Privacy Policy

Information for Dynex platform users and partners.

DYNEX-PRIVACY-2024-V3 Effective: November 1, 2024

Service Provider / Data Processor

Dynex Kft.

Registered Office: 1038 Budapest, Hosok Tere 37, Hungary

Company Registration Number: 01-09-439155

I. Preamble and Scope

Introduction

The purpose of this Privacy Policy is to provide detailed, transparent, and comprehensive information about the data processing and data handling activities carried out within the framework of the software platform and related services operated by Dynex Kft.

Legal Compliance

The Service Provider declares that its data processing practices fully comply with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR), Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information (Info Act), as well as the relevant sectoral legislation.

Role Definitions

Data Controller

The contracted Partner (Client) of Dynex Kft., who determines the purposes and means of processing personal data.

Data Processor

Dynex Kft., which performs technical data processing operations on behalf of the Data Controller and according to their instructions, based on the Software Service Agreement concluded with the Data Controller.

II. Activities Involving Data Processing

The Service Provider performs complex, integrated data processing activities during the operation of the Platform:

  • Customer Relationship Management (CRM): Record keeping of data subjects, contact information, interaction history
  • Marketing Automation: Technical execution and performance measurement of email and SMS campaigns
  • Omnichannel Communication: Email, SMS, Facebook, Instagram, Google Business Chat, Webchat
  • Digital Sales Funnels: Website and landing page hosting, forms
  • Appointment Booking System: Calendar functions, booking records, reminders

III. Scope of Processed Data

The Service Provider only processes data uploaded to the Platform by the Data Controller or generated during the use of the Platform:

Personal Identification Data

Name, title, company name

Contact Information

Email, phone, physical address, social media identifiers

Technical and Usage Data

IP addresses, browser types, device information, cookie identifiers

Communication Content

Content of emails, chat messages, SMS, attachments

Financial Transaction Data

Transaction amount, currency, date, status (we do NOT store complete credit card data)

Profiling Data

Interests, activity metrics

IV. Artificial Intelligence (AI) and Machine Learning

Data Protection Guarantee (No-Training Policy)

The Service Provider and its sub-processors (OpenAI) DO NOT use and DO NOT store personal data, business secrets, or knowledge bases entered by the Data Controller for the development, training, or fine-tuning of general-purpose artificial intelligence models.

Conversation AI (Chatbot) Operating Model

"Bring Your Own Knowledge" Principle: The chatbot works exclusively from sources explicitly uploaded by the Data Controller. It does not use external, unverified internet sources.

Content AI

For content generation features, the processing of personal data is limited to transient processing during the generation process only, for the execution of the specified instructions.

V. Automated Decision-Making and Profiling

Certain features of the Service (Marketing Automation, Workflows) may involve data processing that qualifies as profiling under Article 22 of the GDPR.

  • Nature of Profiling: Automated behavior analysis and segmentation
  • Purpose Limitation: Personalization of user experience, relevant offers
  • No Legal Effect: By default, they do not make automated decisions with legal effect

VI. Sub-processors Used

The Service Provider only works with partners who provide adequate guarantees of compliance with GDPR requirements:

Provider Activity Legal Basis
LeadConnector LLC Platform infrastructure EU-US DPF
Vercel Inc. Cloud hosting EU-US DPF
Google Cloud Services Data storage, analytics EU-US DPF
Amazon Web Services Storage, CDN EU-US DPF
Twilio Inc. SMS, voice communication BCR
Mailgun Technologies Email delivery EU-US DPF
Stripe, Inc. Payment transactions EU-US DPF
OpenAI, L.L.C. AI models (GPT) EU-US DPF

VII. Third-Party Integrations

The Platform is an "open architecture" system that allows the Data Controller to connect their account with external systems at their own discretion (e.g., Zapier, Make, Webhooks, Facebook Ads, Google Ads).

Important: The Data Controller is solely responsible for the lawfulness of such data transfers configured by them, as well as the data security compliance of the receiving party.

VIII. Data Security Measures

Encryption

TLS 1.2+ protocol, AES-256 standard encryption

Access Control

Role-Based Access Control (RBAC), mandatory 2FA

Availability

Geographically redundant backups (High Availability)

Zero Data Loss Strategy

Immediate persistent storage, minimized data loss risk

IX. International Data Transfers

Given that some sub-processors are headquartered in the United States, data transfers outside the European Economic Area (EEA) take place.

The legal basis for these data transfers is primarily provided by the adequacy decision of the EU-US Data Privacy Framework (DPF). Where the DPF is not applicable, we apply Standard Contractual Clauses (SCCs).

X. Data Deletion and Return

Following the termination of the contract with the Data Controller, the Service Provider is obligated - based on the Data Controller's decision - to:

  • Permanently and irreversibly delete all personal data from its systems; OR
  • Provide the data to the Data Controller in a structured, commonly used format

XI. Exercising Data Subject Rights

The Data Controller is responsible for exercising data subject rights under the GDPR (access, rectification, erasure, restriction, data portability, objection).

If a data subject submits their request directly to the Data Processor (Service Provider), the Service Provider will forward it without substantive review to the Data Controller without delay and provide technical assistance in fulfilling the request.

Date: Budapest, November 1, 2024

Dynex Kft.

Data Processor

For data protection questions, write to us at: [email protected]