1. Important Information and who we are

This Privacy Policy applies to all personal information collected by AOS LTD. "AOS LTD.", “AOS LTD.”, “we”, “our” or “us” refer to AOS Limited, as applicable. In this policy we explain how and why we collect your personal information, how we use it, and what rights you have over our use of it. We are committed to complying with the highest standard governing privacy of personal information by businesses and to protecting and safeguarding your privacy when you deal with us. This website is not intended for children and we do not knowingly collect data relating to children.

2. Amendments to this Privacy Policy

This Policy was last updated on 20 August 2019. We may amend this Privacy Policy on one or more occasions by posting a revised statement on this website or any successor website

3. Links to Other Websites

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their Privacy Policies. When you leave our website, we encourage you to read the privacy notice of every website you visit.

4. Collection of Information

Some information provided to us by clients, customers, contractors and other third parties might be considered private or personal. Without these details we would not be able to carry on our business and provide our services to you. We will only collect such personal information if it is necessary for one of our functions or activities. We collect the following information from you:

  • names; phone numbers; mailing, billing, email addresses, usernames, your job title and organization if applicable;
  • payment processing information required for buying services.
  • Additional information such as your date of birth, document number (including, but not limited to national ID card number, national ID card country of issue, drivers licence number, passport number, passport country of issue, or birth certificate number) if for specific purposes which may depend upon the nature of service or if you are an employee.
  • The type of information you provide to us and how we use it depends upon how you use our services.
  • For example information you may provide your name, email and postal address when you contact us by phone, letter or using the web form contact facility on this website. :
  • If you or a company you represent, enters a contract with us as a customer or reseller
  • If you instruct someone else to obtain services from us that person may share your information with us (for example you ask a web-developer to get your domain name)
  • If we are asked to contact you in relation to services we provide
  • Subscribe to our newsletters
  • Order other services or products from us from links on this page to domain names services
  • Create an account and logins
  • Use our Whois Services
  • Use our webmail contact service for emailing registrants
  • Interact with us on social media platforms such as Linked-in, Facebook or Twitter
  • Report a problem on our website or contact our support or domain abuse teams
  • Visit our offices
  • Respond to survey
  • Apply for a job with us or work for us
  • Visit our websites
  • Use your credit card to pay for services

How we use your data

We will only use your personal data for lawful purposes. This includes:

  • Provision of the services we have contracted with you or the company you represent
  • To monitor improve our products and services
  • To give notice of changes to the services
  • To administer the website, internal operations, customer support, testing, feedback
  • To manage our relationship with our resellers, customers and affiliates.

Telephone We may monitor or record phone calls for training and quality purposes. We only do so if we inform you at the time of the recording or if you choose to leave a voicemail message.

Traffic data from our websites
Traffic data, e.g. data being collected and used to measure the amount of usage of a telecommunication service, will only be collected as necessary for the purpose of performance of services and invoicing. We also collect traffic data with regard to any login attempts into our systems. Traffic data will not be stored longer than six months above the time required for invoicing and the provision of the service, unless the customer requests a longer storage time within the scope of a statistics function. Traffic data will not be used to create user profiles.

Cookies, Web Beacons, and Logs We collect information related to your use of our website using cookies, web beacons, and log information. Cookies are small files containing strings of text stored on your computer. We use cookies to authenticate you as a user when you log in, track your session, deliver content specific to your preferences and interests, store the contents of your shopping cart, provide features related to payment and customer service, and provide other functions. Web beacons are objects embedded into web pages that allow us to determine whether and for how long users view web pages. We use web beacons for site traffic reporting, unique visitor counts, auditing and reporting, personalization, and other functions. Log information may include website requests, Internet Protocol address, operating system, browser type, browser language, date and time of your request, and cookies that may uniquely identify your browser. We use this information to enhance the functionality of the website and to make your access more convenient, secure, and efficient. We also use information gathered from logs, cookies, and web beacons to monitor website performance; improve website design, functionality, and security; and assemble web analytics and activity trends. We retain such information for as long as reasonably required for business purposes or as reasonably required to comply with our legal obligations. You may stop your browser from accepting cookies or web beacons. The Help portion of your browser should explain how to configure your browser's cookie handling. Your browser may have add-ons that may help you block web beacons. You may have limited functionality if you block cookies or web beacons set by our website.

5. Use of your information

We use the personal information it collects for:

  • Fulfilling our contracts for domain names to Resellers, customers and end users
  • Provision of domain name registration and related internet services; enabling sales and other transactions; processing payments and settlement; handling orders; providing receipts;
  • providing customer service; processing and assistance with dispute resolution; payment processing including chargebacks, refunds, and/or related issues;
  • marketing and surveys; sending service update notices and important renewal notices;
  • recovering debt and collections; detecting and preventing fraud; detecting and preventing violations of our legal agreements and other agreements;
  • measuring, improving, and customizing our services; and
  • fulfilling other technical, logistical, financial, tax, legal, compliance, administrative, and/or back office functions.
  • personalize the content you will see based on your personal characteristics or preferences
  • notify you of relevant new products and features on our websites (if you opt in to receiving such information)
  • notify you of promotions (if you opt in to receiving such information)
  • ensure, as far as is practical, that our site is compatible with the browsers and operating systems used by the majority of our visitors.
  • We may also publish your data based on your explicit, informed and freely given consent, if applicable. For example if you explicitly request the publication of your data in a registration database (WHOIS) despite our ability to redact or hide such data. This consent may be withdrawn by you at any time. The manner of publication of your data on the WHOIS depends on the policy of the Registry Operator’s policies and we encourage you to read their privacy policies and Whois policies to better understand how your data is used and published.

Change of Purpose

We will seek your consent prior to using your personal information in a manner incompatible with the purposes we described in our Privacy Policy at the time of collection. You may choose not to provide any personal information to us, in which case we will be unable to provide services to you where the data is required by law or under the terms of the contract with you.

6. How long we keep your information

We will only retain your personal data for as long as necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
The table below illustrates what information we collect, how we use it and how long we hold it for:

Data Collected Purpose Retention
Visitors Visitor logs – name and purpose of visit Security purposes. Prevention of crime 6 months
Employees Name, email, ID documents, address, etc (Note a full notice is available to employees in the handbook) Performance of employment contract Duration of contract plus 3 years
Prospective Employees Name, address, email, telephone number and CV Assessment of job application 6 months or less from closing of recruitment process
Resellers/ Customers/ Registrants/ Name, address, email and telephone number of registrant and technical contact, administrative contact, billing payment details. Account usage history. Account log in details. Performance of contract for provision of service or product Duration of contract plus 6 years
Support requests Name, email address and telephone number Customer support 6 months from resolution of the issue
customers with accounts and users Name, address, email telephone number. cookies Access to the website and authentication of usersPreferences management The information is purged when the account is de-activatedUsers can de-activate cookies and delete all existing cookies through their browser.

7. Disclosure of Information

We disclose personal information to other organizations that perform services on our behalf. We require third parties to respect the security of your personal data and to treat it in accordance with this Privacy Policy. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes detailed in this Privacy Policy and in accordance with our instructions As a Registrar, we are required to pass on your full name, mailing address, telephone and fax numbers, and email address to the relevant registry when you apply to register, renew, or transfer a domain name. This function is required to facilitate registration and to ensure registry records are correct and current. We encourage you to read the Privacy Policy of the Registry Operator of the TLD you intend to register your domain under (https://ricta.org.rw/policy_details.php?Id=19). We have no role in the setting of such requirements. If you do not wish to disclose such details we recommend choosing alternative domain extensions.

In addition we may use or disclose personal information held about you:

  1. Where you have consented to the use or disclosure;
  2. Where we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious, immediate threat to someone's health or safety or the public's health or safety;
  3. Where we reasonably suspect that unlawful or non-compliant activity has been, is being or may be engaged in and the use or disclosure is a necessary part of our investigation or in reporting the matter to the relevant authorities or the Internet Corporation for Assigned Names and Numbers;
  4. If applicable, your personal data may be provided to operators of registration database ( ‘whois’) services and the users of such services if required and such provision and use is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.
  5. To ensure business continuity, your personal data may be provided to escrow service providers as well as to backup storage providers.
  6. We may disclose your personal information to law enforcement agencies, to other government and/or civil authorities similarly authorized by applicable laws and regulations and to courts of appropriate jurisdiction if so required by law. To ensure data accuracy and to prevent abusive use of our services, we may use third-party verification service providers to check the data you have provided. To assess our business operations, we may also provide access to your data to our auditors;
  7. For support purposes, we may provide access to your personal data to providers of third-party support services.
  8. Between us and RICTA, to provide services to you (such as, for example, a consolidated report or company renewal notice).

8. Security and storage

We place a great importance on the security of all information associated with our customers, clients and contractors. We have security measures in place to protect against the loss, misuse and alteration of personal information under our control. Personal information is anonymised or destroyed securely when no longer required by us. We retain the information you provide to us including your contact and credit card details to enable us to verify transactions and customer details and to retain adequate records for legal and accounting purposes. This information is held on secure servers in controlled facilities. Our website site uses a process called Secure Sockets Layer (SSL) technology. SSL locks all critical information passed from you to us, such as payment information, in an encrypted envelope, making it extremely difficult for this information to be intercepted. The transfer of information across any media may involve a certain degree of risk, and the internet is no exception. As a result, while we take reasonable steps to protect users' personal information, we cannot ensure or warrant the security of any information transmitted to us or from our website.
You should be careful and responsible whenever you are online. Ultimately, you are solely responsible for keeping your passwords and/or account information secure and should take all reasonable steps to do so.

9. WHOIS Policy

The public WHOIS service is a standard feature of domain name systems around the world. The purpose of the WHOIS service is to allow users to query a domain name to find out the identity and contact details of the registrant. The WHOIS service is provided via a web-based tool and Port 43. However full whois data may be accessed where requestors have legitimate interest in accessing full whois data. For example law enforcement may be entitled to access your information for investigation of crime. Where your name, email and addresses are protected by privacy requestors for legitimate purposes may contact you using a webform which will not show any of your identifiable information. This could be used to notify you of claims court processes or other legitimate purposes

9.1 Collection of WHOIS Data

  1. Data about each domain name registration is collected from the registrant by us as registrar or by the reseller, and submitted to the registry in accordance with the procedural requirements of the registry. The WHOIS service displays a subset of the full registry data for each domain name (known as the "WHOIS data"). The data displayed on the WHOIS will vary depending on the policies of Registry the .rw registry authority RICTA under which the domain is registered.
  2. Under the Registrar Agreement, registrars must inform registrants of the fact that some of their personal information will be disclosed on the WHOIS service. Under the domain name licence agreement, registrants grant to the registry the right to disclose information for the purposes of maintaining the WHOIS service.
  3. Due to the policy requirements in the .rw domain, the WHOIS data that is collected by registrars at the time of registration is intended to be highly accurate and reliable. However, the integrity of the WHOIS database is undermined if the data is not kept up-to-date.
  4. In order to maintain the integrity of the WHOIS database, registrants are required to notify their registrar of any changes to WHOIS data for their domain name(s) and the registrar must update the WHOIS database on receipt of new information from the registrant.

9.2 Disclosure of WHOIS Data

9.2.1 The table in Schedule A lists the data fields that will be disclosed on the WHOIS service (web-based and Port 43) for all domain names in the .rw name space open 2LDs.

9.2.2. It is necessary for the WHOIS data to include a contact email address for the registrant, for the purpose of contacting the registrant in relation to their domain name. The registrant does not have to nominate their own personal email address, but they must nominate an email address at which they can be contacted.

9.2.3. To address user concerns about privacy and spam, and in line with international best practice, RICTA has implemented Image Verification Check (IVC) on the web-based WHOIS service. The purpose of IVC is to prevent or hinder unauthorized access to WHOIS data by automated data mining programs or scripts. For consistency, RICTA has removed all email addresses from Port 43 WHOIS responses; users of Port 43 WHOIS will be referred to the web-based WHOIS service to access email addresses via IVC.

9.2.4. In the past, it was possible to use WHOIS to find out the creation and/or expiry date of a domain name. This enabled some members of the domain name industry to send unsolicited renewal notices to registrants with whom they did not have a prior business relationship, causing significant levels of customer confusion. As a result of these problems, RICTA has determined that creation, renewal and expiry dates will not be disclosed on the WHOIS service. Registrants who wish to check the creation, renewal or expiry date of their own domain name can do so through their registrar or reseller.

10. Correction of personal information

  • We are committed to maintaining accurate, timely, relevant and appropriate information about our customers, clients and web-site users. For the purposes of receiving timely renewal notices, consumer alerts, and other related correspondence, it is imperative that the contact details we hold for you are always current. If you would like to access or advise us of a change to your personal information, please e-mail your request to idc@aos.rw or call our customer service department on 4747. We may also contact you from time to time to confirm that your details are still current.
  • Inaccurate information will be corrected upon receiving advice to this effect from you. To ensure confidentiality, details of your personal information will be passed on to you only if we are satisfied that the information relates to you

11. Your rights and access to information

All information that we have collected is available online in your account and you may access such information at any time by logging in to your account through our website. Under the privacy laws you have rights which may include the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and receive information about how we process it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us to protect your security and comply with our data accuracy policies.
  • Request erasure of your personal data. You may request to delete or remove personal data where there is no good reasons for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in such limited circumstances as: where you wish to cancel all services and close your accounts; or where you need us to hold the data to establish, exercise or defend legal claims when we would normally delete or anonymise the data.
  • Request the transfer of your personal data to you or to a third party. We will allow you to copy your information held by us. If you wish to transfer domain names to another registrar please login and go to the “Manage Transfers” tab on the website.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Automated decision-making Other than the use of cookies, logs and web beacons, set out above which are automated on the website, we do not use automated profiling or decision making based upon your personal information in providing you with services. We will not contact you solely as a result of visiting our website
  • If you wish to exercise any of the rights set out above, please contact us on idc@aos.rw

    Further Information

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    12. Contacting us and complaints

    If you require further information regarding our Privacy Policy, or if you have a complaint about out handing of your personal information, please email us at the following address: idc@aos.rw. If you have a complaint about our handling of personal information, we will be in contact promptly and work with you to resolve the issue.