Tucows Privacy Policy

Purpose

This Tucows Privacy Policy sets out principles for the processing of Personal or Confidential Data by any Tucows employee or Tucows system.

Tucows' privacy principles (minimize, protect, delete, and disclose) are centred around data protection by design and by default. We build data protection into every project from the start; privacy controls are enabled by default instead of upon request. Tucows never sells Personal Data.

Definitions

● “Confidential Data” means any data held by Tucows or any of its subsidiaries which is not and should not be publicly available.

• "Data Subject" means an individual whose Personal Information is processed and, therefore, subject to Data Protection laws.

• "Personal Data" or "Personal Information" means any information relating to a Data Subject.

• "Processing" means any operation or set of operations which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization storage, adaptation, retrieval, alteration, consultation, use, disclosure, transmission dissemination, or otherwise.

• "Processor" means the entity that Processes Personal Information.

• "Subprocessor" means any Processor engaged by a Processor to Process Personal Information on its behalf.

Scope

This Policy governs the processing of Personal Data of Tucows employees and of Tucows’ third party stakeholders, including customers, prospects, partners, and end-users.

This Policy is applicable to Tucows offices and staff worldwide and is effective for the entire duration of data processing.

Policy

Tucows’ policy with regard to Personal Data can be summarized in four principles: minimize, protect, delete, and disclose.

Minimize what we collect, process, and disclose

We plan exactly what we want to do before we collect data and we process the least amount of personal data necessary.

Protect what we hold

We implement security controls appropriate to the level of sensitivity of the data, ensuring that Confidential or Personal Data cannot be accessed, altered, or erased without appropriate approval.

Delete data when we’re done with it

We don’t keep data forever. Each piece of data that we collect is assigned a lifetime and, when that time is up, we delete it. How long that lifetime lasts is determined collaboratively by the business.

Disclose what we do

We tell people what we’re doing with their data and we do what we said we would. This information is always available in our brand-specific Privacy Policies. If appropriate, we send emails reference. We respond promptly and helpfully when someone requests a copy of their data that we hold or when they need to correct inaccurate data on file.

Roles and Responsibilities

● All Tucows staff are responsible for following this and all other Tucows Policies.

● The Tucows Privacy Team

• The Legal Team reviews Data Protection Impact Assessments prior to completion.

• The Chief Legal Officer is ultimately responsible for the requirements of this Policy and for Tucows staff compliance with this Policy.

Have Questions?

If you have questions about this Policy, please reach out to the Data Protection Officer via dpo@tucows.com.