Version 1.0

Last Revised : Nov 21st 2017

 

Ghost Locomotion (“Company”) is committed to protecting your privacy.  We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at https://www.gh.st/, our mobile application (“Application(s)”), and our widgets (collectively, the “Site”) and online services (“Services”).

1.              Questions; Contacting Company; Reporting Violations.  If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or email address:

Ghost Locomotion Inc.

Legal Department

800 California St., Suite 200

Mountain View, CA 94041

legal@gh.st

 

2.              User Consent.  By submitting Personal Data through our Site or Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.

3.              A Note About Children.  We do not intentionally gather Personal Data from visitors who are under the age of 13.  If a child under 13 submits Personal Data to Company and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible.  If you believe that we might have any Personal Data from a child under 13, please contact us at privacy@gh.st. 

4.              A Note to Users Outside of the United States.  If you are a non U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy.  In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country.  By providing your data, you consent to such transfer.  If you wish to obtain express consent from EU users, as set forth in this section, you will need to implement a separate click-through pursuant to which each user agrees to the terms of this section. 

5.              Types of Data We Collect.  “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.  “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons.  We collect Personal Data and Anonymous Data, as described below .

(a)             Information You Provide to Us.  

  •  We may collect Personal Data from you, such as your first and last name, e-mail, phone number, and password if you choose to create an account to log in to our network (“Account”).
  •  If you use our Services on your mobile device, including through our Application(s), we may collect your phone number and the advertiser id number, and detailed location and route information in the form of GPS signals and other information sent by your mobile device to create a detailed location history of all of the routes you have taken while using the Application.
  • Our Site lets you store preferences like how your content is displayed, your location, favorite destinations you travel to such as “home” and “work,” safe search settings, and favorite widgets.  We may associate these choices with your ID, browser or the mobile device, and you can edit these preferences at any time.
  • Our Site collects and analyzes video and driving sensor recordings to provide an enriched presentation to you.
  • When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
  • Certain Services, such as two-factor authentication, may require our collection of your phone number.  We may associate that phone number to your mobile device identification information.
  • When you order services on our Site, we will collect all information necessary to complete the transaction, including your name, credit card information, billing information and shipping information.
  • If you are interested in joining our team and indicate your interest through our website, we will collect the role you are interested in, your email address, first and last name and any other information you choose to provide to us.
  • If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply. 
  • We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Services.
  • We may also collect Personal Data at other points in our Site that state that Personal Data is being collected.

(b)            Information Collected via Technology.

  • Information Collected by Our Servers.  To make our Site and Services more useful to you, our servers (which may be hosted by a third-party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. 
  • Log Files.  As is true of most websites, we gather certain information automatically and store it in log files.  This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data.  We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs.  For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.  Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.
  •  Cookies.  Like many online services, we use cookies to collect information.  “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website.  We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site.  This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs. 
  • Collection of Data by Advertisers.  We may also use third parties to serve ads on the Site.  Certain third parties may automatically collect information about your visits to this and other websites, your IP address, your ISP, the browser you use to visit our Site (but not your name, address, e-mail address or telephone number).  They do this by using Cookies, Pixel Tags, or other technologies.  Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Site and the other sites tracked by these third parties.  This policy does not apply to, and we are not responsible for, Cookies or Pixel Tags in third-party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of Cookies and other technologies .  You may opt out of receiving interest-based advertising from some of our partners by visiting http://optout.networkadvertising.org.  If you would like more information about this practice and to know your choices about not having this information used by these companies, click here: http://www.aboutads.info/choices or http://www.networkadvertising.org.
  •  Mobile Services.  We may also collect non-personal information from your mobile device if you have downloaded our Application(s).  This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the Application(s), and information about the type of device you use.   In addition, in the event our Application(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Application(s).  This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.
  •  Analytics Services and Interest-Based Advertising.  In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Site.  This includes third-party analytics services, including but not limited to Google Analytics (“Analytics Services”), that we engage to help analyze how users use the Site, as well as third parties that deliver content or offers.  We may receive reports based on these parties’ use of these tools on an individual or aggregate basis.  We use the information we get from Analytics Services only to improve our Site and Services.  The information generated by the Cookies or other technologies about your use of our Site and Services (the “Analytics Information”) is transmitted to the Analytics Services.  The Analytics Services use Analytics Information to compile reports on user activity.  The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy.  By using our Site and Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.  For a full list of Analytics Services, please contact us at legal@gh.st.  We may also partner with ad companies to support out marketing efforts, including by serving you ads better tailored to your likely interests.  If you don’t want to take advantage of these services, you may be able to opt-out by visiting http://www.aboutads.info/ or http://networkadvertising.org/choices/ , or if you are located in the EU, http://www.youronlinechoices.eu/.

(c)         Information Collected from Third-Party Companies.  We may receive Personal and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Site.  These third-party companies may supply us with Personal Data.  We may add this information to the information we have already collected from you via our Site in order to improve the Services we provide.

(d)            Location Information.  If you have enabled location services on your mobile device, we collect your physical location of your device will be collected in order for Ghost or our providers to provide you with such location-based services.

6.              Use of Your Personal Data

(a)             General Use.  In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better.  We use your Personal Data in the following ways: 

  • provide navigation services;
  • analyze video and sensor recordings for enriched presentation;
  •  facilitate the creation of and secure your Account on our network;
  • identify you as a user in our system;
  • provide improved administration of our Site and Services;
  •  provide the Services you request;
  • improve the quality of experience when you interact with our Site and Services;
  •  send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
  • send you administrative e-mail notifications, such as security or support and maintenance advisories;
  • respond to your inquiries related to employment opportunities or other requests;
  • make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback; and
  • send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Company.

(b)            User Testimonials and Feedback.  We often receive testimonials and comments from users who have had positive experiences with our Services.  We occasionally publish such content.  When we publish this content, we may identify our users by their first and last name and may also indicate their home city.  We obtain the user’s consent prior to posting his or her name along with the testimonial.  We may post user feedback on the Site from time to time.  We will share your feedback with your first name and last initial only.  If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback.  If you make any comments on a blog or forum associated with your Site, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages.  We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.

(c)             Creation of Anonymous Data.  We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you.  We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation.  We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.

7.              Disclosure of Your Personal Data.  We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

(a)      Third Parties Designated by You.  When you use the Services, the Personal Data you provide will be shared with the third parties that you designate to receive such information, including other websites, your friends, relatives and business associates.  Depending on the type of access you grant to such third parties, they may also be permitted to edit the information you have provided to us and to designate others to access and edit such information.  You may change your settings at any time as to who has access to your information by going to your account settings and changing your publishing options.

(b)     Users.  We will share your Personal data with other Users solely for the purpose of providing the Services.  For example, the Company may use your location history to improve its navigation data and the experience of other users.

(c)      Third-Party Service Providers.  We may share your Personal Data with third-party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company.  These third-party service providers are required not to use your Personal Data other than to provide the services requested by Company.

(d)      Affiliates.  We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. 

(e)      Corporate Restructuring.  We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.  In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

(f)          Disclosure to Third-Party Companies.  We may enter into agreements with companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our website (“Third-Party Companies”). A Third-Party Company may want access to Personal Data that we collect from its customers.  As a result, we may disclose your Personal Data to a Third-Party Company; however, we will not disclose your Personal Data to any Third-Party Company for the Third-Party Company’s own direct marketing purposes, unless you have “opted-in” by following the instructions we provide to allow such disclosure.  If you have opted-in to receive e-mail communications from a Third-Party Company and later wish to discontinue receipt of these e-mails, please contact the Third-Party Company directly to update your preferences.  The privacy policies of these Third-Party Companies may apply to the use and disclosure of your Personal Data that we collect and disclose to such Third-Party Companies.  Because we do not control the privacy practices of Third-Party Companies, you should read and understand their privacy policies.

 (g)     Other Disclosures.  Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (c) to protect or defend the rights or property of Company or users of the Site or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

8.          Third-Party Websites.  Our Site may contain links to third-party websites.  When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect Personal Data or Anonymous Data from you.  We have no control over, do not review, and cannot be responsible for, these outside websites or their content.  Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites.  We encourage you to read the privacy policies of every website you visit.  The links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

9.              Your Choices Regarding Information.  You have several choices regarding the use of information on our Service:

(a)             Email Communications.  We will periodically send you free newsletters and e-mails that directly promote the use of our Site or Services.  When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below).  Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.

(b)            Cookies.  If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below.

(c)             De-Linking SNS.  If you decide at any time that you no longer wish to have your SNS account (e.g., Facebook) linked to your Account, then you may de-link the SNS account in the “preferences” section in your account settings.  You may also manage the sharing of certain Personal Data with us when you connect with us through an SNS, such as through Facebook Connect.  Please refer to the privacy settings of the SNS to determine how you may adjust our permissions and manage the interactivity between the Services and your social media account or mobile device.

(d)            Changing or Deleting Your Personal Data   All users may review, update, correct or delete the Personal Data in their user account (including any imported contacts) by contacting us or editing their profile via the Services.  If you completely delete all of your Personal Data, then your user account may become deactivated and the deletion of your Personal Data disassociates you from any retained data.  We will maintain any source data, such as video and sensor data and derived data in an anonymized fashion. We may retain an archived copy of your records as required by law or for legitimate business purposes.    

(e)            Applications.  You can stop all collection of information by the Application(s) by uninstalling the Application(s).  You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

10.           Changes to This Privacy Policy .  This Privacy Policy may be updated from time to time for any reason.  We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here https://gh.st/privacystatement and we will change the “Last Updated” date above.  You should consult this Privacy Policy regularly for any changes.