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

gTLDFull Legal NameE-mail suffixDetail
.mtnMTN Dubai

The core goals of the .mtn TLD are as follows:



A goal of the .mtn TLD is to develop the reputation of domain names within the .mtn TLD as authoritative points of reference for the MTN brand online, which customers and Internet users will intuitively navigate to and trust.

Operated and controlled exclusively by MTN (Dubai) Limited, the .mtn TLD will leverage the power of the MTN brand to promote .mtn domain names as the single point of reference for the wider MTN brand online. Thus, the .mtn TLD will reduce confusion for Internet users and reduce the likelihood for harm by interacting with online entities that falsely and misleadingly purport to either represent the brand, or in some cases, even impersonate the brand online. Due to the very nature of the telecommunications industry, this is always a prevalent threat. The .mtn TLD will assure users that the content of .mtn domain names is authoritative, genuine and legitimate.

MTN (Dubai) Limited will ensure that the content of the .mtn namespace conforms to its usual terms of use and registration pertaining to Internet policies.

This goal to be the authoritative TLD will be achieved by ensuring all content and registrations are tightly controlled and strictly authorised by MTN (Dubai) Limited immediately upon creation of the TLD.

A benefit for MTN (Dubai) Limited will be the strengthening of the MTN brand via the provision of an authoritative and coherent brand information channel. An additional benefit is the reduction in the risk that consumers may be misled by unauthorised or infringing content within other TLDs. Having this authoritative TLD will create an Internet ‘lighthouse’ that clearly displays to customers and Internet users without doubt that these websites are approved and controlled by the MTN brand.

Such an authoritative TLD could potentially deliver financial benefits to the company by reducing the need for Search Engine Optimisation (SEO) costs, due to marketing and labour not being required to be devoted to this activity. In addition, costs incurred by maintaining a portfolio of defensive domain name registrations within other TLDs and ccTLDs in order to protect the brand and internet users will, over time, be reduced as they become unnecessary.

Consumers will benefit from having certainty that all content on .mtn websites can be trusted, is authorised and company-approved. Users of .mtn domain names will be able to access, within a single TLD, information about the MTN brand, its products, services and affiliates - as designated by clear, logical domain names. The added confidence inherent in MTN (Dubai) Limited being the only possible registrant will ensure a direct and trusted line of communication between customers and the MTN brand. Internet users can also be assured that any information they access through the .mtn TLD is legitimate and supported by the reputation of the brand.

The TLD can also benefit the wider Internet and online communities by generating trust around the reputability of content. It is in the interest of the MTN brand to ensure that the .mtn TLD remains true to its mission and purpose.

Surveys will be conducted by MTN (Dubai) Limited to assess site users’ experience, alongside assessment of the authority and suitability of the information that the .mtn TLD conveys.

The authoritative goal of the TLD will be considered achieved when the majority of survey responses in a reporting cycle reveal a positive and trusting experience in using .mtn websites.


Following the introduction of the .mtn TLD, efforts will shift to focusing on transferring the brand reputation of the existing domain names to the .mtn TLD in the marketplace, while promoting the additional benefits the TLD provides. This will serve to expand the overall attractiveness of the brand to customers and Internet users. External marketing campaigns will begin to promote the .mtn TLD and drive traffic to websites within the .mtn TLD only.

Brand building will be achieved through the organic usage and gradual replacement of the existing domain name portfolio in marketing campaigns, with the .mtn TLD to be incorporated over time into all new global and directed marketing. Once established, the TLD’s reputation will then serve as a springboard for efforts to promote the use of the TLD, facilitating the mission⁄purpose of the TLD.

The promotion of .mtn TLD-based websites will also provide an efficient marketing model that encompasses both brand and product. This is a more efficient marketing approach than that currently employed - the usage of existing TLD’s which are neither brand nor product-specific. The benefit to the MTN brand will be in the enablement of internal departments to register, via an ICANN accredited Registrar, brand and product-supportive domain names. The MTN brand will be able to use these registrations to represent product lines and strategic initiatives in support of MTN brand core strategy and the mission⁄purpose of the .mtn TLD. The company will also benefit from maintaining a more marketable online identity.

A website hosted within the .mtn TLD will assure Internet users that they are accessing authoritative and reliable MTN brand, product or company information. As such, it is anticipated that more traffic will be directed to MTN brand sites and away from unreliable and illegitimate websites purporting to provide information relating to the MTN brand.

Surveys will be conducted to measure the impact of the introduction of the .mtn TLD against the existing domain name portfolio. Visit metrics will be utilised to measure the volume of traffic on .mtn websites and subsequently compared to existing data of the current domain name portfolio.


Having the .mtn TLD in the control of MTN (Dubai) Limited is another goal. This goal of control will be achieved when the TLD is delegated for use by ICANN and the company’s internal policies are in place to manage the registration of domain names. This creates numerous benefits to the company, consumers and the wider Internet community.

In addition to the aforementioned statements concerning trust and genuine content, MTN (Dubai) Limited sees additional benefits such as:


As the Registry Operator, MTN (Dubai) Limited will benefit from having ultimate control of the TLD and the policy that underpins it. This will enable policy development that serves the mission and purpose of the domain, but at the same time, allow it to be dynamic over time to support the future direction of the business on the Internet.

Being in control of the TLD gives MTN (Dubai) Limited the comfort of knowing any future products or services will have a dedicated TLD in which to reside. It allows the company a platform from which to innovate or adapt to any changes in Internet policy or best practice. Being in control of the TLD also gives the MTN brand the ability to change direction and approach quickly, and in line with the company’s current and future goals.


Being in control of the TLD will enable MTN (Dubai) Limited to register domain names without needing to compete within other TLDs and ccTLDs for domain names. This will benefit the company by allowing key marketing campaigns to be undertaken which will be promoted with shorter domain names that are easier to remember. Thus consumers and Internet users will be able to intuitively navigate and find relevant domain names – which can be trusted as authoritative from the MTN brand.

The benefits to consumers will be similar to those mentioned above. As also mentioned above, surveys will be used to measure user experience and determine that the goal of control has been met.


The leadership goal is to promote and further identify the MTN brand as a leader in innovation and online content in the telecommunications industry.

By securing the .mtn TLD, MTN (Dubai) Limited creates a platform by which the company can lead innovation within the telecommunications industry via online content, marketing initiatives and delivery.

Success will be achieved by tightly integrating existing MTN branded content about the company, as well as current, new and forthcoming products, while using the TLD as an innovative marketing and communications tool and actively involving itself in adding to the development of the Internet. As Internet usage evolves and new TLDs emerge, it is the MTN brand’s goal to be a leader in this new era of Internet development.

An additional benefit to the MTN brand will be in furthering its existing reputation as a global leader of the telecommunications industry. This will serve to enhance the MTN brand as a whole.

The leadership goal will be measured by survey results relating to the perception of the MTN brand in terms of industry leadership.



A goal of the .mtn TLD is to have accessible and easily locatable information freely available online. Clients and affiliates, both prospective and existing, require readily available and easily-accessible information about MTN-branded products. The .mtn TLD will facilitate this by offering a centralised location for all MTN products and information pertaining to the brand. As previously stated, this will also be authoritative and governed by MTN (Dubai) Limited.

The MTN brand will benefit from having a cohesive and dedicated online space that will serve as a digital hub for all brand-related activities on the Internet. This will support the diverse global approach that the MTN brand utilises in its operations and serve as a basis for its corporate operations. As previously stated, this will potentially reduce the costs of SEO and reduce company-related expenditure on marketing as a whole.

The consumer will benefit from the naming conventions employed in the .mtn TLD (for example, or; enabling a better user experience for online consumers searching for products and information, while also reducing confusion. The .mtn TLD provides for intuitive navigation which, coupled with the introduction of other TLDs, will enhance the overall navigability of the Internet.

Surveys will be conducted to assess the experience of a site user and the ease of accessing .mtn TLD websites. Visit metrics will be utilised to measure the volume of traffic on .mtn websites – where the traffic has originated from and where it is being directed to. This will be compared to existing data on the current domain name portfolio and then analysed for performance.



The .mtn TLD also seeks to create more competition on the Internet. In creating its own TLD, the MTN brand hopes to drive innovation, not only to its own market segment, but to the Internet as a whole. Having already shown this innovation and leadership in its own market, the MTN brand will give Internet users, as well as existing and potential customers, greater levels of service through the creation of the .mtn TLD. This innovation, service level increase and trust in the TLD will promote more competition on the Internet and thus increase overall levels of service across the industry.

The success of this goal will be tied to the success of the new gTLD program as a whole. As more new TLD’s are delegated to the root, more competition will be created and consequently an increase in service levels will follow.

MTN (Dubai) Limited will not have a specific measure in place for this goal, but will rely on the post-program analysis to be conducted by ICANN and the GAC to determine the overall success of the program.



The .mtn TLD will make a significant contribution to the current space in the following ways:

– The TLD primarily differs from existing TLDs in relation to its unique mission⁄purpose – to promote the MTN brand and its diverse operations. No other TLD currently exists that is devoted specifically to the needs of a single brand. The .mtn TLD will be one of the first TLDs added to the root in which a brand’s digital operations and very image are communicated by and through the TLD via authoritative channels.

MTN (Dubai) Limited intends to request an exemption from clause 1b of the Registry Operator Code of Conduct (Specification 9) pursuant to clause 6 of the Code of Conduct to enable it to register domain names in its own right in this TLD. This planned operating model will allow the .mtn TLD to be one of the first TLDs added to the root in which domain names are not commercially available and are registered only by and in the complete control of the Registry Operator via an ICANN-approved Registrar. This will bring added benefits to the DNS by preventing abuse and infringement, thus increasing reliability and trust. Consequently, the .mtn TLD model and other TLDs will contribute to the development of a new level of trust and confidence on the Internet.

– The use of an authoritative space will also help reduce and⁄or eliminate the number of domain names that are registered for the purpose of infringing the trademark. When end users are educated as to the benefits of the .mtn TLD, the reliance on vast portfolios of defensive domain name registrations to protect Internet users and the MTN brand will be less warranted.

– Where existing TLDs often apply to diverse and broad markets, with no imposed cap on the number of registrations made available, the .mtn TLD will be differentiated by having a relatively small number of domain names. This means that users searching for content related to particular MTN-branded products or services will be easily directed to that content via a potentially small global number of applicable sites.

– With restrictions placed on registrations and their use and content, the .mtn TLD will distinguish itself as a TLD with an online brand identity reflecting the unique and diverse MTN brand.

The above-described features of the .mtn TLD clearly differentiate it from existing top level domains. The .mtn TLD serves to consolidate the MTN brand’s online presence by providing an easily identifiable, globally visible home for MTN brand operations.

Additionally, the .mtn TLD addresses the needs of Internet users by providing an easily identifiable and dedicated TLD, with assurances regarding the legitimacy of content. Websites within other TLDs that are providing unauthoritative information relating to MTN branded products will be easily identifiable, as they will not carry a .mtn top level domain name. This will reduce risk to Internet users of reliance on unauthorised and infringing MTN brand-related content provided by unauthorised third parties.

Because domain name registrations in the .mtn TLD will be the exclusive reserve of MTN (Dubai) Limited, internal departments who register a .mtn domain name will have a distinct advantage over registration within existing TLDs and ccTLDs in terms of value proposition – due to the synonymous relationship between the .mtn string, the registrant and its aims. The .mtn TLD will be recognised by Internet users as the dedicated, authoritative and trusted online space for the MTN brand, as supported by its inclusion within MTN brand marketing activities.


All domain names registered within the .mtn TLD will be registered and maintained by MTN (Dubai) Limited for the exclusive use of MTN (Dubai) Limited, MTN (Dubai) Limited internal departments and affiliates (as defined in Article 2.9(c) of the Registry Agreement). MTN (Dubai) Limited will not sell, distribute or transfer control or use of any registration in the TLD to any third party that is not an affiliate of MTN (Dubai) Limited. All domain names will be registered via an ICANN-accredited Registrar.

Eligibility to register domain names in the .mtn TLD will be restricted to specifically-authorised MTN (Dubai) Limited marketing staff members. Clearance for registration will come from an authorised staff member within MTN (Dubai) Limited. Departments within MTN (Dubai) Limited will be able to register associated .mtn domain names to promote activities, products and services and⁄or events with authority. The safeguards against allowing for registrations in violation of this eligibility restriction, including Trademarks, are discussed in the responses to Question 28 and 29. Registration policies will strive to avoid registering any domain names that are confusingly similar to any third party trademarks or related proprietary material; offensive and obscene material will not be tolerated.

An authorised MTN (Dubai) Limited staff member will be designated as the technical contact on all registrations within the .mtn TLD. This staff member will be responsible for the ongoing technical services of websites utilising .mtn domain names.

Domain names registered within the .mtn TLD must further the published strategic goals of MTN (Dubai) Limited, as mandated by the registration policy created and maintained by MTN (Dubai) Limited.

These restrictions underpin the achievement of the goals of the TLD, in particular enhancing trust in the MTN brand and forming an authoritative source of information relating to the brand and its products.


All domain name registrations in the .mtn TLD will be registered to and maintained by MTN (Dubai) Limited for its own exclusive internal use. No measures need be taken for protecting the privacy or confidential information of registrants in the .mtn TLD because no information of a private nature will be collected during the registration process.

MTN (Dubai) Limited will not distribute or transfer control or use of any registrations in the TLD to any third party that is not an affiliate. Use of .mtn domain name registrations will be reserved for the exclusive use of MTN (Dubai) Limited and its affiliates. Accordingly, MTN (Dubai) Limited considers that no measures need be taken toward protecting the privacy or confidential information of users of domain name registrations in the .mtn TLD.


The outreach and communication activities for the .mtn TLD will be conducted in two different formats and include above the line (public) and below the line (closed and directed) marketing initiatives.

Above the line communications will focus on directed communications to internal departments, members and affiliates of the MTN brand, for the purpose of communicating the new TLD and the opportunities this presents. It is envisaged that this will be carried out and implemented by initiatives such as internal communiqués, email communications from the marketing department and public speaking opportunities at company-sanctioned events and gatherings.

Below the line communications will focus on launching the .mtn TLD to targeted audiences and prospective MTN brand customers. This will be executed via an initial awareness campaign designed to notify and educate target audiences and members on the introduction of .mtn and its benefits. The campaign will be executed via advertising and public relations activity in line with existing marketing activities already conducted by the MTN brand. Additionally, domain names within the .mtn TLD will be introduced as the primary domain names for high-profile campaigns within pre-selected market and geographic segments. This will drive end user utilisation and begin the process of behavioural change within the target audience. This is in line with the mission⁄purpose of the TLD to promote and enhance the overall MTN brand.
gTLDFull Legal NameE-mail suffixDetail
.dayCharleston Road Registry
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 offer a new Internet environment that allows users to create and organize events that have or will occur on a particular day. The proposed gTLD will provide a single domain name hierarchy for Internet users globally to promote celebrations, such as a,, or

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, .day, will provide new web spaces dedicated to planning and organizing events or promoting traditions related to a particular day. As an alternative to existing second-level domains, Charleston Road Registry anticipates that the .day gTLD will increase competition among registrars by increasing consumer choice and creating new opportunities for registrar pricing differentiation. Charleston Road Registry also anticipates the .day gTLD will grow the volume of online events and will encourage the public to provide more content related to special celebrations. Charleston Road Registry further anticipates the .day gTLD may contribute to an increase in online advertising given the specific nature of the domain. Entities will compete to advertise their goods and services that are specific to a particular .day second-level domain.

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 .day gTLD will provide a new mechanism whereby businesses and individuals can differentiate their content by signifying that their information is in relation to a special day. 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 .day 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, .day, 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 .day gTLD. In addition, .day will cater to a global registrant user base and allow innovation in planning, promoting, and organizing events or traditions online. This will encourage second-level domain registrants to provide new features and service innovation, such as birthday reminders, e-cards or event mass emails, 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 .day 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 .day 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, .day.

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:⁄⁄⁄policies⁄privacy⁄. 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.