Effective 7/28/2020

About this Policy

Dynamic Signal, Inc. (“DySi”, “us”, “our”, or “we”) is a technology company and provides cloud-based services (which include a website, mobile apps, and other technology and services) dedicated to employee communications and engagement.

This Privacy Policy is designed to assist you in understanding how we collect, use, and process personal data that we collect through our DySi Open app and website.

This Privacy Policy does not cover policies related to the use of our Employee Communication and Engagement platform (“Customer Platform”).  For information about our Customer Platform Privacy Policy, please refer to the separate Privacy Policy here.

For additional information regarding how we collect and process personal data through our general website (dynamicsignal.com) and other sales and marketing activities, please see our Website & Marketing Privacy Policy.

Overview of the Platform
Information Collected
Use of Information
Information We Share
Third Party Websites
Our Security
Information about International Transfers
Your Choices
Dispute Resolution Procedure
Data Retention
Updates to this Policy
How to Contact Us

Overview of DySi Open

DySi Open is an online service that includes a web site, mobile apps, and other technology and components (collectively “DySi Open” or the “Platform”), owned and operated by DySi. DySi Open is an interactive community (the “Community”) for communicators, marketers and human resource professionals to access and share relevant thought leadership content. Use of DySi Open is subject to the DySi Open Terms of Use found here .

When you register and join DySi Open, you become a “User”. If you have chosen not to register, you may access certain DySi Open features as a “Visitor.”  DySi Open is based upon the same technology as our Customer Platform, and provides prospective customers of our Customer Platform to evaluate or demo our Customer Platform technology.

DySi Open is an interactive community that is accessible through a website and a mobile app where Users may view and comment on content such as information about products, services, events and other content chosen and posted onto the Platform, and where Users may view such content and potentially share it with other Users or outside DySi Open.  Visitors will only have access to view a limited amount of content and will not be able to comment or share any content.

DySi Open can connect your social media sites with your account, but only based on your explicit consent, which you may withdraw at any time. However, even if consent is withdrawn, historical activity may continue to be shown.  A request of erasure may anonymize your user name but may not delete the substance of any comments or posts that were made.

Information Collected

We collect different types of personal data through DySi Open. Users may provide personal data to us through the service in a number of different ways, from registration to communications, or when uploading content within and outside DySi Open.

Account registration: Basic account information that you provide to us when setting up a user account, consist of your name and email address, or mobile phone number. Other optional information that you may voluntarily provide include your language, notification preferences, privileges assigned in DySi Open, and your role or job title within your organization.

Other optional information: You may, optionally, choose to provide your mobile phone number (if you desire to enable SMS notifications) and add other information about yourself, such as a photo, to your profile.

Platform content: You can post, upload and share content through DySi Open, comment on others’ posts, and provide other information such as when you fill out a form, respond to a survey, or use the Platform to send emails or other communications.

Metrics, maintenance and analytics: When you access or use DySi Open, we may collect certain information automatically about your device and your use of DySi Open.  This will include IP addresses, browser types, log files, and other information regarding your system and connection. We collect information about how you access and use DySi Open, such as what pages are viewed, when the profile was registered and what portions of DySi Open are used. We also collect metrics related to comments, total posts that you viewed, shared and submitted, and other activities you conduct through DySi Open. This information is collected automatically through the use of various commonly used information-gathering technologies, including cookies and web beacons.  Some of these cookies and web beacons can be turned off through your website browser; however, on a mobile device, including DySi Open app, you may not be able to turn them off.  For additional information please see the Cookie section of our Platform Privacy Policy.

Information collected from Social Networking Sites (“SNS”): We provide Users with the option to link some of their SNS (e.g. Facebook, YouTube, Twitter, LinkedIn, etc.)  to DySi Open. As a User, you will then have the option to link your SNS to DySi Open.  Once connected, the SNS will send us your user profile (including profile photo, handle name) and analytics information about the posts you share on their platform, such as how many people potentially see a post, the number of responses generated by your content, and information about the activity related to your post (such as the number of likes and shares, but we will not have access to the actual responses and identity of individuals who interact with such content). Your SNS profile photo and handle name may also be viewable by other Users in the Community.  We do not collect passwords to your SNS, as that information is confirmed by the SNS separate from our Platform.  Certain SNS permit sharing without linking to our platform.  In these cases, the information collected may be a subset of the above.

Our Platform does not process sensitive data. DySi does not allow and does not knowingly solicit or collect, and you should not provide, any information regarding an individual’s financial, medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs or other sensitive or special categories of data.

Use of Information

We may use the information we collect through the Service for a range of reasons, including:

• • For marketing communications:  DySi Open is based upon the same technology as our Customer Platform, and provides prospective customers of our Customer Platform to evaluate our Customer Platform technology. As such, we send you information about our Customer Platform or other products and offerings if you have opted-in to receiving such communications; however you can opt-out to receive these communications at any time.
  • To manage DySi Open, system administration, and account management.  The Platform’s administrative tools allow DySi’s relevant employees to view content in a network in order to troubleshoot specific issues, maintain and improve DySi Open or perform other platform-related functions, or as may be required by law.  We also use third party analytics services for our web and mobile applications.  We use these services for quality assurance, product interaction analysis, product improvement, and trouble-shooting.
  • To handle Users’ inquiries and support requests, and to provide information and access to resources or services that they have requested from us;
  • To compile aggregated data about the operation and use of the Platform and to better understand the preferences of Organizations and Users;
  • For quality-assurance, and to carry out research and development to improve our products and services;
  • To investigate and prevent fraud, unauthorized access or use of the Platform, breaches of terms and policies, and other wrongful behavior;
  • To enforce our agreements, and as required by applicable law.

When you download and use our mobile app to access the Platform or DySi Open, we and our service providers may track and collect app usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app based on your device number.

Information We Share

At times, we engage third party contractors, service providers, and other vendors to help use accomplish our business objectives. There are other circumstances where we are required by law to disclose personal data to third parties such as public bodies or judicial authorities.

Examples of some of these circumstances include:

• • With other Users within and outside the Platform: if you choose to submit comments, post or upload content, you will share this content with others within DySi Open Community. You can also decide to share this information outside DySi Open with a wider audience, for instance when you share this information through your Social Networking Site (SNS) – e.g. Facebook, YouTube, Linkedin, Twitter, etc. When you choose to link your SNS to DySi Open some information from your SNS (e.g. profile photo and handle name) will also be viewable by other Users within the Community.
  • Within the DySi group of companies, for the purposes outlined in this Policy.  For clarity, DySi is based in California, USA and has one wholly-owned subsidiary in the U.K, but may include other offices that may be established in the future.
  • To vendors and other third-party service providers who may have access to your personal data to assist in the provision of the Platform service and other business-related functions such as cloud storage, mobile phone push data, and usage analytics.
  • To law enforcement authorities, government agencies, or judicial courts. We may be required to disclose personal data that we handle in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, in connection with the sale, transfer, merger, bankruptcy, restructuring or other reorganization of our business; to protect or defend our rights, interests or property, or that of third parties; to investigate any wrongdoing in connection with the Website, our Platform or our services; or in connection with a subpoena, warrant, discovery or other legal order.
  • With your consent. We may share other information with third parties when we have your consent to do so.

Third Party Websites

DySi Open may contain links to other websites and services that are outside our control and are not covered by this Policy.

There may be postings of articles and other information on DySi Open. We are not responsible for the content, security or privacy practices employed by other websites. If you access other websites or services using the links provided, or interact with your SNS the operators of these websites and services may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours. If you do not wish these third parties to process your personal data, please do not click on these links.  We are not responsible for the content, security or privacy practices employed by other websites.

Our Security

We are committed to process your data in a secure manner, by putting in place specific technical and organizational measures to prevent the personal data we hold being accidentally or deliberately compromised. 

We conduct information risk assessments and we ensure that our staff understands the importance of protecting personal data. We include both physical security and IT security in our overall data security approach. We are diligent in selecting vendors that process personal data on our behalf so that they also ensure appropriate technical and organizational measures to protect the data. We also integrate privacy in the design of our projects that involve the use of personal data in order to secure the information and implement the aforementioned principles.

We will provide support to organizations in their duty to notify individuals and regulatory authorities, as required by law, when personal data has been stolen, disclosed, altered or infringed by an unauthorized person. If you have questions or concerns regarding this policy or if you are aware of a potential breach, please contact us.

Information about International Transfers

When using the platform your personal data may be stored and processed by us in the United States. To provide appropriate safeguards for personal data we receive from the European Economic Area (EEA), United Kingdom (UK), and Switzerland, we are certified under the Privacy Shield framework.

For personal data we receive from the EEA, UK, and/or Switzerland, DySi has self-certified with the U.S. Department of Commerce under the U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.

DySi acknowledges its commitment to comply with the EU – U.S. and Swiss – U.S. Privacy Shield Principles (“Principles”) for all Personal Data received from the EU, UK, or Switzerland in reliance on the Privacy Shield. DySi will collect, use, and disclose Personal Data received from the EU, UK, or Switzerland only in accordance with this Privacy Policy and the Principles, or as required by law. For Purposes of Privacy Shield compliance enforcement, DySi acknowledges that it is subject to the investigatory and enforcement powers of the United States Federal Trade Commission (FTC). DySi also complies with the Privacy Shield Principle regarding liability for onward transfers. To learn more about the Privacy Shield program, and to view DySi’s certification, please visit https://www.privacyshield.gov.

If you are one of our customers and the use of DySi Open requires DySi to process personal data falling within the scope of the EU General Data Protection Regulation (GDPR), DySi’s Data Processing Addendum is available for review here.

Your Choices

You have the right to opt-out of receiving marketing materials from us. In addition, if you are in the EEA, UK, and Switzerland you have certain privacy rights recognized under the General Data Protection Regulation (GDPR), for instance the right to request access to information, rectification, or erasure.

Right to access, and correct your personal data: You may access, or correct, information you have uploaded to DySi Open by using the tools within the Platform. If you do not see the tools within the Platform, please contact us at privacy@dynamicsignal.com. Changes on DySi Open take immediate effect on your specific network, but data will be retained by us in our backup systems for a commercially reasonable amount of time, typically 90 days.

Account closure and right of erasure: If you would like to stop using DySi Open, please contact us at privacy@dynamicsignal.com. In addition, you can also request:

• Account closure and delete identifiable information: In general, account closure means that your name and other identifiable information (including your photo, if provided) will be deleted and not available to us or other Users of DySi Open– your name will be changed to an “anonymous user”. Your comments and posts will not be deleted, but those will no longer be linked to you.
• Deletion of content: Please note that content you create and share may remain on DySi Open and be accessible even if we deactivate or terminate your account.  In this way, content you provide on the service is similar to other types of content (such as presentations or memos) that you may generate in the course of your work.  Note that we cannot manage or delete posts or comments that you or other Users shared or published outside DySi Open, using Social Network Sites.

Information viewable within DySi Open will be deleted within 30 days upon receiving your request, in any case complete removal of data stored on our backup systems, will happen in a commercially reasonable period of time, typically 90 days.

Right of objection and restriction: You have the opportunity to elect whether you would like to receive certain correspondences from us or opt out of DySi’s promotional emails. Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with support, updates, and other relevant communications related to DySi Open, until your account is deleted.

Dispute resolution procedure

Data Retention

We will retain your personal data for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other lawful purposes.

In general, closure or deletion of your User account will not result in the deletion of your personal data.  If you would like to erase your personal data in addition to deleting your account, please contact us at privacy@dynamicsignal.com with this specific request. See Account closure and right of erasure for more information.

California Privacy Rights

The California Consumer Privacy Act, (Cal. Civ. Code § 1789.100 et seq., “CCPA”) gives California residents certain data rights, with regard to how their personal information is collected and used. Dynamic Signal upholds the requirements of the CCPA for California residents including (and in addition to the descriptions of how we handle your data described elsewhere in this Policy) the following:

• We do not sell personal data to third parties as contemplated by the CCPA. As such, we do not provide an opt-out mechanism.
• We do not distinguish different levels of service or cost based on an individual’s exercise of their right to opt-out or delete data.
• We generally collect, use, and disclose personal information at the instruction of either the Organization or the individual themselves. All other exceptional collection, use, and disclosure is pursuant to what is permitted under the law.
• We provide you with access to and right to delete your personal information as described under Your Choices.

We are committed to collecting and processing personal data responsibly and in compliance with the applicable data protection laws in all countries in which we do business. Our goal is to apply data protection standards established on the basis of internationally accepted data protection principles supporting an effective protection of personal data we process. In addition to upholding your rights set forth under the GDPR and CCPA, we will consider other applicable data privacy laws and comply where necessary. We reserve the right to evaluate any request against the governing data privacy law.

Children

DySi Open is not directed at children under the age of 18.  We do not knowingly solicit or collect personal data from children under the age of 18.

Updates to this Policy

We may update this Privacy Policy from time to time. When we update this Privacy Policy, we will revise the “Effective Date” date above and post the new Privacy Policy online, make it available through the Platform, and provide you notice of it through the email you provided upon registration. the Organization.If you disagree with the changes you may cancel your account by contacting us at privacy@dynamicsignal.com. See “Your Choices” for more information.

How to Contact Us

If you have any questions about this policy or concerns regarding the use or disclosure of your personal data through the Platform, you can contact us by sending an email to privacy@dynamicsignal.com or by contacting us at:

Dynamic Signal, Inc.
Attn: Privacy Office
1111 Bayhill Dr #125
San Bruno, CA 94066
U.S.A.
(888) 996-3630

Please provide your identification and contact details, and a complete explanation of your concern.

To communicate with our Data Protection Officer, please email privacy@dynamicsignal.com.