1. Introduction

The purpose of this policy is to explain how Sofo Dynamix collects, protects, and uses personal data. Sofo Dynamix is committed to ensuring that any personal data supplied by its Clients or is otherwise generated by its business activities is collected and processed fairly and lawfully.

2. What Types Of Personal Data Does Sofo Dynamix Collect?

Sofo Dynamix needs certain personal data to enable it to provide its products and services to its Clients and end users. The personal data collected will generally include: company name, company size and sector, individual contact names (first and last name) and job titles for delivery, installation, support and billing, postal address, telephone and fax numbers, e-mail addresses. Sofo Dynamix will also collect logs of verification checks made. Access to personal data that is generated over the Network utilised by Sofo Dynamix services include IP and email addresses for incoming and outgoing data and network usage data. In certain circumstances Sofo Dynamix may also collect financial information about Sofo Dynamix Clients and end users from third parties to enable Sofo Dynamix to assess its risks in granting credit terms and contact information about organisations Sofo Dynamix considers may be interested in Sofo Dynamix products and services.

3. How Does Sofo Dynamix Obtain Personal Data

Sofo Dynamix obtains personal data in a number of ways including from orders placed by Clients and end users (whether by telephone, fax or email or by application form); from enquiries made by existing Clients and potential Clients, (including information gathered at marketing events and via the Sofo Dynamix website); from third party list brokers; from resellers who pass on personal data to Sofo Dynamix about end users; and directly from the Network utilised by Sofo Dynamix services.

4. How Does Sofo Dynamix Use The Personal Data It Holds?

4.1 Providing and Improving the Sofo Dynamix Service

Most of Sofo Dynamix' use of personal data is necessary to enable it to provide a service to its Clients and its end users, including order processing, delivery, installation and support services as well as for invoicing and in order to answer general Client enquiries. For example, during the order process Sofo Dynamix shall verify and/or cross validate the email address and postal address you provide us with upon registration, upon purchase of WHOIS Privacy and making any updates once a year and at any other time Sofo Dynamix deems necessary. These verification logs will be stored for as long as is deemed necessary by ICANN.

In addition, Sofo Dynamix may also use personal data to improve on the level and type of service Sofo Dynamix offers to its Clients. As part of this interest in improving the service provided, Sofo Dynamix may process personal data for the purposes of sales analysis and Client usage statistics.

4.2 Direct Marketing

Sofo Dynamix may from time to time inform its Clients, end users and potential Clients about Sofo Dynamix and Sofo Dynamix affiliate products and services and other information Sofo Dynamix feels may be of interest.

Clients and other recipients of information from Sofo Dynamix may indicate at the time they first place an order with Sofo Dynamix whether or not they wish to receive such information or at any later time by simply contacting Sofo Dynamix, as indicated in paragraph 9 below.

4.3 Third Party Marketing

Sofo Dynamix, like many other companies, use remarketing features whereby third party vendors (including Google) display Sofo Dynamix's adverts on sites on the internet and use cookies - to serve adverts - based on a user's prior visits to the Sofo Dynamix website to assist Sofo Dynamix in collecting information on who visits the Sofo Dynamix site.

Sofo Dynamix will use first party cookies (such as Google Analytics cookie) and third party cookies (such as Double click cookie) together to report on how Sofo Dynamix use ad impressions, other uses of ad services and interactions with ad impressions and ad services for visits related to the Sofo Dynamix site, in addition to data or third party audience data in relation to age, gender and interests.

Clients may opt out of Google's use of cookies by visiting the Google advertising opt-out page. Alternatively Clients may opt out of a third party vendor's use of cookies by visiting the Network Advertising Initiative opt out page.

Clients also have the option to opt out of Google's use of Doubleclick's by visting the Google Doubleclick opt out page.

5. Does Sofo Dynamix Transfer Personal Data Overseas?

As Sofo Dynamix is part of a global organisation with local operating companies in a number of countries worldwide, to fulfil its Client service obligations it is necessary for Sofo Dynamix to transfer and process personal data outside the country in which the personal data is collected. This will include transfers to Sofo Dynamix affiliates based in the United States. Prior to making any such transfer Sofo Dynamix will put in place security procedures and firewalls designed to prevent unauthorised use of or access to personal data.

6. To Whom Does Sofo Dynamix Disclose Personal Data?

Sofo Dynamix will pass personal data within its internal departments in order to fulfil sales and support obligations as well as to finance departments to enable invoicing.

As a general rule, Sofo Dynamix does not disclose personal data to unaffiliated third parties except where Client consent has been obtained, where Sofo Dynamix is under an obligation by law to disclose personal data or where Sofo Dynamix has contracted with third parties to assist in providing services to Sofo Dynamix Clients such as for delivery, installation and systems support services.

7. How Does Sofo Dynamix Protect the Personal Data it Holds?

Sofo Dynamix takes Client confidentiality and security very seriously. Sofo Dynamix has implemented appropriate internal security procedures that restrict access to and disclosure of personal data within Sofo Dynamix. These procedures will be reviewed from time to time to determine whether they are being complied with and are effective.

Sofo Dynamix will not use any of the Clients sensitive information about the site or app whilst collecting data for the purpose of remarketing. Sensitive data includes:

  • interest or participation in adult activities (including alcohol, gambling, adult dating, pornography, etc.)
  • sexual behaviour or orientation
  • racial or ethnic information
  • political affiliation
  • trade union membership or affiliation
  • religion or religious belief
  • negative financial status or situation
  • health or medical information
  • status as a child under 13
  • the commission or alleged commission of any crime

8. Clients' Rights

The law in certain jurisdictions (including countries within the European Economic Area) gives individuals whose personal data is held by Sofo Dynamix specific rights to access and rectify personal data held about them. These include the right to:

8.1

obtain from Sofo Dynamix, for a prescribed fee, confirmation that personal data is held, as well as a written description of such personal data, the purpose(s) for which it is being used, the source(s) of the personal data and details of any recipients;

8.2

request the deletion or rectification of personal data which is inaccurate; and inaccurate; and

8.3

as explained in paragraph 4.2 above to object to any unsolicited information sent by Sofo Dynamix regarding promotions or new products and services.

9. Contact Details

If any individual wishes to contact Sofo Dynamix regarding the personal data held about them or has any other question about Sofo Dynamix's data privacy procedures, they should direct an email to [email protected] or send a letter to the direction of "Sofo Dynamix Client Services Department" at the local Sofo Dynamix office.

10. Policy Updates

As part of Sofo Dynamix's commitment to compliance with data privacy requirements, and to reflect changes in Sofo Dynamix's operating procedures, Sofo Dynamix may update the terms of this policy from time to time.