Last modified: Nov 18 2020
Ghost Writers takes its users’ privacy very seriously and will process and use your personal data in a safe and secure manner. When you make use of Ghost Writers, you naturally want us to handle your personal data with care and ensure that your data does not end up with other companies. In this document we explain in full which personal data we collect and how we deal with it with due care. Put briefly, we use your personal data to be able to offer you Study Material, to inform you about our service and to be able to make personal offers. If you have any questions regarding your personal data, please contact us via [email protected].
Privacy Statement Navigation:
1. Who is Ghost Writers?
Ghost Writers is brand for the platform under the same name owned and managed by the private company Zirks Services Limited, having its registered offices at 27 Old Gloucester Street, London, WC1N 3AX, in the United Kingdom
2. What data does Ghost Writers collect and process?
Ghost Writers Profile
If you want to upload or download Study Material through the Platform, you are required to create a Profile. When you are creating a Profile, you will be asked to disclose certain data about yourself. You are not obliged to disclose all data, but the following data is required:
a valid email address, username and password, your name and paypal email address, to enable us to pay you for your Study Material.
a valid email address, institute/school and studies.
You can also choose to log in using your Facebook profile. You will have to allow Ghost Writers one-time only access to a limited number of data from your Facebook profile, namely, your email address, first and last name, and your gender. You may amend the data you have disclosed in the Profile at all times.
The personal data you disclose when creating the Ghost Writers Profile and the personal data you subsequently add to your Profile or disclose through other features will also be used to provide you with personal offers. For more information, please refer to the “Personal Offers” section.
As well as the purposes discussed in this Privacy Statement, our main purpose for using the disclosed personal data is to create your Ghost Writers Profile and to provide you with the corresponding features. This use of your personal data is required to perform an agreement to which you are a party, which agreement pertains to your use of the services Ghost Writers offers to you through the Platform.
Furthermore, Ghost Writers would like to keep you updated on the development of its Platform. If there is an upcoming extension or an update or other amendment concerning the Platform, Ghost Writers will let you know. The same applies to information regarding payments or amounts due. It is not possible to opt out of such notifications.
On the Platform, you grant Ghost Writers the right to disclose the personal data (such as your username and profile picture) and Study Material you have submitted, as well as to reproduce such data and Material, in the context of providing the Platform. Among other things, this means that Ghost Writers may use certain personal data you have disclosed to promote the Platform, for example by indicating who the most successful user is, which Study Material is being downloaded most often or which Study Material or Users are new to the Platform. Your personal data will only be used in this context if you have given your consent for it. If you no longer want your personal data to be used for this purpose, you can withdraw your consent by sending a message to [email protected].
Automatically Generated Information
Ghost Writers collects Automatically Generated Information on all Users. This information comprises your browsing behaviour on the Platform, such as the pages you visit, the amount of time you spend on a specific page, the items you download and/or upload and how you use your Profile. Furthermore, Ghost Writers collects your IP address, your browser type (computer program used to visit webpages) and cookies. Among other things, Ghost Writers uses this information to adjust the services to fit your needs as much as possible and to solve technical and security issues. This processing of your personal data is required for the purposes of Ghost Writers’s legitimate interests, namely, Ghost Writers’s interest in securing its Platform and being able to offer it in the most user-friendly way possible. If the Automatically Generated Information is collected using cookies, Section 3 (cookies) will also apply.
Ghost Writers may keep you posted about special offers it organises by means of its newsletter. The newsletter is sent on a regular basis. If you have subscribed to the newsletter, Ghost Writers will use the email address you have submitted to send the newsletter. Ghost Writers may also use your name and/or gender to personalise the newsletter. If you no longer wish to receive the newsletter, you can opt out by unticking ‘Newsletter’ in your Profile. Also, each separate newsletter contains the option to opt out. If you do decide to opt out, Ghost Writers advises you to keep an eye on the Platform to see whether there are any new special offers.
Ghost Writers processes your email address for direct-marketing purposes based on its legitimate interest in order to be able to send you the newsletter.
Based on the personal data Ghost Writers collects, Ghost Writers may make personalised offers to you by means of emails or by drawing your attention to the personal offer in the Portal.
To do this, we use:
- the products you buy and the amounts you spend;
- your browsing behaviour on the website; and
- data we collect using cookies.
Your personal data will only be used in this way if you have given your consent for it. If you no longer want your personal data to be used for this purpose, you can withdraw your consent by sending a message to [email protected] or by changing your email settings in your Profile.
Ghost Writers strives to provide you with a Platform of the highest quality. This requires Ghost Writers to carry out statistical surveys so that it can adjust the Platform where necessary.
For such statistical surveys, Ghost Writers may use your personal data, among other things by using cookies. Ghost Writers does this based on its legitimate interest in the statistical surveys, namely, to improve the quality of its services. The results of the surveys are always aggregated. This means that the data contained in the results cannot be traced back to you personally.
3. What are cookies and how does Ghost Writers use them?
Ghost Writers uses functional cookies. These cookies are necessary to provide you with the services and features you have requested. For example, functional cookies enable you to log in to the Platform just once and ensure that you are not asked to log in again on every page you visit. It is not possible to disable functional cookies.
To collect web statistics on the use of and visits to the Platform, Ghost Writers uses Google Analytics. Google Analytics installs a persistent cookie on your Device. This cookie records your use of the Platform. That data is then analysed by Google and it subsequently sends the results to Ghost Writers. In this way, Ghost Writers develops an understanding of the manner in which the Platform is used and can then adjust the Platform and/or its services based on that data. Google may disclose this data to third parties if it is statutorily required to do so and/or if third parties process the data on Google’s behalf. Google may not use the data for other services offered by Google.
The Platform provides access to various social media, including but not limited to Facebook, Twitter and Instagram. Using these “social plug-ins”, you can share information with or recommend information on the Platform to other people. When you visit a web page that has the social plug-ins of these social media, third parties will install cookies on your Device. These cookies will collect, among other things, data about your browser and the websites you have visited with your IP address.
The use of the cookies that are installed on the Platform via the social plug-ins is subject to further third-party terms and conditions. Ghost Writers does not assume any responsibility or liability for those third-party terms and conditions. Ghost Writers refers you to the terms and conditions of those parties.
Facebook Website Custom Audiences
Aided by Facebook’s Website Custom Audiences, Ghost Writers may use data from its Platform to show you relevant advertisements on Facebook. Through a pixel that is integrated in Ghost Writers’s website, general data regarding your browser session, including any Facebook cookies and the website you are visiting, is transmitted to Facebook. Based on this data, Facebook users may be placed in specific Custom Audiences and may be shown personalised ads. The data that is collected in this manner is not linked to the data in your Ghost Writers account.
You are at all times entitled to withdraw the consent you have given to Ghost Writers to install and read cookies. To do so, you will need to change your browser settings so that it no longer accepts cookies and/or you will need to disable all the cookies that have already been installed on your browser. In such event, however, you may no longer be able to use or fully use all the features of the Platform or you may be denied access to the Platform or sections of it. For more information on enabling or disabling cookies, go to your browser´s Help menu.
If you have enabled cookies and you are on a publicly accessible computer, Ghost Writers advises you to log out when you leave the computer unattended, in order to maintain the confidentiality of your password and username.
4. Disclosure to third parties
Without your explicit consent, Ghost Writers will not disclose your personal data to third parties for direct-marketing purposes (e.g. to send promotional material).
To provide the Platform, Ghost Writers occasionally uses third parties, for example, for hosting its central database (Amazon). Ghost Writers has entered into agreements with those third parties, which agreements contain arrangements regarding the technical and organisational measures those third parties must implement to protect your personal data.
Furthermore, Ghost Writers finds it important that your personal data is stored within the European Economic Area (hereinafter: the “EEA”) as much as possible. For the Google Analytics services, personal data is transferred to and stored by Google on servers in the United States. The same applies to Amazon for the hosting activities it performs for Ghost Writers. Ghost Writers ensures that these services comply with the law.
Ghost Writers may disclose your personal data to third parties if you have given your consent for it to do so. Ghost Writers may also disclose your personal data to third parties, in so far as the data cannot be traced back to you personally (such as Automatically Generated Information, excluding the IP address) and therefore does not constitute personal data.
Finally, Ghost Writers may disclose your personal data to third parties if it is statutorily required to do so, if it is required to do so as a result of legal proceedings, and/or if it believes this is necessary to protect its own rights.
The Platform may contain hyperlinks that lead you away from the Platform and take you to third-party websites. Ghost Writers has no control over the third-party websites to which its website is linked. This means that the use of these third-party websites may be governed by different privacy policies. This Privacy Statement relates solely to personal data obtained through the Platform. Ghost Writers does not assume any responsibility or liability for the operation and/or contents of third-party websites.
5. How does Ghost Writers protect personal data?
Ghost Writers has implemented appropriate technical and organisational measures to protect your personal data against loss or any form of unlawful processing.
For example, the Platform is protected in such a way that it cannot be accessed without login codes. Your personal data is protected against unwanted use by means of a username and a password.
Furthermore, communications with the Platform itself are protected as well. This security is evidenced by the inclusion of ‘https’ in the browser’s URL (the web address bar) and the image of a locked padlock at the bottom of the screen. If you double-click on the padlock, you can check whether the connection with the Platform is secure.
6. Retention of data
Ghost Writers will not retain your personal data for longer than is necessary to fulfil the purposes for which the personal data has been collected.
7. Transfer of enterprise
If Ghost Writers further grows and develops, it may be the case that one or more divisions or assets of the business are transferred to a third party or Ghost Writers may merge with a third party. In such event, your personal data may be transferred as well. Naturally, we will inform you if that is going to be the case, and you are at all times entitled to opt out of the service.
8. Your rights
Under privacy laws, you have various rights as a data subject. This section of the Privacy Statement describes the rights you have and how you can invoke them.
We endeavour to respond to your requests as soon as possible and in any event within one month. However, it may be that we need more time. If that is the case, we will inform you about this before the end of the month referred to in the previous sentence. The extra time will not exceed two months.
You may submit your requests to [email protected].
To ensure that the personal data you are requesting is really yours, we ask that you attach a copy of a valid ID. Please render the citizen service number (BSN) on your ID illegible.
There is a chance that we reject your request, for example if your request is unfounded or excessive or if the law does not enable or require us to meet your request. We will also inform you of any rejections. Furthermore, we may ask you to identify yourself before we consider your request.
We would like to point out that, if we reject your request, you are entitled to file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
Right of access
You have the right to submit a request to find out if we are processing personal data concerning you. If that is the case, we will provide you with a copy of the personal data we have collected about you, as per the law.
Right to rectification
You have the right to submit a request for rectification of inaccurate personal data concerning you. If possible, you also have the right to disclose additional personal data in order to complete the personal data we have collected.
Right to be forgotten
You have the right to request erasure of certain personal data concerning you (the right to be forgotten). If your request is granted, we will delete the personal data concerned.
Right to restriction of processing
You have the right to request for restriction of processing of your personal data. This means that if the restriction request is granted, we will not continue to process your personal data for as long as the restriction is in effect, unless we are statutorily allowed to do so.
Right to object
Under certain circumstances, you have the right to object to the processing of your personal data, for example if we process your personal data based on legitimate interests. If you lodge an objection, we will balance your privacy interests against our company interests. If your interests override our interests, we will cease processing your personal data.
If your personal data is used for direct-marketing purposes, you are at all times entitled to object to the processing. In such event, we will cease processing your personal data for those purposes.
Right to data portability
You have the right to request data portability. We will provide the data that falls under this right in a structured, commonly used and machine-readable format to you so that you can transmit it to a third party.
9. Is this Privacy Statement subject to change?
This Privacy Statement is subject to change. Any changes will be communicated through the Platform. The Privacy Statement was last updated on November 18th, 2020.
10. Questions or complaints?
If you have any questions about this Privacy Statement, please send an email to [email protected].
If you have a complaint about the use of your personal data and you are unable to find a solution with Ghost Writers, you can also lodge your complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).