GHOSTERY PRIVACY POLICY

IN ESSENCE: GHOSTERY NEVER COLLECTS PERSONAL INFORMATION.

Please find below our statement on the processing of personal data by our company in accordance with the legal requirements,
particularly the EU General Data Protection Regulation (GDPR - available here [https://gdpr.eu/]).


CONTENT

* A. General information

* I. Definition of main terms
* II. Scope of validity
* III. Controller
* IV. Data protection officer
* V. General information about the data processing operations
* VI. Accessing our services

* B. Details of data processing within Ghostery Browser Extensions

* I. Telemetry
* II. Customer Messaging Platform
* III. Block list updates
* IV. WhoTracks.Me
* V. Phishing and Malware protection
* VI. User Account Session refresh
* VII. Country detection
* VIII. Setting Synchronisation
* IX. A/B tests

* C. Rights of data subjects

* I. Right to object
* II. Right of access
* III. Right to rectification
* IV. Right to erasure (“right to be forgotten”)
* V. Right to restriction of processing
* VI. Right to data portability
* VII. Right to withdraw consent
* VIII. Right to object

* D. California


A. GENERAL INFORMATION

This section of the data privacy statement contains information on the scope of validity, the person responsible for data
processing (controller), the data protection officer and data security. It also begins with a list of definitions of important
terms used in the data privacy statement.


I. DEFINITION OF MAIN TERMS

Browser: Computer program used to display websites (e.g. Chrome, Firefox, Safari)

Cookies: Text files placed on the user’s computer by the web server by means of the browser which is used. The stored cookie
information may contain both an identifier (cookie ID) for recognition purposes and content data, such as login status or
information about websites visited. The browser sends the cookie information back to the web server with each new request upon
subsequent repeat visits to these sites. Most browsers accept cookies automatically. Cookies can be managed using the browser
functions (usually under “Options” or “Settings”). The storage of cookies may be disabled in this way or it may be made dependent
on the user’s approval in any given case or otherwise restricted. Cookies may also be deleted at any time.

Third countries: Countries outside of the European Union (EU)

GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons
with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General
Data Protection Regulation), available here [https://gdpr.eu/].

Personal data: Any information relating to an identified or identifiable natural person. An identifiable natural person is one who
can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number,
location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person.

Services: Our offers to which this data privacy statement applies (cf. Scope of validity).

Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by
automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval,
consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction,
erasure or destruction.

II. SCOPE OF VALIDITY

This data privacy statement applies to the following services:

* Ghostery Tracker & Ad Blocker extension available for Firefox at addons.mozilla.org

All of these offers are also collectively referred to as “services”.


III. CONTROLLER

The following party is responsible for the processing of data in relation to the services, i.e. the role of controller which
involves determining the purposes and means of processing personal data:

Ghostery GmbH
Arabellastraße 23
81925 München, Germany
Email: info@ghostery.com



IV. DATA PROTECTION OFFICER

The contact details of our data protection officer are given in III. Controller. Messages should be marked for the attention of
the data privacy department or sent to privacy@ghostery.com [privacy@ghostery.com].


V. GENERAL INFORMATION ABOUT THE DATA PROCESSING OPERATIONS

The following applies to all the processing operations listed below, unless stated otherwise:

A) NO OBLIGATION TO PROVIDE PERSONAL DATA & CONSEQUENCES OF FAILURE TO PROVIDE SUCH DATA

The provision of personal data is not required by law or contract, and you are under no obligation to provide any data. We will
inform you during the data entry process when personal information must be provided for the relevant service (e.g. by indicating
“mandatory field”). In cases where the provision of data is required, the consequence of not providing data will be that the
service in question cannot be provided. Otherwise, failure to provide data may result in our inability to provide our services in
the same form and quality.

B) CONSENT

In various cases, you may also grant us your consent to the further processing of data (or some of the data, where applicable) in
connection with the operations listed below. In this case, we will inform you separately in connection with the submission of the
respective declaration of consent about all the procedures and the scope of the consent and concerning the purposes which we
pursue in these processing operations. The processing operations based on your consent are therefore not listed again here (Art.
13 (4) GDPR).

C) TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

When we send data to third countries, i.e. countries outside of the European Union, the data are then transmitted strictly in
compliance with the statutory conditions of admissibility. If the transmission of the data to a third country does not serve the
purpose of fulfilling our contract with you, if we do not have your consent, if the transmission is not required for asserting,
exercising or defending legal claims, and if no other exemption applies under Art. 49 GDPR, we will only transmit your data to a
third country if in possession of an adequacy decision pursuant to Art. 45 GDPR or appropriate guarantees under Art. 46 GDPR. In
order to ensure an adequate level of data protection, we provide appropriate safeguards pursuant to Art. 46 (2) c) GDPR by the
conclusion of EU standard data protection clauses adopted by the European Commission with the receiving body. Copies of the
standard EU data protection clauses are available on the website of the European Commission here.

D) HOSTING AT EXTERNAL SERVICE PROVIDERS

Our data processing work is carried out to a large extent with the involvement of hosting service providers who provide us with
storage space and processing capacities at their data centres and who also process personal data on our behalf according to our
instructions. It may be the case that personal data are transmitted to hosting service providers in respect of all of the
functions listed below. These service providers process data either exclusively in the EU or subject to guaranteed levels of data
protection which we have put in place based on the standard EU data protection clauses (cf. subsection c).

E) TRANSMISSION TO GOVERNMENT AUTHORITIES

In principle, we do not transmit any data to government authorities. We only send personal information to government authorities
(including law enforcement agencies) when required to fulfil a legal obligation to which we are subject (legal basis: Art. 6 (1)
c) GDPR) or when it is necessary for the assertion, exercise or defence of legal claims (legal basis: Art. 6 (1) f) GDPR).

F) PERIOD OF STORAGE

The time specified in the “period of storage” paragraph indicates how long we use the data for the relevant purposes in any given
case. At the end of this period, the data will no longer be processed by us but will be erased at regular intervals, unless
continued processing and storage are required by law (mainly because it is necessary to fulfil a legal obligation or for the
establishment, exercise or defence of legal claims) or unless you grant us extended consent.

G) DATA CATEGORIES

The category names listed below are used for specific types of data in the following sections:

* Account data: Login/user ID and password
* Personal master data: Forename, surname
* Contact data: Email address(es)
* Login data: Times and technical information on login, authentication and logout; data entered by you when logging on
* Purchase order data: Products ordered, prices, payment
* Payment data: Account information, credit card details, data for other payment services like Stripe, Street, house number,
additional address lines (where applicable), postcode, city, country are solely used in connection to payments
* Newsletter and transactional email user profile data: Opening of newsletter/email (date and time), contents, selected links, as
well as the following information relating to the computer system accessing the newsletter: Internet Protocol address used (IP
address), browser type, browser version, device type, operating system and similar technical information.
* Access data: Date and time of visit to our services; the page from which the system accessed our site (“referrer”) as well as
the following information relating to the computer system accessing the service: Internet Protocol address used (IP address),
browser type, browser version, device type, operating system and similar technical information. It may include other data
categories like Login data, and Visitor behavioural data if they are present (cookies).


VI. ACCESSING OUR SERVICES

The passages below set out how your personal data are processed when you access our services (e.g., loading and viewing the
website, opening the mobile app and navigating within the app). We would point out that it is impossible not to send access data
to external content providers (cf. subsection b) due to the technical processes involved in transmitting information over the
Internet. The third-party providers are themselves responsible for the privacy-compliant operation of the IT systems which they
use. The service providers are required to decide how long the data will be stored.

A) PURPOSES OF DATA PROCESSING, LEGAL BASIS, LEGITIMATE INTERESTS (WHERE APPLICABLE), AND PERIOD OF STORAGE

* Data category:

Access data

* Purpose:

Establishing connection; presenting contents of the service; detecting attacks on our site due to unusual activities; fault
diagnosis

* Legal basis:

Art. 6 (1) f) GDPR Our legitimate interest: Proper functioning of the services; security of data and business processes;
prevention of misuse; prevention of damage through interference in information systems

* Period of storage:

Four weeks

B) RECIPIENTS OF THE PERSONAL DATA

* Recipient category:

External content providers who provide content which is needed to display the service (e.g. images, videos, embedded postings
from social networks, banner ads, fonts, update information, shortened links) as well as IT Security Service Provider

* Data concerned:

Access data

* Legal Basis:

Art. 6 (1) f) GDPR Our legitimate interest: Proper functioning of the services; (accelerated) display of content; Prevention of
attacks through exploitation of security gaps/vulnerabilities

B. DETAILS OF DATA PROCESSING WITHIN GHOSTERY BROWSER EXTENSIONS

A fundamental piece of technology that started Ghostery, the Browser Extension drives our mission to improve web privacy. It’s a
powerful add-on that gives users the choice to block ads and trackers, and to improve the browsing experience by hiding annoyances
such as cookie notices and distracting banners or popups. Ghostery can either notify users about trackers it finds or silently
block them in the background, so you don’t have to worry about them.

By design, the Ghostery Browser Extension ensures that all data it processes has strictly non-personal character. Because tracking
protection and ad blocking requires us to understand the browser network traffic, we detach and discard any personal identifiers
from the shared information that is required to provide the extension features.

Information on the processing of your personal data within the Ghostery Browser Extension for the purposes of Creating a User
Account, Paid-for-services, Support as well as for Submitting a tracker can already be found in section B. of this Privacy Policy.


I. TELEMETRY

To get basic insights on the health and performance of the Ghostery Browser Extension a very simple information snippet about the extension
installation is sent to Ghostery. This information is strictly non-personal, it covers a general overview of the extension
settings, like whenever or not tracking protection or ad blocking are enabled. Furthermore, basic information about the browser
Ghostery runs in is collected as well as the operating system, language and country from which it is being used.

For the purpose of this activity we process Access Data only, as defined in VI. Accessing our services. No other personal data is
ever shared with a third party.

In the event of critical errors, additional crash reports may be generated and shared to help identify and measure the severity of the problem. These crash reports do not include any identifiers. No personal data is ever shared with a third party for the purpose of crash reporting.

II. CUSTOMER MESSAGING PLATFORM

For the purpose of reaching out to certain groups of users, the Customer Messaging Platform distributes marketing messaging to all
Ghostery Browser Extension users. The individual Ghostery Browser Extension sends strictly non-personal information to the
Ghostery Customer Messaging Platform servers. This information is very basic like browser type, extension version or language of
the browser. In this messaging model, Ghostery does not know which exact users get the particular message and is unable to target
individuals.

For the purpose of this activity we process Access Data only, as defined in VI. Accessing our services. No other personal data is
ever shared with a third party.


III. BLOCK LIST UPDATES

Multiple Ghostery Browser Extension features rely on regular data updates for best coverage. E.g. the ad blocker and anti-tracking
features integrated in the Ghostery Browser Extension get daily updates.

For the purpose of this activity we process Access Data only, as defined in VI. Accessing our services. No other personal data is
ever shared with a third party.


IV. WHOTRACKS.ME

Ghostery operates to track the trackers. All users accepting the Ghostery Privacy Policy report information on online tracking and
non-private search engines to whotracks.me [https://www.ghostery.com/ghostery-manifesto#whotracks-me-methodology]. This way
Ghostery creates a feedback loop from the user community observing the behaviour of online trackers and stopping the tracking and
fingerprinting as it happens. The reported information is strictly related to the observed parties and never includes information
about the observer (the user). All communication is encrypted end-to-end. In addition a protocol is used to ensure anonymity on a
network layer, by making every individual message look like as coming from a different browser. No two messages can be linked.

For the purpose of this activity we process Access Data only, as defined in VI. Accessing our services. No personal data is ever
shared with a third party.


V. PHISHING AND MALWARE PROTECTION

One of Ghostery features is Phishing and Malware protection which requires Ghostery Browser Extension to test every visited url
against a large list of potentially harmful domains. As this domain list is extremely large and frequently changed, shipping it
with the extension is not feasible. To be able to provide this type of protection and ensure users’ privacy, the Ghostery Browser
Extension never shares a full url with the Ghostery backend but sends a checksum (technically half of it) only, being sufficient
for checking if the domain is on the block list but insufficient to tell which page it exactly is.

For the purpose of this activity we process Access Data only, as defined in VI. Accessing our services. No other personal data is
ever shared with a third party.


VI. USER ACCOUNT SESSION REFRESH

For providing premium features the Ghostery Browser Extension relies on the ghostery.com [http://ghostery.com] login session. Once
logged in via extension or Ghostery website, the user session will automatically refresh as long as the browser is open. The
session will be destroyed once a user logs out from the website or the Ghostery Browser Extension.

A) PURPOSES OF DATA PROCESSING, LEGAL BASIS, LEGITIMATE INTERESTS (WHERE APPLICABLE), AND PERIOD OF STORAGE

* Data category:

Access data; Account Data

* Purpose:

Insofar as we process personal data in this context, this processing is carried out exclusively for the purpose of user
convenience.

* Legal basis:

Your personal data is processed on the legal basis of Art. 6 (1) sentence 1 lit. f GDPR. Our legitimate interest is to provide
you with the most user-friendly service possible.

* Period of storage:

Your personal data will be deleted as soon as their further processing is no longer necessary for the respective purpose and
legal retention periods do not prevent deletion. This is regularly the case upon the deletion of your account.

B) RECIPIENTS OF THE PERSONAL DATA

* Recipient category:

In the context of a User Account Session refresh, we don’t transmit any personal data to third parties.

* Data concerned:

All data listed under (a) in this section

* Legal Basis:

Art. 28 GDPR


VII. COUNTRY DETECTION

For providing features like country-based ad blocking and reporting telemetry, the Ghostery Browser Extension needs to know the
approximate region from which the browser connects to the internet. Ghostery requires only very basic information on the region,
namely the country. No other detailed information like state or city are ever inferred. To detect it, Ghostery uses two methods:
1. The mapping of IP address to a country; 2. Content Delivery Network’s edge location which is the country of the closest data
center by which the Ghostery Browser Extension is able to reach.

For the purpose of this activity we process Access Data only, as defined in VI. Accessing our services. No other personal data is
ever shared with a third party.


VIII. SETTING SYNCHRONIZATION

Logged in Ghostery premium users have their settings automatically synchronised across all browsers with Ghostery Browser
Extension installed. Those settings are stored on the Ghostery servers. The information about the settings synchronisation is
never logged or processed by Ghostery in other way but to provide the Synchronisation feature.

A) PURPOSES OF DATA PROCESSING, LEGAL BASIS, LEGITIMATE INTERESTS (WHERE APPLICABLE), AND PERIOD OF STORAGE

* Data category:

Access data; Account data

* Purpose:

The processing is carried out for the purpose of synchronizing your settings within the browsers you are using. Processing for
other purposes is excluded.

* Legal basis:

The processing of your personal data is based on the legal basis of Art. 6 (1) sentence 1 lit. f GDPR. Our legitimate interest
is based on the provision of a more user-friendly service.

* Period of storage:

Your personal data will be deleted as soon as their further processing is no longer necessary for the respective purpose and
legal retention periods do not prevent deletion. This is regularly the case upon the deletion of your account.

B) RECIPIENTS OF THE PERSONAL DATA

* Recipient category:

In the context of the setting synchronisation, we don’t transmit any personal data to third parties.

* Data concerned:

All data listed under (a) in this section

* Legal Basis:

Art. 28 GDPR


IX. A/B TESTS

Ghostery’s A/B tests functionality is available to all users and will periodically download a list of active A/B test setups. The
individual Ghostery Browser Extension sends strictly non-personal information to Ghostery A/B test servers. This information is
very basic like browser type, country, extension version or operating system. Ghostery never gets any reports on which exact users
are participating in a specific A/B test and A/B test information is never connected to the Ghostery account. Ghostery users can
opt out of this functionality in Ghostery control panel.

For the purpose of this activity we process Access Data only, as defined in VI. Accessing our services. No other personal data is
ever shared with a third party.


D. RIGHTS OF DATA SUBJECTS


I. RIGHT TO OBJECT

If we process your personal data for direct marketing purposes, you have the right to object at any time to the processing of your
personal data for such marketing with future effect.

You also have the right, at any time with future effect and for reasons pertinent to your particular situation, to object to the
processing of your personal data in accordance with Art. 6 (1) e) or f) GDPR; this also applies to any profiling based on these
provisions. The right to object may be exercised free of charge. In order to be able to process your request faster, please reach
us by emailing us at privacy@ghostery.com [privacy@ghostery.com].


II. RIGHT OF ACCESS

You have the right to obtain confirmation from us as to whether or not personal data concerning you are being processed and, where
that is the case, to access the personal data and the other information listed in Art. 15 GDPR.


III. RIGHT TO RECTIFICATION

You have the right to obtain from us without undue delay the rectification of incorrect personal data concerning you (Art. 16
GDPR). Taking into account the purposes of the processing, you have the right to have incomplete personal data completed,
including by means of providing a supplementary statement.


IV. RIGHT TO ERASURE (“RIGHT TO BE FORGOTTEN”)

You have the right to obtain from us the erasure of personal data concerning you without undue delay if one of the grounds listed
in Art. 17 (1) GDPR is applicable and the processing operations are not required for one of the purposes approved in Art. 17 (3)
GDPR.


V. RIGHT TO RESTRICTION OF PROCESSING

You are entitled to obtain from us the restriction of the processing of your personal data where one of the conditions laid down
in Art. 18 (1) a) to d) GDPR is met.


VI. RIGHT TO DATA PORTABILITY

You have the right, in respect of the personal data which you have given us, to be provided with these data in a structured,
commonly used and machine-readable format and the right to send these data to another controller without any hindrance on our
part, insofar as the requirements set out in Art. 20 (1) GDPR are met. In exercising your right to data portability, you have the
right to have the personal data transmitted directly by us to another controller where technically feasible.


VII. RIGHT TO WITHDRAW CONSENT

If the processing is based on your consent, you have the right to revoke your consent at any time. This will not affect the
legality of the processing operations on the basis of the consent until such time as the revocation takes effect.


VIII. RIGHT TO OBJECT

You have the right to lodge a complaint with the supervisory authority responsible for our company. The supervisory authority
responsible for our company is as follows:

Bayerisches Landesamt für Datenschutzaufsicht
Promenade 18
91522 Ansbach
poststelle@lda.bayern.de



E. CALIFORNIA

For residents of California, please see our Privacy Policy Supplemental Notice – California
[https://www.ghostery.com/privacy/privacy-policy-supplemental-notice-california].