Effective Date: September 11, 2015
Introduction: At Ghostery our mission is “transparency for all.” We believe deeply in this core principle and recognize that transparency, when done right, requires ongoing effort. That is why you may see us change our Privacy Statement from time to time, so we can share with you not only new information about our data practices, but also new ways to communicate that information. Our goal is to empower you by giving you straight forward information so you can make an informed decision whether or not to use our products or services. Ghostery makes software products that reveal the invisible digital activity on websites. Our consumer privacy products are free and allow you to see the invisible trackers on any given website. In order to provide free consumer privacy tools, and as a for-profit company, we license commercial privacy products to corporations so they to can see the invisible digital activity on their own websites so they can: (i) make more meaningful disclosures to their consumers, (ii) comply with relevant privacy laws, and (iii) deploy good digital governance. We’re dedicated to improving the online ecosystem by helping people and businesses see, understand, and control how data is collected and used across the web — for advertising, e-commerce, and more. Transparency for everyone.
Ghostery has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus (the “BBB”). If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Ghostery, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
Information Collection and Use: Ghostery may ask you to provide us with personal information if you would like to take advantage of services we offer. Personal information means any information that may be used to identify an individual, including, but not limited to, your name, company name, telephone number, and email address. We use this information to respond to your requests and otherwise provide you with information regarding our products and services.
E-mail Communications: We allow you to subscribe to our blog and weekly privacy news summary (the Ghostery Weekly Dispatch) and receive notifications of new posts by email. From time to time we will send you general marketing emails, notifications of events, and other important news about Ghostery. If you wish to learn how to opt-out from receiving these types of email communications, please see the “Choice/Opt-out” section below. Our emails also contain an opt-out function that you can click to stop receiving emails from us.
Website Tracking by Ghostery: We track the use of the Website to analyze our marketing efforts, improve the services we offer, and improve the efficiency of the Website. We automatically collect user traffic patterns throughout the Website using a technology called cookies, which do not contain personal information. The collection of this type of information is for website operational purposes. Users who do not wish to have their data collected can opt-out of that collection via our site’s privacy notice, which can be accessed by clicking the “cookie consent” icon in the lower-right hand part of any page.
California Online Protection Act Notice
Do Not Track (DNT): Because there is not yet a consensus on how companies should respond to web browser-based DNT mechanisms, Ghostery does not respond to any browser-based DNT signals.
Children’s Privacy: This Website is not directed at nor targeted to children. If you have not reached the age of majority or are not able to enter into legally binding agreements in your country, you may not use this Website unless supervised by an adult. Our goal is to comply with applicable laws and regulations relating to collection and use of information from children as defined by applicable laws. If you believe that we have received information from a child or other person protected under such laws, please notify us immediately by email at email@example.com or by mail at Ghostery, Inc., 10 E. 39th Street, 8th Floor, New York, NY 10016 attention: Legal Department and we will investigate the matter and if take reasonable steps to remove that information from our database.
Clear Gifs (Web Beacons/Web Bugs) : Act-On and Marketo may also deploy a technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help them better manage content on our site. Clear Gifs are not cookies. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. Ghostery does not connect the information gathered by clear gifs to any user’s personal information. As above, to learn more about their practices with Clear Gifs (Web Beacons/Web Bugs), please go to the applicable privacy policies of those companies.
Blog and Newsletter: Except for the information you have provided to us in order to subscribe to our blog or newsletter, we do not collect any other personal information. To request removal of your personal information that you gave us, please contact us at firstname.lastname@example.org. Please note that when you post to a blog, that post becomes public information and we have no control over the content within your post, so if you provide personal information in a post, it will be in the public domain and out of our control. In such a case we may not be able to remove your personal information you posted.
Customer Testimonials: From time to time we may post customer testimonials on the Website. Before we post a customer testimonial on the Website, we obtain the customer’s written consent to post the customer’s testimonial and name. To request removal of your personal information from our customer testimonials, contact us at email@example.com. In some cases we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
User Access : We provide you with reasonable access to your personal information to correct data that may be inaccurate or delete data at your request. Please contact us at firstname.lastname@example.org if you would like to notify us of inaccurate data or request that we delete your data. We may decline to process requests that: are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical, or where information is required to be retained by law or for legitimate business purposes.
Data Retention: We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at email@example.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and as required by law.
Ghostery Transfer and Information Sharing: We do not share personal information collected on the Website with third parties without your permission, unless it is for the purpose of processing personal information on our behalf. In all such cases we use commercially reasonable efforts to comply with the relevant Principles. However, even though Ghostery does not otherwise share personal information about Website users with third parties, we reserve the right to disclose your personal 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 our Website.
Merger, Sale, or Reorganization of Ghostery : If Ghostery should ever file for bankruptcy or have its assets sold to or merged with another entity, information Ghostery receives from you on this Website is a Ghostery asset and may be transferred without recourse or sold without recourse.
Affiliated Websites, Other Websites, and Advertisements : We do not exercise control over the websites of third parties that you may link to or view as part of a frame on a page on this website. We are not responsible for the actions and policies of such third parties. You should check the applicable privacy policies of those third parties when providing information on a feature or page operated by a third party.
Choice/Opt-out: For information on how to opt-out of the collection and use of your personal information by Ghostery, go to www.ghostery.com/en/about-us. There are two ways that you may elect to opt-out of our collection and/or use of the information you provided to us through the Website. The first way is by opting-out through our Cookie Consent tool that is found in the bottom right hand corner of the Website. If you opt-out by this method, we will still record the privacy notices we deliver and continue to communicate the preferences you explicitly set with us (for example, opt-out choices.) To ensure we remember your request, we store your preferences in a cookie on your browser. The second way you can opt-out is by emailing us at firstname.lastname@example.org. In your email, make sure to say in the subject line: opt-out of cookie collection. Also, if you no longer wish to receive email communications, you may opt-out of receiving them by emailing us at email@example.com and say in the subject line that you no longer wish to receive email communications.
International Visitors and Customers : The Website is hosted in the United States. If you are visiting 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 are transferring your personal data to the U.S., which does not have the same data protection laws as the EU. However, our adherence to and compliance with the Safe Harbor Programs is the mechanism for us to the collect and transfer personal information from the E.U. to the U.S. If you are a citizen of the E.U. or Switzerland, please refer to the section entitled “U.S.-E.U. and E.U Swiss Safe Harbor Adherence” found above.
Security : No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and therefore you do so at your own risk. Once we receive your transmission, we make reasonable efforts to ensure that physical, administrative, and technical safeguards are in place to protect the security of our systems and data we collect. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such measures.
If Ghostery learns of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Website or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Website. Ghostery may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us at firstname.lastname@example.org. Ghostery may post a notice on the Website if a security breach occurs.
Changes and Updates: We may occasionally update this Privacy Statement. When we do, we will also revise the “Effective Date” at the top of the Privacy Statement. For changes to this Privacy Statement that may be materially less restrictive on our use or disclosure of personal information you have provided to us, we will notify you here or by means of notice on our homepage or by obtaining consent via email. It is your responsibility to periodically review this Privacy Statement to stay informed about how we are protecting the personal information we collect. Your continued use of the Website constitutes your agreement to this Privacy Statement and any updates.
Dispute Resolution: The BBB serves as our independent resource mechanism to resolve disputes alleging a violation of the Safe Harbor Principles. If your inquiry to us is not timely or satisfactorily addressed by us, you may contact the BBB in writing as provided in the section entitled “U.S.-E.U. and E.U Swiss Safe Harbor Adherence” above.
Contacting Ghostery : To access your information, ask questions about our information practices, to make comments, or to share concerns regarding Ghostery’s information practices, you can mail us at the address found below or email us at email@example.com. Privacy Department, Ghostery, Inc. ,10 E 39th Street, 8th Floor, New York, NY 10016. You can always reach us by telephone in the Privacy Department at 917-262-2528.