Privacy Policy

Ghost Talent, Inc. (“Ghost,” “we,” “our,” or “us”) values the privacy of individuals who use our websites and any of our other websites, applications, or services that link to this Privacy Policy (collectively, our “Services”). This Privacy Policy explains how we collect, use, process, and disclose personal information from users of our Services. By using our Services, you agree to the collection, use, processing, and disclosure of your personal information as described in this Privacy Policy. Your use of our Services is also subject to our Terms of Service.

Information We Collect

We may collect a variety of personal information from or about you or your devices from various sources, as described below. We collect only the personal information that is necessary and proportionate to allow us to provide you the Services you request.

A. Information You Provide to Us

Brand inquiries. If you contact us about working with Ghost on a brand campaign, we collect the personal information you submit, including your name, email address, phone number, company name, role, and information about your campaign goals.

Creator inquiries. If you contact us about being represented by Ghost or working with Ghost on a campaign, we collect the personal information you submit, including your name, email address, phone number, social handles, content samples, and information about your audience and niche.

Communications. If you contact us directly, we may receive additional personal information about you. For example, if you contact us for a demo, we will receive your name, phone number, and email address. If you participate in a video demo or sales call, we may record that call and we will receive your image and voice. If you subscribe to our marketing communications, we will receive your name, email address, and the topics you have opted into.

Careers. If you apply for a job with us, you may submit your contact information and your resume online. We will collect your contact information and the personal information you choose to provide on your resume, such as your education and employment experience. You may also apply through certain third-party websites. If you do so, we will collect the personal information you make available to us through those websites in connection with your job application.

B. Information We Collect When You Use Our Services

Device Information. We receive information about the device and software you use to access our Services, including internet protocol (IP) address, web browser type, and operating system version.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with them, such as the length of time you spend on a page, objects such as hyperlinks you click on, and the dates and times of your visits.

Location Information. We may infer your general location, for example by using your internet protocol (IP) address.

Information from Cookies and Similar Technologies. We and our third-party partners may collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.

C. Personal Information We Receive from Third Parties

Partners. We may receive personal information about you from third parties such as data or marketing partners and combine it with other personal information we have about you.

D. Payment Processing

When we collect or remit payments in connection with our Services, your payment is processed by a third-party payment processor such as Stripe (“Payment Processor”). This Payment Processor may collect personal information from you, including your name, email address, billing address, and payment information. The use of your personal information by the Payment Processor is governed by its terms and conditions and privacy policy.

How We Use the Personal Information We Collect

We use the personal information we collect:

• To provide, maintain, debug, improve, and enhance our Services;
• To understand and analyze how you use our Services, and develop new products, services, features, and functionality;
• To develop, train, fine-tune, evaluate, and improve our proprietary artificial intelligence and machine-learning models and features (as described in “AI and Machine Learning” below);
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
• To facilitate transactions and payments;
• For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you;
• To find and prevent fraud, and respond to trust and safety issues that may arise;
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• For other purposes for which we provide specific notice at the time the personal information is collected.

AI and Machine Learning

We design, develop, and operate proprietary artificial intelligence and machine-learning features as part of our Services. These features may include, for example, brand-match scoring, content recommendations, AI-assisted drafting of communications, AI agents you can interact with, and analytics that summarize how creators and brands use the Services. To build, train, fine-tune, evaluate, and improve these features, we may use:

• information you provide to us (such as inquiry, application, and onboarding information);
• information about how you use our Services (such as device, usage, and interaction information);
• communications you send to or receive through our Services (subject to the limitations below); and
• aggregated, de-identified, or pseudonymized information derived from any of the above.

Where reasonably feasible, we aggregate or de-identify information before using it for model training. We do not sell or otherwise make your personal information available to third parties for the purpose of training their generalized or foundation models.

If you connect a Gmail or other email account to our Services, our use of the content of your email messages is further limited by the Creator Agreement and by the Google API Services User Data Policy, including the Limited Use requirements. We do not use the content of your email messages to train generalized or third-party artificial intelligence or machine-learning models.

You may have the right to opt out of certain “profiling” or automated decisions that produce legal or similarly significant effects about you, as described in “Your Privacy Rights” below. We do not currently use AI to make decisions that produce legal or similarly significant effects about consumers without meaningful human involvement.

How We Share the Personal Information We Collect

We do not share or otherwise disclose personal information we collect from or about you except as described below or otherwise disclosed to you at the time of the collection.

Vendors and Service Providers. We may share the personal information we receive with vendors and service providers retained in connection with the provision of our Services.

Marketing. We do not rent, sell, or share personal information about you with nonaffiliated companies for their direct marketing purposes unless we have your permission.

Analytics Partners. We may use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources.

As Required by Law and Similar Disclosures. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. We may transfer your personal information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

Consent. We may also disclose your personal information with your permission.

Your Choices

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

SMS. If you opt in to receive text messages from us, our text message marketing program is described in our Messaging Privacy Policy. You can opt out at any time by replying STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to any of our messages.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Website Visitor Identification. When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout. We honor the Global Privacy Control browser signal: when it is present, these technologies are not loaded on our site.

Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy and advertising practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any personal information you disclose to these third parties. We encourage you to read their privacy policies before providing any personal information to them.

Data Retention and Deletion

We retain your personal information for as long as necessary for the purposes described in this Privacy Policy, and this varies depending on data type, the relationship we have with you, and whether the data must be retained to meet tax, insurance, legal, or regulatory requirements.

You may request that we delete your information by writing to us at the mailing address listed in this Privacy Policy. Following a deletion request, we will delete your information except as necessary for safety, security, fraud prevention, dispute resolution, or compliance with legal requirements. We generally delete personal information within 90 days of a deletion request, except where retention is necessary for the reasons above.

Security

We make reasonable efforts to protect your personal information by using physical and electronic safeguards designed to improve the security of the personal information we maintain. However, as no electronic transmission or storage of personal information can be entirely secure, we can make no guarantees as to the security or privacy of your personal information.

International Visitors

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. We may also transfer your personal information from the U.S. to other countries in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to our Services, you consent to such transfer, storage, and processing.

Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no parts of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us by writing to us at the mailing address listed in this Privacy Policy.

Pose a Question

If you have questions about your privacy on the Services or this privacy policy, please write to us at the mailing address listed in this Privacy Policy.

Changes to this Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through our Services, we will attempt to notify you through our Services, by email, or other means.

How to Contact Us

Ghost is responsible for processing your personal information. If you have any questions, comments, or concerns about our processing activities, or wish to exercise any of your rights as a consumer regarding your personal information, please write to us at:

Ghost Talent, Inc.
c/o Cooley LLP
Two California Plaza
350 S. Grand Avenue, Suite 3200
Los Angeles, CA 90071

Your Privacy Rights

Residents of many states, including California, Colorado, Connecticut, Delaware, Florida, Iowa, Indiana, Montana, Oregon, Tennessee, Texas, Virginia, and Utah, may have additional rights, including:

• Right to Know/Access: To confirm whether we process your personal information and to access such information.
• Right to Delete: To request deletion of personal information we collected.
• Right to Correct: To request correction of inaccurate personal information.
• Right to Data Portability: To obtain a copy of your personal information in a portable format.
• Right to Opt-Out: To opt out of the sale of personal information, targeted advertising, and certain profiling.
• Right to Appeal: To appeal our decision if we decline to fulfill your request.

To submit a request, write to us at the mailing address listed in this Privacy Policy.

Additional Disclosures for California Residents

The California Consumer Privacy Act (as amended by the California Privacy Rights Act) requires businesses to disclose whether they sell or share personal information. As a business covered by the CCPA, we do not sell personal information. We may share personal information (in the form of identifiers and internet activity information) with third-party advertisers for purposes of targeting advertisements on non-Ghost websites, applications, and services. We may also allow third parties to collect personal information from our sites or services if those third parties are our authorized service providers who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal information, or if you direct us to disclose your personal information to third parties.

California law requires that we detail the categories of personal information that we disclose for certain “business purposes,” such as to third parties that assist us with providing our Services or marketing our product. We disclose the following categories of personal information for our business purposes:

• Basic account information, including your name;
• Device identifiers;
• Account information;
• Internet activity information;
• Geolocation data; and
• Inferences drawn from any of the above information categories.

California law grants state residents certain rights, including the rights to know and access specific types of personal information, to learn how we process personal information, to request deletion of personal information, to request correction of personal information, to opt out of sharing your personal information for third-party advertising purposes, and not to be denied goods or services for exercising these rights.

If you are a California resident under the age of 18 and have registered for an account with us, you may ask us to remove content or information that you have posted to our website. Please note that your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have been reposted by another user.

For information on how to exercise your rights, please refer to the How to Contact Us section of this privacy policy. If you are an authorized agent wishing to exercise rights on behalf of a California resident, please contact us using the information in the How to Contact Us section above and provide us with a copy of the consumer’s written authorization designating you as their agent.

We may need to verify your identity and place of residence before completing your rights request.

Do Not Sell or Share My Personal Information

To opt out of the sharing of your personal information with our website visitor identification partners, visit https://app.retention.com/optout, or enable the Global Privacy Control signal in your browser, which we honor automatically. To opt out of other sharing described in this section, or to exercise any other right, contact us using the information in the How to Contact Us section above.

California Privacy Rights Reporting

Request Type	Submitted	Fulfilled	Avg Days to Respond	Avg Days to Complete
Requests for access to personal information	0	0	n/a	n/a
Requests to delete personal information	0	0	n/a	n/a
Objections to processing personal information	0	0	n/a	n/a
Requests to correct personal information	0	0	n/a	n/a

These metrics will be reported annually and, where required, made available to consumers in states that mandate disclosure, including residents of California, Colorado, Connecticut, Oregon, and Texas.