BrightMinds Hub, LLC (“The Stratega”) is a leading provider of cloud Web hosting services as well as domain registration and management services.
We highly value our customer’s privacy and care about protecting the personal information of our customers and visitors who use our websites, products, or services (collectively, our “Users”)
You can learn more about our organization at https://thestratega.com.
For the sake of this policy, the covered entities to which it is applied are:
Our website – https://thestratega.com
Our blog – https://thestratega.com/blog
Information We Collect From You
Like most website operators, The Stratega collects non-personally-identifying information of the sort that web browsers and servers typically make available such as:
- Browser Type
- Language Preference
- Referring Site
- Date & Time of each visitor request
- Pages Your View
Our purpose to collecting non-personally identifying information is to better understand how The Stratega’s visitors use its website.
The Stratega also collects potentially personal-identifying information like:
- Email address
- Personal website URL
- Internet Protocol (IP) address for logged in users
- Internet Protocol (IP) address for users placing an order
- Internet Protocol (IP) address for users leaving comments on our blog
- The Stratega only discloses logged in user and commenter IP addresses under the same circumstances that it uses and discloses personally-identifying information as described below, except that blog commenter IP addresses and email addresses are visible and disclosed to the administrators of the blog where the comment was left.
Signing Up For Services; User Information
To provide web hosting services and/or domain registration/management we obtain the following information about you as described below:
- Information you provide prior to any registration process, such as your email when you provide it to us;
- Information that you provide during any registration process (such as your name, company name, email address, phone number, billing address, or credit card information, geographic location and industry), when you call or email us (for support or otherwise) or when you use our products or services; and
- Payment information that you provide to us (by way of our Service or otherwise) when you purchase some of our products and services, including credit card data.
When you purchase Domain Registration services for top level domains (TLDs), as the domain registrar, we are required to collect the following personal information from you (collectively, “Personal Information”):
- Registrant Name
- Registrant Organization (where applicable)
- Registrant Address
- Registrant Email
- Registrant Fax (where applicable)
- Registrant Phone number
- Administrative Contact
- Administrative Contact Organization (where applicable)Administrative Contact Address
- Administrative Contact Email
- Administrative Contact Fax (where applicable)
- Administrative Contact Telephone Number
- Technical Contact
- Technical Contact Organization (where applicable)
- Technical Contact Address
- Technical Contact Email
- Technical Contact Fax (where applicable)
- Technical Contact Telephone Number
- Billing Contact
- Billing Contact Organization (where applicable)
- Billing Contact Address
- Billing Contact Email
- Billing Contact Fax (where applicable)
- Billing Contact Telephone Number
Our collection of Personal Information is necessary to comply with contractual obligations we have with the Internet Corporation for Assigned Names and Numbers (“ICANN”) and with certain TLD registries (“Registries”) so that you can validly register your domain name. In addition to Personal Information, our contracts with some Registries may require us to collect other personal information for the registration of a TLD such as certain professional affiliations, identification or other qualifiers (“Additional Personal Information”).
Disclosure Of Information
Public Whois. Our contracts with ICANN and other Registries require us to make certain domain name information (“WHOIS Information”) available and accessible to the public through a searchable port 43 “WHOIS” Service via a public webpage operated by the applicable registrar of record (“WHOIS Site”). The WHOIS Site is a publicly accessible database that lists WHOIS Information, including a particular domain name, the name server(s) to which the domain name points, and the domain name’s creation and expiration date. Except for EU/EEA natural persons (as described below), your Personal Information could be displayed on the WHOIS Site.
EU/EEA natural persons. Notwithstanding the foregoing, pursuant to the European Union’s General Data Protection Regulation 2016/679, or GDPR, if you are a EU/EEA natural person (as defined by the GDPR), other than as specified in this addendum, our publication of WHOIS Information will not contain any Personal Information. Accordingly, we will not display Personal Information of a EU/EEA natural person on the WHOIS Site.
Transfer Out. If you initiate a transfer out of a domain name away from us as the registrar of record, pursuant to our contract with ICANN, we may need to publish your registrant email address obtained from your Personal Information on the WHOIS Site for a period of approximately five (5) calendar days. After this period and assuming a valid transfer has occurred, you would cease to be our customer for that domain name and your WHOIS Information would be managed by the gaining registrar.
Certain Registries. Registries are third party providers of TLDs that are independent of domain registrars. If required by contract with a particular Registry, we may be obligated, as a domain registrar of domains provided by the Registry, to provide Personal Information and Additional Personal Information to such Registry to successfully complete your domain name registration. If we provide your Personal Information and Additional Personal Information to a Registry, the Registry has its own obligation to comply with applicable data privacy laws.
Data Escrow. Our contract with ICANN requires us to deposit the Personal Information collected with a secure third-party escrow provider who acts solely as a holder of the data.
Permitted Disclosures. We may also disclose your Personal Information when required by the rules, regulations and policies of ICANN, including but not limited to the Uniform Domain-Name Dispute-Resolution Policy (UDRP).
We store this data we collect in a variety of places within our infrastructure, including system log files, back end databases and analytics systems.
Protection Of Certain Personally Identifying Information
The Stratega discloses potentially personally-identifying and personal-identifying information only to those of its employees, contractors, and affiliated organizations that:
- Need to know that information in order to process it on The Stratega’s behalf
- Provide services available at The Stratega’s website and;
- Have agreed not to disclose it to others
- Some of those employees, contractors, and affiliated organizations may be located outside of your home country; by using The Stratega’s website, you consent to the transfer of such information to them.
- The Stratega will not rent or sell potentially personally-identifying information to anyone.
- Other than to its employees, contractors, and affiliated organizations, as described above, The Stratega discloses potentially personally-identifying and personally-identifying information only in response to a subpoena, court order, or other governmental request, or when The Stratega believes in good faith that disclosure is reasonably necessary to protect the property or rights of The Stratega, third parties, or public at large.
- If you are a registered user of The Stratega and have supplied your email address, The Stratega may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with The Stratega and our products.
- We primarily use The Stratega blog and social media channels to communicate this type of information, so we expect to keep this type of email to a minimum.
- If you send us a request (for example via s support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users.
- The Stratega takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personal-identifying information.
How We Use Your Information
We have a legitimate interest in running a successful and efficient business and in providing you with Services and useful content, and we use the information we collect, both on its own and combined with any other information we collect about you, for the following purposes:
- To provide the requested Services to you;
- To provide you with useful content;
- To ensure the proper functioning of our Services
- To offer and improve our Services;
- To provide you with requested information or technical support
- To facilitate your movement through our websites or your use of our Services;
- To do a better job of advertising and marketing our Services (our use of your information to do this is performed with your consent where required by applicable law);
- To advertise and market third party products and services (such advertisement is only performed with your permission where your consent is required by applicable law)
- To diagnose problems with our servers or our Services;
- In connection with our security and compliance programs;
- To administer our websites;
- To communicate with you;
- To target prospective customers with our products or services (such targeting is only performed with your permission where your consent is required by applicable law);
- To assist us in offering you a personalized experience or otherwise tailor our Services to you; and
We also use the information we receive in aggregated and anonymized formats to produce reports on trends and statistics, such as mobile search trends, email open rates by industry, campaign best practices or the number of users that have been exposed to, or clicked on, our websites or evaluated or purchased our products and services.
Payment information that you provide to us, including credit card data, will only be used to facilitate payment for our products and services.
We also use recorded telephone conversations for quality control purposes, to train our employees and for our own protection.
How We Shared Information
The Stratega may share personal data with third parties in order to provide a better service.
- Advertising – Based on the cookies and other tracking devices, we may work with advertising companies to display ads that may be of interest to you.
- Business Transactions – To provide information to a third party in the event of any disposition of all or any portion of our business (e.g. reorganization, sale, assignment, bankruptcy).
- Aggregated or De-identified Data – We may disclose or use aggregated or de-identified information with third party providers for research purposes relating to our Services.
- As Required by Law or Similar Investigations – To comply with legal obligations (e.g. subpoena) or investigate potential legal violations. The Stratega may be required to share personal data in response to lawful requests from public authorities including to meet national security and/or law enforcement requirements.
- Safety – We may disclose your information to protect and defend the safety of The Stratega in connection with investigating and preventing fraud or security issues.
- Consent – The Stratega may share your information with your consent.
You may unsubscribe from receiving promotional or marketing emails from The Stratega at any time by using the “unsubscribe” link in the email received, or by emailing us at [email protected]. As outlined in the Section, Cookies and other Tracking Technologies, you can also control your cookie settings.
With respect to your account information, you may update, correct or delete information that you provided to us by logging into your The Stratega account or contacting us at [email protected].
For individuals in the EEA, The Stratega’s legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. The Stratega will process personal information from you where, a) we have your consent to do so, b) where processing is necessary for The Stratega to perform Services pursuant to an agreement, or c) where processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information, or may otherwise need the personal information to protect your vital interests or those of another person. At any time, you have the right to withdraw or decline consent. If you do not provide the requested information, The Stratega will not be able to perform Services for you. Also, you have the right to object where we rely on our legitimate interests to process your personal information.
If The Stratega, or substantially all of its assets, were acquired, or in the unlikely event that The Stratega goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of The Stratega may continue to use your personal information as set forth in this policy.
Individuals located in the EEA may have additional statutory rights available to them with respect to their personal information, including the right to access your personal information, have it erased, have it corrected, or object to or restrict processing. If you would like to make such a request, please email [email protected] and we will respond within thirty (30) days. The Stratega will need to verify that the individual is inquiring about his/her own information before we can assist with the request.
Our Website and/or Services is not directed at children and our services are designed for businesses. We do not knowingly collect information from or about children under 13 years of age, and use of our services by children under 13 years of age is forbidden.