document: title: privacy policy
text: Last updated: July 2, 2012

## Our Approach to Privacy in Plain English

Before we let our lawyer get into the weeds on how we keep your information private, let’s get something straight. We believe in the golden rule when it comes to privacy – we wouldn’t do anything to you that we would get annoyed about if it were done to any of us (and some of us are pretty paranoid). If you have a question about what personal information we collect or how we protect it, read on or feel free to shoot us an email at privacy@dyn.com. We respect your privacy and want to answer any questions you have.

This Privacy Policy covers our collection, use and disclosure of information we collect through dyn.com, all other web sites to which this policy is linked, and our DynECT services . The use of information collected through our services shall be limited to the purpose of providing the services for which the Client has engaged Dynamic Network Services, Inc. (“Dyn”).

Our Approach to Privacy in (What Our Lawyer Calls) Plain English

I. Introduction

Dyn has been awarded TRUSTe’s Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe’s Program Requirements and the TRUSTed Cloud Program Requirements including transparency, accountability and choice regarding the collection and use of your personal information. TRUSTe’s mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions.

II. Contact Information

If you have questions or concerns regarding this statement, you should first contact our legal department at privacy@dyn.com. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php TRUSTe will then serve as a liaison with us to resolve your concerns.

III. EU Safe Harbor Framework

Dyn complies with the U.S. – E.U. Safe Harbor Framework and the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union and Switzerland respectively. Information regarding the both the E.U. and Swiss Safe Harbor Frameworks can be found at:  http://export.gov/safeharbor.

IV. Information Related to Data Collected Through our Service

A. Service Provider Collection and Use

Our Clients provide us with the following kinds of personal information:

  * Name(s)
  * Email Address(es)
  * Mailing Address(es)
  * Phone Number(s)
  * Billing Information (e.g., credit card information, billing address, etc.)



We use this information:

  * in connection with the provision of our services, and
  * to administer Client accounts, billing and reconciling Client accounts, operational maintenance and support activities.



Dyn collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes.

B. Choice

Our Clients provide us with the aforementioned information in connection with their use of our services. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the client that you interact with directly.

C. Access to Data Controlled by our Clients

Dyn has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Dyn’s Client (the data controller). If the Client requests Dyn to remove the data, we will respond to their request within 30 business days.

V. Types of Personally Identifiable Information That We Collect on our Web Site

A. Dyn.com Account Creation

When you create an account on Dyn.com, we will ask you to create a user name and password and to provide us with your email address. In addition, while it is not required, you may provide us with further information, such as your name and address, to complete your profile on Dyn.com.

B. Dyn.com Service Purchases

When you purchase services on Dyn.com, we will ask you to provide personally identifiable information (“PII”), including your name, address, phone number and financial information (e.g. your credit card number and expiration date).

C. Third party information.

Dyn customers who sign up for certain services must supply contact information. You can enter third party information such as name, email address and company in the “Create a Contact” section of your account on the site. These records are used as official contacts for services such as registering a domain name.

VI. Protecting Your Privacy

It is the policy of Dyn to protect and respect your privacy and PII. Therefore, Dyn will not monitor, edit, or disclose the contents of your private communications to third parties for promotional or marketing purposes unless required to do so by law, judicial proceeding, court order, subpoena or legal process or in the good faith belief that such action is necessary to: (i) conform to the edicts of the law or comply with legal processes served on Dyn; (ii) identify, contact or bring legal action to defend and protect the rights or property of Dyn, its customer or end users, or anyone else; (iii) act under exigent circumstances to protect the personal safety of its end users, customers, or the public; (iv) administer its networks or systems to maintain performance for its end users or customers; or (v) provide authenticated domain owners (registrant, administrative, or technical contacts) with contact information for the account which controls DNS for their domain. Additionally, Dyn will not to apply this policy in any manner that is contrary to applicable law or governmental regulation.

VII. Newsletter, Technical Notices and Other Communication

A. You may receive the following types of communications from Dyn

1\. Newsletters. Dyn allows you to opt-in to receive Newsletters, sent periodically, which provide information on updates existing services, new services, and what is going on in at Dyn and with Dyn.com. If you wish to subscribe to our newsletter, we will use the email address you have on file with Dyn to send the newsletter to you. If you do not get the Newsletter, you may opt-in by selecting the appropriate setting on your account settings page at Dyn.com.

2\. Support Related Emails. Dyn allows you opt-out of receiving, on an as-needed basis, emails regarding the provisioning, trouble shooting and enhancement of services that you purchase on Dyn.com.

3\. Service Notices. Dyn requires that you allow it to use the email address you have on file with Dyn to receive, on an as-needed basis, technical and service notices on topics such as changes to service specifications and account and/or service expiration information.

B. How to Unsubscribe

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 privacy@dyn.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.

VIII. Third Parties

A. Service Providers

1\. Domain Names. When you purchase a domain registration service, Dyn will, as such required by ICANN policy and/or Dyn contractual obligation, share with the applicable third party vendor, either a registry or a registrar, the name, address and phone number for every contact that you provide for the domain name at issue so that it may be included in the WHOIS database for the registry at issue. You may avoid the sharing and publishing of this information by purchasing the Secret Registration service.

2\. Secure Socket Layer (“SSL”) Certificates. When you purchase a SSL certificate, Dyn will share with the applicable Certificate Authority, the organization name and location, as submitted to Dyn in the SSL certificate signing request.

3\. Credit Card Processing. We use a third party credit card processor to handle financial transactions on the Site.

B. Business Partners

Dyn transmits some non-personally identifiable information to its business partners for the purpose of improving its website (e.g, web analytics), its network and the Internet. However, Dyn will not give out personal identifiable information to advertisers, business partners, sponsors, or other third parties for promotional use.

IX. Financial Data

Any financial data collected from you shall be stored in encrypted form, and will be made available for future transactions immediately upon request, and stored only for as long as required by applicable financial regulations.

X. Correcting, Updating and Removing Information

You may contact Dyn at privacy@dyn.com to correct, update, delete or remove personal information that you have given us. We will respond to your request to access within 30 days.

XI. Cyber and Physical Security Measures

Dyn encrypts financial information, as well as other sensitive information, sent to it using SSL technology. To protect information once it is in Dyn’s possession, the company takes industry standard security measures. Active systems that are network accessible are protected by firewalls. Backup systems that are not network accessible are protected by physical security measures and are stored in encrypted form. The company’s headquarters and data center facilities are all protected by industry standard (or better) physical security measures.

XII. Cookies

A. Definition and use on Dyn.com

A cookie is a small text file that is stored on your computer for record-keeping purposes. Dyn uses two types of cookies on Dyn.com.

B. Session Cookies

Dyn uses Session Cookies, which do not contain PII, to enable you to use Dyn.com without entering login credentials on each page.

C. Persistent Cookies

Dyn uses Persistent Cookies, which are connected to your Dyn.com account, which may contain PII, for the purpose of web analytics.

XIII. Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at privacy@dyndns.com.  We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

XIV. No Guarantee of Privacy

While Dyn strives to protect your PII and privacy, due to many reasons, including the inherent security flaws in the Internet, Dyn cannot guarantee the security of any information you disclose online and, as such, your disclosure of such information at your own risk. Additionally, Dyn’s policies do not extend to anything that is inherent in the operation of the Internet, and therefore beyond Dyn’s control.

XV. Changes to this Privacy Policy

Dyn reserves the right to modify this policy at any time, so please review it frequently. If we determine that a material change to this policy is necessary, we will notify you of the change by email or by means of a notice on our home page. Additionally, if changes are made, Dyn will post them to on this web page and to other places we deem appropriate.

XVI. Dyn Physical Address

If you want to send Dyn anything by postal mail, including fan letters, please reach us at:

Dynamic Network Services, Inc.  
150 Dow Street, Tower Two  
Manchester, NH 03104 USA  
privacy@dyn.com

XVII. Effective Date

THE EFFECTIVE DATE OF THIS PRIVACY POLICY IS THE DATE FIRST SET FORTH ABOVE.