Dyn Privacy Policy

1. INTRODUCTION AND SCOPE

This Privacy Policy for Dyn Internet Performance Tools (‘Privacy Policy’) provides information on the collection, use, sharing and processing of personal information by Oracle Corporation and its affiliates (“Oracle”, “we” or “us”) in connection with your use of Dyn’s Recursive DNS service, Updater Client, Gauge web browser extension, and RUM beacons (“Internet Performance Tools”). For more information on Oracle’s personal information collection and use practices in connection with these tools, see section 4, “WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?”

This Privacy Policy does not apply to personal information collected by customers of Oracle when they use the Internet Performance Tools on their websites and collect information about you for their own purposes. To find out more about how our customers may collect and use information about you on their websites, please review the privacy policy of the company who collected your information, and consult them if you have any further questions.

This Privacy Policy also does not apply to personal information Oracle collects in connection with your interactions with the www.dyn.com website, which is subject to the terms of Oracle’s Privacy Policy.

This Privacy Policy was last updated on October 20, 2020. However, the Privacy Policy can change over time, for example to meet changing business or legal requirements. The most up-to-date version can be found on this website. In case there is an important change that we want to highlight to you, we will also inform you in another appropriate way (for example, via a pop-up notice or statement of changes on our website).

2. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL INFORMATION?

Oracle Corporation and its affiliated entities are responsible for processing your personal information described in this Privacy Policy. A list of Oracle entities is available here. Please select a region and country to view the registered address and contact details of the Oracle entity or entities located in each country.

3. WHICH CATEGORIES AND SPECIFIC PIECES OF PERSONAL INFORMATION DO WE PROCESS AND FROM WHICH SOURCES?

Oracle’s Internet Performance Tools are designed to improve the way you experience the Internet by monitoring the performance of your internet connected devices and services you use to access the Internet. Any time you use or interact with the Internet Performance Tools as described below in Section 4, information is automatically generated and collected by Oracle. Personal information is information collected online by the Internet Performance Tools and may indirectly identify you, which includes:

• IP address and port
• Country, State, and City
• IP address of recursive DNS provider
• Time and date of query
• Domain queried
• Query details (e.g., TTL, query type, DNS flags, DNSSEC info)
• Query response
• Information related to your device’s performance when accessing and utilizing the internet, including time to resolve DNS, time spent making request, time spent downloading the response, and the total time between the response and the site loading (collectively referred to as “Internet Performance”).

Oracle does not collect direct identifiers (such as first and last name, address, or email address) through the use of the Internet Performance Tools and will not associate—and does not allow our third party partners to associate—the indirect identifiers listed above with direct identifiers.

4. WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?

Oracle uses the information collected by the Internet Performance Tools for the following purposes, which are described in further detail below:

a) to enable the Recursive DNS service for users who choose to use that service;

b) to enable analytics for users who download the Gauge Chrome web browser extension;

c) to enable the Dyn Updater Client to update IP address for Remote Access services;

d) to collect data on site performance via RUM beacons;

e) to analyze, develop, improve, and optimize the use, function and performance of Oracle products and services;

f) to manage and assess the security of our sites, networks and systems and to allow our third party partners to manage and assess the security of sites, networks, and systems; and

g) to comply with applicable laws and regulations and to operate our business.

a) to enable the Recursive DNS service for users who choose to use the service;

We collect information to enable the Recursive DNS service for users who want an alternative to existing DNS recursive resolvers. For example, if you have noticed that your internet performance has been lagging on your internet connected device, you may enable the Dyn Recursive DNS service on your device by pointing to Dyn recursive resolvers to try to improve internet performance.

b) to enable analytics for users who download the Dyn Gauge Chrome extension;

Users can download a free extension, the Dyn Gauge Chrome extension, from the Chrome Web Store to test and analyze their internet connected device’s Internet Performance. The Gauge Chrome extension allows you to gain insights such as whether your slow internet connection is due to your WiFi, ISP or a website. This product uses RUM beacons, as described in subsection 4(d) below.

c) to enable the Dyn Updater Client to update IP address for Remote Access services;

Oracle’s Remote Access service allows you to choose a unique hostname (e.g., MyHome.dyndns.org) and link it to any IP-compatible device (such as a router, webcam, security camera, DVR, thermostat, computer, or file storage) to create your own unique Remote Access subdomain. The Dyn Updater Client works in conjunction with Remote Access services to keep your dynamic IP address up to date. The Updater Client allows Oracle to recognize that your dynamic IP address has changed and automatically update your IP address for your Remote Access subdomain to enable continued, uninterrupted remote access to your device.

d) to collect data on Internet Performance via RUM beacons;

Oracle’s RUM Beacons are a technology that executes a series of small file requests when users connect and interact with the Internet. This technology may be deployed in one of a number of ways. Oracle might deploy the RUM Beacon as a “web beacon” (or “single-pixel” or “clear” GIFs) embedded in our website that is invisible to users. For example, when you visit an Oracle site that deploys RUM Beacons, your browser will send requests for test files to different locations on the Internet to determine Internet Performance to various datacenters across the globe, allowing Oracle to determine the best data center to serve content from for your Internet Service Provider.

Oracle may also deploy its RUM Beacons as part of your use of Oracle’s other services, like its Updater Client or the Dyn Gauge Chrome extension, as described above. For example, when you use the Dyn Gauge Chrome extension, your browser will send requests for test files to different locations on the internet to provide your Dyn Gauge Chrome extension dashboard with metrics on your Internet Performance that you can view. When you download the Updater Client, it will send requests for test files to different locations on the internet to provide Oracle with Internet Performance information.

e) to analyze, develop, improve, and optimize the use, function and performance of Oracle products and services

We process the information collected from the Internet Performance Tools to enhance or develop new features and functionality. We also use the information for statistical analyses related to the performance and operation of the Internet Performance Tools.

f) to assess and manage the security of Oracle sites, networks and systems and to allow our third party partners to assess and manage the security of sites, networks, and systems

We process personal information for managing security and operations to help keep our networks and systems as well as our products and services secure, or to investigate and prevent cyber-attacks or potential fraud. We may share the data with our third party partners to allow our partners to assess and manage the security of sites, networks, and systems, or to investigate and prevent cyber-attacks or potential fraud. Please see section 7 for our sharing practices with our partners.

g) to comply with applicable laws and regulations and to operate our business

In some cases, we may process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the operation of our business. For example, to conduct audits and investigations, for finance and accounting, archiving and insurance purposes.

5. FOR EUROPEAN UNION (EU) RESIDENTS, WHAT IS OUR BASIS FOR PROCESSING INFORMATION ABOUT YOU?

For personal information collected about you in the EU/EEA, our basis for processing is the following:

• Information about you collected to enable your use of the Internet Performance Tools are necessary for the performance of the applicable terms of service or license agreement.
• We rely on our legitimate interest to conduct analytics on internet performance and to analyze, develop, improve and optimize our sites, products, and services to assess and maintain the security of our sites, networks, and systems.
• In order to comply with applicable laws and regulations, such as to comply with a subpoena or other legal process.

6. FOR WHAT PERIOD DO WE RETAIN PERSONAL INFORMATION?

Oracle maintains personal information collected by the Internet Performance Tools for up to 12 months as of the moment it was first collected by the Internet Performance Tools. We may retain de-identified data (such as a hashed IP address incapable of being re-identified) for longer than 12 months.

7. WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION?

Sharing within Oracle

As a global organization, information about you can be shared globally throughout Oracle’s worldwide organization for a business purpose. A list of Oracle entities is available here. Please select a region and country to view the registered address and contact details of the Oracle entity or entities located in each country. Oracle employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.

Sharing with third parties

We may share personal information with the following third parties for a commercial purpose:

• Oracle partners such as internet security companies or retailers, for analytics on site security and site or internet performance. IP addresses are truncated by removing the last octet prior to sharing with internet security companies or retailers for the purposes described in Section 4(f) above and
• third-party service providers as necessary to perform services on behalf of Oracle.

We may share personal information with the following third parties for a business purpose:

• relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings and
• as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.

When third parties are given access to personal information, we will take appropriate contractual, technical and organizational measures designed to ensure that personal information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy and in accordance with applicable law.

8. WHAT ARE YOUR PRIVACY RIGHTS?

Sharing within Oracle

You can refuse certain web beacons by adjusting the settings on your browser, DNS updater, or email software. Disabling javascript will disable RUM Beacons integrated into websites and will impact your ability to use the Internet Performance Tools. Please refer to your browser software instructions or help screen to learn more about these functions.

Oracle does not collect direct identifiers (such as first and last name, address, or email address) through the use of the Internet Performance Tools and will not associate—and does not allow our third party partners to associate—the indirect identifiers collected by the Internet Performance Tools with direct identifiers. Thus, requests to access, amend, correct, or delete data collected via the Internet Performance Tools would create a burden or expense disproportionate to the risks to your privacy.

9. WHAT ARE YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)?

If you are a California resident, you may request that we:

1. disclose to you the following information covering the 12 months preceding your request:

• the categories and specific pieces of personal information we collected about you and the categories of personal information we sold (see Section 3);
• the categories of sources from which we collected such personal information (see Section 3);
• the business or commercial purpose for collecting or selling Personal Information about you (see Section 4); and
• the categories of third parties to whom we sold or otherwise disclosed personal information (seeSection 7).

2. delete personal information we collected from you (see Section 8); or

3. opt-out of any future sale of personal information about you (see Section 8).

We will respond to your request consistent with applicable law.

If you are a California resident, you may obtain information about exercising your rights, as described above, by contacting us at 1-800-633-0748.

10. DOES ORACLE COLLECT PERSONAL INFORMATION FROM CHILDREN?

Oracle does not knowingly collect any personal information from, and does not tailor any services to, children under the age of 16.

11. HOW IS PERSONAL INFORMATION HANDLED GLOBALLY?

Oracle is a global corporation with operations in over 80 countries and has developed global data security practices designed to ensure that your personal information is appropriately protected. Please note that personal information may be transferred, accessed and stored globally as necessary in accordance with this policy.

12. HOW IS INFORMATION ABOUT YOU SECURED?

Oracle has implemented appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing.

13. HOW TO CONTACT ORACLE IF YOU HAVE QUESTIONS, COMMENTS OR COMPLAINTS?

Oracle has appointed a Global Data Protection Officer. If you believe your personal information has been used in a way that is not consistent with the Privacy Policy or your choices, or if you have further questions, comments or suggestions related to this Privacy Policy, please contact the Global Data Protection Officer by filling out an inquiry form.

Written inquiries to the Global Data Protection Officer may be addressed to:

Oracle Corporation
Global Data Protection Officer
Willis Tower
233 South Wacker Drive
45th Floor
Chicago, IL 60606
U.S.A.

14. DISPUTE RESOLUTION OR FILING A COMPLAINT

If you have an unresolved privacy or data use concern that you believe we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, you may invoke binding arbitration when other dispute resolution procedures have been exhausted. You also have the right to file a complaint with a competent data protection authority if you are a resident of a European Union member state.

15. ORACLE CORPORATE HEADQUARTERS

Oracle’s corporate headquarters are located at:

500 Oracle Parkway
Redwood Shores, CA
94065, USA

Tel: +1.650.506.7000
Fax: +1.650.506.7200