What happens if the user does not provide, or revokes consent?

The answer depends on whether the product is asynchronous or synchronous.

For synchronous Products:

If the registrant withholds or revokes consent, any existing services will remain active, and any pending orders will be processed normally. Tucows will simply substitute placeholder data for any consent-based personal data.

For asynchronous products:

If the order is currently pending, failure to provide consent within 10 days or the decision to withhold consent will result in the order being placed on hold in the Tucows system. We are not able to complete orders for asynchronous products without consent from the registrant because placeholders for consent-based data will be rejected at the registry level and true personal data may not be handled in a GDPR-compliant manner.

If an asynchronous service is currently active and the registrant chooses to “withdraw” consent, they will be instructed to work with their service provider to cancel the service. Again, this is because, while Tucows does not require this consent-based data, it is required by the registry or service provider, and that registry or provider has not offered a GDPR-compliant data erasure request process. While ideally, we would replace these consent-based data with placeholder data, we are not permitted to do so by the registry or provider, and so the service would need to be canceled in order for the withdrawal of consent to have any real effect.

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2 Comments

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