Privacy & Security Policy
Use of information shared and collected
In order to deliver Ghostly™ products to its users and members, to improve those products, and to create new products and services to help users and members save time and money, Ghostly™ collects information from you during your use of the Services. We collect information you share directly with Ghostly™ and other information during your use of Ghostly™ products.
Information you share
When you become a member of Ghostly™ you share a limited amount of information in connection with the registration process, including your name, email address, member password and other registration information. As you continue to use Ghostly™ products, you can save products of interest to you to monitor price drops and share promotional codes and deals you found useful for other users and members to benefit from. This additional information is optional and does not impact your use of Ghostly™ products.
Information we collect
- In addition to information that you share with us, Ghostly™ products automatically collect certain information to enable Ghostly™ products, to function properly and to help us better understand how our products work on various devices and browsers. That includes the type of devices you use, your device’s unique IDs where available or set, your IP address, your operating system, the type of browsers you use, URLs and domain names, how you engage with websites you visit when using Ghostly™ products, error logs, and other similar information. This information also allows us to upgrade and improve your experience.
- We take our users' time seriously and always want to make sure that any communication or service we provide is useful and relevant. It is in this spirit and scope that we also collect information which allows us to know whether you took an action from our communications. To do that we use common digital tools that allow us to see if you opened an email or visited a link we sent.
- We are always happy to help our users and members when you reach out with questions. The information we collect during that process is used to better improve Ghostly™ products and the experience of our users and members.
The information you share, and we collect, enables us to do that and gives us insights about pricing and availability of products. We also may use information you share, and we collect, in aggregate with other data for research and analytical purposes. We do not sell your personal information to anyone, but we may be obligated to disclose information you share, and we collect, in connection with legal requirements imposed on us and obligations we have as set forth below in the section titled "How do we share your information with third parties?".
Information we do not collect
We collect information that we believe can help us save our users and members time and money. This does NOT include any information from your search engine history or from your email, bank or credit card accounts.
Your choices for managing your information
We have made it easy and simple to opt out of Ghostly™ at any time. We have instructions on how to uninstall the Extension on our Website (https://www.ghostlyapp.com) and if you have any issues you can contact our support team for assistance by sending an email to email@example.com. We have also given members the ability to control the data we collect, while still continuing to use our products. This information can be adjusted in the accounts settings pages, but limiting the information you offer to provide may impact Ghostly™ ability to provide certain products.
If you are an individual accessing the Website or Ghostly™ products from the European Economic Area, please see the section below entitled "Additional privacy and security information" for further information regarding additional rights you have.
How do we share your information with third parties?
We may be required to disclose information under these limited situations:
- as required by law, or to comply or respond to a government request, such as to comply with a subpoena, or similar legal process;
- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud;
- with service providers who work with us, who have agreed to adhere to the rules set forth in this privacy statement, and who do not have an independent use of the information we disclose to them; or
- with a buyer, affiliate or other successor if Ghostly™ is involved in a merger, acquisition, similar corporate transaction. In such instances, you will be notified via email and/or a prominent notice on the Website of any change in ownership, as well as any choices you will have as a result of such transaction.
Storage of your data
As we are located in the United States and Ghostly™ products are operated in the United States, if you are located outside of the United States, please be aware that information you share and we collect will be transferred to, and processed, stored and used in the United States in order to provide Ghostly™ products to you. The United States does not have an adequacy decision regarding data protection from the European Commission.
Additional privacy and security information:
Users and members residing in the European Economic Area:
Controller: We are a private company, established in the U.S.A. Our legal contact email address is firstname.lastname@example.org. For the purposes of the General Data Protection Regulation we are the data controller.
Legal Bases: We describe in the section above titled 'Use of information shared and collected' the purposes for which we use the data collected and shared. Where we are using the data in order to provide Ghostly™ products to you, our legal basis for such use is on the basis of our contract with you. For all other purposes our legal basis is our legitimate interest in running our business, including ensuring Ghostly™ products function properly and improving and creating new products and services except where we obtain your consent for a particular processing, in which event the legal basis will be your consent.
Your rights: To exercise any of these rights above, please contact us at email@example.com. Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or where we are required by law to retain your personal data.
- Access and portability: You are entitled to request access to your personal data we hold and be provided with certain information about how we use your personal data and who we share it with. Where you have provided your personal data to us with your consent, you have the right to ask us for a copy of this data in a structured, machine readable format and to ask us to share (port) this data to another data controller.
- Correction: You have the right to ask us to correct your personal data where it is inaccurate or incomplete.
- Right to deletion: In certain circumstances, you have the right to ask us to delete the personal data we hold about you.
- Restriction: In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data.
- Objection: You can object to our processing of your personal data based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.
- Withdrawal of consent: In the event we have relied upon your consent to process your personal data, you may withdraw consent at any time by contacting us at firstname.lastname@example.org.
- Cease use: Finally, you may always cease using Ghostly™ products, and you may uninstall the Extension. After a reasonable time following such uninstallation, as set forth below, Ghostly™ products would no longer have access to your personal information.
Complaints: In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at email@example.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to raise a complaint with a relevant supervisory authority.
Users and members residing in New York
New York residents are permitted to ask any Internet based company, including Ghostly™, to identify categories of personal information shared with affiliates and/or third parties for direct marketing purposes. Ghostly™ does not share personal information with any affiliate or third party for direct marketing purposes without your prior approval. If you are a New York resident and would like us to confirm in writing that we have not provided any of your personal information to affiliates and/or third parties for direct marketing purposes, please submit a written request to firstname.lastname@example.org and we will do so at no cost to you.
Ghostly™ only keeps your information as long as is required to provide Ghostly™ products to you, as required to fulfil our legal requirements and defend legal claims.
After you have terminated your use of Ghostly™ products, we will store your information in an aggregated and anonymised format.
If you would like us to delete the information you provided, you can always contact us directly at email@example.com. We can explain how we can delete your profile immediately. Once you delete your profile, there is no longer any data attributable to you.
We use "cookies" and other semi-persistent but non-personally identifying member identification markers to identify members ("IDs"). When you join as a member and create an account, information you share, and we collect, will be synced with these IDs.
We created Ghostly™ for the exclusive use of adults aged 13 and older. We do not knowingly collect or solicit personally identifiable information from children under the age of 13; if you are a child under 13, please do not attempt to register for Ghostly™ products or send any personal information about yourself to us. If we learn we have collected personal information from a child under 13, we will delete that information as quickly as possible. If you are a parent or guardian of a child under 13 who you believe may have provided us personal information, please contact us at firstname.lastname@example.org.
We take great precaution to protect and safeguard our users' and our members' information. We have put in place physical, electronic, and procedural safeguards to protect the information we collect and process. This includes, limiting access to employees, vendors, and others; use of pseudonymization and anonymization techniques where feasible; and use of industry standard encryption techniques when transmitting information. Nonetheless, we are unable to guarantee that user or member information will not be accessed, viewed, disclosed, altered, or destroyed as a result of a breach of any of our physical, electronic and procedural safeguards.
If you have any questions about our privacy policies and practice, please contact us at email@example.com.
This version was approved by the legal team of Ghostly™ and went into effect on December 16, 2019.