Effective 7/28/2020
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
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.
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.
We may use the information we collect through the Service for a range of reasons, including:
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.
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:
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.
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.
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.
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:
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.
If you or your organization believes that we are not complying with our privacy policy, or if you have any issues or concerns, you can submit a complaint with us and we will respond to you within 45 days. To that end please contact us in writing and provide your identification and contact details, name or domain of your Organization and a complete explanation of your concern.
In compliance with the Privacy Shield Principles, Dynamic Signal, Inc. commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Dynamic Signal at privacy@dynamicsignal.com or contact us at:
Dynamic Signal, Inc.
Attn: Privacy Office
1111 Bayhill Dr #125
San Bruno, CA 94066
U.S.A.
(888) 996-3630
Dynamic Signal has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://go.adr.org/privacyshield.html for more information or to file a complaint. The services of the American Arbitration Association are provided at no cost to you.
In the event that you cannot fully resolve your complaint through the Department of Commerce, it is possible that you may use binding arbitration as a final resort. For more information on how to invoke arbitration under the Privacy Shield Framework, please visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
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.
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 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.
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.
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.
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.