GHOST® PRIVACY POLICY
Effective Date: July 1, 2023
1. Introduction
2. Scope
3. What Information We Collect
4. How We Use Your Information
6. Your Choices
7. How We Share Your Information
9. International Transfers of Personal Information
10. Security
11. Retention of Personal Information
12. Your Rights Under the General Data Protection Regulation
13. Your Rights Under the UK GDPR
14. Your California Privacy Rights
15. Your Privacy Rights under Other US State Laws
17. Changes to This Privacy Notice
18. Contact Us
1. Introduction
Welcome! You have arrived at a website operated by Ghost LLC or our affiliates (“Ghost,” “we”, “our” or “us”). Ghost at its simplest form is the world's first lifestyle sports nutrition brand. The name GHOST® and mantra "be seen" come from that feeling of being behind the scenes and wanting to be heard, wanting to make an impact; we're all ghosts. This is our time.
At Ghost, we take your privacy very seriously. This Privacy Notice (“Notice”) describes the types of personal information (as defined below) that we collect, how we use it, how and when we share it, and the rights you have with respect to your information. It also explains how we communicate with you and how you can make inquiries and requests to us about your information. We strive to help you understand how we use your information to improve our products, services, marketing, and interactions with you, as part of our commitment to maintaining your trust.
2. Scope
This Notice applies when you use or access the website, www.ghostlifestyle.com and its subdomains or portals (the “Site”); our mobile application (“App”); or otherwise provide Personal Information or interact with us online or in-person. For the purpose of this Notice, "Personal Information" means any personal information relating to an identified or identifiable individual that is protected by applicable privacy laws. We refer to all of the above as “Services.” Our Services are used by our customers and fans (“Fans”), individuals who visit our Site (“Site Visitors”) and individuals applying for employment with Ghost (“Employment Applicants”). By using the Services, you agree to our Terms of Service.
Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that Personal Information is necessary to provide you with the Services or if we are legally required to collect it.
If you have any questions about this Privacy Notice, please contact us using the information in the Contact Us section below.
3. What Information We Collect
This section describes what information we collect from you through our Site, App or Services. We may receive information (including Personal Information) in the following ways:
Information That You Provide to Us
As you interact with our Site, App or Services such as when you contact us or make a purchase on the Site or App, we may collect the following Personal Information via webforms or inputs/uploads on our Site or App, and through telephone calls, text messages, letters, emails and other communications with you:
Site Visitors
• Contact information such as your first and last name, email address, job title, home or business address, telephone numbers, mobile numbers.
• Financial information such as your business credit card or debit card number, bank account information and your payment, service and purchase history.
Fans
• Contact information such as your first and last name, job title, email address, business address, shipping address, telephone numbers, mobile numbers; and
• Financial information such as your business credit card or debit card number, bank account information and your payment, service and purchase history.
Employment Applicants
• Contact information such as your first and last name, email address, home or business address, shipping address, telephone numbers, mobile numbers;
• Your current or past employment or educational information;
• Relevant licenses and certifications; and/or
• Other information that could reasonably be used to identify you personally.
Your decision to provide us with Personal Information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all the features of the Site, App or Services.
Information That Is Automatically Collected
Like many businesses, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Site, App or Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site or App. Usage Information may include:
• Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
• Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
• Referring and exit web pages and URLs;
• The areas within the Site and App that you visit and your activities there, including remembering you and your preferences;
• Your Device location or other location information, including the zip code, state or country from which you accessed the Services;
• Your Device characteristics;
• Certain other Device data, including the time of day you visit our Site or App or other information used to provide analytics or other usage information;
• Information about your engagement with our emails; and
• Statistical information about how both unregistered and registered users, collectively, use the Site, App and Services. This aggregate information is derived from Personal Information but cannot be tied back to you or your web browser.
Information Collected from Third Parties
The Site or App may include functionality that allows certain kinds of interactions between the Site or App and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of Ghost from third parties. We might also provide links to facilitate sending a communication from the Site or App, or we may use third parties to facilitate emails or postings to social media (like a “Share” or “Forward” button). These third parties also use cookies and other tracking technologies to capture information about your interactions with Ghost. Ghost does not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.
4. How We Use Your Information
We use your information for business and commercial purposes, including to use or browse the Site or App, to offer our Services, to provide you with customer service, to prevent security and fraud, to provide marketing information about our products and services, and to perform website and mobile application analytics.
We may use the information we collect about you in a variety of ways, including to:
To Provide Our Services
We process certain Personal Information when you access or use our services, including to:
• process your purchases, returns, refunds and customer support for our products and services;
• create and verify user accounts;
• support and improve our Ghost Loyalty program;
• facilitate the functionality of our Site and App, including payment-related functionality; and
• customize experiences and personalization when you are on our Site, using our App.
To Communicate with You
We process certain information in order to communicate with you in relation to your accounts, our services, our marketing, and your requests, including to:
• communicate with you about orders, purchases, returns, services, accounts, programs, contests, and sweepstakes;
• respond to your customer service inquiries and requests for information;
• send you personalized promotions, content, and special offers;
• communicate with you about our brands, products, events, or other promotional purposes;
• implement your communications preferences, such as sharing information with our business partners so that they may email you about their promotions, products and initiatives; and
• provide important product safety information and notice of product recalls.
For Improvement of Our Site, App or Services
We want to ensure that our Site, App, and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain Personal Information, including to:
• maintain, improve, and analyze our Site, App or Services; and
• detect, prevent, or investigate suspicious activity or fraud.
To Comply with Applicable Laws
We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:
• maintain appropriate records for internal administrative purposes; and
• comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.
To Enforce our Terms, Agreements, or Policies
To maintain a safe, secure, and trusted environment for you when you use our Site, App, and Services, we use your Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.
To Evaluate Your Application for Employment
We may use your information to evaluate your application for employment or administer employment benefits.
With Your Consent
We may process certain Personal Information in order to fulfill any other business or commercial purposes at your direction or with your consent.
5. Use of Cookies
We use cookies (a small text file sent by your computer each time you visit our site) and other tracking technologies to personalize your experience, analyze user trends, and improve the Services. These tracking technologies allow us to collect information such as your device type, browser type, interactions with our Site or App, geographic location, your web request, the date and time of your web request, your Internet Protocol address, the domain name of your Internet service provider and other data. If you can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Information.
Many browsers default to accepting cookies. You may be able to change this setting in your browser and you can also clear your cookies. If you do, you may lose some functionality of our site. Check your browser’s help function to learn more about your cookie setting options.
We may use the following types of cookies:
• Strictly necessary cookies. These cookies are essential for you to browse the website and use its features, such as accessing secure areas of the site. Cookies that allow web shops to hold your items in your cart while you are shopping online are an example of strictly necessary cookies. While it is not required to obtain consent for these cookies, what they do and why they are necessary should be explained to the user.
• Functionality cookies. Also known as “preference cookies,” these cookies allow a website to remember choices you have made in the past, like what language you prefer, what region you would like weather reports for, or what your user name and password are so you can automatically log in.
• Analytics cookies. Also known as “performance cookies,” these cookies collect information about how you use a website, like which pages you visited and which links you clicked on. None of this information can be used to identify you. It is all aggregated and, therefore, anonymized. Their sole purpose is to improve website functions. This includes cookies from third-party analytics services as long as the cookies are for the exclusive use of the owner of the website visited.
• Advertising cookies. These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and almost always of third-party provenance.
We might also use pixel tags, which are small graphic files that allow us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site. These tags may collect the IP address of the device from which you loaded the page and the browser type. Pixel tags are also used by our third parties to collect information when you visit our site, the links and other actions you take on our site, and we may use this information in combination with cookies to display targeted advertisements.
Other data technologies may be used that collect comparable information for security and fraud detection purposes.
If you have any questions about cookies or to generally find out more about cookies, the All About Cookies website is a trusted resource.
6. Your Choices
Cookies
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
• Apple Safari
• Google Chrome
• Microsoft Edge
• Mozilla Firefox
Note, however, that if you reject our request to use cookies or turn cookies off, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site. To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org, and/or www.youronlinechoices.com.
Do Not Track
Your browser may offer you a “Do Not Track” (“DNT”) option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites and platforms. There is no universally agreed-upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. Learn more about Do Not Track here.
Communication Preferences
With your consent, Ghost communicates with you via a variety of print and digital media.
To help us make e-mails more useful and interesting, we use pixels that enable us to see if you open e-mails from us, if your computer supports such capabilities. You can opt out of receiving emails from us at any time. To manage your communications preferences with Ghost — or to opt out of communications entirely — please unsubscribe at the bottom of our emails or contact us at privacy@ghostlifestyle.com.
If you opt in to our text messages, you agree to our Messaging Terms and Messaging Privacy Policy. You can opt-out of receiving further commercial text messages via the Messaging Service by responding to any of our text messages with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, or QUIT.
Analytics
We use Google Analytics to help us understand how our customers use the Site. Read more about how Google uses your Personal Information here and opt-out of Google Analytics here.
7. How We Share Your Information
Services Providers
We share your Personal Information with our third-party service providers who provide services such as website hosting, payment processing, online chat functionality, data analysis, information technology, customer service, email delivery, online advertising, auditing, event planning and other services. For instance, we use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here.
Third Party Advertising
We share information about your use of our Site and Services, and your interaction with our ads on other websites with our advertising partners to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other technologies (which you may consent to, depending on your location).
For more information about how targeted advertising works, visit the Network Advertising Initiative’s educational page here.
You can opt out of targeted advertising by visiting the following:
• Meta
• Bing
• Tik Tok
Other
Aside from the instances described above, we may share your Personal Information:
• to comply with the law;
• to respond to claims or comply with legal process served on Ghost (e.g., a lawful subpoena, warrant, or court order);
• to enforce or apply our policies or agreements;
• to protect and defend our rights or property or that of our customers, employees, visitors, or the public;
• in connection with a business transfer, sale, liquidation, or merger;
• if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; and
• to other parties only with your consent.
8. Third Party Links
Out Site may contain links to other websites such as social media platforms, other websites, and event and partner websites. These websites are not covered by this Privacy Notice. Please review the Privacy Notices or Policies of those websites to understand the privacy practices of these third parties.
9. International Transfers of Personal Information
The Site and App are operated in the United States. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in the United States. By using the Site and providing us with information, you consent to this transfer, processing and storage of your information in the United States. It is important to note that the privacy laws in the United States may not be as comprehensive as those in other countries such as those in the European Union (“EU”). Our service providers use appropriate safeguards to transfer your Personal Information to the United States.
10. Security
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Where we have given you (or where you have chosen) a password so that you can access certain areas of our site, you are responsible for keeping this password confidential. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us using the information in the Contact Us section below.
11. Retention of Personal Information
Ghost will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
When deciding how long to keep your information, we consider:
• How long we have had a relationship with you or provided our Services to you;
• Whether we are subject to any legal obligations (e.g., any laws that require us to keep transaction records for a certain period of time before we can delete them)
• Whether we have taken any legal positions (e.g., in connection with any statutes of limitation).
Rather than delete your data, we might de-identify it by removing identifying details.
All information you provide to us is stored on our secure servers or those of our third-party data storage providers.
12. Your Rights Under the General Data Protection Regulation
This section of our Privacy Notice applies if you are a data subject who resides or is located in the European Economic Area (“EEA”). We adopted this Policy to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this Section.
Under applicable law, we are considered the “data controller” of the personal information we handle under this Notice. In other words, Ghost is responsible for deciding how to collect, use and disclose this information, subject to applicable law.
We hope to ensure that the Personal Information we possess is always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take every reasonable step to ensure that the Personal Information that we process are limited to the Personal Information that are reasonably required in connection with the purposes set out in this Privacy Notice.
If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:
• The right to access, update or delete the information we have collected from you. Whenever made possible, you can access, update or request deletion of your Personal Information by contacting us at the contact information below.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Information.
• The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Ghost relied on your consent to process your Personal Information.
Legal Basis for Processing Personal Information
We rely on the following legal bases for processing your Personal Information:
• Processing of your Personal Information that you provide to us when you interact with our Services, such as making a purchase or watching our videos, is necessary to respond to or implement your request prior to entering into a contract with us.
• When you apply for employment through our Site, processing of your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through our Site.
• We use account-related data to set up accounts for users in our platform and to administer and support those accounts (such as usernames, email address and billing information), provide you with access to the Services, contact you regarding your use of the Services or to notify you of important changes to the Services. Such use is necessary for the performance of the contract between you and us.
• We will send you information by email on our new services or other promotions only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.
• Our use of data relating to your use of the Site, App and/or the Services, described above, is necessary for our legitimate interests in understanding how the Site, App and the Services are being used by you, to improve your experience on it and our Services offerings. We have also a legitimate interest in aggregating and/or anonymizing the information that we collect through our Site and/or the Services and using this information for our business purposes, as described above. When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below.
Exercising Your Rights Under GDPR
If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the information in the Contact Us section below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.
Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.
Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us using the information in the Contact Us section below.
13. Your Rights Under the UK GDPR
If you are based in the United Kingdom, the following provisions also apply:
UK GDPR means the Retained Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
If we share your personal data within Ghost or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.
You have the same data subject rights as those for the EU listed above, except that references to the "GDPR" should be read as references to the "UK GDPR" and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office.
14. Your Rights Under the UK GDPR
This section of our Privacy Notice applies to consumers who reside in California. We adopt this section to comply with the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”).
If you are a California resident, you may be able to exercise the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.
Right to Access and Information Regarding Personal Information
You have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:
• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information is collected;
• Our business or commercial purpose for collecting or selling Personal Information;
• The categories of third parties with whom we share Personal Information;
• The specific pieces of Personal Information we have collected about you;
• The categories of Personal Information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of Personal Information for each third party to which we disclosed the Personal Information; and
• The categories of Personal Information about you that we disclosed for a business purpose.
Right to Deletion of Personal Information
You have the right to request that we delete Personal Information about you that we have collected from you. There may be certain exceptions to our obligation to delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.
Right to Correct Personal Information
You have the right to request that we correct any inaccurate information that we maintain about you.
Right to Opt-Out of the Sale or Sharing of Personal Information
You have the right to opt out of the sale or sharing of Personal Information. Ghost discloses your Personal Information to our business partners as described below. We do not sell Personal Information, but we recognize that some privacy laws define “personal information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” To opt-out of this, please click on this link.
Right to Non-Discrimination
We may not discriminate against you because you have exercised any of the aforementioned rights, including by:
• Denying you goods or services;
• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Providing you a different level or quality of goods or services; or
• Suggesting that you will receive different price or rate for goods or service or at a different level or quality of goods or services.
This includes the right of current and prospective employees not to be retaliated against for the exercise of their CCPA rights.
However, as permitted by the CCPA, we may offer you certain financial incentives. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value. Participation in a financial incentive program requires your prior opt-in consent, which you may withdraw at any time.
Notice of Financial Incentives
As permitted by the CCPA, we may offer you certain financial incentives and benefits by joining our Ghost Loyalty program. The information that we collect for enrollment in the program (listed above) allows us to tailor our communications and products and services suggestions for you. This, in turn, helps us establish a stronger relationship with you – something we at Ghost value.
If you participate in the Ghost Loyalty program, there are two types of financial incentives:
• Points. You can earn points when you do a number of activities, such as purchasing products from our online store, tagging us on social media, telling us your birthday, and referring friends to Ghost. These points can be used to discount the price of future purchases or buy exclusive merchandise from us. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value. We estimate the value of Personal Information we request from our Ghost Loyalty program customers by comparing the amount spent by Ghost Loyalty program customers to similarly-situated customers who do not participate in the Ghost Loyalty program over a 12-month period.
• Promotions. You may have access to certain special launches and promotions, along with giveaways where your status and/or points will grant you access to various prizes.
In determining the value of this Personal Information to Ghost, we consider the profit generated from products that include Personal Information, which is reasonably correlated to the value provided to the consumer through personalized points, promotions, and other discounts or offers.
Participation in the Ghost Loyalty program is voluntary and requires your prior opt-in consent, which you may revoke at any time. If you wish to leave the Ghost Loyalty program, please reach out to us using the information in the Contact Us section below.
Personal Information Collected
We have collected the following categories of Personal Information from consumers within the last twelve (12) months:
|
Category of Personal Information |
Examples of this Category |
Sources of Personal Information |
Business Purpose for Collection |
|
Identifiers |
Real name, alias, postal address, unique personal identifier, online identifier, Internal Protocol address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers. |
You Automatically Third Parties |
To provide our products and Services To provide information you requested To improve our products and Services To identify potential customers To market our products and Services To verify identity To prevent fraud To process payments To comply with law To offer employment, to provide insurance and benefits, for background checks |
|
Personal information described in California Civ. Code § 1798.80(e) |
Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. |
You Automatically Third Parties |
To provide our products and Services To provide information you requested To improve our products and Services To identify potential customers To market our products and Services To verify identity To prevent fraud To process payments To comply with law To manage payroll and provide and administer employee benefits |
|
Characteristics of protected classifications under California or federal law |
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or credit, marital status, medical condition (AIDS/HIV status, cancer), physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), political activities or affiliations, familial status, source of income status, status as a victim of domestic violence, assault, or stalking. |
N/A |
N/A |
|
Commercial information |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
You Automatically |
To provide our products and Services To market our products and Services To improve our products and Services To provide information you requested To comply with law |
|
Biometric information |
An individual’s genetic, physiological, biological or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA) or activity patterns that can be used to establish individual identity, including images of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health or exercise data that contain identifying information. |
N/A |
N/A |
|
Internet or other electronic network activity information |
Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. |
Automatically |
To provide our products and services To market our products and services To improve our products and services (e.g., usage pattern data) To track employee actions for internal reports and information security purposes |
|
Geolocation data |
Physical location and/or movements. |
N/A |
N/A |
|
Sensory data |
Audio, electronic, visual, thermal, olfactory, or similar information. |
N/A |
N/A |
|
Professional or employment related information |
Current or past job history or performance evaluations |
You |
To offer employment, to provide insurance and benefits, for background checks |
|
Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99) |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
N/A |
N/A |
|
Inferences drawn from other Personal Information |
Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
You Automatically Third Parties |
To provide our products and services To market our products and services To improve our products and services |
|
Sensitive Personal Information |
Social security number, driver’s license number, account log-in, debit, or credit card number in combination with password or PIN, precise geolocation (less than 1850 sf radius), racial/ethnic origins, religious or philosophical beliefs, union membership, contents of e-mails or texts to others, genetic/biometric data, health information, sex life/sexual orientation data |
N/A |
N/A |
Information related to how long we retain Personal Information is included in the Retention of Personal Information section above.
Personal Information Sold or Shared
We have sold or shared (as those terms are defined in the CCPA) to third parties the following Categories of Personal Information in the last twelve (12) months:
|
Category of Personal Information |
Recipient Categories |
Purpose for Sale/Sharing |
|
Identifiers |
Advertising, marketing, and analytics providers Suppliers |
Marketing and analytics |
|
Personal information described in California Civ. Code § 1798.80(e) |
N/A |
N/A |
|
Characteristics of protected classifications under California or federal law |
N/A |
N/A |
|
Commercial information |
Advertising, marketing, and analytics providers Suppliers |
Marketing and analytics |
|
Biometric information |
N/A |
N/A |
|
Internet or other electronic network activity information |
Advertising, marketing, and analytics providers |
Marketing and analytics |
|
Geolocation data |
N/A |
N/A |
|
Sensory data |
N/A |
N/A |
|
Professional or employment-related information |
N/A |
N/A |
|
Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99) |
N/A |
N/A |
|
Inferences drawn from other Personal Information |
Advertising, marketing, and analytics providers |
Marketing and analytics |
|
Sensitive Personal Information |
N/A |
N/A |
We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.
Personal Information Disclosed for Business Purposes
We have disclosed the following categories of Personal Information for business purposes in the last twelve (12) months:
|
Category of Personal Information |
Recipient Categories |
Business Purpose for Disclosure |
|
Identifiers |
Service Providers |
Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Providing advertising and marketing services (other than cross-context behavioral advertising) Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services |
|
Personal information described in California Civ. Code § 1798.80(e) |
N/A |
N/A |
|
Characteristics of protected classifications under California or federal law |
N/A |
N/A |
|
Commercial information |
N/A |
N/A |
|
Biometric information |
N/A |
N/A |
|
Internet or other electronic network activity information |
|
Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Short-term transient use Performing services on behalf of the business Providing advertising and marketing services (other than cross-context behavioral advertising) Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services |
|
Geolocation data |
N/A |
N/A |
|
Sensory data |
N/A |
N/A |
|
Professional or employment-related information |
Service Providers |
Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Short-term transient use Performing services on behalf of the business Providing advertising and marketing services (other than cross-context behavioral advertising) Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services |
|
Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99) |
N/A |
N/A |
|
Inferences drawn from other Personal Information |
Service Providers |
Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Short-term transient use Performing services on behalf of the business Providing advertising and marketing services (other than cross-context behavioral advertising) Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services |
|
Sensitive Personal Information |
N/A |
N/A |
How to Exercise Your California Privacy Rights
You or your authorized agent may make a request to access, correct, delete or opt-out of the disclosure of your Personal Information for business purposes. You may also make a verifiable consumer request on behalf of your minor child if you believe we have received their information inadvertently. You may request to exercise the aforementioned rights by contacting us using the information in the Contact Us section below.
Please note that we may take steps to verify your identity and residency before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. This might include asking for your email address.
If you use an authorized agent to exercise your rights, we may require proof of written authorization you have given the authorized agent to make the request on your behalf.
We may limit our response to your exercise of the above rights as permitted by law. We will confirm receipt of the request within 10 business days describing our verification process. We will respond to your request within 45 days or let you know if we need additional time.
Data Sharing for Direct Marketing Purposes
California Civil Code § 1798.83 further permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your Personal Information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us using the information in the Contact Us section below.
15. Your Privacy Rights under Other US State Laws
If you are a resident of Colorado, Connecticut or Virginia, you have the right, upon a verified request, to:
• To confirm whether a controller is processing your personal data and to access such personal data;
• To correct inaccuracies in your personal data;
• To delete your personal data;
• To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;
• To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
To exercise these rights, you or your authorized agent may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by using this link or contacting us using the information in the Contact Us section below.
If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency in order to obtain the information. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident of Colorado, Connecticut or Virginia. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.
Right to Opt Out Under Applicable State Laws
Residents of Colorado, Connecticut, and Virginia have the right to opt out of the sale of their Personal Information and targeted advertising. To exercise your right, please click on “Do Not Sell My Information” link on the bottom of the webpage where your information is being collected.
Opt-Out Preference Signals
Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.
Appeals of Our Decisions
In some states, you may appeal to us if we refuse to take action on your exercise of certain choices described above. To appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email. If your appeal is denied, residents of certain states can contact their attorney general as follows:
• Virginia Attorney General
• Colorado Attorney General
• Connecticut Attorney General
16. Children’s Privacy
Our Site and Services are not directed at children under 18 years of age, and we do not knowingly collect or receive Personal Information from them or sell or share such information. If you believe that we have received Personal Information from a child under the age of 18, you may contact us using the information in the Contact Us section below to request deletion of that information.
17. Changes to This Privacy Notice
We may change this Privacy Notice at any time. We will post all changes to this Privacy Notice on this page and will indicate at the top of the page the modified notice's effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy notice. If required by the applicable law, we will notify you of the changes. By continuing to use the Site and/or the Services or providing us with information following such a replacement Notice being uploaded, you agree that you will be deemed to have agreed to be bound by the Privacy Notice as changed.
18. Contact Us
If you have any questions or suggestions regarding this Privacy Notice, please contact us at:
Ghost, LLC
170 S. Green Valley Parkway, Suite 300
Henderson, NV 89012
Email: privacy@ghostlifestyle.com
Contact number: 1.844.GHOST.88
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