But first, foremost, and most important, we will never sell or share your email address or information with third parties for their promotional purposes — rest easy on that account.
I. THE BASICS
We’ll start by getting a few definitions out of the way that should help you understand this policy.
When we say “we” or “us” or the “Company”, we’re referring to Dynamo Software, Inc. (previously known as Netage Solutions, Inc.), a State of Delaware limited liability company, its subsidiaries (including Q-Biz Solutions, LLC), and the other affiliated companies within the Dynamo Software group
The online application Dynamo™ is used for deal, investor, fund and portfolio management (“Dynamo”) by our clients, consisting of both general and limited partners, and the software tool PEView™ is used by general partners for data capture, reporting, and transactional processing (“PEView”). In addition, the Company uses PEView and its team of fund accounting professionals (“Q-Biz”) to provide outsourced fund administration services to private equity and venture capital clients (the “Fund Administration Services”).
We offer Dynamo on http://dynamo(1,2,3).dynamosoftware.com and via the mobile application DynaMobile™. PEView is offered via installation on client’s computer systems. We will be referring to Dynamo, PEView, the Fund Administration Services, the Company websites and the related applications and services collectively as the “Services”. In addition, we will use “Dynamo” to also refer to the special edition of the online application Dynamo™ that we use for our own CRM needs.
When we say “you” we’re referring to: (i) an individual that is visiting our Sites or the entity such individual represents; (ii) a user/visitor of the Services or an entity of a user/visitor of the Services when referring to an individual or an entity that has authorized access to Dynamo as per a legal agreement with the Company (“Customer”); or (iii) an individual who registers to attend a corporate event organized by the Company (via our Sites or a third-party service).
In the course of providing Dynamo or PEView, making available the Sites, or offering other Services, we may collect “Personal Information”, which means any information that identifies or can be used to identify an individual. Examples of such Personal Information include, but are not limited to, first and last name, the organization an individual represents, position, and business contact information, such as business address, email, and telephone.
4. Questions & Concerns
If you have any questions or comments, or if you want to update, delete, or change any Personal Information you’ve submitted on the Sites, please use our contact form to get in touch or contact us by email at: [email protected] or by regular mail sent to Dynamo Software, Privacy Office, 480 Pleasant Street, Suite B200, Watertown, MA 02472.
II. YOUR INFORMATION
5. Information Collected
When expressing an interest in obtaining additional information about our company, Dynamo or other services, when registering a user of Dynamo or completing a form for other purposes (such as registering for an event), the Company may (depending on the purpose of your inquiry or registration) require you to provide us with some personal contact information, such as name, phone number, email address, company name, and industry. When purchasing Dynamo licenses or other related services or registering for a paid event, the Company may also require you to provide the Company with billing information, such as billing name and address, as well as contact details (email and phone number) for certain employees within the organization that will be using the Services. If needed, depending on your business relationship with the Company, the Company may also ask you to provide additional information, such as (but not limited to) value of assets under management, number of employees and industry of the organization that you are representing. If you are applying for a job with the Company, the Company may also require you to submit additional personal information as well as a resume or curriculum vitae.
As you navigate the Sites and Dynamo, we may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”), and our Customers may collect similar information from their clients in their usage of Dynamo (e.g. when investors use Dynamo Investor Portal to view information provided by Dynamo Customers ). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on our Sites and Dynamo (such as the Web pages viewed and the links clicked).
6. Use of Information Collected
We use data collected from the Sites to perform the services requested. For example, if you fill out a “Contact Me” Web form, the Company will use the information provided to contact you about your interest in the Service.
We may also use data collected from the Sites for marketing purposes. For example, the Company may use the information you provide to contact you to further discuss your interest in Dynamo, and to send you information regarding Dynamo or the Company. In the event you would like to discontinue receiving communications from the Company, you can unsubscribe at any time by responding to the sender of the offending communications.
We may also use Web Site Navigational Information to operate and improve the Sites, and create an overall easier navigation or usability experience based on usage patterns.
7. Web Site Navigational Information
This section describes the types of Web Site Navigational Information the Company or its Customers may collect and how the Company or its Customers may use this information.
There are two types of cookies: session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer.
If you have chosen to identify yourself to us through the Sites, the Sites use session cookies containing encrypted information to allow us to uniquely identify you. These session cookies allow us to process your online transactions and requests.
Dynamo and the Sites use persistent cookies that only the Company can read and use to identify browsers that have previously visited the Dynamo application. When you access Dynamo or the Sites, a unique identifier is assigned to you through the server. This unique identifier is associated with a persistent cookie that Dynamo or our Sites place on your Web browser. The Company is especially careful about the security and confidentiality of the information stored in persistent cookies. For example, Dynamo does not store account numbers or passwords in persistent cookies. If you disable your Web browser’s ability to accept cookies, you will be able to navigate the websites, but you will not be able to successfully use Dynamo due to Secure Socket Layer (SSL) security precautions.
Dynamo uses Web beacons alone or in conjunction with cookies to compile information about your usage of the Sites or Dynamo, or to make it possible for our Customers to compile information about their clients’ interactions with Dynamo or emails generated by Dynamo. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site tied to the Web beacon, and a description of a Web site tied to the Web beacon. For example, we may and our Customers may use Dynamo to place Web beacons in marketing emails that notify if the recipient opens an email. Dynamo uses Web beacons to help Customers operate and improve email communications. We may use Dynamo and information from Web beacons to provide you with information about our Company or services and our Customers may use Dynamo and information from Web beacons to provide you with information about their Company or services.
When you visit the Sites or Dynamo, the Company collects IP addresses to track and aggregate non-personally identifiable information. For example, our Sites uses IP addresses to monitor the regions from which visitors navigate the Sites.
Dynamo also collects IP addresses from its users when they log into Dynamo as part of Dynamo’s “Identity Confirmation” and “IP Range Restrictions” security features.
Information from the use of our Mobile App
When you use our mobile application DynaMobile, we may collect information about the type of device and operating system you use. We may ask you if you want to receive push notifications about activity in your account. If you have opted into these notifications but no longer want to receive them, you may turn them off through your operating system. We don’t access or track any location-based information from your mobile device unless you’ve given us permission. We may use mobile analytics software to help us better understand how people use our mobile application. We may collect information about how often you use the application and other performance data. We don’t collect or link that data with any personally identifiable information.
8. Public Information and Disclosure to Third Parties
The Company does not share, sell, rent, or trade any Personal Information with third parties for their promotional purposes. The following include cases where we may share some of your Personal Information with our affiliates or third parties for other legitimate purposes, or where you make your Personal Information or other data public by your own choice.
We maintain presences on social media platforms like LinkedIn, Facebook and Twitter. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
Links to Third-Party Sites
The Company, Inc. may share limited data about Dynamo users with the Company’s affiliates involved in providing the contracted service. For example, the Company may need to share data about the Company’s Customers for customer relationship management purposes or technical support.
From time to time, the Company may partner with other companies to jointly offer products or services (such as data feeds that work with Dynamo). If you purchase or specifically express interest in a jointly-offered product or service from or through the Company, the Company may share certain Personal Information collected in connection with your purchase or expression of interest with our partner(s). The Company does not control our business partners’ use of that Personal Information (which will be subject to their own privacy policies). If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly-offered product or service.
The Company reserves the right to use or disclose Personal Information you provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.
9. Communications Preferences
The Company offers its Customers and visitors of our Sites who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by responding to such communications with a notice to adjust preferences at any time. You can also inform us about your communications preferences by using any of the communication channels listed in Section 4 above.
Customers of the Company cannot opt out of receiving transactional emails related to their account with Dynamo.
10. Correcting and Updating Your Information. Transparency and Choice.
We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do that. If your data changes (like a new email address), then you’re responsible for notifying us of those changes.
The Company’s Customers may update or change their registration information by editing their user or organization record via their Personal and Site Settings after login. To update Billing Information, please email billing[at]dynamosoftware.com.
For other requests to access, change, or delete your Personal Information, please use any of the communication channels listed in Section 4 above.
We will share or give you access to any Personal Information we hold about you within 30 days of any request for that information.
We will retain your information for as long as your Dynamo account is active or as long as needed to provide you Services or send you Services-related information (unless you have asked us not to do so). We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
However, at your request, unless it’s prohibited by law, we can delete any Personal Information about you that we have on file. There is no charge for an individual to access or update his or her Personal Information.
In summary, your rights regarding your Personal Information, subject to local data protection laws, would normally include the following rights:
- to access your Personal Information (right to access);
- to rectify inaccurate Personal Information and ensure it is complete (right to rectification);
- to erase/delete your Personal Information to the extent permitted by other legal obligations (right to erasure; right to be forgotten);
- to restrict our processing of your Personal Information (right to restriction of processing);
- to transfer your Personal Information to another controller to the extent possible (right to data portability);
- to object to any processing of your Personal Information carried out on the basis of our legitimate interests (right to object). Where we/ our customers process your Personal Information for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
- not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”); Automated Decision-Making currently does not take place on our websites;
to the extent we base the collection, processing, and sharing of your Personal Information on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.
11. Customer Data
Dynamo Customers use Dynamo to host data and information of their clients (“Customer Data”). The Company will not review, share, distribute, or reference any such Customer Data except as provided in the relevant Master Service Subscription Agreement, or as may be required by law. Individual records of Customer Data may be viewed or accessed under permission by the Customer only for the purpose of resolving a problem, support issues, or suspected violation of the Master Service Subscription Agreement, or as may be required by law. The Company’s Customers are responsible for maintaining the security and confidentiality of their Dynamo usernames and passwords.
Dynamo uses robust security measures to protect Customer Data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of Customer Data. When Dynamo is accessed using a recent version of Mozilla Firefox, Google Chrome, Internet Explorer or Safari, Secure Socket Layer (SSL) technology protects Customer Data using both server authentication and data encryption. These technologies help ensure that Customer Data is safe, secure, and only available to the Customer to whom the information belongs and those to whom the Customer has granted access. Dynamo also implements an advanced security method based on dynamic data and encoded session identifications, and the Company hosts its Sites in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders. Dynamo also offers enhanced security features that permit Customers to configure security settings to the level they deem necessary.
Because the Company uses a version of Dynamo to maintain data about the Company’s Customers, this information is secured in the same manner as described above for Customer Data.
13. We Operate Primarily in the United States
While the data protection, privacy, and other laws of the United States or the other countries where we operate might not be the same as those in your country, we take many steps to protect your privacy, including the option to execute an individual data processing agreement or comply with additional requirements applicable for Customers in a particular jurisdiction (such as the requirements of the Australian Privacy Act for Customers domiciled in Australia), or an option to host Customer Data in the EU for Customers domiciled in the EU/EEA or Switzerland. We also comply with the Privacy Shield Frameworks, as discussed in further detail in Section 14.
Unless you are a Customer domiciled in the European Union (“EU”) / the European Economic Area (“EEA”) or Switzerland who has explicitly requested hosting of your data in the EU, by using our Sites or Dynamo, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States or other countries where we operate and to those third parties with whom we may need to share it as described in this policy.
14. Data Transfers from the EU/EEA and Switzerland
The Company abides by the EU–U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce and the European Union, as well as with the Swiss–U.S. Privacy Shield Framework. You can view a description of how we comply with the Privacy Shield Principles in our Privacy Shield Notice. For more information on the Privacy Shield Frameworks and to view the scope of the Company’s certification, please visit the U.S. Department of Commerce’s Privacy Shield website here.
Your Personal Information may be collected, transferred to and stored by us in the United States and by our affiliates in other countries where we operate. In this event, we will ensure that such recipient offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.
15. Do Not Track Disclosure
Currently, various browsers — including Firefox, Internet Explorer and Safari — offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Web sites visited by the user about the user’s browser DNT preference setting. The Company does not currently commit to responding to browsers’ DNT signals with respect to the Sites or Dynamo, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. The Company takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.