Effective Date: April 11, 2017
International Visitors and Customers: The Company is located in Germany and partly operates out of the United States. The data we collect, personal or otherwise, are located in the United States. If you accessing or using the Website from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you may be allowing the collection or transferring of your personal data in or to the U.S. However, we have a strong data privacy framework in place to ensure an adequate level of protection for your personal data (“Personal Data”).
Communication: The Consumer Messaging Platform (“CMP”) is used from time to time as a way for us to effectively and generically communicate to our users, while still honoring their privacy. The CMP is automatically turned on, but you can easily turn it off by going to the GBE options page and following the instructions provided. If you turn off the CMP, you can still use the GBE, but you won’t receive any generic communications from us.
Section I: Ghostery Browser Extension: We recognize that the GBE is popular because people want to be informed and empowered. We share the belief that privacy, when done right, is empowering, and that is why privacy is central to the GBE and new functionality that we may add. In other words, except as otherwise provided below, the GBE does not collect any Personal Data about you unless you affirmatively provide it to us.
Basis to Collect and Use Personal Data – There is no obligation on your part to provide your Personal Data. However, if you do, we have a legitimate interest to collect and use it, namely so we can provide products or services, or complete a transaction with you.
What Data is Collected – When you download the GBE it collects on an ongoing basis the following data:
- Non-Personal Data: Internet Protocol (IP) addresses, web browser, operating systems, and opt-in settings to share Tracker information with the Company, when an installation, upgrade, or uninstallation occurs, and whether the GBE is active or engaged by you.
- Personal Data: Many GBE users had previously requested the ability to open accounts so they can receive product information and also take advantage of new GBE functionality. The prior owner enabled you to do just that, and we will continue to allow for user accounts to be created, but note that you are not required to open a user account in order to use the GBE. If you choose to open a user account, you can do so either when you download the GBE, or any other time through the GBE settings. If you choose to create a user account, we will collect your Personal Data such as name and email address. At any time you can deactivate your user account, at which time you will no longer have access to the added functionality or other services that a user account offers. When you deactivate your account, we retain your Personal Data, using appropriate security safeguards referenced in Section III for a reasonable period of time, just in case you change your mind.
How is this Data Used –
- If you have not opened an account: The use of the GBE data that we collect if you have not opened an account is limited to: (i) communicating through the CMP–since we don’t have your name or email address–in order to share product information or updates and Company news, (ii) for internal analytical purposes such as accurately counting the number of browser extension downloads, or (iii) surveying our users from time to time.
- If you opened an account: The use of the GBE data (Personal Data) that we collect when you open an account is used for: (i) syncing your GBE settings across browsers and devices, (ii) serving as your login credentials so you can access the added functionality in the GBE, and (iii) communicating directly to you through your email address in order to give you information about our products, services, updates and upgrades (in certain cases for a fee).
What’s New –
Human Web: We developed a technology called Human Web, which is turned on by default, and creates anonymous group models that power the private quick-search, anti-tracking and anti-phishing technologies featured in the Cliqz products and will be soon be featured in the GBE.
- Data Collection: In order for Human Web to function we automatically collect non-private URLs, search queries along with search engine results pages, suspicious URLs that could potentially be phishing websites, information related to safe and unsafe trackers, and information related to the prevalence and performance of Trackers.
- Data Use: The data that we collect so Human Web can work is anonymized, aggregated and transmitted through the Human Web Proxy Network and used to improve the search, anti-tracking and anti-phishing features in the Cliqz browser.
Offers: Offers, also turned on by default, allows companies to show relevant marketing offers to users based upon an algorithm we created that anonymously determines intent and therefore particular commercial offers that may be of interest to you. This new functionality does not rely upon collected Personal Data.
Section II: Company Opt-In Community
What Data is Collected – In order to continue offering the GBE for free, you are asked at the point of download, if you will opt-in to a data exchange relationship with us, as millions of GBE users have already agreed to do, giving us permission to monitor and catalogue data on the Trackers that may be following you as you traverse the Internet. There is no obligation to opt-in to this community, and if you do you can always withdraw your consent as described below. To be clear, the list of things we collect is not about you. It’s about those Trackers we mentioned in the Introduction. We don’t associate any Trackers with you or your devices. The only way we will collect this Tracker data is if you affirmatively opt-in, and when you do so, the data we collect is limited to the following:
- the Trackers identified by the GBE,
- the blocking status of the Trackers,
- domains identified as serving Trackers,
- the time it takes for the page and the Trackers to load,
- the Trackers’ position on the page,
- the browser in which the GBE has been installed,
- the browser language,
- standard web server log information like your web request,
- the data sent in response to that request,
- a timestamp for the request, page,
- Tracker weight (megabytes of data attributable to each Tracker), and
- whether Trackers appeared on any visited webpage.
Why the Tracker Data is Important and How it’s Used: We incur significant costs in order for you to enjoy this free and valuable privacy tool, but we believe that a data exchange relationship–where you give us permission to collect and use Tracker data and we give you a free privacy tool–is a fair way to do business. We derive value from the Tracker data by licensing it back to the GBE’s prior owner, who will use it, as it has done so before, to build commercial software products or services to sell to companies to improve their websites, have better digital data governance practices, and comply with various privacy laws. We may also use this Tracker data to build or improve our other consumer privacy products. This data is not shared with any other third party and is not used for the purpose of tracking individuals or to otherwise target individuals in order to serve advertisements to them.
Withdrawing Opt-In Consent: You can always withdraw your opt-in consent through the GBE settings by unchecking the “Enable” box and saving your new preference. Once that is done you will no longer be in the opt-in community and we will not collect or use any of the information described above from that point onward.
Section III: Miscellaneous – This Section applies to both Section I and Section II.
Acknowledgement: By downloading or using the GBE you acknowledge that: (i) that the Company’s data practices are essential to the performance of the GBE, and (ii) the Company has a legitimate interest in collecting and using any Personal Data you provide.
Data Retention and Sharing Policy: The Company retains the collected data for as long as it is reasonably needed for the purpose for which it was collected, or as otherwise may be required by law, judicial order, or to protect our rights or the rights or safety of others. Likewise, we reserve the right to disclose or share any information as required by law, or when we believe that disclosure is necessary to protect our legal rights and/or to comply with a judicial proceeding, court order, or legal process served on us, or to protect the safety or rights of a third person.
Security: The Company has reasonable and appropriate technical, physical and administrative safeguards in place for a company of our size and complexity to protect the data that is collected.
Merger, Sale, or Reorganization of Company: If the Company should ever be sold or merged with another entity, or have its assets sold in whole or in part, or file for bankruptcy, all data and information are Company assets and may be transferred or sold without recourse.
Contacting Company: All inquiries, comments or concerns about these practices should be sent either by email to firstname.lastname@example.org , or regular mail to Cliqz International, doing business as Ghostery USA.,10 E. 39th Street, 8th Floor, New York, NY 10016, Attention: Privacy Department. You can also call us at 917-262-2528.