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18(b) How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

gTLDFull Legal NameE-mail suffixDetail
.insurancefTLD Registry Services LLCfsround.orgView
The .insurance gTLD will serve as a trusted destination on the Internet for insurers, insurance services providers, consumers and Internet users. The .insurance gTLD will seek to reach insurance professionals, their employees and partners while modeling a template of trust for online commercial interactions. The pre-registration and screening conducted by FRS will serve the industry by allowing it to congregate under one umbrella gTLD. This presents consumers with clear choices in an environment that will encourage .insurance registrants to be innovative and provide maximum value to consumers in their online experience, while providing significant competition to existing gTLDs.

Additionally, the proposed .insurance gTLD will offer the following benefits:
- Provide a trusted online marketplace for consumers seeking to access insurance products and services;
- Provide FRS and its community members with memorable Internet addresses and improve navigation to products, services, advertising campaigns, public interest content, public awareness initiatives, etc.;
- Protect the namespace for the benefit of institutions, consumers and the overall insurance community;
- Provide a variety of high value-added services through its backend registry services provider; and
- Create an opportunity to design innovative online products and services for the insurance industry and its consumers.

18(b)(i) What is the goal of your proposed gTLD in terms of areas of specialty, service levels, of reputation?

FRS was founded by organizations that hold a leadership role in the U.S. insurance industry. FRS’ Board and Advisory Board will be composed of insurers and insurance associations and therefore it is uniquely situated to understand the needs and goals of registrants in the insurance industry. FRS’ goal is that there will be no confusion for Internet users when they encounter a .insurance website. Every .insurance registrant will be a legitimate member of the insurance community, committed to a trustworthy commercial transaction experience for its clients and consumers. Registrants will work with FRS and adhere to the strictest terms of service and security standards, generated specifically by the global financial services community for this undertaking.

18(b)(ii) What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

FRS’ primary driving factor is to provide a vetted and therefore, more secure online environment for businesses and consumers to interact with the insurance community. The success of the gTLD will not be measured by the number of registrants, but rather by the level of institutional and consumer recognition and trust placed in the .insurance gTLD. Using this benchmark, FRS will strive to build recognition and trust that rises to a level meeting or exceeding that found in the .edu and .gov gTLDs.

As noted above, FRS is committed to serving the insurance community as it increasingly relies upon emerging technologies to securely deliver information between institutions and about insurance products and services to its consumers. The .insurance gTLD has the potential to serve as the cornerstone of this type of online strategy for the industry. FRS seeks to become a trusted source for inter-institution exchanges and transactions and a platform for more secure, consumer-facing insurance activities, including the purchase of insurance products and services.

In addition to the education and outreach initiative discussed above, FRS is keen to continue its work with ICANN and the broader Internet community in promoting security controls within gTLDs that require enhanced security measures, such as financial gTLDs. Its most recent effort in this area was the creation of security requirements formally proposed to the ICANN Board in December 2011 by the joint ABA and BITS (the technology policy division of the Roundtable) Security Standards Working Group. Following its submission to ICANN, the requirements have since been referenced in question 30 of the Applicant Guidebook. FRS will contractually incorporate these requirements into both its Registry-Registrar Agreement (RRA) and the end Registrant Registration Agreement to ensure that it has the legal means to enforce these obligations.

The creation of the .insurance gTLD will provide the insurance community with opportunities to explore and create new products and services that support the community in addressing the Internet based issues and concerns referenced above. It will also provide the insurance community with a space to innovate, improve current insurance services, and address the increasing consumer demand for faster and more convenient transactions.

FRS plans for its operation of the .insurance gTLD to provide significant benefits to the larger Internet community in the following ways:

1. Trust
The .insurance gTLD will allow the Internet user, before he or she even clicks on a search engine result, to know that the site belongs to a trusted member of the insurance community.

Among the results that would arise in a typical search of existing gTLDs are fraudulent businesses that intend to put Internet users, especially consumers and their personally identifiable information, including, but not limited to, financial data, at serious risk. Often, these rogue online operators register domains that look similar to legitimate domains to intentionally mislead users, resulting in increased costs to the industry and consumers. FRS’ ultimate goal on behalf of the industry is that the .insurance gTLD will reduce the efficacy of such attacks, as users on a bona fide .insurance site would know that their information was safe with a vetted insurance provider.

2. Ease of search
As the amount of information available online continues to grow, it will become increasingly more difficult for consumers to choose which websites to visit for their desired insurance services and products. However, consumers will know that Internet search results listing websites ending in .insurance belong to legitimate members of the insurance community. Will a typical Internet search produce legitimate insurance providers via the Internet? Yes. But, will the individual performing the search have the tools at hand to determine which of the results are trustworthy and legitimate? Not necessarily, but with .insurance they will.

3. Vetting and Oversight
The reason Internet users will be able to trust a .insurance domain is because FRS will aggressively govern both the issuance and continued use of a second-level .insurance domain. More information on the vetting and oversight can be found in 18(b)(iv) below.

18(b)(iii) What goals does your proposed gTLD have in terms of user experience?

FRS will ensure that the .insurance gTLD will create an enhanced user experience both for registrants and Internet users. FRS’ goal is to operate the .insurance gTLD in a manner that instills trust and confidence in the domain names and websites associated with the gTLD. For users this means a small, specialized, highly controlled environment, free from much of the abusive behaviors found in existing gTLDs.

1. Registrants
The number of .insurance registrants will be relatively small. As such, registrants will receive higher levels of customer service than can reasonably be expected in existing gTLDs. Once granted a .insurance domain, registrants will benefit through the domain nameʹs positive brand identity and consumer trust. Likewise, .insurance’s reputation will benefit from the upstanding efforts of second-level domain operators seeking to maintain their registration status.

2. Internet users
As stated above in 18(b)(ii), the restricted and manageable size of the .insurance community will provide both a trusted and secure online experience. The controls managing the community will foster competition among registrants to compete on a user-experience basis for Internet users.

18(b)(iv) Provide a complete description of the applicantʹs intended registration policies in support of the goals listed above.

To ensure a trusted environment, FRS will restrict registrations to a select group and will limit the types of activities that may take place within the gTLD with a series of policies meant to prevent and address negative behavior. These policies include:

Registrations within the community may initially be made by the following for-profit and not-for-profit businesses, individuals or organizations:
- Licensed insurance companies regulated by a government entity
- Licensed insurance agents and brokers regulated by a government entity
- Associations whose members include licensed insurance companies, agents or brokers (if approved by the FRS Board)
- Organizations that are controlled by insurance companies (if approved by the FRS Board)
- Entities whose operations are dedicated to serving insurance companies (if approved by the FRS Board)
- Specialized organizations (e.g., research or risk coordination) (if approved by the FRS Board)

In working on behalf of the insurance industry, FRS understands its responsibilities to the industry. Because of the proposed insurance-service activities that will occur within the .insurance namespace, it is essential that registrations only be permitted by verified members of the insurance community. In addition to validating the eligibility of the registrant, the domain name to be registered must comply with appropriate name selection and use requirements.

To ensure strict compliance with these policies, FRS will develop and implement a Registrant Eligibility Evaluation Process. This process will require .insurance accredited registrars to collect registrant information that will be used by FRS, or its designated third party service provider, to validate that the registrant is a member of the insurance community. These requirements will be incorporated into FRS’ Registry-Registrar Agreement (RRA).

As part of the registration process, potential registrants must provide its registrar with the following information:
- Full legal name
- Business address
- Professional title of representative of the administrative contact of the potential applicant
- Business name
- Point of contact within the business who can verify their representation of the business
- Phone
- Email
- Another proof of identity, necessary to establish that the registrant is an eligible member of the appropriate .insurance gTLD community
- For insurance companies, the state regulatory authority issuing its charter
- For agents and brokers, the state licensing agency
- For organizations that are majority controlled by insurance companies (if approved by the FRS Board), list of and proof of its owner(s)
- For entities whose operations are principally dedicated to serving insurance companies (if approved by the FRS Board), corporate operating agreement or like document(s) as determined necessary to validate alignment with the goals of the community
- For specialized organizations (e.g., research or risk coordination) (if approved by the FRS Board), a copy of the corporate operating agreement if for-profit or the mission statement if non-profit (or like document(s) as determined necessary to validate alignment with the goals of the community)

Applicants who meet the eligibility requirements and have been validated as legitimate members of the community will then be able to register their domains in .insurance.

Domain names that pass the vetting process will enter a 5-day Add Grace Period (AGP), or Pending Create, before becoming valid. Applicants whose domain name fails the vetting process will be notified with reasons for denial and procedures for appeal. Any applicant who is rejected for either a non-eligibility criteria or use of domain evaluation can appeal the validator’s decision to FRS.

FRS will audit approved registrants and their strings to ensure compliance with all applicable eligibility and use requirements.

Domains initially registered in the .insurance gTLD must correspond to a trademark, trade name or other service mark owned by the registrant. Initially, all other registrations (e.g., geographic, generic, etc.) will not be allowed. FRS will reserve a set of generic domain names prior to launch. These reserved domain names will either be used by FRS in its capacity as Registry Operator for the management, operation and purpose of the gTLD, or they will be equitably allocated to members of the community. The subset of domain names reserved for FRS’ use is necessary to create a trusted, hierarchical, and intuitive framework for the .insurance namespace to facilitate the ease by which consumers can navigate the gTLD.

Although these reserved words will be commonly used words and phrases and⁄or geographic terms, FRS will provide an enhanced Rights Protection Mechanism that will provide trademark owners with an avenue to challenge the reservation and potential use of these domain names. This challenge process will be modeled after the highly successful dotAsia Pioneering Program.

18(b)(v) Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such measures.

The .insurance gTLD will be governed by strict guidelines and policies regarding issues of privacy and the protection of confidential registrant information. The policies will be transparent and rigorous. Each level of the gTLD (registry, registrar and registry services provider) will have privacy and security policies in place to protect against unauthorized access to confidential information.

Privacy and security will be key elements of the .insurance Acceptable Use Policy (AUP), which will govern how a registrant may use its registered name. Draft AUP language specifically addresses privacy by noting that a registrant may not use a .insurance domain for any activity that ʺviolates the privacy or publicity rights of another member of the .insurance gTLD community or any other person or entity, or breaches any duty of confidentiality that you owe to another member of the .insurance gTLD community or any other person or entity.ʺ

Members of the .insurance gTLD community operate under the highest standards of privacy and protection of personally identifiable information and financial data. Such protection is an essential component of the insurance industry and a legal necessity for any Internet enterprise. State insurance regulators and the National Association of Insurance Commissioners support strong laws and regulations that protect the privacy of individual consumer information. Every state has adopted comprehensive privacy laws to protect the extensive personal information collected by insurers to underwrite and administer insurance policies. Insurance regulators also support efforts to mandate fair treatment and notification to consumers when their private information is improperly disclosed to third parties, especially where such unauthorized disclosures may result in identity theft. It is in the best interest of an insurance provider or affiliate to continue to provide maximum privacy protections for consumers, and this will continue to be their responsibility in operating a .insurance gTLD. FRS will implement the latest online technology (e.g., DNSSEC and multi-factor authentication) and services to help ensure the .insurance domain is synonymous with trust. These steps will align with actions instituted by .insurance registrants, working in lockstep with FRS. This is a manifestation of the larger goal of .insurance, that of a trusted source of safe online transactions, as stipulated in 18(a).

The protection of privacy and confidential data is of paramount importance, especially in an industry as highly regulated as insurance services. Not only will the registry have its own set of measures, but each individual institution or registrant will be required to remain compliant with existing laws and regulations in place regarding privacy and the protection of customer data. FRS will accomplish this, in part, through the inclusion of contractual language in its RRA that is modeled after similar language in Registry Agreements of existing ICANN gTLD registry operators. Specifically, some of this language will include the following:
- Registry Operator shall notify the Registrar of the purposes for which Personal Data submitted to Registry Operation by Registrar is collected, the intended recipients (or categories of recipients) of such Personal Data, and the mechanism for access to and correction of such Personal Data.
- Registry Operator shall take reasonable steps to protect Personal Data from loss, misuse, unauthorized disclosure, alteration or destruction.
- Registry Operator shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars.
- Registry Operator may, from time to time, use the demographic data collected for statistical analysis, provided that this analysis will not disclose individual Personal Data and provided that such use is compatible with the notice provided to registrars regarding the purpose and procedures for such use.

The draft AUP informs registrants that FRS maintains ʺcomplete enforcement rights over registrant’s use of their .insurance domain name. If registrant violates this AUP, registrant will be subject to a rapid domain name compliance action, be in material breach of the Agreement, and along with all other rights and remedies under this Agreement with respect to such a breach, FRS reserves the right to revoke, suspend, terminate, cancel or otherwise modify registrant’s rights to the domain name.ʺ

On a regular basis, FRS will audit domain names, or require an attestation by second-level domain holders, registered in the .insurance gTLD space to ensure compliance with all eligibility and use criteria. If a violation is discovered, an investigation will begin immediately to rectify the violation. If an applicant chooses to appeal, FRS will review the appeal to determine if there is any material change to the action or activity. FRS will retain the right to assign the dispute to an ombudsman if necessary.

A more detailed discussion of FRS’ privacy policies, specifically steps to avoid unauthorized access to sensitive information, can be found in responses to question 30.

Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

Outreach and communications with the insurance services community will be critical to the success of this project and has already begun over the past four years by FRS’ founding members. FRS’ founding members have discussed possible impacts to the industry with domestic insurance associations as well as ICANN’s Governmental Advisory Committee (GAC). Current conversations with and among insurance companies and members of the industry include ways to reach the insurance community and build an infrastructure that includes all members of the insurance services community. Ultimately, a communications strategy and plan will be implemented by FRS and its Board to guide its efforts. Advisory groups and committees will also be consulted to ensure continued alignment.

FRS and its Board will utilize all existing channels of communication to increase the awareness of the value and merit of the .insurance gTLD. Finally, the gTLD will be promoted by registrants themselves. Insurance providers will have an incentive to direct consumers to the .insurance sites they operate, and thus will promote their second-level domains containing .insurance throughout existing media channels.
gTLDFull Legal NameE-mail suffixDetail
.adsCharleston Road Registry Inc.google.comView
18.b. Benefits to Registrants, Internet Users, and Others

18.b.i.1 Specialty

The goal of the proposed gTLD is to create a new Internet environment that provides registrants, Internet users, and the public with the opportunity to associate with a meaningful term. Specialization will arise from this environment through market dynamics as entities align their offerings with the term.

The specialization goal of the proposed gTLD is to create a new Internet environment that provides registrants with the opportunity to associate with the term ʺadsʺ and to provide content or offerings related to advertising goods and services within that dedicated domain space. This specialization introduces a new gTLD environment with the express purpose of acting as a hub for advertising-related content. Charleston Road Registry expects content in the gTLD may include but is not limited to links from quick response codes, interactive advertising across media mediums, or a place to find more information on goods or services that have been promoted through other mass media.

18.b.i.2 Service Levels

Through its association with Google, Charleston Road Registry is uniquely positioned to enable and support the proposed gTLD by providing its service reliability and speed of delivery as a part of its services. Google brings unique expertise and a proven record of excellence in infrastructure operations: Google now runs the largest DNS system in the world, has industry-leading uptime on its services, such as web search, and offers enterprise services on which governments and businesses depend.

Google is known for its high level of quality and speed, and Charleston Road Registry’s service level goal for the proposed gTLD is to extend that high level of quality, speed, and service to registrars. Indeed, two of Google’s core principles in providing Internet search and related goods and services are “focus on the user and all else will follow” and that “fast is better than slow.”

Charleston Road Registry is committed to using the most technologically advanced, secure, and reliable registry services for all of the domain names in the gTLD so as to not compromise the service levels, security, and stability of the gTLD to users worldwide.

Charleston Road Registry will provide both Engineering and Customer Service support to registrars. All registrars will also have the same level of access to Charleston Road Registry resources to resolve disputes and technical and⁄or administrative customer service issues.

Charleston Road Registry will provide all registrars with 24-hours-a-day, 7-days-a-week Customer Support in the form of telephone, email, and⁄or web chat for technical and non-technical issues relating to the operation of the gTLD system. Charleston Road Registry will provide all registrars with the same level of access to customer support via telephone, email, and Charleston Road Registryʹs website; email and web-based interactions will be the primary method of provisioning customer service support to registrars.

Additionally, Charleston Road Registry will implement strict policies and procedures to minimize abusive domain name registrations and uses and other activities that have a negative impact on Internet users. It will dedicate ample resources for the purpose of responding promptly to abuse complaints from government, judicial and⁄or law enforcement.

18.b.i.3 Reputation

Google has a proven record of providing high-quality, secure online services. Charleston Road Registry seeks to enhance Google’s reputation for excellence, superior quality, and high level of security and become known as an exemplary domain name services provider. When registrants assess opportunities in the marketplace to obtain a name, they will have confidence in Charleston Road Registry’s ability to meet ongoing needs as the registry operator for the proposed gTLD. When Internet users visit a domain name in the proposed gTLD environment, they will be able to reliably expect and experience the high level of security and quality on which Google’s reputation has been built.

The registry will be structured so that Charleston Road Registry allows registrars to register and oversee second-level domain names in the proposed gTLD; that registrars develop and deploy a reasonable process for ensuring that those domain names are used for gTLD-relevant purposes as specified in the registry-registrar agreement; and per Specification 4 that the WHOIS is thick and reliable; and that the registry is responsive to legal rights owners (if applicable) who may have complaints about potentially abusive registrations.

In addition, Charleston Road Registry’s operation of the new gTLD will provide the opportunity for registrars and registrants to build and⁄or bolster their unique brands and brand reputation in association with the proposed gTLD.

18.b.ii.1 Competition

Charleston Road Registry supports the advancement of registry operators as a whole and the diffusion of gTLDs amongst diverse stakeholders to generate increased competition for the benefit of the Internet public. Increased competition will result in more competitive prices for consumers, generate efficiencies and increase productivity in enterprises, and spur innovation in the gTLD space.

The proposed gTLD, .ads, will provide a new online structure for the aggregation of advertising online. As an alternative to existing second-level domains, Charleston Road Registry anticipates that the .ads gTLD will increase competition among registrars by increasing consumer choice and creating new opportunities for registrar pricing differentiation. Charleston Road Registry anticipates that the .ads gTLD will help grow the volume of entities offering advertising-centric content online, thereby increasing competition among content providers to deliver new, unique, and more relevant content and offerings.

Managing this Internet space will allow Charleston Road Registry to provide to registrars and registrants the high level of technical operations quality and service for which Google is known, which in turn will incent other existing and new gTLDs to improve the quality of their offerings.

Charleston Road Registry will facilitate a fair and equitable registrar process, providing open access to any registrar who meets ICANN accreditation guidelines by fully complying with the Registry Operator Code of Conduct. Charleston Road Registry is committed to treating all registrars equitably and will not offer preferential treatment to Google in its capacity as registrar.

18.b.ii.2 Differentiation

Charleston Road Registry believes in the commercial viability of alternatives to existing gTLDs such as .com and .net. The proposed gTLD will provide the marketplace with opportunities for differentiation not currently available in the gTLD space.

The .ads gTLD will provide a new mechanism whereby businesses and individuals can differentiate their content by signifying that their offerings are in relation to a promotional brand campaign. This signification is not currently available in the gTLD space.

Given its association with Google, Charleston Road Registry offers a unique value proposition to registrars resulting from the strength of Google’s trusted brand, technical leadership, and support for free speech on the Internet. Registrars will have the opportunity to leverage this brand in devising their own market positions.

18.b.ii.3 Innovation

The proposed gTLD will foster innovation by creating a new space for the categorization and classification of online content. It will therein provide a mechanism by which registrars and registrants can better brand and manage their online presence by associating it with the .ads namespace. This namespace delivers value to the public through the provision of new and differentiated content, goods, and services to Internet users.

The proposed gTLD, .ads, will promote innovation among registrars by providing for the sale of a second-level domain in a gTLD that will attract a specific segment of registrants. This provides registrars with the opportunity to create and offer tailored new products and services that benefit registrants and⁄or improve user experience in association with the registration of a second-level domain in the .ads gTLD. The proposed gTLD aspires to become an authoritative online resource for content related to advertising. The concentration of content providers in the .ads gTLD will likely invite user comparison among second-level domain sites, encouraging second-level domain registrants to innovate and improve upon their content and⁄or offerings as a point of differentiation.

In addition, the proposed gTLD will promote innovation in the marketplace by providing additional second-level domain options for the public’s use. This will invite new entrants to establish a domain name presence, facilitating innovation in their offerings, and their interactions with Internet users.

Charleston Road Registry considers the proposed gTLD to be a platform for innovation with existing and future Google products and services. Charleston Road Registry, therefore, may incorporate these new offerings into future registry service options (subject to the ICANN approval process), infusing new ideas into the gTLD for the betterment of the public.

Google consistently aims to improve upon technologies that connect people with information, as demonstrated by a proven record of innovation and iteration. Charleston Road Registry strives to offer its constituents this same level of continuous development in advancing its management and operation of the gTLD, engendering benefits to registrars, registrants, and end users.

18.b.iii User Experience

Charleston Road Registry will strive to provide the highest level of user experience through operational stability, security, and performance to serve the interest of registrants in the proposed gTLD. Charleston Road Registry is uniquely positioned to provide this level of experience given its relationship with Google; Google invested over $3 billion in its IT infrastructure in 2011 and maintains a record of excellence in infrastructure operations.

The proposed gTLD will provide registrants with the opportunity to differentiate their dedicated domain space such that the end users are able to discern the type of content intended to be found within the proposed gTLD. This will enable increased user visibility of registrants’ offerings, as well as provide registrants with the opportunity to enhance their respective content offerings and innovate in new ways.

The proposed gTLD will provide a more trusted and user-friendly environment where domain names and content related to the .ads gTLD can flourish. Charleston Road Registry seeks to have users deem the gTLD trustworthy and reliable and recognize it as an aggregated source of targeted goods, services, and information.

The proposed gTLD, furthermore, facilitates an improved online user experience through greater structure and categorization on the Internet.

18.b.iv Registration Policies

Charleston Road Registry believes that given its wide variety of uses, the .ads gTLD will best add value to the gTLD space by remaining purely open and unencumbered by registrant restrictions. There will, therefore, be no restrictions on second-level domain name registrations in the proposed gTLD, .ads.

Charleston Road Registry will make access to Registry Services, including the shared registration system, available to all ICANN-accredited registrars. Domain names within the proposed gTLD will be available to the general public for registration and use.

Charleston Road Registry is committed to implementing strong and integrated intellectual property rights protection mechanisms. Doing so is critical to Google’s goals of model Internet citizenship and fostering Internet development, especially in emerging regions. Accordingly, Charleston Road Registry intends to offer a suite of rights protection measures, which builds upon ICANNʹs required policies while fulfilling our commitment to encouraging innovation, competition and choice on the Internet.

18.b.v Protection of Privacy and Confidential Information

Charleston Road Registry will strive to ensure the appropriate level of privacy and security will be met for its users. Charleston Road Registry and its provider of registry services, Google, have imposed measures to achieve this protection; additional specifics regarding the practices for the registry include but are not limited to the following:

- All data transmitted from registrars to the registry will be encrypted using transport layer security (TLS) or other similar data protection schemes to ensure that third parties cannot access personally identifying information or other sensitive data as it crosses the Internet.

- Charleston Road Registry will attempt to prevent the misuse of WHOIS data for improper purposes such as spam, intellectual property theft, or phishing. Charleston Road Registry will attempt to identify patterns of abusive usage of the WHOIS and will appropriately use CAPTCHA, query throttling or other techniques to prevent information scraping.

- Google will restrict access to data and information systems maintained by the registry to a specific list of individuals involved with supporting the Google Registry system in production. Google will review this list on a periodic basis to ensure that the level of access granted to individuals is appropriate. Google uses two-factor authentication and other mechanisms to ensure that staff with access to user information are properly identified prior to using registry systems.

- Google data backups stored offsite are encrypted with passwords that are securely managed on Google’s internal systems. Google can effectively remove the ability to access this data by destroying the relevant encryption password.

- Supplying Google account information will be optional for registrants unless the domain registration is directly associated with another Google product offering. Google will not disclose Google account information except for any contact information provided by the user that is required by ICANN (per Specification 4) to be displayed in response to a WHOIS query.

- Registrar billing and payment information will not be stored alongside domain name registration information. All registrar billing and payment information will be stored in a payment card industry (PCI)-compliant billing system similar to that used by Google Ads.

- Data will not be shared with third parties without the permission of registrants, except as required for registry operations or as required under the law, such as in response to a subpoena, other such court order, or demonstrated official need by law enforcement.

Beyond these specific mechanisms, both Charleston Road Registry and Google will govern its approach to privacy by the Google Privacy Policy. This policy applies to registrars, registrants and end users of registry services such as DNS zone publication and WHOIS data publication. The Privacy Policy is located at http:⁄⁄www.google.com⁄policies⁄privacy⁄.

18.b.vi. Outreach and Communications Efforts

Once Charleston Road Registry begins developing public-facing resources in its gTLD, it intends to inform the public about the gTLD and the opportunity to obtain domain space there through investments in marketing and public relations.

Charleston Road Registry intends to promote gTLDs in its portfolio, such that the public gains an awareness and understanding of new gTLDs and the availability of new second-level domain space on the Internet. Charleston Road Registry believes that this approach will make the strongest impact in modifying consumer behavior and is the best path to achieving success for all new gTLDs collectively.

Charleston Road Registry will reach out to the Internet community via a number of different outreach and communications methods and venues to deliver its mission and message to the public, including but not limited to: press briefings, videos posted on various Internet sites, blogs and other social media, and paid advertising. In addition, when developing resources for localized Internet registrars in different global regions, Charleston Road Registry will use local marketing and communications platforms as needed.