Effective Date: February 22, 2016
Introduction: Ghostery is a for-profit company and works hard to communicate with clarity, but that is easier said than done, so while this Product Privacy Statement (“Privacy Statement”) discusses what information our particular products collect and use, it should be read in concert with our corporate Privacy Statement. Some of those products include our popular and free consumer privacy tool called the Ghostery Browser Extension (“GBE”), as well as commercial products that we may license, such as Ghostery’s Trackermap®. The GBE is a downloadable consumer browser extension that helps you to see what companies are tracking (“Trackers”) you on any given website. With the information provided by the GBE, you can learn more about these Trackers and exercise personal control over this activity. The GBE can be downloaded onto your computer, subject to the Ghostery Product End-User License Agreement (“EULA”).
International Visitors and Customers: Ghostery is located in the United States. If you are accessing our products or services 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 transferring your personal data to the U.S., which does not have the same data protection laws as the EU. However, we have a strong data privacy framework in place to ensure an adequate level of protection for your personal information.
Communication: Many of our GBE users have contacted us and asked to be kept abreast of changes to the GBE and our other products, certainly a good idea. In response we have developed the Consumer Messaging Platform (“CMP”), that will allow us to communicate to our users while still honoring their privacy by not collecting their names or email addresses. The CMP is automatically turned on, but it can be easily turned 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: Except as provided in this Privacy Statement, the GBE does not collect any personal data about you such as your name, address, or email address unless you affirmatively provide it to Ghostery.
What Data is Collected - When you download the GBE it collects on an ongoing basis the following data:
1. Non-personal Information: Internet Protocol (IP) addresses, web browser, operating systems, and opt-in settings to share Tracker information with Ghostery, when an installation, upgrade, or uninstallation occurs, and whether the GBE is active or engaged by you.
2. Personal Information or Personal Data: Many GBE users have contacted us and requested the ability to open accounts so they can receive product information and also take advantage of new GBE functionality. We’ve heard you and now enable you to have a user account, although there is no requirement to do so. If you choose to open a user account, you can do so either at the point of download, or anytime through the GBE settings. If you choose to create a user account, we will collect your name and email address. At any time you can de-activate your account, at which time you will no longer have access to the added functionality or other services that an account offers. When you deactivate an account, we retain your personal information using appropriate and reasonable security safeguards referenced in Section III for a reasonable period of time in case you change your mind.
a. Credit Card Information: Some products, such as Trackermap, may require payment by credit card after opening an account. In these cases we use a third party called Stripe (https://stripe.com/us/terms) to collect and process our credit card transactions. Stripe is not affiliated with Ghostery and we have no control over their privacy or security practices. Ghostery does not collect or retain your credit card information. We encourage you to go to Stripe’s website and review its practices before purchasing one of our commercial products.
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 Consumer Messaging Platform--since we don’t have your name or email address-- in order to share product information or updates and Ghostery news, and (ii) for internal analytical purposes such as accurately counting the number of GBE downloads..
- If you opened an account: The use of the GBE data (personal information) that we collect when you open an account is limited to: (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, updates and upgrades (in certain cases for a fee).
Section II: Ghostery Opt-In Community
What Data is Collected - In order to continue offering the GBE for free, you are asked when downloading the GBE if you will opt-in to our Ghostery community, millions strong, that we used to call Ghostrank, 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. 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.
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 with your devices.
How Is the Data Used: The data we collect if you opt-in is used to: (i) increase our Tracker intelligence, and (ii) build and improve our products that we license to businesses. That is how we make money and is how we are able to continue to offer the GBE as a free consumer privacy tool. We do not use or share with third parties any collected information for the purpose tracking individuals or otherwise target ads to them. To learn more visit www.ghostery.com.
Withdrawing Opt-In Consent: You can always withdraw your opt-in consent by opening the GBE, going to the settings, unchecking the “Enable” box and saving your new preferences. Once that is done you will no longer be in our opt-in community and we will not collect any of the information described above.
Section III: Miscellaneous - This Section applies to both Section I and Section II.
Consent and Acknowledgement: By downloading or using the GBE you: (i) consent to Ghostery’s information collection and use practices described in this Privacy Statement and agree to the terms of the GBE EULA, and (ii) acknowledge that Ghostery’s information collection and use practices are essential to the performance of the GBE and Ghostery’s ability to provide its services to you.
Data Retention: Ghostery retains the collected data for as long as it is needed for the purpose for which it was collected.
Security: Ghostery has reasonable technical, physical and administrative security safeguards in place to protect the collected data.
Information Sharing Policy: We reserve the right to disclose any information as required by law, or when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on us, or to protect the safety of a third person.
Merger, Sale, or Reorganization of Ghostery: If Ghostery should ever file for bankruptcy, or have its assets sold to or be merged with another entity, all collected data are Ghostery assets and may be transferred or sold without recourse.
Changes to Privacy Statement: We may occasionally change this Privacy Statement and when we do, we will also revise the “Effective Date” at the top of the Privacy Statement. If we make any material changes to our Privacy Statement, we will try to inform you via our CMP and, if you opened an account and gave us your email address, then we will also attempt to email you about those material changes. Ultimately, however, it is your responsibility to periodically review this Privacy Statement to stay informed about our information practices. Your continued use of the GBE constitutes your agreement to this Privacy Statement and any changes to it.
Contacting Ghostery: All inquiries, comments or concerns about our information practices should be sent either by email to email@example.com , or regular mail to Ghostery, Inc., 10 E. 39th Street, 8th Floor, New York, NY 10016, Attention: Privacy Department. You can also call us at 917-262-2528.