Effective as of: August 26, 2016
HOW DYN COLLECTS INFORMATION AND THE TYPES OF INFORMATION COLLECTED
Any time you use Dyn’s Sites or Services, information is generated. Some of this information is considered “Personal Information,” meaning information that either directly identifies you individually (like your name, address, email, or billing information) or could reasonably be used to identify you in combination with other data. Other information is considered “Anonymous Information,” meaning information that does not directly identify, and cannot reasonably be linked with other data to identify you individually.
Dyn collects information from you in the following ways:
A. YOU GIVE IT TO US
When you visit or use our Sites or use our Services, you may provide us with information. For example, when downloading a Dyn whitepaper or setting up a new DynID account, we will prompt you to provide us with your name, physical address, email address and phone number.
B. WE RECEIVE IT FROM THIRD PARTIES
Dyn engages with third party vendors to try to determine new customers who might be interested in Dyn’s services. In such instances third parties may give Dyn your name and contact information.
C. WE AUTOMATICALLY COLLECT IT FROM YOU
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 COOKIES AND SIMILAR TECHNOLOGY
“Cookies” are small files that are placed on an individual’s computer when you interact with the Sites or Services. Cookies are often used to enable you to more easily communicate and interact with the Sites and Services. “Web beacons” (also known as “single-pixel” or “clear” GIFs) include electronic images embedded in the Site or in communications sent through the Services which are invisible to users. Web beacons collect information, such as identifiers, time and date of access, and descriptions of the pages or communications in which the web beacons are embedded.
- Saving user preferences;
- Customizing content of the Site for individual users;
- Ensuring that users are not repeatedly sent the same banner ads;
- Recording session information;
- Fraud prevention;
- Saving certain information about users of the Sites and others who visit the Sites;
- Keeping track of whether you’ve had a chance to open an email or view an advertisement; and
- Otherwise facilitating and enhancing interaction with the Sites.
HOW DYN USES AND SHARES INFORMATION
Dyn uses your information for a variety of purposes related to provisioning, maintaining and improving the Sites and Services, as well as for developing new services. For example, Dyn uses your information to administer your account, provide technical support and to communicate with you about your account. Dyn also uses your information to send you new and exciting information about Dyn.
Other than as described above, Dyn does not use your Personal Information, nor does it share your personal information with companies, organizations or individuals outside of Dyn, unless one of the following circumstances apply:
- Dyn has your express consent;
- It is for Dyn’s internal use, research and product development;
- It is for domain registration in accordance with the RAA and ICANN policies. (Please see Domain Registration section below for more information regarding our treatment of Personal Information in connection with our domain name registration services.)
- It is for external processing by our affiliates or other trusted third parties we use to support our business based on our instructions or other appropriate confidentiality and security measures (for example, companies that help Dyn improve its web site’s usability or understand customer interests); or
- It is to detect, prevent or otherwise address fraud, security or other legal related issues.
Note that Dyn may share Anonymous Information with third parties. Dyn may also share Personal 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;
- 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 Personal 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 Personal 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, the Services may depend upon the use of your Personal 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.
UNSUBSCRIBING FROM COMMUNICATIONS. If you no longer wish to receive Newsletters, Support Related Emails or other promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter, by going to https://account.dyn.com/profile/mailinglist.html or emailing email@example.com. In order to ensure the integrity, security and operation of our systems and networks, we do not allow you to unsubscribe from Service Notices.
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).
In order to provide domain registration services, Dyn is required to be an ICANN accredited registrar. As an ICANN accredited registrar, Dyn is required to share, process and maintain Personal Information of customers of its domain registration services in accordance with the ICANN Registrar Accreditation Agreement (as amended from time to time) (“RAA”) and policies related to the domain name registration services provided by Dyn. By using Dyn’s domain name registration services, you agree that Dyn may use, share, transfer, process and retain any Personal Information provided to Dyn in connection with such services in accordance with the version RAA by which Dyn is bound and any applicable ICANN policies. For more information regarding the RAA and ICANN policies, you contact Dyn or visit www.icann.org. Please note that Dyn is currently bound by the terms and conditions of the 2013 RAA.
Dyn has implemented policies that include administrative, technical, and physical safeguards designed to help protect Personal Information against 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.
INFORMATION PROCESSED BY DYN’S CLIENTS
Our clients may provide us with Personal Information belonging to their customers or other third parties in connection with their use of our services. Dyn does not control the content or nature of the information processed by our clients in connection with their use of our services. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate Personal Information processed by one of our clients should direct his/her request to the client (the data controller) directly.
Dyn may make chat rooms, forums, message boards, and/or news groups available to its users. Please note that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information.
Dynamic Network Services, Inc.
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Manchester, NH 03101