Ghost Locomotion Privacy Policy

Last modified: November 11, 2019

Introduction

At Ghost Locomotion Inc. (“Company” or “we”), we are building a self-driving kit that will transform the cars people already own. We are currently in beta and testing our kits with consumers.

We are committed to protecting your privacy. This privacy policy applies to information we or our service providers collect as follows:

  • on our websites, including www.driveghost.com and www.gh.st, and our mobile application,
  • 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, and
  • when you sign up to participate in, and when you actually participate in, our pilot program and use our products in your vehicle (collectively with all of the above, the “Service”).

This privacy policy does not apply to information collected by, and we are not responsible for:

  • Any third parties (other than our service providers who provide services for us).

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 of our Services.

User Consent

By submitting your information to us in one or more of the formats above, you agree to the terms of this privacy policy and you expressly consent to the collection, use and disclosure of your information in accordance with this privacy policy. If you do not agree with our policies and practices, your choice is not to use our Service. In addition, you give us your express written consent to deliver automated text messages and make automated phone calls to you at the phone number provided, even if you are on a do not call list. Consent is not a condition of purchase. Your use of and access to our Service acts as your binding electronic signature.

Changes

This privacy policy may change from time to time. Your continued use of our Service after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. Where required by law, we will obtain your consent to make these changes.

Contacting the Company

If you have any questions, 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 as follows:

Ghost Locomotion
Attention: Legal
900 Villa Street
Mountain View, CA 94041

or via email: legal@gh.st

Users Must Be At Least 18 Years Old

Our Service is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Service. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Service. If we learn we have collected or received personal information from a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at legal@gh.st.

United States Users Only

Our Service is intended for individuals located in the United States and our Services are operated in the United States. If you use the Services from outside of the United States you are not authorized to use the Service. If you continue to use the Services without authorization from outside the United States, then the information collected through the Services will be transferred to, stored, and processed in the United States or other countries in which our service providers and third party partners operate. Your consent to this Privacy Policy or your use of any of the Services or your submission of your information to us, represents your consent to such transfer, storage and processing outside of your country of residence, including the United States, which may have different data protection rules than those of your country of residence.

If we learn or determine that a user of our Services is located outside the United States, we delete such user’s personal information from our systems.

Information We Collect About You

We and our service providers may collect several types of information from and about users of our Service, including the following:

  • name,
  • contact information including e-mail address, telephone number, and physical mailing address,
  • your driving information including your precise geographic location as tracked by your vehicle’s GPS, how you accelerate, decelerate and your speed, your controller area network (CAN) information, certain images taken by our cameras, how many miles the vehicle was driven, video and driving sensor recordings from driving a vehicle with our products, vehicle indicator usage, data about remote services such as remote lock/unlock, odometer readings, electrical system functions and software information, safety and security data, accident data, the use of other car features and functionalities, and additional driver information, including how many drivers use your vehicle, their names and their respective ratios of driving, and other environmental information such as the weather and information about other cars near your vehicle,
  • identification numbers including your driver’s license number, Ghost Locomotion member number, password, vehicle insurance number, vehicle identification number (VIN), and IP address and your location derived from IP address,
  • information necessary to complete a transaction with you, including credit card information, billing information and shipping information,
  • vehicle information, including vehicle year, make and model,
  • installation preferences with respect to our products (e.g., preferred city, date and time you would like the product installed),
  • feedback that you provide about our products through surveys and discussion groups,
  • gender, date of birth, and professional information such as job title,
  • 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 using our Services, such as the date and time you were using the Services, the web pages you visited, the website you came from, information about your interactions with our emails, and other traffic-related data,
  • 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, and
  • aggregated information.

Some of this information is optional, but in some cases if you do not provide the information, then you will not be able to access our Service, in full or in part.

Notwithstanding the foregoing, we do not store any driving information collected by the device (such as precise location, time and date, acceleration, deceleration and speed, CAN information, GPS information, and how many miles driven) in a manner that is readily identifiable to you (or any driver).

How We Collect Your Information

We and our service providers collect your information:

  • directly from you when you provide it to us (for example, when you sign up to participate in our pilot program and test our products, or when you send us an email, or when you complete a survey or questionnaire),
  • automatically through your browser, device or vehicle when you navigate through our website or mobile application or when you drive your vehicle using our products, and
  • through the use of cookies and other tracking technologies (see Cookies and Other Tracking Technologies below).

How We Use Your Information

We and our service providers use information that we collect about you or that you provide to us:

  • to enable you to log in and access our Service,
  • to provide you with responses, information, products, or services that you request from us,
  • to provide you with notices about your account and to send administrative information to you, including to notify you about maintenance being performed on our systems, potential fraud, or changes to our Service or our terms of use or this privacy policy,
  • to conduct research about our business and the self-driving industry,
  • to provide an enriched presentation to you from your video and driving sensor recordings,
  • to improve or modify our existing products and services, including to refine our algorithms to allow for further development of our products, to validate our driving model, to better refine their performance and to engage in lobbying efforts regarding the same, and for training purposes,
  • to analyze and improve the safety and security of our Services,
  • to analyze trends and develop new products and services,
  • 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),
  • to track users’ movements around our Service and to customize your experience on the Services,
  • to gather demographic information about our user base as a whole (for example, some of the information may be collected so that when you visit the Service again, it will recognize you and the information could then be used to provide our Services to you and for analytics purposes),
  • to contact you (for example, via emails, calls and text messages) about information that we believe may be of interest to you, including any communications for marketing purposes related to the Services, to solicit your feedback, and to advise you of safety-related information about your vehicle,
  • 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 public, law or government authorities (including national security and law enforcement requirements) and private parties; (e) to enforce our terms and conditions; (f) to protect our operations and the security of our Services; (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, 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

We may disclose your personal information that we collect or you provide as described in this privacy policy:

  • to our subsidiaries and affiliates,
  • to contractors, service providers, and other third parties we use to support our business, including to: facilitate the creation of accounts; provide you with the Services that we offer you; help us analyze information we collect from products; conduct quality assurance testing; install our products in your vehicle at your request; provide technical support; evaluate the viability of services provided by our service providers; and/or provide other services to the Company,
  • to other users of our Services for the purpose of providing the Services (for example, we may use your anonymized location history to improve navigation data for other users of our Services),
  • to third parties to allow such third parties to market their products or services to you, if permitted by applicable law,
  • 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 public, law or government authorities (including national security and law enforcement requirements) and private parties; (e) to enforce our terms and conditions; (f) to protect our operations and the security of our Services; (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.

We use our best efforts to contractually require all of our service providers not to use your personal information other than to provide the services requested by us.

Cookies and Other Tracking Technologies

The technologies we and our service providers use for data collection may include the following:

  • Cookies.
    • A cookie is a small file placed on the hard drive of your computer. Some cookies help you navigate our Services, including setting a cookie to remember your login details. Cookies also help us better understand the effectiveness of our Services (for example, by tracking the way in which you respond to, select, and interact with our Services). Other cookies collect information about how you use our Services, which highlights areas we can improve, including navigation.
    • If you submit an inquiry through our Service and provide your name and email and similar information, that personal information will not be tied back to you for interest-based advertising purposes across websites and applications. However, third parties may use cookies or other tracking technologies on users of our Service to serve interest-based advertisements to such users when they visit other websites and mobile applications. The collection of information through cookies or other 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.
    • 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.To read about your choices with regard to the Company’s and third parties’ uses of cookies in our Services, please see “Choices and Opting Out.
  • Web Beacons. Pages of our the Services (including emails) may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those 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).

Do not track signals

We do not respond to Do Not Track (DNT) signals at this time. However, we do not track users when they cross from our website to third party websites, and we do not provide targeted advertising to users.

Choices and Opting Out

We have created mechanisms to provide you with the following control over your information:

  • How to opt out of receiving promotional emails from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties' products or services, you can follow the unsubscribe process in the email from us or email us at legal@gh.st. 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.
  • 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 legal@gh.st.
  • 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 legal@gh.st.
  • How to opt out of the collection of data from our products. If you no longer wish us to collect data about you from our products, you may stop using the products or contact us at legal@gh.st. Please note that if you opt out from this collection, it may disable functionality including dashcam functionality, software updates, and interactivity with mobile applications.
  • 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 Services or may have portions of the Services not 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.
    Android: For Android 6.0 and above: you can modify privacy settings in Settings > Applications > App Permissions > Location and tap the on/off toggle switch next to Location for each app which has permission to use your location data. For earlier versions of Android: you can modify privacy settings in Settings > More > Permission and tap the on/off toggle switch next to Location to turn location functions off for your device. Alternatively, you may uninstall the relevant program(s).
    iOS: In iOS you can modify privacy settings in Settings > Privacy. You can select location data from this list to see which apps have asked for permission to use your location data.
  • De-Linking Social Networking Service (SNS). 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 your social media account or mobile device.
  • How to opt out of interest-based advertising by third parties from cookies. Some of our service providers drop cookies when you visit our Service, 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 see the following instructions on utilizing your mobile device operating system’s opt-out settings.
    For iPhone/iOS users: For instructions on how to “Limit Ad Tracking” on the iOS, please visit this link or see the instructions below:
    Go to “Settings” > “Privacy” > “Advertising.”
    Turn on “Limit Ad Tracking.”
    For Android users:For instructions on how to opt out of interest-based ads in the Android OS, please visit this link or see the instructions below:
    Open Google settings on your device (may be an app called Google Settings or an entry in your phone’s Settings menu, depending on your device)
    Tap “Ads”
    Switch on “Opt out of interest-based ads” or “Opt out of Ads Personalization.”
  • How to opt out of cross device targeted advertising by third parties from cookies. 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.

User Rights

You can email us at legal@gh.st 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 your account. 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.

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 of our Service 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 will retain your personal information for the period necessary to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law, or an individual requests deletion in accordance with applicable law.

As described under “United States Users Only” above, when we learn or determine that a user of our Services resides outside the United States, we delete such user’s personal information from our systems.

Security

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 have given you (or where you have chosen) a password for access to certain parts of our Service, 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 to our Website.

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 Locomotion
Attention: Legal
900 Villa Street
Mountain View, CA 94041

or via email: legal@gh.st

Sensitive Information

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 Service or otherwise to us, except where such information is legally required.

Third Parties

Our Service may contain links to third party websites. When you click on a link to any other website or location, you will go to another site, and another entity may collect personal information 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 information 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 are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.