Registration Agreement
Fewmoretaps OÜ doing business as Trustname
This Domain Name Registration Agreement (“Agreement”) sets forth the terms and conditions applicable to domain name registration and related registrar services (“Services”) provided by Fewmoretaps OÜ doing business as Trustname (“Trustname”).
This Agreement is incorporated into and forms part of the Trustname Universal Terms of Service. If there is a conflict between this Agreement and the Universal Terms of Service concerning domain name registration, this Agreement controls to the extent of that conflict. Mandatory applicable law, ICANN Consensus Policies, applicable Registry requirements and binding dispute-resolution policies prevail where they cannot lawfully or contractually be modified.
1. Definitions
For purposes of this Agreement:
Account Holder means the person or entity paying for a Domain Name or otherwise controlling or managing it through a Trustname Account when that person or entity is not the Registered Name Holder.
Applicable Policies means the then-current ICANN Registrar Accreditation Agreement (“RAA”), ICANN Consensus Policies, specifications incorporated into the RAA, applicable Registry policies, Registry-Registrar Agreements, UDRP, URS, Transfer Policy, Expired Registration Recovery Policy, Registration Data Policy and other policies binding upon Trustname or the applicable registration.
Domain Name means any domain name registered, transferred, renewed, maintained or otherwise managed through Trustname.
P/P Customer means the Account Holder, customer or domain user for whose benefit an applicable Privacy Service or Proxy Service is provided and who is not necessarily the Registered Name Holder.
P/P Provider or Privacy/Proxy Service Provider means a person or entity providing a Privacy Service or Proxy Service in connection with a Domain Name.
Privacy Service means a service under which the Registered Name remains registered to its Registered Name Holder but alternative reliable contact information supplied by a Privacy Service Provider may be used for publication or communication-relay purposes in accordance with applicable ICANN policy, Registry requirements and law.
Proxy Service Provider means an entity that is identified as the Registered Name Holder for a Domain Name while providing contractual use and management rights concerning that Domain Name to a P/P Customer.
Privacy Registrant means Perfect Privacy LLC or WHOIS Privacy Protection Service LLC when the applicable entity acts as Registered Name Holder for a particular Domain Name.
Privacy Service Provider means an entity providing privacy, masking, alternative contact information, forwarding or communication-relay functionality without necessarily becoming the Registered Name Holder.
Proxy Service means a service under which the Registered Name Holder licenses use of a Registered Name to a P/P Customer and the Registered Name Holder's identity and/or contact information is used as the registration data instead of the P/P Customer's identity and/or contact information.
Applicable Privacy Registrant means Perfect Privacy LLC or WHOIS Privacy Protection Service LLC, whichever entity is identified in Trustname's applicable domain-level registration record as the Registered Name Holder for a Domain Name at the relevant time.
Registered Name has the meaning assigned to that term under the applicable ICANN Registrar Accreditation Agreement.
Registered Name Holder means the holder of a Registered Name and, where applicable, the registrant of record.
Registration Data means information collected or processed in connection with a Domain Name registration, including information concerning the Registered Name Holder, Account Holder, P/P Customer, administrative or technical contact, Domain Name, registration dates, Registry information and other data required or permitted under Applicable Policies or law.
Registry Operator means the registry operator responsible for the applicable top-level domain.
Suggested Default Contact means Trustname's Proxy Service arrangement under which Perfect Privacy LLC acts as the Registered Name Holder for an eligible Domain Name and licenses use of that Domain Name to the applicable P/P Customer.
Change of Registrant or COR means a Change of Registrant within the meaning of the ICANN Transfer Policy, including any Material Change to Registered Name Holder data that is required to be processed as a Change of Registrant.
Change of Registrant or COR means a Change of Registrant within the meaning of the ICANN Transfer Policy, including any Material Change to Registered Name Holder data that is required to be processed as a Change of Registrant.
Designated Agent means an individual or entity that the Prior Registrant or New Registrant explicitly authorizes to approve a Change of Registrant on its behalf within the meaning of the ICANN Transfer Policy.
Designated Agent means an individual or entity that the Prior Registrant or New Registrant explicitly authorizes to approve a Change of Registrant on its behalf within the meaning of the ICANN Transfer Policy.
New Registrant means the person or entity that will be identified as the Registered Name Holder following a proposed Change of Registrant.
Prior Registrant means the Registered Name Holder at the time a Change of Registrant is initiated. Where the same legal entity remains the Registered Name Holder but its registration data undergoes a Material Change, that entity shall be treated in its pre-change capacity as the Prior Registrant to the extent required by the ICANN Transfer Policy.
New Registrant means the person or entity that will be identified as the Registered Name Holder following a proposed Change of Registrant. Where the same legal entity remains the Registered Name Holder but its registration data undergoes a Material Change, that entity shall be treated in its post-change capacity as the New Registrant to the extent required by the ICANN Transfer Policy.
Perfect Privacy means Perfect Privacy LLC.
WHOISPPS means WHOIS Privacy Protection Service LLC.
Two-Tier Privacy means a privacy and proxy arrangement under which an approved Privacy Registrant acts as Registered Name Holder and an additional Privacy Service Provider may provide alternative contact, masking, forwarding or communication-relay functionality. A provider's role may vary by Domain Name and configuration. A provider may act as Registered Name Holder for one Domain Name and solely as a Privacy Service Provider for another.
You and Your mean the person or entity using the Services, maintaining the applicable Trustname account or acting as the Account Holder, together with any properly authorized representative acting on that person's or entity's behalf.
Where You are registered directly as the Registered Name Holder, references to “You” also include You in that capacity.
Where a Proxy Service is active, the Account Holder or P/P Customer and the Registered Name Holder are separate persons or entities.
Trustname, We, Us and Our mean Fewmoretaps OÜ doing business as Trustname.
2. Acceptance and Incorporated Agreements
By applying for, registering, transferring, renewing, managing or otherwise using a Domain Name through Trustname, You agree to this Agreement and all applicable policies and agreements incorporated by reference.
These include, as applicable:
Where a Privacy or Proxy Service is used, this Agreement governs the relationship between Trustname and the Account Holder or P/P Customer to the extent applicable to that person.
The obligations, authority and standing instructions of Perfect Privacy LLC or WHOIS Privacy Protection Service LLC when acting as Registered Name Holder are additionally governed by the applicable agreement between Trustname and that Privacy Registrant, including the Privacy Registrant & Designated Agent Framework Agreement.
Such separate Privacy Registrant agreement does not, merely by its existence, impose obligations upon the P/P Customer that are not otherwise contained in the agreements applicable to the P/P Customer.
Acceptance of this Agreement by an Account Holder or P/P Customer does not, by itself, make that person the Registered Name Holder and does not, by itself, constitute a Designated Agent appointment, Change of Registrant confirmation or transfer-lock election on behalf of a separate Privacy Registrant.
The Registered Name Holder for a Domain Name is determined by the applicable domain-level registration record and governing agreements.
3. Eligibility and Authority
You represent that You are legally capable of entering into binding agreements.
If You act for a legal entity or another person, You represent that You possess sufficient authority to bind that person or entity to the applicable agreements.
If You register or manage a Domain Name on behalf of another person, reseller customer or entity, You must have the authority necessary to submit instructions and Registration Data concerning that person or entity.
Trustname may request reasonable evidence of authority where necessary to protect an Account, Domain Name, Registered Name Holder or other affected party.
4. Domain Registration Service
A Domain Name registration becomes effective only after the applicable Registry Operator accepts and records the registration.
Submission of an order, payment or availability result does not guarantee successful registration.
Domain Name registration is provided for a limited registration term and remains subject to:
this Agreement;
Applicable Policies;
applicable Registry requirements;
eligibility requirements;
dispute-resolution procedures; and
applicable law.
Nothing in this Agreement is intended to determine the characterization of a Domain Name as property under any particular jurisdiction. The rights provided through Trustname are contractual registration and management rights subject to the applicable registration system.
Trustname is not responsible for errors, delays, omissions, outages or actions attributable to a Registry Operator or another third-party registration infrastructure provider except to the extent responsibility cannot lawfully be excluded.
4.1 Third-Party DNS Functionality
Domain name registration and registrar-level nameserver delegation are distinct from authoritative DNS hosting and resolution. Trustname may provide access through its account interface to DNS-management functionality operated by an independent third-party DNS provider. Fewmoretaps OÜ does not operate the underlying authoritative DNS network used to answer DNS queries. Additional terms are set out in Section 11A of the Universal Terms of Service.
5. Registered Name Holder Status
5.1 Direct Registration
Where a Domain Name is registered directly in Your name, You are the Registered Name Holder and are responsible for the Registered Name Holder obligations contained in this Agreement and Applicable Policies.
5.2 Suggested Default Contact / Proxy Registration
For an eligible Domain Name using Suggested Default Contact or another Trustname Proxy Service, the Applicable Privacy Registrant identified in the applicable domain-level registration record is the Registered Name Holder and registrant of record.
Depending on the applicable configuration, the Applicable Privacy Registrant may be:
- Perfect Privacy LLC; or
- WHOIS Privacy Protection Service LLC.
The Account Holder or end customer is the P/P Customer and licensee under the applicable Privacy/Proxy Service & Domain License Agreement.
While the Proxy Service remains active, the P/P Customer is not the Registered Name Holder unless and until Trustname completes a registration-data change that makes the P/P Customer the Registered Name Holder.
The P/P Customer may nevertheless receive contractual rights to:
- use the Domain Name;
- configure and manage DNS;
- manage applicable registration settings;
- renew the registration;
- request an inter-account change where permitted;
- request an inter-registrar transfer;
- request a permitted change to the applicable privacy or proxy configuration;
- request removal of the Proxy Service; and
- otherwise control or manage the registration as permitted under the applicable agreements.
Such rights are contractual rights and do not change Registered Name Holder status while the applicable Proxy Service remains active.
A request submitted by the P/P Customer may constitute an instruction to Trustname to initiate an applicable registration or COR workflow but does not, by itself, constitute the explicit consent of a separate Privacy Registrant where such consent is required under the ICANN Transfer Policy.
5.3 Two-Tier Privacy
Where Two-Tier Privacy is enabled, either Perfect Privacy LLC or WHOIS Privacy Protection Service LLC may act as the Applicable Privacy Registrant and Registered Name Holder, depending on the domain-level configuration.
A different approved provider may simultaneously act solely as a Privacy Service Provider by supplying alternative reliable contact information, masking, forwarding or communication-relay functionality for RDAP/RDDS or another applicable registration-data system.
The use or display of an entity's contact information solely in its capacity as a Privacy Service Provider does not, by itself, make that entity the Registered Name Holder.
The Registered Name Holder is the entity identified as such in Trustname's applicable domain-level registration record.
Accordingly, depending on the applicable configuration:
- Perfect Privacy LLC may be the Registered Name Holder while WHOISPPS acts solely as a Privacy Service Provider;
- WHOISPPS may be the Registered Name Holder while Perfect Privacy LLC or another approved entity provides an additional privacy-related function;
- Perfect Privacy LLC may replace WHOISPPS as Registered Name Holder; or
- WHOISPPS may replace Perfect Privacy LLC as Registered Name Holder.
Where substitution of one Privacy Registrant for another, or a modification to the registration data of an existing Privacy Registrant, constitutes a Material Change under the ICANN Transfer Policy, Trustname shall process the modification as a Change of Registrant in accordance with Section 17.
Trustname is not required to provide the P/P Customer's underlying personal Registration Data to an additional Privacy Service Provider merely for operation of a standard masking, contact or communication-relay layer unless such disclosure is necessary for provision of the applicable service, required by Applicable Policies or law, or otherwise permitted under the applicable agreements.
5.4 Removal of Proxy Service
A P/P Customer may request removal of Suggested Default Contact and substitution of its own Registration Data.
Such request may be subject to:
identity and authority verification;
applicable Registry requirements;
ICANN Change of Registrant requirements;
transfer restrictions;
pending disputes;
legal holds or court orders;
abuse or security restrictions;
outstanding payment obligations where action is permitted by Applicable Policies; and
the applicable Proxy Service agreement.
The P/P Customer becomes the Registered Name Holder only after Trustname confirms that the applicable registration-data change has been completed.
5.5 Availability
Privacy and Proxy Services are available only for eligible TLDs.
Certain Registry Operators, ccTLD authorities or applicable laws may prohibit or restrict Privacy or Proxy Services or require different registration information.
6. Registration Data and Accuracy Requirements
6.1 General Requirement
You must provide accurate, current, complete and reliable information requested by Trustname in connection with a Domain Name or Account and must keep such information current.
Use of a Privacy Service or Proxy Service does not authorize submission of fictitious, misleading, fabricated or placeholder underlying customer information to Trustname.
6.2 Registered Name Holder Requirements
Where You are the Registered Name Holder, You must provide accurate and reliable contact information required under Applicable Policies and correct and update that information within seven (7) calendar days of any change.
The willful provision of inaccurate or unreliable information, willful failure to correct or update such information within seven (7) calendar days of a change, or failure to respond for more than fifteen (15) calendar days to Trustname inquiries concerning the accuracy of Registered Name Holder contact information constitutes a material breach of this Agreement and may constitute grounds for suspension or cancellation of the registration.
6.3 P/P Customer Information
Where You are a P/P Customer rather than the Registered Name Holder, You must provide Trustname with accurate, current and complete underlying customer information requested in connection with the Privacy or Proxy Service.
The applicable Privacy or Proxy Service agreement may require corrections, responses or cooperation within a shorter period than the periods applying to a Registered Name Holder.
6.4 Verification
Trustname may validate, verify or reconfirm Registration Data before or after:
registration;
transfer;
renewal;
Change of Registrant;
material data modification;
receipt of an accuracy complaint;
detection of inconsistencies or security indicators; or
another event reasonably requiring verification.
Verification procedures will be reasonable and proportionate in light of applicable legal, Registry and ICANN requirements.
Verification may include, where appropriate:
email confirmation;
telephone or one-time-code verification;
verification of legal-entity records;
comparison with reliable public or authoritative sources;
requests for supporting information or documentation;
examination of payment, transaction, account, device, IP-address, fraud or security indicators; and
manual review.
Trustname may use qualified third-party providers and lawful data sources for verification.
A successful verification does not permanently establish that Registration Data remain accurate.
6.5 Failure of Verification
Where Registration Data cannot reasonably be verified, are materially inaccurate or incomplete, or the responsible party fails to cooperate with an applicable verification procedure, Trustname may take proportionate measures permitted by Applicable Policies and law, including:
requesting correction;
requesting additional information;
restricting completion of a registration or data change;
restricting particular management functions;
applying an appropriate registrar status;
suspending the affected Service; or
cancelling the affected registration where permitted or required.
Where practicable and consistent with security, law and Applicable Policies, Trustname may provide an opportunity to correct the relevant information before cancellation.
7. NIS2 Domain Registration Data Requirements
Where Directive (EU) 2022/2555 (“NIS2”) or applicable national implementing legislation applies, Trustname may collect and maintain Registration Data necessary to identify and contact the Domain Name holder and applicable point of contact.
Trustname maintains publicly available policies and procedures relating to Registration Data verification, correction, publication and lawful disclosure.
Trustname may implement proportionate verification procedures designed to maintain accurate and complete Registration Data.
Where required under applicable law, Trustname may make non-personal Registration Data publicly available.
Requests by legitimate access seekers for non-public Registration Data must be lawful, sufficiently substantiated and processed in accordance with applicable data protection law.
Trustname will process such requests without undue delay and within any mandatory timeframe imposed by applicable law, including any applicable timeframe arising under national implementation of Article 28 of NIS2.
Nothing in this Agreement requires Trustname to disclose Registration Data where the legal requirements for disclosure have not been satisfied.
8. Processing and Protection of Registration Data
Trustname processes Registration Data in accordance with:
applicable data protection law, including the GDPR where applicable;
the ICANN Registration Data Policy;
the RAA and Applicable Policies;
applicable Registry requirements;
the Trustname Privacy Policy; and
applicable cybersecurity and domain-registration legislation.
8.1 Legal Basis
Trustname does not rely exclusively on consent for processing necessary to:
perform a Domain Name registration contract;
administer a Domain Name;
satisfy ICANN or Registry obligations;
satisfy legal obligations;
maintain security;
prevent or investigate fraud or abuse;
maintain required records; or
establish, exercise or defend legal claims.
Processing may rely, as applicable, on performance of a contract, compliance with a legal obligation, legitimate interests, consent where appropriate, or another lawful basis.
Where the RAA or another Applicable Policy requires a Registered Name Holder to consent to described Registration Data processing, the Registered Name Holder provides such consent to the extent contractually required. This does not make consent the exclusive lawful basis under applicable data protection law.
8.2 Privacy Notice
Trustname's Privacy Policy describes, among other matters:
purposes for which Registration Data are processed;
categories of recipients;
mandatory and optional information;
data-subject rights;
correction procedures;
retention;
international transfers; and
disclosure procedures.
8.3 Third-Party Data
Where You supply personal data concerning another individual, You represent that:
You are authorized to provide that information;
any notices required under the RAA and applicable law have been provided; and
any consent required under the RAA or applicable law has been obtained.
8.4 Data Security
Trustname will take reasonable technical and organizational precautions appropriate to the risk to protect personal Registration Data against accidental or unlawful loss, misuse, alteration, destruction, unauthorized access or unauthorized disclosure.
9. Registry Transfer, RDAP/RDDS and Data Escrow
Trustname will collect, transfer, publish, redact, retain and escrow Registration Data in accordance with Applicable Policies, applicable Registry requirements and law.
9.1 Registry Operators
Data transmitted to a Registry Operator will consist of information required or permitted to be transferred under applicable ICANN policy, Registry agreements, Registry requirements and law.
9.2 Registrar Data Escrow
Trustname maintains Registrar Data Escrow arrangements as required for applicable gTLD registrations.
Where a Privacy or Proxy Service is offered or made available by Trustname or an applicable affiliated provider, Trustname will include required underlying P/P Customer information in its Registrar Data Escrow deposits in accordance with applicable ICANN requirements and the applicable Data Escrow specification.
Registrar Data Escrow is a non-public registration-data continuity safeguard.
The inclusion of underlying P/P Customer information in escrow does not by itself authorize public publication of that information.
9.3 RDAP/RDDS Publication
Trustname will publish Registration Data through RDAP/RDDS or another applicable registration-data service only as required or permitted by:
- ICANN policy;
- applicable Registry requirements;
- applicable law; or
- valid data-subject consent where consent is an appropriate legal basis.
Where a Proxy Service is active, the Applicable Privacy Registrant identified in the applicable domain-level registration record is the Registered Name Holder.
Where Two-Tier Privacy is enabled, contact or other information associated with a separate Privacy Service Provider may be used for publication, masking, forwarding or contact purposes to the extent permitted by Applicable Policies and law.
Publication or display of Privacy Service Provider contact information does not, by itself, change Registered Name Holder status.
A change in Registered Name Holder status occurs only when the applicable registration record is changed accordingly and, where required, the applicable Change of Registrant process has been completed.
Underlying P/P Customer information will not be made public merely because Trustname collects, verifies, retains or escrows that information.
9.4 Legal-Person Data
Where applicable law requires publication of non-personal Registration Data concerning a legal person, Trustname may publish the required information while applying appropriate safeguards to personal data contained within the registration record.
10. Requests for Non-Public Registration Data
Trustname may receive requests for access to non-public Registration Data from:
competent governmental authorities;
law-enforcement authorities;
courts;
dispute-resolution providers;
cybersecurity authorities;
legitimate access seekers;
intellectual-property rights holders;
security researchers; or
other third parties.
Submission of a request does not itself establish an entitlement to Registration Data.
Trustname may evaluate:
identity and authority of the requester;
stated purpose;
legal basis;
specificity and scope;
proportionality;
necessity;
data minimization;
applicable jurisdiction;
supporting evidence; and
procedural requirements.
Trustname may request additional information where necessary.
Trustname may deny, restrict or defer disclosure where a request is incomplete, inadequately substantiated, disproportionate, unlawful or otherwise fails to establish an appropriate basis.
Underlying P/P Customer information is subject to applicable Privacy/Proxy procedures and is not automatically disclosed merely because a third party requests it.
Trustname may disclose Registration Data where disclosure is required or permitted under applicable law, a binding legal process, Applicable Policies or another valid legal basis.
11. Licensing a Domain Name to a Third Party
Where You are the Registered Name Holder and license use of the Registered Name to another person, You remain the Registered Name Holder of record unless and until an applicable Change of Registrant is completed.
You remain responsible for:
- Your obligations under this Agreement;
- maintaining Your own accurate contact information; and
- providing and updating required technical and administrative contact information adequate to facilitate timely resolution of problems concerning the Registered Name.
A Registered Name Holder licensing use of a Registered Name to another person accepts liability for harm caused by wrongful use of the Registered Name unless the Registered Name Holder discloses the current identity and contact information of the licensee within seven (7) calendar days to a party providing reasonable evidence of actionable harm, to the extent required by Applicable Policies.
Where a Trustname Proxy Service is active, this Registered Name Holder obligation applies to the Applicable Privacy Registrant in its capacity as Registered Name Holder.
The P/P Customer must cooperate with the Applicable Privacy Registrant and Trustname within any shorter period specified in the applicable Privacy/Proxy Service agreement where reasonably necessary to enable the Registered Name Holder to satisfy its contractual, ICANN, Registry or legal obligations.
A change from Perfect Privacy LLC to WHOISPPS, from WHOISPPS to Perfect Privacy LLC, or another Material Change to the Applicable Privacy Registrant's registration data shall be processed as a Change of Registrant where required under the ICANN Transfer Policy.
12. Registration or Management for Third Parties
If You register or manage a Domain Name on behalf of another person, including as a reseller, agent, nominee, licensee, P/P Customer or intermediary, You must:
- possess appropriate authority;
- ensure required underlying Registration Data are accurate and current;
- provide required privacy or verification notices;
- assist with verification and correction requests;
- forward notices where appropriate;
- maintain reasonable evidence of Your authority; and
- not misrepresent Your ICANN accreditation status.
Use of a reseller, agent, nominee, Privacy Service or Proxy Service does not remove any obligation to provide accurate underlying information to Trustname where required.
Where a Trustname Proxy Service is active, the Applicable Privacy Registrant identified in the applicable domain-level registration record is the Registered Name Holder, and the end customer remains the P/P Customer or licensee unless and until an applicable Change of Registrant making another person the Registered Name Holder has been completed.
An authenticated instruction from a P/P Customer may authorize Trustname to initiate an eligible account, privacy, proxy, transfer or Change of Registrant workflow to the extent permitted under the applicable agreements.
Such P/P Customer instruction does not, by itself, constitute explicit confirmation by a separate Prior Registrant or New Registrant where the ICANN Transfer Policy requires confirmation from that Registrant or its Designated Agent.
13. Rights of Third Parties and Domain Name Use
The Registered Name Holder represents, to the best of its knowledge and belief, that neither registration of the Registered Name nor the manner in which it is directly or indirectly used infringes the legal rights of a third party.
You remain responsible for determining whether Your selection or use of a Domain Name violates:
trademark rights;
copyright;
rights of publicity;
applicable consumer-protection law;
applicable criminal law; or
other third-party rights.
Trustname does not determine ownership of competing trademark or domain-name claims merely because a complaint has been submitted.
Content or intellectual-property complaints do not automatically require registrar-level suspension or cancellation.
Where appropriate, such disputes may be addressed through:
UDRP;
URS;
an applicable ccTLD dispute procedure;
a court of competent jurisdiction;
the applicable hosting provider; or
another legally appropriate mechanism.
Trustname may nevertheless act where required by Applicable Policies, applicable law, a binding order or another valid contractual basis.
14. DNS Abuse and Prohibited Use
You must not use, or knowingly permit use of, the Services in violation of applicable law or Applicable Policies.
Trustname may investigate reports concerning DNS Abuse and may take proportionate mitigation measures reasonably necessary to stop or otherwise disrupt DNS Abuse where required by the RAA or other Applicable Policies.
Such measures may include, where appropriate:
contacting the Account Holder or Registered Name Holder;
requesting remediation;
disabling access through the Trustname platform to third-party DNS functionality, where technically available and appropriate;
applying a registrar hold or other appropriate status;
restricting account functions;
suspending the registration; or
taking another technically and legally appropriate action.
Trustname may consider the nature and severity of the activity, available evidence, technical feasibility, collateral effects, applicable law and the actions reasonably available to a registrar.
Trustname is not required by this Section to act as a hosting provider or content moderator where the complained-of activity does not create a registrar-level obligation.
15. UDRP, URS and Other Domain Disputes
For applicable gTLD registrations, the Registered Name Holder agrees to be bound by the then-current UDRP and applicable UDRP Rules.
Where applicable, the registration is also subject to the URS and other ICANN-mandated dispute procedures.
ccTLD registrations may be subject to separate Registry or national dispute-resolution procedures.
Trustname may:
lock;
hold;
transfer;
cancel;
maintain; or
otherwise modify
a registration where required by a binding UDRP/URS decision, court order, Applicable Policy or applicable Registry procedure.
16. Transfers Between Registrars
Inter-registrar transfers of gTLD Registered Names are governed by the then-current ICANN Transfer Policy.
The Registered Name Holder is the party having authority to approve or deny an inter-registrar transfer request, subject to the Transfer Policy.
Where You are the Registered Name Holder, Trustname will provide applicable transfer functionality, AuthInfo credentials and removal of eligible transfer-prohibited statuses in accordance with the Transfer Policy.
Trustname may require reasonable authentication to establish that the person requesting a transfer has authority to do so.
16.1 Suggested Default Contact
Where Suggested Default Contact is active, Perfect Privacy LLC remains the Registered Name Holder.
A transfer request submitted by a P/P Customer will be processed pursuant to:
the applicable Proxy Service agreement;
authority granted by Perfect Privacy LLC;
the ICANN Transfer Policy;
Registry requirements; and
Trustname security procedures.
16.2 Transfer Restrictions
A transfer may be denied, delayed or restricted only where permitted or required under Applicable Policies, Registry requirements or law.
Applicable restrictions may include those resulting from:
initial registration;
a previous inter-registrar transfer;
Change of Registrant;
fraud;
a reasonable dispute concerning Registered Name Holder identity;
applicable payment circumstances permitted by the Transfer Policy;
UDRP or URS proceedings;
court orders; or
another ground permitted under the then-current Transfer Policy.
ccTLD transfers are governed by the applicable Registry or national authority rules.
17. Change of Registrant and Designated Agent
A Material Change to Registered Name Holder data constitutes a Change of Registrant where required under the ICANN Transfer Policy.
Without limitation, this may include:
- a non-typographical change to the Registered Name Holder's name;
- a non-typographical change to the Registered Name Holder's organization;
- any change to the Registered Name Holder's email address;
- substitution of Perfect Privacy LLC with WHOIS Privacy Protection Service LLC as Registered Name Holder;
- substitution of WHOIS Privacy Protection Service LLC with Perfect Privacy LLC as Registered Name Holder;
- a Material Change to Perfect Privacy LLC's registration data while Perfect Privacy LLC remains the Registered Name Holder; or
- a Material Change to WHOIS Privacy Protection Service LLC's registration data while WHOISPPS remains the Registered Name Holder.
Where You personally are the Prior Registrant or New Registrant, You may expressly authorize Trustname or another eligible individual or entity to act as Your Designated Agent to the extent permitted by the ICANN Transfer Policy.
Where Perfect Privacy LLC or WHOIS Privacy Protection Service LLC is the Prior Registrant or New Registrant, Trustname's authority to act as that entity's Designated Agent is governed by the applicable Privacy Registrant & Designated Agent Framework Agreement or another applicable express Designated Agent appointment between Trustname and that Privacy Registrant.
Acceptance of this Agreement solely by a P/P Customer does not create Designated Agent authority on behalf of Perfect Privacy LLC or WHOISPPS.
Privacy Registrant COR Procedure
Where a proposed Change of Registrant involves an Applicable Privacy Registrant, Trustname shall create a domain-specific COR Event and process the change in accordance with the ICANN Transfer Policy.
Trustname shall use a secure, access-controlled and recordable mechanism to establish and preserve the required confirmations.
For each applicable COR Event:
- Trustname shall identify the Prior Registrant and New Registrant from the applicable pre-change and proposed post-change registration data.
- Trustname shall obtain and record explicit confirmation of the specific Change of Registrant from the New Registrant or the New Registrant's Designated Agent.
- In obtaining such confirmation, Trustname shall inform the New Registrant or its Designated Agent that the New Registrant is required to enter into the applicable registration agreement with Trustname and that the Change of Registrant will not proceed unless confirmed within the period specified by Trustname, which shall not exceed the period permitted by the ICANN Transfer Policy.
- Trustname shall inform the Prior Registrant or its Designated Agent of the applicable inter-registrar transfer-lock consequences of the proposed Change of Registrant, including any applicable prior opt-out under Section 17.1.
- Trustname shall obtain and record separate explicit confirmation of the specific Change of Registrant from the Prior Registrant or the Prior Registrant's Designated Agent.
- In obtaining the Prior Registrant confirmation, Trustname shall inform the Prior Registrant or its Designated Agent that the Change of Registrant will not proceed unless confirmed within the period specified by Trustname, which shall not exceed the period permitted by the ICANN Transfer Policy.
- Trustname shall process the Change of Registrant within the period required by the ICANN Transfer Policy after obtaining all required confirmations.
- Trustname shall send the required Change of Registrant notifications to both the Prior Registrant and New Registrant before or within the period required by the ICANN Transfer Policy.
Where Trustname has been expressly appointed Designated Agent by the applicable Privacy Registrant, Trustname may provide the applicable confirmation in its Designated Agent capacity.
Trustname shall separately record the confirmation made:
- on behalf of the Prior Registrant; and
- on behalf of the New Registrant.
This requirement applies even where the Prior Registrant and New Registrant are the same legal entity.
Accordingly, a Material Change such as:
Perfect Privacy LLC / email A → Perfect Privacy LLC / email B
or
WHOISPPS / email A → WHOISPPS / email B
shall, where subject to the Change of Registrant procedure, result in separate recorded confirmations in the entity's Prior Registrant capacity and New Registrant capacity.
Each COR Event record should include, to the extent applicable:
- Domain Name;
- COR Event identifier;
- Prior Registrant;
- Prior Registrant pre-change data;
- New Registrant;
- New Registrant proposed post-change data;
- description of the Material Change;
- basis or instruction initiating the COR;
- applicable Designated Agent authority;
- New Registrant or New Registrant DA confirmation and timestamp;
- Prior Registrant or Prior Registrant DA confirmation and timestamp;
- applicable Registration Agreement;
- applicable Section 17.1 opt-out status and evidence;
- COR completion timestamp; and
- required notification records.
Successful authentication of a P/P Customer, possession of valid Account credentials, an Account push, a contact-update request, generation or use of an AuthInfo code, or another customer action may constitute evidence of the instruction initiating a transaction.
Such customer activity shall not, standing alone, replace a separate Change of Registrant confirmation required from the Prior Registrant, New Registrant or their respective Designated Agents.
17.1 Advance Opt-Out from the Post-Change-of-Registrant Transfer Lock
Where permitted by the ICANN Transfer Policy, Trustname permits a Registered Name Holder to opt out, in advance of a Change of Registrant request, of the sixty (60) day inter-registrar transfer lock that would otherwise apply following a Change of Registrant.
Direct Registered Name Holders
Where You are personally the Registered Name Holder, by entering into this Agreement as Registered Name Holder You affirmatively and expressly elect, in advance of any future Change of Registrant request, to opt out of the sixty (60) day post-Change-of-Registrant inter-registrar transfer lock wherever such opt-out is permitted by the ICANN Transfer Policy.
This election constitutes a continuing advance instruction until prospectively withdrawn or changed by You.
If You wish the sixty (60) day post-COR transfer lock to apply, You must withdraw or modify the advance election through the method made available by Trustname before submitting the applicable Change of Registrant request.
Privacy Registrants
Where Perfect Privacy LLC or WHOIS Privacy Protection Service LLC is the Registered Name Holder, the applicable standing advance opt-out election is governed by the Privacy Registrant & Designated Agent Framework Agreement or another express advance election made by that Registered Name Holder.
Acceptance of this Agreement solely by a P/P Customer does not constitute the transfer-lock opt-out of Perfect Privacy LLC or WHOISPPS.
Trustname shall maintain evidence that the applicable Privacy Registrant's opt-out election was effective before initiation of the relevant Change of Registrant request and should associate the applicable election with the corresponding COR Event.
Where an Applicable Privacy Registrant has affirmatively elected in advance to opt out, Trustname may rely upon that standing election for subsequent eligible Changes of Registrant until the election is prospectively withdrawn.
An opt-out may not be created or elected after the applicable Change of Registrant request has already been submitted for purposes of avoiding a lock resulting from that request.
This Section applies only to the sixty (60) day inter-registrar transfer lock resulting from a Change of Registrant.
It does not waive or override:
- a transfer restriction following initial registration;
- a transfer restriction following a previous inter-registrar transfer;
- a restriction arising from fraud or a reasonable dispute concerning identity;
- UDRP or URS restrictions;
- a court order;
- Registry-level restrictions;
- a transfer restriction required by another Applicable Policy; or
- any other restriction that may not lawfully or contractually be waived.
Trustname shall advise the Prior Registrant or its Designated Agent of the applicable transfer-lock status as part of the Change of Registrant procedure required under Section 17.
18. Renewal and Expiration
You are responsible for monitoring Domain Name expiration dates and maintaining sufficient funds or a valid payment method where automatic renewal is enabled.
Trustname will provide expiration notices for applicable gTLD registrations in accordance with the ICANN Expired Registration Recovery Policy.
At a minimum, where required by that Policy, Trustname will send:
a pre-expiration notice approximately one month before expiration;
a pre-expiration notice approximately one week before expiration; and
where applicable, a post-expiration notice within the period required by the ERRP.
Required notices will be directed to the Registered Name Holder using an applicable contact method maintained by Trustname.
Where Suggested Default Contact is active, Trustname may additionally send renewal and expiration notices to the Account Holder or P/P Customer.
Additional notices may be provided as a courtesy.
Failure to receive an additional courtesy notice does not relieve You of responsibility for timely renewal.
19. Auto-Renewal, Deletion and Redemption
Trustname's current renewal, deletion and auto-renewal procedures are published on the Trustname website and incorporated into this Agreement.
Trustname may attempt automatic renewal where:
automatic renewal is enabled;
the applicable Domain Name is eligible;
adequate account balance or payment authorization exists; and
renewal is otherwise technically possible.
Trustname does not guarantee that automatic renewal will succeed.
A non-renewed registration may expire, be suspended, have its DNS resolution interrupted, enter a grace period, be deleted or become available to another party according to the applicable Registry lifecycle and Applicable Policies.
Where the ICANN Expired Registration Recovery Policy applies, Trustname will comply with applicable post-expiration renewal, DNS-interruption and Redemption Grace Period requirements.
Applicable renewal, post-expiration renewal and redemption/restore fees are published on Trustname's website.
Current redemption/restore fees are available in the policy.
Registry grace periods and redemption procedures vary by TLD.
20. Fees and Payment
You agree to pay all registration, transfer, renewal, restore, premium-name and other fees applicable to the Services requested.
Prices applicable to completed registration periods will not ordinarily change retroactively.
Renewal prices may differ from initial registration or promotional prices.
Registry Operators may change wholesale prices or premium classifications.
Trustname may change future prices and renewal fees by publishing updated pricing before the applicable transaction, subject to mandatory consumer law.
All applicable taxes, duties and regulatory charges may be added where required.
Payments are non-refundable except where:
expressly provided in the Trustname Refund Policy;
a transaction fails;
Trustname cancels a transaction and elects to refund it; or
applicable mandatory law requires a refund.
20.1 Payment Disputes
Where a chargeback, reversal, disputed payment or unpaid balance occurs, Trustname may pursue lawful remedies including suspension of affected Services and recovery of applicable charges and administrative costs.
Trustname will not deny or prevent a gTLD inter-registrar transfer solely for payment reasons except where denial is permitted under the applicable ICANN Transfer Policy.
21. Account Security and Authority
You are responsible for protecting:
account credentials;
passwords;
support PINs;
API credentials;
authentication devices; and
other security information.
Trustname may require additional verification where:
an Account is compromised;
ownership or authority is disputed;
a high-risk change is requested;
fraud is suspected; or
additional verification is reasonably necessary.
21.1 Allocation of Account Compromise Risk
Except to the extent prohibited by applicable mandatory law, the Account Holder assumes the risk of unauthorized use of Account credentials, authentication factors, authenticated sessions and Account access, regardless of the means by which such credentials, authentication factors or sessions were obtained or compromised.
Trustname may rely upon and treat instructions submitted through an authenticated Account, authenticated session, API credential or other valid authentication mechanism as authorized instructions of the Account Holder unless Trustname has actual knowledge or reasonable grounds, based on information available to Trustname at the relevant time, to believe that the Account has been compromised or that the particular instruction is unauthorized.
Trustname's processing, execution or reliance upon an instruction received through an authenticated Account does not, by itself, constitute negligence, breach of duty, failure of security, or acceptance of liability for the identity, authenticity or authority of the person submitting the instruction.
The Account Holder must promptly notify Trustname upon discovering or reasonably suspecting unauthorized Account access, credential compromise or unauthorized instructions. Except where required by applicable law, Applicable Policies or binding Registry requirements, Trustname does not guarantee that an instruction already executed, or a Domain Name already transferred or modified before Trustname received sufficient notice of the compromise, can be reversed or recovered.
This Section is subject to Section 25 and any liability that cannot lawfully be excluded or limited under applicable mandatory law.
Trustname may temporarily restrict an Account or Domain Name while a bona fide ownership, authority or security dispute is investigated.
22. Suspension, Cancellation, Transfer and Correction
A Registered Name Holder agrees that a Registered Name may be subject to suspension, cancellation or transfer pursuant to:
an ICANN Specification or Consensus Policy;
a Registry procedure not inconsistent with Applicable Policies;
a registrar procedure not inconsistent with Applicable Policies;
applicable law;
a binding court order;
a UDRP, URS or equivalent decision;
correction of an error by Trustname or the Registry Operator;
resolution of a dispute concerning the Registered Name; or
another basis expressly permitted under this Agreement.
Trustname may additionally take proportionate action where reasonably necessary because of:
materially inaccurate Registration Data;
failure to satisfy applicable verification requirements;
fraud;
unauthorized account access;
DNS Abuse;
nonpayment where action is permitted;
legal or regulatory requirements; or
threats to the security or stability of the Domain Name System.
Trustname will not interpret marketing descriptions concerning privacy, security or customer protection as limiting mandatory obligations under law, the RAA or Applicable Policies.
23. Court Orders and Legal Process
Trustname will review court orders, subpoenas, governmental requests and other legal process under:
applicable law;
the issuing authority's jurisdiction;
Trustname's legal obligations;
applicable ICANN and Registry requirements; and
Trustname's published legal-request procedures.
Submission of a legal document does not automatically establish that it is binding upon Trustname, the Registry Operator, the Registered Name Holder or the Domain Name.
Trustname may request evidence concerning authenticity, jurisdiction, enforceability, scope or legal basis.
A customer's objection to a legal order does not, by itself, stay or suspend Trustname's legal obligations.
Where Trustname receives a legally sufficient stay, superseding order or other binding basis not to act, Trustname may act accordingly.
24. Data Access, Rectification and Deletion
Subject to applicable law and verification of identity or authority, a data subject may exercise applicable rights concerning personal data processed by Trustname.
Certain Registration Data cannot be deleted or restricted while their continued processing is necessary for:
an active Domain Name registration;
performance of this Agreement;
compliance with the RAA or Applicable Policies;
Registry requirements;
NIS2 or other legal obligations;
Registrar Data Escrow;
dispute resolution;
fraud, abuse or security investigations; or
establishment, exercise or defence of legal claims.
Where removal of required Registration Data would make continued registration impossible, Trustname may require replacement information, transfer of the registration or termination of the applicable Service.
25. Limitation of Liability
To the fullest extent permitted by applicable law, Trustname will not be liable for indirect, consequential, incidental, punitive or special damages arising from or connected with the Services.
Without limiting the foregoing, Trustname is not responsible for losses arising from:
Registry Operator errors or outages;
DNS outages outside Trustname's control (third-party DNS infrastructure made accessible through the Trustname platform_;
unauthorized Account access, Account compromise, credential misuse, session hijacking, or unauthorized instructions submitted through an Account, including where such access, compromise, misuse or instructions arise from or are contributed to by an act, omission, security incident, vulnerability, or breach of obligation by Trustname, except to the extent liability cannot lawfully be excluded or limited under applicable mandatory law;
failure to renew caused by insufficient balance or an invalid payment method;
lawful suspension, cancellation or transfer;
enforcement of Applicable Policies;
acts of governmental authorities;
third-party disputes;
Registry policy changes; or
events outside Trustname's reasonable control.
To the fullest extent permitted by mandatory law, Trustname's aggregate liability concerning a particular Domain Name will not exceed the amount paid to Trustname for the registration Services for that Domain Name during the relevant registration period.
Nothing in this Agreement excludes liability that cannot lawfully be excluded or limited.
Mandatory consumer rights remain unaffected.
26. Indemnification
To the fullest extent permitted by applicable law, You agree to indemnify and hold harmless Trustname and its officers, directors, employees, agents and contractors from third-party claims, liabilities, damages, costs and reasonable legal expenses arising from:
Your breach of this Agreement;
Your unlawful use of the Services;
Your infringement of third-party rights;
false or materially inaccurate information supplied by You;
unauthorized instructions submitted through Your Account; or
activities of a person to whom You have granted use or control of the Services.
This indemnification does not apply to the extent a claim results from Trustname's own unlawful conduct or where indemnification is prohibited by mandatory law.
27. Registry Operator Indemnification
Where required by the RAA or applicable Registry agreement, the Registered Name Holder agrees to indemnify and hold harmless the applicable Registry Operator and its directors, officers, employees and agents from and against claims, damages, liabilities, costs and reasonable legal expenses arising out of or related to the Registered Name Holder's domain name registration.
This obligation survives expiration or termination of the registration to the extent required by Applicable Policies.
28. Privacy and Proxy Service Procedures
Trustname and applicable P/P Providers maintain separate terms and procedures governing Privacy and Proxy Services.
Those published terms may describe:
pricing;
provider business contact information;
abuse and infringement reporting;
communication relay;
termination of the Privacy or Proxy Service;
circumstances in which privacy data may be removed or replaced;
circumstances in which underlying information may be disclosed;
customer support; and
applicable service limitations.
A Privacy or Proxy Service does not provide immunity from:
UDRP or URS proceedings;
applicable law;
valid legal process;
Registry requirements;
ICANN obligations; or
lawful disclosure requirements.
29. Notices
Trustname may provide contractual notices through:
the Account email address;
an applicable verified contact method;
the Registered Name Holder contact information maintained by Trustname;
a P/P communication-relay mechanism where appropriate;
the Account Panel; or
another method permitted by Applicable Policies or law.
You are responsible for maintaining operational contact information and monitoring the applicable communication channels.
Verification notices are deemed transmitted when sent to the latest applicable contact information maintained by Trustname, except where applicable law requires another method.
30. Governing Law
Except where another governing law is required by a Registry policy, dispute-resolution policy or mandatory law, this Agreement and the relationship between You and Trustname are governed by the laws of Estonia.
Disputes between You and Trustname relating to this Agreement shall be subject to the competent courts of Estonia, except where applicable mandatory consumer law grants jurisdiction elsewhere.
31. Registered Name Holder Jurisdiction
For adjudication of third-party disputes concerning or arising from use of a gTLD Registered Name, the Registered Name Holder submits, without prejudice to other potentially applicable jurisdictions, to the jurisdiction of the courts:
of the Registered Name Holder's domicile; and
where Trustname is located, currently Estonia.
Where Suggested Default Contact is active, Perfect Privacy LLC is the Registered Name Holder and its applicable jurisdictional obligations are governed by its Registered Name Holder agreement, the applicable dispute policy and Applicable Policies.
32. Changes to this Agreement
Trustname may modify this Agreement where reasonably necessary because of:
changes to applicable law;
ICANN policies;
Registry requirements;
security requirements;
regulatory obligations;
changes to Services; or
legitimate operational or commercial requirements.
Changes will be published with an effective date.
Where applicable law requires advance notice, affirmative acceptance or another procedure for a material change, Trustname will follow the applicable requirement.
Changes required by binding ICANN, Registry or legal requirements may take effect on the date required by the applicable authority.
Continued use after the effective date may constitute acceptance to the extent permitted by applicable law.
33. Priority of Applicable Requirements
Nothing in this Agreement requires Trustname to act inconsistently with:
mandatory applicable law;
the RAA;
an ICANN Consensus Policy;
an applicable Registry-Registrar Agreement;
a binding Registry requirement;
a binding court or administrative order; or
an applicable domain-name dispute-resolution policy.
Where a provision of this Agreement conflicts with such a mandatory requirement, the mandatory requirement controls to the minimum extent necessary to resolve the conflict.
34. No Agency, Partnership or Ownership Transfer
Except for a Designated Agent authorization expressly granted under the ICANN Transfer Policy, nothing in this Agreement creates a partnership, joint venture or general agency relationship between Trustname and You.
Nothing in this Agreement transfers ownership of Trustname's registrar database, systems, software or intellectual property.
Trustname may hold database and compilation rights in its registrar systems to the extent permitted by law and the RAA.
Trustname does not claim ownership of a person's personal data as such and does not claim exclusive ownership or use of Registration Data where such exclusive ownership or use is restricted or disclaimed by the RAA, ICANN policy or applicable law.
35. Severability
If a provision of this Agreement is found invalid or unenforceable, the remaining provisions remain in effect.
The invalid provision will be interpreted or replaced, to the extent legally permitted, in a manner that most closely reflects its lawful purpose.
36. Mandatory Consumer Protections
Nothing in this Agreement excludes, restricts or modifies a consumer right or remedy that cannot lawfully be excluded, restricted or modified.
Where a mandatory consumer-protection rule conflicts with this Agreement, the mandatory rule controls.
37. Entire Domain Registration Agreement
This Agreement, together with the customer-facing agreements and policies incorporated by reference, constitutes the domain-registration agreement applicable between Trustname and You.
Where You are the Registered Name Holder, this Agreement includes the Registered Name Holder obligations applicable to You.
Where a Trustname Privacy or Proxy Service is active, this Agreement governs the relationship between Trustname and the Account Holder or P/P Customer to the extent applicable, while the Registered Name Holder obligations, Designated Agent authority and applicable standing instructions of the Applicable Privacy Registrant are additionally governed by the applicable agreement between Trustname and that Privacy Registrant.
Depending on the applicable domain-level configuration, either Perfect Privacy LLC or WHOIS Privacy Protection Service LLC may be the Applicable Privacy Registrant and Registered Name Holder.
Neither entity shall be deemed the Registered Name Holder merely because it performs a Privacy Service, communication-relay or masking function or because its contact information is displayed in RDAP/RDDS.
The Registered Name Holder is determined by the applicable registration record and governing agreements.
Where the applicable registration record changes from one Privacy Registrant to another, or undergoes another Material Change, the change shall be processed as a Change of Registrant where required by the ICANN Transfer Policy.
No customer-facing description, Account Panel label, marketing statement, privacy-service label or informal communication shall override:
- Registered Name Holder status established by the applicable registration record;
- a Change of Registrant actually completed in accordance with applicable requirements;
- the express Designated Agent authority granted by a Registered Name Holder; or
- a mandatory ICANN, Registry or legal requirement.
Nothing in this Agreement modifies or waives a mandatory requirement of the RAA, an ICANN Consensus Policy, an applicable Registry agreement or requirement, a binding dispute-resolution policy, a court order or applicable law.
38. Contact Information
Fewmoretaps OÜ doing business as Trustname
Legal Department
Roseni tn 13
Harju maakond
Kesklinna linnaosa
Tallinn 10111
Estonia
Privacy, registration-data, verification, legal-process and support requests should be submitted using the contact methods and procedures published on the Trustname website.