Privacy Policy

Last updated: January 8, 2026

This Privacy Policy for Toughbyte Ltd (2704194-5), doing business as Ghostlyn ("we," "us," or "our"), describes how and why we might access, collect, store, use and share ("process") your personal information when you use our services ("Services"), including when you:

  • Use Ghostlyn, a Slack bot for LinkedIn content creation
  • Visit our website at ghostlyn.com or any website of ours that links to this Privacy Policy
  • Engage with us in other related ways, including sales, marketing or events

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@toughbyte.com.

Summary of key points

This summary provides key points from our Privacy Policy, but you can find out more details about any of these topics below.

What personal information do we process? When you visit, use or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We collect limited information from Slack when you install and use Ghostlyn.

How do we process your information? We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by emailing privacy@toughbyte.com, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Policy in full.

1. What information do we collect?

Personal information you disclose to us

We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following:

  • Names
  • Email addresses
  • Professional role and job titles
  • Target audience descriptions
  • Content goals
  • Organization names and descriptions
  • Topics and content ideas you create
  • Draft posts and messages you generate

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information collected from Slack

When you install Ghostlyn in your Slack workspace, we collect:

  • Slack workspace ID and name
  • Your Slack user ID
  • Your email address (for account identification)
  • Messages you send to Ghostlyn in direct messages

We only access Slack data necessary to provide the service.

Information automatically collected

Some information is collected automatically when you use our Services.

We automatically collect certain information when you use the Services. This information does not reveal your specific identity but may include:

  • Usage data (commands used, features accessed)
  • Technical data (timestamps, error logs)
  • Performance and diagnostic information

This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

2. How do we process your information?

We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  • To respond to user inquiries and offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies and other similar information.
  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your information?

We only process your personal information when we believe it is necessary and we have a valid legal reason (that is, legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (that is, consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described to: analyze how our Services are used so we can improve them to engage and retain users, diagnose problems and prevent fraudulent activities, understand how our users use our products and services so we can improve user experience.
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the "data controller" under European data protection laws of the personal information described in this Privacy Policy, since we determine the means and purposes of the data processing we perform.

If you are located in Canada, this section applies to you

We may process your information if you have given us specific permission (that is, express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (that is, implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process or settle an insurance claim
  • For identifying injured, ill or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic or literary purposes
  • If the information is publicly available and is specified by the regulations

4. When and with whom do we share your personal information?

We may share information in specific situations described in this section and with the following categories of third parties.

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

  • Cloud Computing Services
  • Data Storage Service Providers
  • AI Service Providers (OpenAI)

We also may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

5. Do we offer artificial intelligence-based products?

We offer products, features or tools powered by artificial intelligence, machine learning or similar technologies.

As part of our Services, we offer products, features or tools powered by artificial intelligence, machine learning or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Policy govern your use of the AI Products within our Services.

Use of AI technologies

We provide the AI Products through third-party service providers ("AI Service Providers"), including OpenAI. As outlined in this Privacy Policy, your input, output and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in "What legal bases do we rely on to process your information?" You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI products

Our AI Products are designed for the following functions:

  • Content generation and suggestions
  • Topic analysis and rating
  • Natural language processing
  • Text drafting and refinement

How we process your data using AI

All personal information processed using our AI Products is handled in line with our Privacy Policy and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

OpenAI processes data according to their privacy policy and business terms. OpenAI does not use your data to train their models.

6. Is your information transferred internationally?

We may transfer, store and process your information in countries other than your own.

Our servers are located in the United States, hosted by Hetzner, a German company. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored by and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see "When and with whom do we share your personal information?" above).

If you are a resident in the European Economic Area (EEA), United Kingdom (UK) or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

7. How long do we keep your information?

We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

Specifically:

  • Profile information: retained while account is active
  • Topics and drafts: retained until you delete them or request account deletion
  • Usage logs: retained for 90 days for service improvement and debugging

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

When you request deletion, we will delete your data within 30 days. Some data may be retained longer if required by law or for legitimate business purposes (such as resolving disputes or enforcing agreements).

8. How do we keep your information safe?

We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process, including:

  • Encryption of data in transit using TLS
  • Secure database access controls
  • Regular security updates and monitoring
  • Limited access to personal data by our team

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. Do we collect information from minors?

We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@toughbyte.com.

10. What are your privacy rights?

Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change or terminate your account at any time, depending on your country, province or state of residence.

In some regions (like the EEA, UK, Switzerland and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the details below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express or implied consent depending on the applicable law, you have the right to withdraw your consent at any time by contacting us using the details below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Contact us using the contact information provided
  • Send a message to Ghostlyn in Slack requesting changes

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at privacy@toughbyte.com.

11. Controls for do-not-track features

We do not currently respond to Do-Not-Track (DNT) browser signals as no uniform standard exists. If a standard is adopted that we must follow, we will update this policy.

12. Do United States residents have specific privacy rights?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of personal information we collect

We have collected the following categories of personal information in the past 12 months:

A. Identifiers Contact details, such as real name, email address and account name. YES

B. Personal information as defined in the California Customer Records statute Name, contact information, education, employment, employment history. YES

C. Protected classification characteristics under state or federal law Gender, age, date of birth, race and ethnicity, national origin, marital status and other demographic data. NO

D. Commercial information Transaction information, purchase history, financial details and payment information. NO

E. Biometric information Fingerprints and voiceprints. NO

F. Internet or other similar network activity Browsing history, search history, online behavior, interest data and interactions with our Services. YES

G. Geolocation data Device location. NO

H. Audio, electronic, sensory or similar information Images and audio, video or call recordings created in connection with our business activities. NO

I. Professional or employment-related information Business contact details to provide you our Services at a business level or job title. YES

J. Education Information Student records and directory information. NO

K. Inferences drawn from collected personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics. NO

L. Sensitive personal Information NO

We will use and retain the collected personal information as needed to provide the Services or for:

  • Categories A, B, F and I - As long as the user has an account with us

Your rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

  • Right to know whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request the deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to non-discrimination for exercising your rights
  • Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

  • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)
  • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon's privacy law)
  • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California's privacy law)
  • Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida's privacy law)

How to exercise your rights

To exercise these rights, you can contact us by emailing us at privacy@toughbyte.com, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@toughbyte.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please contact us using the details below.

13. Do we make updates to this policy?

Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

14. How can you contact us about this policy?

If you have questions or comments about this policy, you may contact our Data Protection Officer by email at privacy@toughbyte.com, or by post at:

Toughbyte Ltd
Lapinlahdenkatu 16
00180 Helsinki
Finland

For residents in the European Economic Area or Switzerland: we are the "data controller" of your personal information.

15. How can you review, update or delete the data we collect from you?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update or delete your personal information, please email: privacy@toughbyte.com.