us). In this email you will provide all the
information that you can gather to assist in verifying that you indeed own this
service. From there, the Dispute team will reply to your email with the way forward.
- Can Truehost share some information with me, like the owner of a domain,
invoice amount, or any other account details pertaining to a domain or hosting, so
that I can contact the owner or make payment?
No, we do not share account or billing information with anyone who is not the
registered user. This would amount to a breach of privacy. You will need to reach out
to the said registrant using other means. - I got a call/email/WhatsApp message from someone who wants to design a
website for me, but I have not shared my details with anyone. How did they get my
number? Is Truehost sharing my contacts?
Truehost will not share your details with anyone except as stated under Section 9.5
above and as per industry obligations and compliance purposes, especially with
ICANN rules. When a domain name is registered, the registrant details are shared
with a global database called WHOIS. This is an industry practice. There are people
who are always checking the WHOIS database to get registrant details for different
reasons, some of which may be malicious.
We strongly advise that when you receive such messages/emails, kindly reach out to
us so we can advise you to either ignore or delete the same in totality.
You may also consider getting WHOIS Privacy/ID Protection to mask your WHOIS
details.
