Data Request Policy

1. Privacy Notice. Please see SiteEngine’s Privacy Notice for further information on what
information SiteEngine collects, how it is used and when it may be disclosed. Subject to
SiteEngine’s Privacy Notice, this Data Request Policy describes the types of data requests
that SiteEngine may receive and how SiteEngine may respond to such requests.

2. Types of Requests. SiteEngine may receive the following types of requests concerning its
Subscribers:

a. Data Requests. A data request is a request for information or documents relating to
Subscriber accounts in connection with official criminal investigations or other legal
proceedings. Except in limited emergency situations (see below), SiteEngine
requires data requests to be made through formal U.S. legal process and procedures,
and such requests will be handled in accordance with applicable law. Examples of
acceptable data requests include:

i. Subpoenas

ii. Court Orders

iii. Search Warrants

iv. Legal process received from outside the United States may require a Mutual
Legal Assistance Treaty (MLAT) with the United States

v. Other forms of legal process such as Civil Investigative Demands

b. Preservation Requests. A preservation request asks SiteEngine to preserve
Subscriber account records in connection with official criminal investigations or other
official legal proceedings. Preservation requests must include the following information:

i. Identification of the account(s) at issue (as further described in Section 6 below);

ii. Identification of the investigating agency and/or specific pending official
proceedings (requests must be signed on law enforcement letterhead);

iii. Assurances that the requesting agency or individual is taking steps to obtain
appropriate legal process for access to the data that SiteEngine is being
asked to preserve; and

iv. A valid return email address and phone number.

3. Emergency Requests. An emergency request is only appropriate in cases involving imminent
serious bodily harm or death. We respond to emergency requests when we believe in good faith
that such harm may occur if we do not respond without delay.

4. Disclosure of Non-Public Domain Registrant Information. As the sponsoring registrar or
reseller of certain domain names governed by the Internet Corporation for Assigned Names and
Numbers (“ICANN”), SiteEngine must permit third parties with a legitimate interest to access
masked (non-public) registrant information subject to the data subject’s rights under the General
Data Protection Regulation (“GDPR”) or other similar privacy laws as applicable.

5. Notice to SiteEngine Subscribers. SiteEngine’s policy is to notify its Subscribers of
requests for their data unless SiteEngine is prohibited from doing so by applicable law or
court order.

6. Information to Include in a Request. The following information must be included in a request
for Subscriber data:

a. First and last name of the Subscriber and email address associated with the account;
and

b. Domain name, username and/or IP address associated with the account.
NOTE: A Request that only includes an IP address may be overly broad and insufficient
for SiteEngine to locate a Subscriber account. Please include additional identifiers such
domain name or username whenever possible. SiteEngine may not be able to respond
to a request without this information.
Additionally, SiteEngine reserves the right to request a copy of the complaint and any
supporting documentation that demonstrates how the information requested is related to
any pending litigation, formal legal proceeding or investigation.

7. Sending a Request to SiteEngine. All data requests should be sent to:
SiteEngine
Legal Department
3857 Indian Trail Unit 214 Destin, Florida 32541
E-mail: datarequests@siteengine.io

IMPORTANT NOTE: IN THE EVENT YOU SEND US A NOTICE OF ANY KIND VIA EMAIL AND
DO NOT RECEIVE A RESPONSE FROM SiteEngine DIGITAL, PLEASE SUBMIT A
DUPLICATE COPY VIA MAIL. DUE TO THE VAGARIES OF THE INTERNET AND EMAIL
COMMUNICATION IN PARTICULAR, INCLUDING THE OCCASIONAL UNINTENDED
EFFECTS OF SPAM FILTERS, SENDING AN ALTERNATE FORM OF NOTICE WILL HELP
ASSURE THAT YOUR NOTICE IS RECEIVED BY SiteEngine DIGITAL AND ACTED ON IN A
TIMELY MANNER.

8. Fees. SiteEngine may seek reimbursement for costs in responding to requests as provided
by law and may charge additional fees for costs in responding to unusual or burdensome
requests.
9. Available Information. Subject to receiving a valid request, SiteEngine may provide data
as follows:

a. Non-Content. SiteEngine will produce non-content information such as basic
Subscriber information which may include the following:

i. Name

ii. Email address

iii. Date and time of account creation