We, Dynamo Software, Inc., issue this California Consumer Privacy Act Privacy Policy (“CCPA Privacy Policy”) to provide information about how we collect, use, disclose, and otherwise process California residents’ personal information and rights that California residents may have under the California Consumer Privacy Act, as amended (the “CCPA“). If you are a California resident, this CCPA Privacy Policy applies to you and is supplemented by our Privacy Policy. This Policy does not reflect our processing of California residents’ personal information where an exception under the CCPA applies. This CCPA Privacy Policy applies to personal information collected through Dynamo Software’s own Sites and Services (as defined in our Privacy Policy). It does not apply to other affiliated platforms or websites, which maintain their own separate privacy policies. For purposes of this CCPA Privacy Policy, “personal information” has the meaning given to it under the CCPA and does not include information that is publicly available, deidentified, or aggregated as defined under the CCPA.
1. Our Personal Information Handling Practices over the preceding 12 months
Below are categories of personal information we have collected about California residents in the preceding 12 months and, for each category of personal information collected, the categories of sources from which that information was collected, the business or commercial purposes for which the information was collected, and the categories of third parties to whom we disclose the personal information.
| Category of Personal Information | Purpose(s) of Processing | Sources of Personal Information | To Whom Disclosed |
| Identifiers such as name, postal address, Internet Protocol address, email address | Providing, tailoring, securing, and optimizing our products and services
Communicating with individuals who have a business relationship with us and managing those relationships Facilitating registration for a Dynamo sponsored event Recruiting and evaluating individuals for employment or other similar opportunities with us or our affiliates |
Directly from California residents, for example, when filling out forms or applications | Service providers who assist us in providing products and services and other benefits to you, our customers, and other third parties |
| Personal information categories described in the California Records statute § 1798.80(e) such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account, credit card, and debit card numbers, or any other financial, medical, or health insurance information, including sleep, health, or exercise data
Some categories may overlap with other categories |
Providing, tailoring, securing and optimizing our products and services
Communicating with individuals who have a business relationship with us and managing those relationships Facilitating registration for a Dynamo sponsored event Recruiting and evaluating individuals for employment or other similar opportunities with us or our affiliates |
Directly from California residents, for example, when filling out forms or applications | Service providers who assist us in providing products and services and other benefits to you, our customers, and other third parties |
| Protected classifications under California or federal law such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information) | Recruiting and evaluating individuals for employment or other similar opportunities with us or our affiliates | Directly from California residents | Service providers that provide us with IT services |
| Commercial information such as products or services purchased, obtained, or considered | Providing, tailoring, securing and optimizing our products and services
Communicating with individuals who have a business relationship with us and managing those relationships Facilitating registration for a Dynamo sponsored event Recruiting and evaluating individuals for employment or other similar opportunities with us or our affiliates |
Directly from California residents, for example, when completing a purchase | Service providers who assist us in providing products and services and other benefits to you, our customers, and other third parties |
| Biometric information, such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns | Not collected | N/A | N/A |
| Internet or other similar network activity such as browsing history, search history, and information regarding a California resident’s interaction with a website, application, or advertisement | Providing, tailoring, securing and optimizing our products and services
Communicating with individuals who have a business relationship with us and managing those relationships Facilitating registration for a Dynamo sponsored event Recruiting and evaluating individuals for employment or other similar opportunities with us or our affiliates |
Directly from California residents, for example, when filling out forms or applications
Directly from California residents’ devices |
Service providers who assist us in providing products and services and other benefits to you, our customers, and other third parties |
| Geolocation data such as physical location or movements | Tailoring and optimizing our products and services | Directly from California residents’ devices | Service providers that analyze, for example, users’ interactions with our websites |
| Sensory data such as audio, electronic, visual, thermal, olfactory, or similar information | Providing, tailoring, securing and optimizing our products and services
Communicating with individuals who have a business relationship with us and managing those relationships Facilitating registration for a Dynamo sponsored event Recruiting and evaluating individuals for employment or other similar opportunities with us or our affiliates |
Directly from California residents, when, for example, entering our facilities or participating in source video for product development | Service providers that assist in providing security for our facilities |
| Professional or employment-related information such as current or past job history or performance evaluations | Recruiting and evaluating individuals for employment or other similar opportunities with us or our affiliates | Directly from California residents, for example, when filling out forms or applications
Indirectly from public sources or from third parties, such as background check providers |
Service providers assisting us with recruiting or evaluating candidates from employment, consultancies, and similar positions |
| Inferences drawn from other personal information such as the consumer’s preferences, characteristics, and behavior | Providing, tailoring, securing and optimizing our products and services
Communicating with individuals who have a business relationship with us and managing those relationships Facilitating registration for a Dynamo sponsored event Recruiting and evaluating individuals for employment or other similar opportunities with us or our affiliates |
Directly from California residents based on their use of our services | Service providers that analyze users’ interactions with our websites |
2. Sensitive Personal Information
We may collect personal information that is considered “sensitive” under the CCPA, such as race and ethnicity data that you voluntarily provide in connection with application for a job with us, which we use for equal employment purposes. When we collect sensitive personal data, we use such information only for lawful purposes in compliance with applicable privacy laws.
3. Retention of Personal Information
We retain the personal information we collect for as long as reasonably necessary for the purposes described in this CCPA Privacy Policy, our Privacy Policy, and as required or permitted under applicable law. The retention period may vary depending on the context of the processing and our legal obligations. For more information about our retention practices, please see the Data Retention section of our Privacy Policy.
4. Sales of Personal Information
We do not sell California residents’ personal information for monetary consideration. However, we do use cookies and other online technologies for advertising purposes, which are considered “sales” of identifiers and internet and other network activity information under the CCPA. For a comprehensive list of the cookies and third parties involved, please see our Cookie Policy at https://www.dynamosoftware.com/cookie-policy.
To opt out of such “sales” or sharing of your personal information, you may use the controls in the cookies notice which appears in your browser when you first visit our Sites, or contact us using the methods described in Section 10 below.
5. Right to Know About Personal Information Collected, Disclosed, or Sold
You have the right to request that we disclose what personal information we collect, use, disclose and share about you.
6. Right to Request Deletion of Personal Information
You have the right to request the deletion of personal information about you that we collected from you in certain circumstances.
7. Right to Correct Personal Information
You have the right to request that we update inaccurate personal information about you that we collect or maintain.
8. Right to Limit Use of Sensitive Personal Information
You have the right to request that we limit use of your sensitive personal information to certain purposes allowed by law. At this time, we do not use sensitive personal information for any purposes for which you have a right to limit.
9. Right to Opt-Out of Cross-Context Behavioral Advertising
You have the right to opt out of the use and sharing of your personal information for the purposes of selecting or delivering advertising based on your activity over time and across different online platforms, including the right to opt out of certain disclosures that are considered “sales” under applicable U.S. state laws. As stated above, we do not sell personal information at this time, except that the use of cookies and similar online technologies may constitute “sales” or “sharing” under the CCPA. Please note that your right to opt out does not apply to our sharing of personal information with service providers, as described in our Privacy Policy.
10. Right to Opt-Out of Profiling
You have the right to opt-out of automated profiling in certain instances where such processing would produce legal or other similarly significant effects. At this time, we do not use personal information to make automated decisions about you in any situations where you may have a legal right to opt out.
11. Exercising Your Rights
To exercise your rights under the CCPA, you may submit a request to us using one of the following channels:
- Use our contact form
- Email us at privacy@dynamosoftware.com
- By mail sent to Dynamo Software, Privacy Office, 480 Pleasant Street, Suite B200, Watertown, MA 02472.
Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child. You may designate an authorized agent by taking the steps outlined under “Authorized Agent” further below.
In your request or in response to us, you, or your authorized agent, must:
- Provide sufficient information to allow us to reasonably verify that you are, in fact, the person whose personal information was collected which will depend on your prior interactions with us and the sensitivity of the personal information being requested; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
If you do not provide enough information for us to reasonably verify your identity, we will not be able to fulfill your request. We will only use the personal information you provide to us in a request for the purposes of verifying your identity and to fulfill your request.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
12. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you for electing to exercise any rights under the CCPA.
13. Authorized Agent
You can designate an authorized agent to make a request under the CCPA on your behalf if:
- The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
- The authorized agent verifies his or her own identity directly with us by contacting us by phone or email as provided under Section 11 above; or
- You directly confirm with us that you provided the authorized agent permission to submit the request. To do so, you must contact us using the methods provided under Section 11 above; or
- You sign a written statement that you authorize the agent to act on your behalf.
Please note that we may need to verify your identity, and may request you to provide additional information in order to verify your identity. The information that we ask from you will depend on your prior interactions with us and the sensitivity of the personal information at issue.
If you provide an authorized agent with power of attorney pursuant to California Probate Code sections 4000 to 4465, it may not be necessary to perform the above steps, and we will respond to any request from such authorized agent in accordance with the CCPA.
14. Notice of Financial Incentive
We do not currently offer any financial incentive programs or price or service differences in exchange for the retention or sale of personal information.
15. Changes to this Policy
From time to time we may revise this CCPA Privacy Policy. When we do so, the changes will be posted and the revised document will be available online and the “last updated” date above revised.