18(b) How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
|gTLD||Full Legal Name||Detail|
|.bbva||BANCO BILBAO VIZCAYA ARGENTARIA, S.A.||View|
18(B)I. WHAT IS THE GOAL OF YOUR PROPOSED gTLD IN TERMS OF AREAS OF SPECIALTY, SERVICE LEVELS OR REPUTATION?
The key goals of the proposed new .bbva gTLD are in line with ICANN’s Affirmation of Commitments: to promote consumer trust, competition and consumer choice. BBVA also seeks to foster its online reputation and provide an authoritative internet space through which BBVA is able to communicate with its customers directly and effectively. The ability to create domain names on demand related to specific marketing, specialty service and product development supports these goals. Strengthened security measures, service levels and more effective functionality will provide a trusted and positive user experience.
18(B)II. WHAT DO YOU ANTICIPATE YOUR PROPOSED gTLD WILL ADD TO THE CURRENT SPACE, IN TERMS OF COMPETITION, DIFFERENTIATION, OR INNOVATION?
It is anticipated that the proposed .bbva gTLD will make positive contributions to the wider internet community by providing:
DIFFERENTIATION (INCREASED TRUST):
The .bbva gTLD will simplify how internet users interact with BBVA by providing a distinctive domain space. Internet users will be able to directly navigate to the .bbva gTLD site, saving time and resources searching for an official site. The current domain name system has shown that it is vulnerable to malicious abuses due to registration of domain names which seek to exploit consumer confusion. BBVA can address some of these vulnerabilities by maintaining complete control over the domain names registered under the .bbva domain space. Together with consumer trust, internet users will be able to rely on the authoritativeness of the domain names under .bbva domain space, which will differentiate interaction between internet users and BBVA.
The differentiation of .bbva gTLD as a trusted site for BBVA will drive existing and new TLD registry operators to make improvements in mechanisms to improve consumer trust of their TLDs. Internet users will be encouraged to interact with domain names under .bbva domain space. As a result, .bbva will have a flow on effect to enable increased competition. Therefore, the benefits of the proposed .bbva will be distributed not only to its direct customers, but to the internet community at large with improved services and competitive pricing in the market place.
With the expansion of the internet community to all corners of the world, the existing TLD structure presents limitations, not only in the availability of domain names for registrants, but also to businesses and organisations establishing a coherent global online brand presence to meet their evolving business needs. It is often difficult to register a domain name in existing domain space due to unavailability of the desired name. This problem is amplified for organisations such as BBVA who work across many different jurisdictions and geographical markets. Even when the desired domain name is available, it may come with a high price tag associated with a purchase of such desired name from a third party. BBVA has the ability to create second or third level domain names including the use of geographic names and IDNs on demand which are relevant to its customer base, services and products. BBVA will be able to combine its use of the domain space with innovative user focused marketing and services to address the currently unmet needs in the existing domain name system providing greater consumer choice.
The proposed .bbva will provide a positive user experience, which meets the changing and growing needs of the global internet community. BBVA will maintain control in the registration and use of domain names and will ensure that the new gTLD will only be used for purposes authorised by BBVA. Therefore, .bbva gTLD will:
- provide an easy and intuitive reference and access point for internet users;
- represent authenticity thus promoting user confidence;
- direct internet users to relevant information in a timely manner by creating domain names on demand;
- use IDNs to enable customer to interact directly in their native language;
- use geographic names to localise its websites to connect with internet users in the relevant regions and to comply with local laws;
- enhance security and minimise security risks by implementing necessary technical and policy measures;
- strengthen brand reputation and user confidence by eliminating user confusion;
- prevent potential abuses in the registration process reducing overall costs to businesses and users; and
- Increase e-commerce impulse: As consumer trust improves, the number of electronic transactions will increase which will have positive effect on the business dynamism worldwide.
.bbva should address the concerns that the current domain name system is open to potential malicious abuse and user confusion in the registration processes. Although the current system allows an eligible party to lodge a claim through existing Uniform Domain Name Dispute Resolution Policy (UDRP) or other dispute resolution processes, the .bbva gTLD will reduce potential abuses in the registration processes and overall costs arising from potential frauds to internet users. User confidence in the domain name system will be strengthened, which will ultimately contribute towards promoting ICANN’s core values in benefiting the public interest.
18(B)IV. PROVIDE A COMPLETE DESCRIPTION OF THE APPLICANTʹS INTENDED REGISTRATION POLICIES IN SUPPORT OF THE GOALS LISTED ABOVE.
The proposed registration policy is attached in response to Question 28.
BBVA’s proposed use for .bbva should, by its very nature, preclude abusive registrations from occurring,as only BBVA and its affiliates will be eligible to register domain names in .bbva at this stage. BBVA is intending to operate .bbva for the benefit of Internet users that would like to interact with BBVA. There is no incentive for BBVA to confuse Internet users, nor otherwise use domain names in bad faith, since BBVA’s branded keyword gTLD is inherently intertwined with all uses of .bbva domain names.
Notwithstanding the above, BBVA understands and agrees that it must comply with the different rights protection mechanisms such as the Uniform Domain Name Dispute Resolution Policy (UDRP) and the Uniform Rapid Suspension System (URS) as described in the gTLD Applicant Guidebook (as may be later amended via Consensus Policy) and the Registry Agreement. The aforementioned policies provide a strong incentive to ensure that relevant and effective checks are in place to ensure that all .bbva domain names are only registered and used in an appropriate manner so as to benefit Internet users who would like to interact with BBVA, rather than in any manner that may be deemed inappropriate or in bad faith.
BBVA will implement a clear written policy which requires the relevant corporate authorizations and approvals to be procured and evidenced in order for any .bbva domain name to be registered for BBVA’s use. In addition to these safeguards, all registered domain names in the TLD will be regularly monitored for abusive use.
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.
BBVA is committed to protection of privacy and confidential information in accordance with its objective of increasing consumer trust and providing a safe and legitimate internet space for internet users. Privacy and confidential information will be protected in accordance with all applicable laws and regulations relating to internet security, privacy and user’s confidential information (in particular, with Spanish Organic Law 15⁄1999 of 13 December, on the Protection of Personal Data). BBVA also complies with all relevant requirements and standards for the banking industry including a strong policy on protection of personal data adequate and sufficient in order to comply at any time with all obligations required by national and international laws, to guarantee the privacy, the confidentiality and the security of the personal data. BBVA also obtained the seal of the Spanish Association of Electronic Commerce (AECE) which endorses BBVA as the first financial institution to apply its Ethical Code for the Protection of Data on the Internet.
In this sense, Royal Decree 1720⁄2007, of 21 December (“Royal Decree 1720⁄2007”), which approves the regulation implementing Spanish Organic Law 15⁄1999 of 13 December, on the Protection of Personal Data, regulates a set of measures aimed at structured, automated and non-automated files and processing, providing with a clear framework in which to act. The referred Royal Decree establishes three different levels of security, basic, medium and high, which BBVA will apply in each case according to the nature of personal data processed.
BBVA has drawn up a Security Document which includes the technical and organizational measures and the obligations according to Royal Decree 1720⁄2007. This Document is kept up-to-date at all times and is reviewed whenever any material changes are made to the information system. Royal Decree 1720⁄2007 rules, inter alia, the implementation of proceedings applicable to: (i) record of incidents, (ii) access control, (iii) management of supports, documents and media, (iv) identification and authentication, (v) backup copies and recovery, etc. The functions and obligations of each user with access to personal data are clearly defined in the Security Document. Further, as regards medium safety level, amongst others, the appointment of one or several Security Officers commissioned in coordinating the data protection measures, and also the obligation for BBVA to be subject, at least every two years, to an external or internal audit to verify the compliance of the systems with specific data protection regulations, is required. Finally in the event of high level security measures, it is significant the obligation of encoding data when the transfer of data is made through public or wireless electronic communications
BBVA will deploy Domain Name System Security Extensions (DNSSEC) which is intended to benefit both BBVA and its users interacting with BBVA online. DNSSEC provides additional security by validating information in the transmission, therefore it is intended to benefit those who publish information in the domain name system (DNS) and the users who retrieve information from the new .bbva gTLD. BBVA already implements measures to protect privacy or confidential information of its users against misuse, loss, alteration and unauthorised access. Such measures include the use of a secure server using Secure Sockets Layer (SSL), encoded transmission of data by means of 128-bit algorithms via the secure server, a corporate security policy, network and system segregation, segregation of duties, least privilege user permissions, network and system monitoring.
BBVA will continue to apply all security measures currently implemented and will comply with all other policies and practices required by ICANN in the Registry Agreement and any relevant Consensus Policy for protecting the privacy and confidential information of registrants and users in the new .bbva domain space.
18(B)VI. DESCRIBE WHETHER AND IN WHAT WAYS OUTREACH AND COMMUNICATIONS WILL HELP TO ACHIEVE YOUR PROJECTED BENEFITS.
As the initial use of the .bbva gTLD will be restricted to internal business use, and only BBVA and its affiliates will be able to register domain names under .bbva domain space, the .bbva gTLD will be publicised by an internal media plan to promote recognition of the .bbva domain space. It will involve various internal communication strategies that will include actions such as news and informative videos on the intranet, banners on internal web sites and on online tools, information on the domain names application online form, information or online postcards sent by e-mail. The internal information aims to inform employees of BBVA on:
- why BBVA is investing in .bbva gTLD;
- the advantages of the proposed new gTLD; and
- what will be BBVA’s future domain names strategy.
BBVA will also inform its customers and the internet community about the .bbva gTLD that promotes the identity, and authenticity of its brand and a secure internet space. This information will be spread through the usual channels of information such as in branches, corporate web sites, advertising, direct marketing actions and customer support services.
During the initial stage of the operation of the proposed .bbva, it is anticipated that internet users will be re-directed to current websites. However, over time, it is foreseen that communication to the internet community of the existence of the proposed new gTLD and encouragement to utilise the trusted site will contribute towards minimising malicious abuses and protecting internet users.
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