- on our websites — including www.ghostautonomy.com, www.driveghost.com and www.gh.st,
- on any mobile applications that we may launch,
- in email, text, and other electronic messages and phone calls between you and the Company or its Service Providers,
- in online surveys and questionnaires about the Company, our business or our industry,
- when you sign up to receive news, announcements and invitations,
- when you apply for a position at the Company,
- if you participate in any demonstration, product evaluation, consumer input or any other type of end-user program we sponsor,
- if you otherwise provide information to us or access our products or software.
- Any third parties (other than our service providers who provide services for us).
(all of the above collectively, the “Services and Programs.”)
“Service Providers” refer to any person or entity other than the Company that collects data in concert with the Company or on behalf of the Company, including in connection with the provision of Services and Programs to or on behalf of the Company; for the avoidance of doubt, these terms do not include persons or entities that collect data on their own behalf and not in connection with activities on behalf of or in concert with the Company.
“Online Applications” refer to websites, mobile apps, and any other online, internet, or software based Services and Programs to access information provided by, or provide information to, the Company or Service Providers through any computing device, including smartphones, tablets, desktop and laptop computers.
Choice and User Rights
See “Choices and Opting Out” for information about opting out of certain data practices and see “User Rights” for information about exercising your rights as a user, recipient or participant in any of the Services and Programs.
In addition, although we may not intend to do so at this time, you give us your express written consent to contact you via text messages at any phone number provided.
Contacting the Company
Ghost Autonomy Inc.
900 Villa Street
Mountain View, CA 94041
or via email: firstname.lastname@example.org
Users and Participants Must Be At Least 18 Years Old
The Services and Programs are not intended for persons under 18 years of age. No one under age 18 is authorized to provide any personal information in connection with the Services and Programs. We do not knowingly collect personal information from persons under 18 years of age.
If you are under 18 years of age, do not use or provide any information in connection with any of the Services and Programs. If we learn we have collected or received personal information from a person under 18 years of age without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18 years of age, please contact us at email@example.com.
Users Outside the United States
Ghost is headquartered in the United States. If you choose to use any of the Services or Programs from outside of the United States, you do so on your own initiative.
Information We Collect About You
We and/or our Service Providers may collect several types of information from and/or about you in connection with your use or participation in the Services and Programs. This may include your name and contact information, including e-mail address, telephone number, and/or physical mailing address.
Should you participate in an end-user demonstration, product evaluation, consumer input or any other type of end-user program we sponsor, we and/or our Service Providers may require information including, but not limited to information regarding your driver’s license (including license number and other personal data reflected on such license), insurance, and/or driving record. Among other things, we may ask you to confirm that you have had a valid driver’s license for at least 3 years with no serious infractions (or as may otherwise be required by applicable law or regulations).
If you are accessing any of our websites or mobile applications, communicating with the Company or any of our Service Providers, providing information to receive updates and product information, or participating in any surveys or questionnaires, we or our Service Providers may collect information, including the following:
- your IP address and your location derived from the IP address,
- information about your settings, including wireless networks and recording preferences,
- information in messages you send to us or in your responses to surveys and questionnaires,
- information about the time spent accessing our online applications or participating in the Services and Programs, such as the date and time you were using or participating in the Services and Programs, which of our web pages you visited, the website you came from, information about your interactions with our emails, and other traffic-related data, and
- information about your device, such as screen dimensions and screen resolution, device brand and model, mobile device identifier, browser type, internet service provider (ISP), and operating system.
If you apply for a career at the Company, we may require a resume, cover letter, information about your education, professional life, skills, qualifications and certifications.
Information collected by us or our Service Providers may be anonymized and/or aggregated. In some cases if you do not provide the information, then, unless prohibited by appliable law, you may not be able to access or participate in our Services and Programs, in full or in part.
How We Collect Your Information
We and our Service Providers collect your information:
- When you send us an email or other communication,
- When you complete a survey or questionnaire,
- When you apply for a career at the Company,
- When you log-in to any online applications for the Services and Programs,
- When you provide information through a website portal or other online application,
- Automatically through your browser or device when you navigate through our website or mobile applications, and
How We Use Your Information
We and our Service Providers use information that we collect about you or that you provide to us:
- to administer the Services and Programs,
- to conduct research about our business and the autonomous vehicle mark et and industry,
- to enable you to log in and access our Services and Programs,
- to provide you with responses, information, products, or services that you request from us,
- to analyze and improve the safety and security of our Services and Programs,
- to analyze trends to inform the development of our autonomous vehicle system and its functionality and features,
- to improve or modify our existing products, Services and Programs, including to refine our algorithms, to engage in lobbying efforts, and for training purposes,
- to verify your identity and to recognize you when you return to our website or mobile application (for example, by storing your log-in cookie), enabling us to track your movement within our websites and to customize your experience with regard to the Services and Programs,
- to contact you (for example, via emails, calls and text messages) about information that we believe may be of interest to you, including any updates on our product and Company developments and/or marketing related communications,
- for employment evaluation and negotiation purposes,
- to fulfill legal obligations we have to governmental authorities or other third parties,
- to bring or defend claims,
- for other legitimate business purposes, and
- in any other way we may describe when you provide the information, or as permitted by applicable law, or with your consent.
Disclosure of Your Information
- to our subsidiaries and affiliates,
- to contractors, service providers, and other third parties we use to support our business, including to third parties to allow such third parties to market their products or services to you, if permitted by applicable law. To opt out of marketing by third parties, see “Choices and Opting Out.”
- to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred, and
- when circumstances require or justify our use, including: (a) a subpoena, warrant, or order issued by a court, person or body with jurisdiction compelling the production of information; (b) we receive a formal request to disclose information in connection with a legal action; (c) we believe that a law, regulation or rule requires us to do so; (d) we receive a request or a requirement from law enforcement or government or regulatory authorities (including national security and law enforcement requirements); (e) to enforce our terms and conditions; (f) to protect our operations and the security of our Services and Programs; (g) to protect our rights, privacy, safety or property, and/or that of you or others; (h) to allow us to pursue available remedies or limit the damages that we may sustain; (i) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity; and (j) the information is needed or helpful to address an emergency that threatens the life, health or security of an identifiable person.
Cookies and Other Tracking Technologies
The Services and Programs capture some information about you automatically utilizing background local storage, session storage technologies, such as cookies and web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs), and device fingerprinting (collectively, “Tracking Technologies”). Tracking Technologies include small files or other pieces of data which are downloaded or stored on your computer or other device, that can be tied to information about your use of the Services and Programs.
- Tracking Technologies help you navigate our online applications, including setting a cookie to remember your login details.
- Tracking Technologies help us better understand the effectiveness of our website structure and operation (for example, by tracking the way in which you respond to, select, and interact with the Services and Programs provided through our online applications).
- Tracking Technologies collect information about how you use our websites, including using or participating in the Services and Programs, which highlights areas we can improve, including navigation.
- Tracking Technologies permit the Company to count users who have visited website pages or opened an email and for other related traffic statistics (for example, recording the popularity of certain content, verifying system and server integrity, and determining the effectiveness of marketing campaigns).
If you submit an inquiry through our online applications and provide your name and email or similar information, that personal information will not be tied back to you for interest-based advertising purposes across websites and online applications. However, third parties may use Tracking Technologies on users and participants of our Services and Programs to serve interest-based advertisements to such users when they visit other websites and mobile applications. The collection of information through Tracking Technologies by such third parties will be governed by such third parties’ own privacy policies and principles, which we do not control. To opt out of interest-based advertising by third parties, see “Choices and Opting Out.”
Do Not Track Signals
We do not respond to Do Not Track (DNT) signals at this time.
Choices and Opting Out
We have created mechanisms to provide you with the following control over your information:
- How to opt out of text messages from the Company. If you do not wish us to send you text messages to your phone, you can follow the unsubscribe process in the text message from us or email us at firstname.lastname@example.org.
- How to opt out of phone calls from the Company. If you do not wish us to call you on your phone, you can tell us verbally when we call you or email us at email@example.com.
- How to opt out of the Company’s cookies. You may disable cookies, including our cookies, by modifying the settings in your browser. However, please note that if you delete or disable cookies, you may not be able to stay logged in to the online applications, or portions of the Services and Programs may not be available to you. Note that if you have opted out of targeted advertising from third parties, deleting your cookies will also delete that opt out. Most opt out mechanisms from targeted advertising are managed by cookies. You will need to re-submit your opt out of targeted advertising with third parties. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
- How to opt out of the use of precise location from your mobile device. To disable the collection of precise location information from your mobile device through mobile applications, you can access your mobile device settings and choose to limit that collection.
- De-Linking Social Networking Service (SNS). In the future, we may associate your information with a Ghost system user account. If you decide at any time that you no longer wish to have your SNS (social networking service) account (e.g., Facebook) linked to your Company account, then you may contact us and ask us to de-link the SNS account. You may also manage the sharing of certain personal information 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 Programs and your social media account or mobile device.
- How to opt out of interest-based advertising by third parties from Tracking Technologies. Some of our Service Providers may create, store or modify Tracking Technologies when you visit our website or participate in our online applications, for example, through certain tracking features on Google Analytics, which may include Remarketing with Google Analytics, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, and integrated services that require Google Analytics to collect data for advertising purposes. These third parties may have opt out mechanisms either directly on their website or on an industry-developed web page. For example, you can opt out of the Google Analytics Advertising features that we employ in our Service, including through Ads Settings, Ad Settings for mobile apps, or any other available means (e.g., the Network Advertising Initiative’s consumer opt out or the Google Analytics Opt-out Browser Add-On). If you go to optout.aboutads.info or www.aboutads.info/choices, you can learn how to exercise choice regarding the collection of information about your online activities over time and across multiple third-party websites, online services, devices, and applications for interest-based advertising purposes. When you opt out of receiving interest-based advertising from third parties, note that the opt out only applies to the applicable browser in which you set it.
- How to opt out of interest-based advertising by third parties in mobile applications. To opt out of third parties’ interest-based advertising that takes place through mobile applications, please utilize your mobile device operating system’s opt-out settings.
- How to opt out of cross device targeted advertising by third parties from Tracking Technologies. Third parties may also combine and use information from websites or applications on your current browser or device with information from your other browsers or devices for advertising purposes. To opt out of such practices, please follow the instructions above for opting out on each of your browsers, and also opt out on each of your mobile devices. Please note that you will need to opt out separately on (1) each of your browsers and (2) each of your mobile devices to ensure that information collected on a particular browser or device is not used on another browser or device.
Grounds for Using Your Personal Data
We rely on the following legal grounds to process your personal information:
Performance of a Contract. We may need to collect and use your personal information to enter into a contract with you and to perform the services that you request.
Compliance with Legal Obligations. We may use your personal information as necessary to comply with our legal obligations.
This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations. You can email us at firstname.lastname@example.org to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We cannot delete all of your personal information except by also deleting any Company account that may be established in the future. You can also stop all collection of information by mobile 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. See also the section above “Choices and Opting Out.” Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
(b) Rights Under GDPR. While we do not specifically market the Service and Programs to those who reside in Europe, we will provide accommodations for the exercise of your rights provided under the General Data Protection Regulation (the “GDPR”). If you are located in the European Union, the United Kingdom or another jurisdiction that has adopted laws substantially similar to GDPR, you are consenting to the transfer of your information from your jurisdiction to the United States.
Data subjects’ rights under GDPR are the following:
- Right of access, objection, restriction of processing, erasure, and portability. You also have the right to withdraw your consent at any time when we process your personal data based on your consent. To exercise these rights, please contact us, as set forth above.
- Right to opt out to direct marketing. You have the right to opt out at any time to receiving marketing materials from us by following the opt out instructions in our commercial emails, by contacting us, or by adjusting your preferences on the Service. Please note that we reserve the right to send you other communications, including service and program announcements and administrative messages relating to your account, without offering you the opportunity to opt out of receiving them.
- Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you. We use Tracking Technologies on our Service to personalize your experience with our online applications.
- Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according to the European Data Protection law, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.
(c) California Users
Because we are still in the early stages of our company, we are not subject to the California Consumer Privacy Act at this time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users and participants of the Services and Programs that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us via one of the methods included under “Contacting the Company” above.
Retention of Information
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we may in the future give you (or where you have chosen) a password for access to certain parts of our online applications, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted over the internet.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of the account you might have with us has been compromised), please immediately notify us of the problem at the contact information below.
Ghost Autonomy Inc.
900 Villa Street
Mountain View, CA 94041
or via email: email@example.com
We ask that you not send us, and you do not disclose, any sensitive personal information (e.g., social security numbers or other government identifiers, other than driver’s license number when required, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal convictions and offenses, trade union membership, or any genetic data, biometric data, or information relating to an individual’s sex life or sexual orientation) on or through the Services and Programs or otherwise to us, except where such information is legally required.