Effective Date: February 15, 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.
Section I: Ghostery Mobile Browser: We bought the GMB for a number of reasons, one of which is because of the loyal following of people like you. We share the belief that privacy, when done right, is empowering, and that is why our data practices are not materially different from the prior owner. In other words, except as otherwise provided below, the GMB 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 GMB, we collect on an ongoing basis the following data: Internet Protocol (IP) addresses, web browser, operating systems, and opt-in settings to share Tracker information with us, when an installation, upgrade, or uninstallation occurs, and whether the GMB is active or engaged by you.
How is this Data Used – The use of the GMB data that we collect is limited to internal analytical purposes such as accurately counting the number of downloads.
Section II: Opt-In Community
Data Exchange Relationship – In order to continue offering the GMB 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 GMB 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 GMB,
- 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 GMB 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 GMB’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 GMB 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 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 GMB you acknowledge that: (i) that the Company’s data practices are essential to the performance of the GMB, 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 email@example.com , 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.