Effective as of: August 26, 2016
HOW DYN’S INTERNET PERFORMANCE TOOLS COLLECT INFORMATION AND THE TYPES OF INFORMATION COLLECTED
Dyn’s Internet Performance Tools are services and technologies designed to monitor and improve the way you experience the Internet. Any time you use or interact with Dyn’s Internet Performance Tools, information is generated. This information is automatically collected, and contains data about the devices and services you use to access the Internet (for example, your IP address and your Internet Service Provider) as well as your geographic location, information about the properties you visited on the Internet, device configurations, and browser history.
NOTE ON CROSS BORDER TRANSFERS: Dyn has established a global network presence and may process information on our servers in many countries around the world, including the United States. You agree that we may process information on a server located outside the country where you reside.
NOTE ON CHILDREN’S PERSONAL INFORMATION: Dyn does not knowingly collect any personal information (as defined under the Children’s Online Privacy Protection Act) from children under the age of 13. If we learn that we have collected or received personal from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have such information, please contact us at the contact information provided below.
NOTE ON HOW DYN GATHERS INFORMATION THROUGH RUM BEACONS
Dyn’s RUM Beacons are technology that executes a series of small file requests when you connect and interact with the Internet. This technology may be deployed in one of a number of ways. Third parties might deploy the RUM Beacon as a “web beacon” (or “single-pixel” or “clear” GIFs) embedded in their web site which is invisible to users. Dyn may also deploy its RUM Beacons as part of your use of Dyn’s other services, like its Updater Client or web browser extensions.
When you interact with the Internet in connection with one of Dyn’s RUM Beacons, the beacon will cause your web browser to request certain test files from a variety of different sources that house content or information. The RUM Beacon helps gather data on how those test files were obtained, including, for example how quickly they were able to be returned to your browser. This information is then sent to Dyn.
HOW DYN USES AND SHARES INFORMATION COLLECTED THROUGH ITS INTERNET PERFORMANCE TOOLS
Dyn uses your information for a variety of purposes related to provisioning, maintaining and improving Dyn’s services, as well as for researching and developing new services. You hereby authorize Dyn to process the information for these purposes. Note that Dyn may share anonymized information (for example, just the first 3 octets of your IP address and the town/city level of your geolocation) with third parties as part of Dyn’s service offerings. Dyn may also share non-anonymized information with third parties that already have access to the same information in connection with Dyn’s Internet Performance Tools. For example, a third party that has deployed a RUM Beacon on its web site already has your full IP address when you visit that site. For more detailed representative lists of information shared with third parties based on the different Internet Performance Tool, please see below. Lastly, Dyn may also share non-anonymized information with companies, organizations or individuals outside of Dyn if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process or enforceable governmental request, including lawful requests by public authorities to meet national security or law enforcement requirements;
- enforce applicable agreements or adherence to terms and conditions, including investigation of potential violations; and
- protect against harm to the rights, property or safety of Dyn, our users, third parties or the public as required or permitted by law.
Dyn does not sell or license your information to a third party for that third party’s own direct marketing purposes.
YOUR PRIVACY CHOICES
ACCESSING AND CORRECTING YOUR INFORMATION. Should you wish to access, amend, correct, or delete any information about you, please contact firstname.lastname@example.org. Dyn will use commercially reasonable efforts to respond to such requests within thirty days, except where the burden or expense of providing access or requested changes would be disproportionate to the risks to your privacy in the case in question. Please note that your ability to use, and Dyn’s ability to provide, various services may depend upon the use of your information. As such, you agree that Dyn will not be liable for any inability to provide all or a portion of the services that may result from Dyn’s compliance with any request to amend, correct or delete any of your personal information.
EU US PRIVACY SHIELD
Dyn complies with the EU-U.S. Privacy Shield framework and adheres to the Privacy Shield Principles with respect to personal data that is received from the European Union and Switzerland. The Department of Commerce lists the participants in the Privacy Shield at https://www.privacyshield.gov/list.
Dyn is accountable for personal data received under the Privacy Shield and that is subsequently transferred to a third party as described in the Privacy Shield Principles. Dyn remains responsible and liable under the Privacy Shield Principles if Dyn’s third-party agents process the personal data on Dyn’s behalf in a manner inconsistent with the Principles, unless Dyn proves that it is not responsible for the event giving rise to the damage.
We encourage you to contact us should you have Privacy Shield-related (or general privacy-related) questions or complaints. Our contact information is below in the “How to Contact Us” section. For any complaints that cannot be resolved with us directly, Dyn has chosen to use TRUSTe as a free independent recourse mechanism available to investigate individual complaints. You can find more about TRUSTe’s Privacy Shield independent recourse services here: https://www.truste.com/consumer-resources/privacy-shield/. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. Dyn is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Dyn has implemented policies that include administrative, technical, and physical safeguards designed to help protect your information from unauthorized access, use, or disclosure. While Dyn strives to protect your privacy, due to many reasons, including the inherent security flaws in the Internet, Dyn cannot guarantee the security of any information you disclose to us and, as such, you agree that your disclosure of such information is at your own risk.
HOW TO CONTACT US
Dynamic Network Services, Inc.
150 Dow Street
Manchester, NH 03101
INTERNET PERFORMANCE TOOL
REPRESENTATIVE LISTS OF SHARED INFORMATION
Dyn’s RUM Beacon
Dyn may share the following information collected via RUM Beacons with third parties:
- Anonymized IP address
- Non-anonymized IP address and visited URL may be shared with third parties that have deployed a RUM Beacon and accordingly already have this information
- Country, State, and City
- Internet Service Provider
- Test information related to Internet performance between your computer or device and a number of endpoints and service providers, including the time to resolve DNS, start receiving data, and complete the transmission of the test object. This is defined in the W3C Timing API specification as DNS Time, Time to First Byte, Time to Last Byte, and Total Duration.
Dyn’s Internet Guide Recursive Services
Dyn may share the following information collected via Dyn’s Recursive DNS Services with third parties:
- Anonymized IP address and port
- Country, State, and City
- Internet Service Provider
- Time and date of query
- Domain queried
- Query details (e.g., TTL, query type, DNS flags, DNSSEC info)
- Query response