Privacy Policy

Last Updated: 10 January 2026

Ghost AI is committed to protecting your privacy. This Privacy Policy explains how personal data is collected, used, and protected.

Ghost AI is a trading name of Easy Switch Limited, which acts as the data controller where legally required.

This Privacy Policy applies to all Ghost AI services and websites operated by Easy Switch Limited, including Ghost Discounts (ghostdiscounts.co.uk).

1. Personal Data We Collect

a) Personal Information

  • Name

  • Email address

  • Membership or account identifiers

  • Contact details provided voluntarily

b) Biometric Data (Special Category Data)

  • Facial images or facial templates used for identity verification and access control

c) Technical & Usage Data

  • IP address

  • Device and browser information

  • Log and access records

d) Affiliate & Advertising Data

  • Referral and attribution data

  • Discount code usage

  • Non-identifying interaction and performance metrics

2. How We Use Personal Data

We use personal data to:

  • Provide secure access control services

  • Verify identity for authorised venues

  • Operate and improve our platforms

  • Display and measure advertising effectiveness

  • Track affiliate referrals and commissions

  • Comply with legal and regulatory obligations

3. Legal Basis for Processing

We process personal data under the following legal bases:

  • Explicit consent (biometric/facial recognition data)

  • Contractual necessity

  • Legitimate interests (platform security, service improvement)

  • Legal obligations

4. Facial Recognition & Biometric Safeguards

  • Facial data is collected only with explicit consent

  • Used solely for access verification

  • Stored securely with appropriate technical safeguards

  • Never shared with advertisers or used for marketing

  • Deleted when no longer required or upon valid withdrawal of consent

5. Data Sharing

We may share data with trusted third parties, including:

  • Hosting and infrastructure providers

  • Security and analytics providers

  • Participating establishments (limited to access control purposes)

 

We do not sell personal or biometric data.

6. International Transfers

Where data is transferred outside the UK or EEA, appropriate safeguards such as Standard Contractual Clauses are used.

7. Data Retention

  • Biometric data: retained only while access authorisation remains active

  • Account data: retained while the account is active or as legally required

  • Affiliate data: retained for reporting and accounting purposes

8. Your Rights

You have the right to:

  • Access your personal data

  • Request correction or deletion

  • Withdraw consent at any time

  • Restrict or object to processing

  • Lodge a complaint with the ICO

          privacy@ghost-ai.co.uk

9. Changes

We may update this Privacy Policy from time to time.

If you have any questions about this policy, please contact us at
privacy@ghost-ai.co.uk