Privacy Policy

Effective July 26, 2023

Focus IP, Inc., doing business as Tracer (“Tracer”) provides products and services related to brand protection as well as domain name management and registrar services. As a provider of brand protection services, Tracer detects and removes fraudulent and infringing uses of our customers’ brands. As a domain name registrar, Tracer provides registrar and domain portfolio management services in compliance with the rules and regulations adopted by domain name regulatory authorities.

Tracer values privacy rights. This Privacy Policy has been adopted with a commitment to safeguarding individual privacy rights. As you use our website and services, we want you to understand how we use the personal information we collect and process in connection with our business and services and the ways in which you can protect your privacy. As discussed in this Policy, we collect and process personal information solely for legitimate interests related to our business. Whether you are new to Tracer or already a customer, please take the time to review our practices. If you have any questions, please contact us at

This Privacy Policy only applies to any information collected through the web site or its services platform (collectively, the “Platform”); it does not apply to information collected by Tracer in any other manner. As discussed below, our Platform is not directed to children under the age of 13.

Tracer reserves the right to change this Privacy Policy from time to time. Revisions will be posted on this website and will become effective immediately. Accordingly, you are advised to regularly check this website for updates and revisions. Your continued use of our services and Platform following revisions to this Privacy Policy shall constitute your acceptance of the amended Privacy Policy.

  1. Personal Information We Collect and How We Use That Information


The personal information which Tracer collects about you will depend on the services you access and how you choose to interact with us. Although we do not generally process sensitive personal data (such as social security numbers or credit card information), we do collect and utilize the following personal data in connection with conducting our business:

  • Login Credentials: We collect personal information to facilitate secure access to our Platform by our customers and other users interested in our services.
  • Contact Details: Our customers and interested parties visiting our website provide us with names, emails, telephone numbers, and other personal contact information so that we can provide information about new or existing Tracer services, inform them of upcoming events of interest, or communicate with them about their services to fulfill our contractual obligations.
  • Suspected Infringer Information. We collect names and other personal information such as emails, IP addresses, and domain names from various internet channels to identify and prevent individuals from infringing on or using our customers’ brands for fraudulent or other illegal activity.
  • Customer Billing Information: We collect financial and personal contact information for the purpose of billing our customers.
  • Website User Information: We collect demographics and usage information (length of visit, pages viewed, etc.) about users of our website to better understand which content and tools are most useful to such users and to enhance and improve our services and website content.
  • Computer/Device Information: We collect information such as IP addresses about devices used to access our website.
  • Domain Registration and Administration: We collect names, emails, telephone numbers, and other personal contact information from our domain management customers to facilitate and communicate with them about the registration, renewal, modification, and transfer of their domains.
  • Domain Information/WHOIS Database: Under ICANN and domain registry requirements, we maintain a public WHOIS database with personal and other contact information about the owners of the domains which we manage.
  • Updates of WHOIS Registries: We are also required to provide updates of domain owner information to the third-party registries for the purpose of providing publicly searchable databases of domain ownership. We also search those databases in connection with our brand protection services to identify the owners of domains suspected of being unlawfully used to commit fraud, sell counterfeit goods, or the like in violation of our customers’ brand rights.
  • Employees and Prospective Employees and Contractors: We collect names, emails, telephone numbers and other personal information from our employees, contractors, and candidates for employment for the purpose of employing, contracting with, or evaluating such individuals.

In connection with our brand protection services we collect personally identifiable information about individuals suspected of infringing our customers’ brands to engage in fraud, phishing, the sale of counterfeit goods, or other illegal activities. We collect that information from various public online digital channels such as marketplaces, social media, mobile app stores, and websites. We then use that personal information to take the enforcement actions requested by our customers against the bad actors to stop further fraudulent, infringing, or illegal activities.

When you use our website, you may be asked to provide additional personal information, which we will use to contact you and send information regarding our services. In some cases, if you choose not to provide such additional personal information you may be unable to access all of our website content. We do not collect personally identifiable information to send out marketing materials without your consent. If you should receive any such materials, you can opt-out of receiving future marketing materials by emailing us at the following address:

  1. Domain Name Registration Data Collection and Use


If you ask us to register and manage your domain names, we are required by third party domain registries and the Internet Corporation for Assigned Names and Numbers (“ICANN”) to collect each domain owner’s contact information (“Contact Information”) consisting of the owner’s name, postal address, fax number (where available), e-mail address, and telephone number, along with similar information for the technical, administrative and billing contacts associated with the domain. We are required to publish the domain Contact Information in a publicly available WHOIS registry. 

The Contact Information provided by our domain management customers is also used by us to  register and renew their domain names, administer their accounts (such as notifying the customer about renewals, updates, or other related matters), and provide other related services requested by the customer. Tracer also logs other identifying details necessary for the provision of domain management services and ensure that we act only on a customer’s authorization. These include written communications, confirmations, requests for renewals and modifications, related correspondence, payment source information, log files, billing records, communications information such as source IP address, HTTP headers and any other records concerning domain registration (dates, times, zones and sessions).

When Contact Information is collected by Tracer from our corporate customers, that information typically contains the personal data of the customers’ employees.  Accordingly, our customers contractually represent that, in providing us with the personal data of such individuals,  or an individual in whose name the customer is registering a domain name, the customer has notified each of such individuals of the following: (1) that their personal information will be provided to Tracer and the third party registries, (2) purposes for which their personal data will be used, and (3) how the individuals can access and correct their personal data in the manner described below.

In accordance with the regulatory requirements imposed on Tracer as a domain name registrar, Tracer is required to disclose its domain customers’ Contact Information (which may, as discussed above, include the personal data of individuals) in the following instances: (1) WHOIS data is made available to the public for free query-based access (as discussed above); (2) domain-related data, including communications between Tracer and its customers, is made available to ICANN and the domain name registries pursuant to their rules and regulations; (3) Tracer must escrow domain related data as often as required to reputable third parties appointed by ICANN or domain registries; and (4) third parties are able to access WHOIS data in bulk provided they agree, in pertinent part, not to use such data improperly, such as for the transmission of spam or unsolicited email. If a domain name customer orders additional products and services from Tracer, that order may require the disclosure of personal data to additional third parties. Customers will be notified at the time of the order about the nature and scope of any such disclosure of personal data and the applicable third parties who will be receiving such data.

Tracer also collects and uses publicly available WHOIS domain ownership information maintained by other registrars and third-party registries in connection with our brand protection services in order to identify the domain owners of websites and domains suspected of using our customers’ brands for fraud or other illegal activities, and to take appropriate action against such parties..

  1. Do We Share Access to Personal Information?


Any personal information Tracer gathers is used by Tracer only for the legitimate purposes relating to its brand protection and domain management services which are described in this Policy. We do not sell personal information to third parties. Unless we are legally compelled to do so (including from public authorities such as meeting national security or law enforcement requirements), required to do so under ICANN and registry requirements (as discussed above), or otherwise legally permitted to do so, we don’t share the personal information we collect in connection with our business with any third party.  If Tracer is involved in a merger, acquisition, or asset sale, we will continue to protect any personal information in our possession, including, where appropriate, notifying affected individuals before personal information is transferred to another organization or becomes subject to a different privacy policy.

Any third-party vendor who assists us in providing services to our customers or who assists in other aspects of our business are carefully vetted to ensure that, to the extent that we must provide them with access to certain personal information, those vendors will adequately safeguard such data with at least the same level of safeguards as Tracer has. 

  1. Security Protections


We take all reasonable and necessary precautions to maintain the security of the personal data which we collect. Any financial information which Tracer collects is collected via secure means and used only for billing purposes.  Our website uses state-of-the-art technology to secure all personal information we collect, including our customers’ billing and account information. We limit physical access to our database servers to only those employees with a need for such access, all of whom are subject to appropriate background checks.  In addition, we have installed state-of-the-art cybersecurity measures to guard against unauthorized intrusion into our system. All Tracer employees are bound by written non-disclosure obligations to protect confidential and personal information and any employees who violate those obligations will be subject to disciplinary action, up to and including immediate termination.

Despite all our precautions, data transmissions over the internet can never be guaranteed to be completely secure. As a result, while we do our utmost to protect your information, we cannot ensure or warrant the security of any information you give us. Accordingly, all personal information which you provide to us is done at your own risk. We recommend that you do not divulge your user identification or password to anyone and that you do not provide access to your Tracer account to any third party. Also remember to sign out of your account, close the browser window and delete any cookies once you have completed your work within your Tracer account.

  1. How Long We Keep Personal Data


We retain your personal data only for as long as necessary to provide services and perform our operations. The period for which we retain such data depends on the purposes for which we collected such information and our relationship with you. Our considerations include: whether our duties and responsibilities require that we retain personal information for a certain period, whether your relationship with Tracer has ended, what specific instructions regarding retention you have provided to us, the period needed to fulfill the purposes for which we collected such information, the existence of any legal claims or proceedings relating to the information, and any retention periods required or recommended by law, regulations or industry associations (such as ICANN). We will keep your personal information only for as long as required for the purposes set forth in this Policy, or as required in order to comply with applicable privacy laws or legal requirements to which we are subject.

  1. Use of Cookies


As part of our personalized services, and, like many other sites, Tracer may use cookies to better understand how our website is used so that we can deliver a better experience to you. A cookie is a small amount of data (such as date and time of visits, pages viewed, etc.) that is sent to your browser from a web server and stored on your computer’s hard drive. Any information which Tracer obtains from cookies will be used solely to improve our services. By modifying your browser preferences, you can, however, choose to accept all cookies, to be notified when a cookie is set, or to reject all cookies. Rejecting all cookies may limit your ability to access all areas and functionalities of our website. Your use of our website in the absence of modifying your browser preferences will constitute your consent to our tracking you with cookies.

Tracer makes no representations with respect to the creation of profiles or the use of cookies by external websites which may have links to or from our website or that may read and use information obtained from our website.

  1. Links


For your convenience, we may provide links to certain third-party websites. If you choose to use those links to visit a third party’s web site or use its products or services, please be aware that the third party’s privacy policy and not the Tracer Privacy Policy will govern your activities and the information you have disclosed while interacting with that third party.  Our Privacy Policy will not apply to services or products offered by other companies, including but not limited to products or services that may be displayed to you in any search results, or any other company which may be linked with our website or services. Our Privacy Policy does not cover any information or practices by such other companies regardless of the technologies used to link those to our website or services.

  1. Compromise of Personal Information


In the event any personal information is compromised as a result of a breach of Tracer security, Tracer will promptly notify, by email or as otherwise required by applicable law, those persons whose personal information has been compromised.

  1. Modification and Deletion of Personal Information


Our website gives you the option of modifying your personal account information at any time by clicking on the “My Account” link in your account page. You may also modify your account information at any time by sending an email to Once your website access is cancelled or you are no longer a user of the website, your personal information will be deleted within twelve (12) months, or as earlier required by applicable law.

  1. Children

Tracer does not knowingly collect personal information about children under the age of 13 years. If we learn that we have inadvertently done so, we will take immediate steps to delete that information.

  1. International Users and Transfers of Personal Information


Tracer is based in the United States. Tracer complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF ,and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce.  Tracer and its subsidiaries RegistrarTrust, LLC, RegistrarBrand, LLC, RegistrarGuard, LLC, RegistrarSecure, LLC, and Tracer AI Europe, Unipessoal, Lda all have all certified to the U.S. Department of Commerce that they adhere to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  Tracer has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit and

In compliance with the DPF Principles, Tracer commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding their personal information and/or this Privacy Policy should first contact Tracer’s Data Protection Officer at:

Tracer has committed to refer unresolved DPF-related complaints to PrivacyTrust, an alternative dispute resolution provider located in the United States and within the EU and worldwide. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit PrivacyTrust at: for more information or to file a complaint. The services of PrivacyTrust are provided at no cost to you.

The Federal Trade Commission has jurisdiction over Tracer’s compliance with the DPF Principles. Additionally, an individual has the possibility, under certain conditions, to invoke binding arbitration for complaints regarding DPF Program compliance and for resolution of claimed violations of the DPF Principles not resolved by any of the other DPF mechanisms. Please see the DPF website for additional information:

Moreover, in conjunction with the DPF, Tracer commits to cooperate with the panel established by the EU data protection authorities (“DPAs”) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable, and comply with the advice given by the panel and/or Commissioner, as applicable, with regard to data transferred from the EU and/or Switzerland, as applicable.

With respect to our domain name management and registrar services, the disclosure of personal data to ICANN and domain name registries necessarily involves the transfer of personal data to entities located outside the EU and the EEA in order to perform the services. The technical safety measures and data protection regulations in certain non-EU or non-EEA countries may not equal or comply with the safety measures and data protection regulations within the EU and the EEA. Thus, the security and confidentiality of personal data in such countries cannot be guaranteed as equivalent to data handling protections within the EU or EEA. Accordingly, when passing on personal data for the purposes stated in this Privacy Policy, it might not be possible to ensure our customers an adequate level of data protection within the meaning of Article 49 of the EU General Data Protection Regulation.

By using the Tracer services, you agree to this Privacy Policy and explicitly consent to the transfer of personal data to such non-EU or non-EEA countries with the understanding that the level of data protection in such countries may be insufficient compared to the level mandated by the EU or EEA. If you refuse such data transfer, you must notify us of such refusal in writing, in which event we may not be able to provide you with the services that you ordered.

Notwithstanding the foregoing, please be advised that in the context of an onward transfer of personal information, a DPF organization has responsibility for the processing of any personal information it receives under the DPF and subsequently transfers to a third party acting as an agent on its behalf. Tracer shall remain liable under the DPF if its agent processes such personal information in a manner inconsistent with the DPF unless Tracer proves that it is not responsible for the event giving rise to the damage.


  1. YouTube API Services


If you are using a Tracer service we want you to be aware of the following:

  • Certain Tracer products and services utilize or require the use of the YouTube API Service (terms available at in order to access the information required to provide the applicable Tracer product or service;
  • Such YouTube API Service use is subject to YouTube’s Terms of Service found at ( in order to access the YouTube API Services;
  • The Google Privacy Policy found at also forms a part of the YouTube API Services, along with their Terms of Service and the Tracer Terms of Services found at
  • Tracer, through its services, collects YouTube API data to determine online fraudulent and other infringing uses of the intellectual property and content of Tracer customers.
  • Tracer uses, processes, and shares the YouTube API data information with its customers making data requests through the applicable product or service and the information is processed internally at Tracer in order to present and share the acquired YouTube API data with the Tracer customers, and/or any external authorized representatives of such customers including their attorneys;
  • Tracer’s use of the YouTube API does not permit third parties to serve content to parties who are using the applicable Tracer products or services and no advertisements or third parties materials, other than the YouTube API data, is provided through the YouTube API Services;
  • Tracer stores, accesses or collects information directly from its customers’ browsers, including by placing, accessing or recognizing cookies or similar technology on users’ browsers, for purposes of providing the Tracer products or services to customers, in accordance with the Tracer cookies policy set forth separately herein;
  • Tracer accesses or uses customer API data that a customer expressly authorizes Tracer to access or otherwise use via the Tracer services provided to that customer. In addition to Tracer’s normal procedure for deleting stored data, customers may, at any time, elect to revoke Tracer’s access to their customer data via the Google security settings page found at pursuant to the contact information listed in this Privacy Policy and the Tracer website or by email at: Attn: Judith Archbold, Corporate Counsel at:; and
  • If a Tracer customer has any other questions, concerns, or complaints regarding use of its YouTube API data, customer can contact Tracer with its questions, concerns, or complaints about Tracer’s privacy practices at: Attn: Judith Archbold at:
  1. Google Analytics


Tracer uses Google Analytics, Google Advt or AdRoll to conduct our business by tracking the behaviors of users of our website. These are tools/services used by many companies. You are hereby notified of the following:

  • Tracer collects and processes such user data for the purpose of improving products and services. From time to time, Tracer may wish to contact you, with your prior consent, about our products and services, as well as other content that may be of interest to you;
  • Tracer may also utilize user data for purposes of retargeting services, including AdRoll or Google Ad;
  • Tracer uses cookies to deliver its products and services and for targeting the marketing of its products and services and for online behavioral tracking;
  • Tracer and/or its third-party vendors, including AdRoll, may place cookies on users’ devices to collect data;
  • Tracer may utilize various types of user data to delivering targeted ads;
  • From time to time, Tracer utilizes the services of third parties for the purpose of delivering targeted ads and messaging based on analyzing user activity;
  • Users will be able to opt out of targeted marketing, which is provided pursuant to the user’s prior consent, through Tracer’s Cookies Policy, this Privacy Policy, or the unsubscribe function embedded in any marketing emails sent by Tracer.
  1. California Privacy Laws


Because Tracer is a global organization and we may interact with certain natural persons in the State of California, we operate in compliance with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”).  CCPA defines “personal information” to cover all information which identifies or is associated with an individual consumer or household, but excludes information which is publicly available, deidentified, aggregated or collected from employees or job applicants.  If you are a California resident, we may have collected certain personal information about you from our Internet searches, directly from you, or from third parties for the business purposes described in this Privacy Policy.  We may share your personal information with third party service providers such as cloud storage providers, our affiliates, business partners, other customers (if agreed), and government agencies (if required). We do not sell your personal information as defined under the CCPA.

Verified California residents have the right to request that companies such as Tracer disclose the personal information they have collected and/or delete such information.

Tracer will not discriminate against any person who chooses to make any of the above requests. In order to make a request for disclosure, California residents may contact us at If you require additional assistance, you may contact our Customer Service staff which is available 24/7 by phone at: (855) 693-3839. We will ask you for information to allow us to reasonably verify your identity and will use that information only for that purpose. We cannot respond to your request or provide you with disclosures if we cannot verify your identity and confirm that any personal information we may hold relates to you.  You may make a request up to twice within any 12-month period. We will endeavor to respond within 45 days of receipt of your request.  If we require more time (up to an additional 45 days), we will notify you of our need for additional time.

California Do Not Track Disclosure:

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit At this time, Tracer does not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to our website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, see “Use of Cookies” above.

  1. How To Contact Us


We make every effort to maximize your privacy rights when you use our website, products, and services. You have the right to oppose the collection of your personal data and request the review, deletion, or correction of that data in accordance with applicable rules and regulations. You also have the right to request copies of your personal information in machine-readable format, to request details as to how we use such information, to opt out of marketing communications, to limit the use of your information to specific purposes, and to object to our processing of your personal data. Please contact us for any of these requests at the below business address or email address and we will promptly act on your request. If you have any questions or concerns regarding this Privacy Policy or any other aspect of our website, products, or services, please contact us at:

Focus IP, Inc., doing business as Tracer
508 S. 8th St.
Boise, ID 83702
Attn: Judith Archbold, Data Protection Officer
or email us at: