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.
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)
