1. Introduction
This policy is intended to comply with the General Data Protection Regulation (GDPR), applicable Belgian data protection laws, and relevant cybersecurity best practices.
2. Who We Are
CyGhost is a cybersecurity and IT services business based in Belgium.
Business name: CyGhost
Enterprise number / VAT: BE1039.531.380
Registered office: Oostende, Belgium
Website: https://cyghost.com
Privacy contact: privacy@cyghost.com
General contact: hello@cyghost.com
For most website, sales, billing and business communication activities, CyGhost acts as a data controller.
When CyGhost processes customer logs, security events, technical data, assessment evidence, endpoint metadata or similar information on behalf of a customer, CyGhost usually acts as a data processor. In that case, the customer remains the data controller and the processing is governed by a contract, statement of work, data processing agreement, or similar written instruction.
3. Scope of This Policy
This Privacy Policy applies to:
- Visitors of our website
- Prospects and customers
- Business contacts
- Suppliers and partners
- Users of CyGhost platforms
- Individuals whose data may appear in customer security logs or technical evidence processed by CyGhost
This policy does not replace a customer agreement, statement of work, data processing agreement, non-disclosure agreement, or professional services contract.
4. Personal Data We Collect
Depending on your relationship with CyGhost, we may process the following categories of data.
Contact and Business Data
- Name
- Company name
- Job title
- Email address
- Phone number
- Business address
- Communication history
- Proposal, contract and project information
Account and Platform Data
- Login details
- User ID
- Role and permissions
- Authentication logs
- Session information
- Tenant or organisation details
- Admin activity logs
- Support requests
Billing and Administrative Data
- Invoice details
- VAT number
- Payment status
- Purchase history
- Accounting records
- Contract records
Website and Technical Data
- IP address
- Browser type
- Device type
- Operating system
- Pages visited
- Date and time of visit
- Referrer URL
- Cookie identifiers
- Security logs
Cybersecurity Service Data
When delivering cybersecurity services, CyGhost may process technical data such as:
- Asset names
- IP addresses
- Domains
- Usernames
- Email addresses
- Device identifiers
- Vulnerability evidence
- Screenshots or proof of concept evidence
- Security alerts
- Authentication logs
- Cloud security events
- Endpoint events
- Firewall or network logs
- Incident details
- Configuration data
CyGhost does not intentionally collect more data than necessary for the agreed service.
5. Special Categories of Data
CyGhost does not intentionally request or collect sensitive personal data such as health data, biometric data, religious beliefs, political opinions, or criminal offence data unless strictly required for a specific legally authorised engagement.
Customers must not submit sensitive personal data to CyGhost unless this is necessary, lawful, documented and agreed in writing.
6. How We Use Personal Data
CyGhost may process personal data for the following purposes:
- Providing cybersecurity and IT services
- Delivering penetration testing, vulnerability assessments and security reviews
- Operating and securing CyGhost platforms
- Responding to contact requests
- Preparing proposals and contracts
- Managing customer relationships
- Providing customer support
- Sending service notifications
- Processing invoices and payments
- Improving website performance
- Detecting abuse, fraud, attacks or misuse
- Maintaining audit trails
- Meeting legal, tax and accounting obligations
- Defending legal claims
- Improving security controls, documentation and internal processes
7. Legal Bases for Processing
CyGhost processes personal data only when a valid legal basis applies.
| Purpose | Legal Basis |
|---|---|
| Responding to enquiries | Legitimate interest or pre-contractual steps |
| Preparing proposals and contracts | Pre-contractual steps or contract performance |
| Delivering services | Contract performance |
| Operating the website | Legitimate interest |
| Securing systems and detecting abuse | Legitimate interest |
| Sending essential service messages | Contract performance or legitimate interest |
| Invoicing and accounting | Legal obligation |
| Marketing communication | Consent or legitimate interest where allowed |
| Processing customer security data | Customer instructions under contract or DPA |
| Legal claims and dispute handling | Legitimate interest or legal obligation |
8. Customer Data and Security Logs
For cybersecurity services and future SaaS/SIEM/SOAR services, CyGhost may process customer-provided data, including security logs and technical telemetry.
CyGhost processes this data only to:
- Provide the agreed service
- Detect, investigate or report security events
- Maintain platform security
- Troubleshoot technical issues
- Support the customer
- Comply with written instructions
- Meet legal obligations
CyGhost does not sell customer data.
CyGhost does not use customer security logs for unrelated advertising.
9. Confidentiality
CyGhost treats customer systems, vulnerabilities, reports, credentials, logs, business information and security findings as confidential.
Access to confidential information is limited to authorised personnel and service providers who need access for legitimate business or technical reasons.
10. Security Measures
CyGhost applies technical and organisational security measures appropriate to the risk, including where applicable:
- Access control
- Least privilege
- Multi-factor authentication
- Encryption in transit
- Encryption at rest where appropriate
- Secure credential handling
- Logging and monitoring
- Vulnerability management
- Patch management
- Backup and recovery controls
- Segmentation where appropriate
- Incident response procedures
- Supplier security review
- Secure development practices
- Audit trails
- Internal confidentiality controls
No system can be guaranteed to be completely secure. However, CyGhost continuously works to reduce risk and protect customer information.
11. Data Retention
CyGhost keeps personal data only as long as necessary.
Typical retention periods are:
| Data Type | Retention Period |
|---|---|
| Website logs | Usually up to 12 months unless needed for security |
| Contact requests | Up to 3 years after last contact |
| Customer records | Duration of contract plus legal retention period |
| Invoices and accounting data | As required by Belgian tax and accounting law |
| Security reports | As agreed in the contract or statement of work |
| Platform logs | As configured by the customer or agreed contractually |
| Backup data | Until backup rotation removes it |
| Legal dispute records | As long as needed to defend claims |
Different retention periods may apply if required by law, contract, security investigation, or customer instruction.
13. Subprocessors
Where CyGhost acts as a processor, subprocessors may be used to deliver hosting, support, security, monitoring, email, backup, analytics or infrastructure services.
A customer may request available information about relevant subprocessors by contacting: privacy@cyghost.com.
For enterprise customers, subprocessor terms may be handled through a separate Data Processing Agreement.
14. International Transfers
CyGhost aims to process and store customer data within the European Economic Area where reasonably possible.
If personal data is transferred outside the EEA, CyGhost will use appropriate safeguards where required, such as:
- Adequacy decisions
- Standard Contractual Clauses
- Contractual safeguards
- Security controls
- Transfer risk assessments where needed
15. Data Subject Rights
Depending on the situation and applicable law, you may have the right to:
- Access your personal data
- Correct inaccurate data
- Request deletion
- Restrict processing
- Object to processing
- Request data portability
- Withdraw consent
- Lodge a complaint with a supervisory authority
To exercise your rights, contact: privacy@cyghost.com.
CyGhost may need to verify your identity before responding.
If CyGhost processes your data on behalf of a customer, we may refer your request to that customer because they are usually the data controller.
16. Complaints
You have the right to lodge a complaint with the Belgian Data Protection Authority.
Belgian Data Protection Authority / Gegevensbeschermingsautoriteit / Autorite de protection des donnees
Rue de la Presse 35
1000 Brussels
Belgium
Email: contact@apd-gba.be
18. Children
CyGhost services are intended for businesses and professional users. We do not knowingly target children or collect children’s personal data through our business services.
19. Automated Decision-Making
CyGhost does not use personal data for automated decisions that produce legal or similarly significant effects without appropriate safeguards.
Future security automation features may help detect risks, prioritise alerts or recommend actions, but final customer decisions remain subject to customer configuration, review and responsibility unless otherwise agreed.
20. Changes to This Policy
CyGhost may update this Privacy Policy from time to time.
The latest version will be published on this page with a new “Last Updated” date.
21. Contact
For privacy questions, contact: