Last modified: May 11, 2020
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.
- 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 user programs and use our products in your vehicle (collectively with all of the above, the “Service”).
- 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.
Contacting the Company
900 Villa Street
Mountain View, CA 94041
or via email: firstname.lastname@example.org
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 email@example.com.
United States Users Only
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:
- 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 user programs 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
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 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
- 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:
- 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.
- 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 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 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 firstname.lastname@example.org. 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.
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).
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)
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.
You can email us at email@example.com 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.
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
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.
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.
900 Villa Street
Mountain View, CA 94041
or via email: firstname.lastname@example.org
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.