Does Ghost need to be disclosed in my privacy policy?

Yes. Ghost collects personal data on your behalf, making Ghost Foundation a data processor under GDPR and CCPA. You must disclose Ghost's data collection practices, specify what data Ghost processes, and explain that subscriber emails are retained by Ghost. Failure to disclose Ghost violates privacy regulations and breaks user trust.

What specific data does Ghost collect?

Ghost collects subscriber email addresses when users sign up for newsletters or membership. Ghost also collects page view data, including which articles or content users access. This data helps track audience engagement and segment subscribers. Email addresses are the primary personal data point requiring privacy protection.

Does Ghost require a cookie consent banner on my site?

No. Ghost does not use cookies for tracking or analytics according to documentation, so a cookie consent banner is not required for Ghost's core functionality. However, if your site uses additional analytics tools alongside Ghost, those tools may require separate consent management.

Who processes Ghost data and where is it stored?

Ghost Foundation, located in Singapore, acts as your data processor. Subscriber emails and page view data are transferred to and processed on Ghost Foundation's servers in Singapore. You must ensure a valid legal mechanism (such as Standard Contractual Clauses) exists to legitimize data transfers from your location to Singapore.

CMS

Privacy policy clauses for Ghost

Ghost is a modern content management system and publishing platform designed for blogs and newsletters. Websites use Ghost to create, manage, and distribute content to subscribers while collecting reader engagement data and email addresses for audience building.

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What data Ghost collects

Your privacy policy must disclose each of the following data types when you use Ghost.

Subscriber emails

Page views

When does Ghost trigger privacy obligations?

Installation triggers immediate obligations

The moment Ghost processes subscriber emails and page views on your site, you become a data controller under GDPR Article 4(7) (if you have EU visitors) and CCPA Section 1798.100 (if you have California residents). Ghost Foundation (Singapore) acts as your processor.

Specific data flows that activate compliance

Subscriber emails: Collection of email addresses for newsletter distribution is personal data processing. This triggers GDPR Articles 13–14 (transparency obligations—you must provide privacy notices *before* collection) and CCPA Section 1798.100(b) (notice at collection requirement). You cannot simply rely on Ghost's privacy policy; you must disclose Ghost's involvement and data flow in *your* policy.

Page views: Analytics data tied to identifiers (IP addresses, cookies, or device IDs) is personal data. Ghost's documented lack of cookies may reduce complexity, but you still track visitor behavior.

First concrete step

Before launching Ghost:

1. Execute a Data Processing Addendum (DPA)

Common compliance pitfalls

Pitfall 1: Missing or incomplete Data Processing Addendum (DPA)

Many indie founders assume Ghost's standard terms satisfy GDPR Article 28 requirements. They do not. Ghost Foundation must contractually commit to: processing data only on your instructions, ensuring processor security, assisting with data subject access requests (DSAR), and providing breach notification. Without a signed DPA, you remain jointly liable for compliance failures. Ghost may not have a standard DPA template ready for small operators—you must request one before go-live or use a GDPR-compliant processor agreement template and have Ghost countersign. Consequence: GDPR fines up to €10 million or 2% of annual turnover, plus regulatory investigation costs.

Pitfall 2: Conflating Ghost's privacy policy with your own

Operators often link to Ghost Foundation's privacy policy and assume that covers disclosure. It does not. Your *own* site's privacy policy must explicitly state: "We use Ghost (operated by Ghost Foundation, Singapore) to collect and process your email address and page-view data." Regulators expect *you* to name your processors and explain the data flow to users visiting *your* site. Ghost's policy explains Ghost's obligations; yours explains *your* processing. Both are required. Consequence: GDPR non-compliance with Articles 13–14 (transparency); CCPA violation of Section 1798.100(b). DPAs will flag missing processor disclosures as a primary audit finding.

Pitfall 3: No lawful basis documented for page-view tracking

Ghost's page-view analytics are often enabled by default with no consent mechanism. Under GDPR, every processing activity needs a lawful basis (Article 6). Many operators assume "legitimate interest" (Article 6(1)(f)) covers analytics without documenting: (i) the interest (e.g., understanding subscriber engagement), (ii) necessity, (iii) balancing test against user privacy. Without this, you have no documented lawful basis. CCPA requires notice but not consent for analytics; however, GDPR requires *documented* lawful basis. Consequence: GDPR enforcement action for unlawful processing; obligation to delete page-view data retroactively.

Privacy policy clauses for Ghost

What data Ghost collects

When does Ghost trigger privacy obligations?

Installation triggers immediate obligations

Specific data flows that activate compliance

First concrete step

Where data goes

Common compliance pitfalls

Pitfall 1: Missing or incomplete Data Processing Addendum (DPA)

Pitfall 2: Conflating Ghost's privacy policy with your own

Pitfall 3: No lawful basis documented for page-view tracking

Sample privacy policy clause

What regulators look for

Primary audit focus: Processor accountability and transparency

Enforcement priority: Consent for email collection

Secondary focus: International data transfer

Frequently asked questions

Does Ghost need to be disclosed in my privacy policy?

What specific data does Ghost collect?

Does Ghost require a cookie consent banner on my site?

Who processes Ghost data and where is it stored?

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