LEGAL & PRIVACY TERMS

Part 1: Terms of Service

1. Operator & Corporate Information

GhostLink is an independent zero-knowledge peer-to-peer (P2P) communication platform owned and operated by Morgan Wheatley Technologies Ltd, a private limited company incorporated and registered in England and Wales.

• Company Registration Number: 17465315
• Registered Office Address: 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
• Contact: Direct electronic communication is available via our website Contact Page.
• Governing Law & Jurisdiction: These Terms and any dispute or claim arising out of or in connection with them (including non-contractual disputes or claims) are governed by the laws of England and Wales, subject to the exclusive jurisdiction of the courts of England and Wales.

2. Nature of Service & Zero-Knowledge Architecture

GhostLink provides a real-time, browser-based peer-to-peer (P2P) communication tool facilitating encrypted video, audio, and text communication.

• End-to-End Encryption (DTLS-SRTP): All real-time media streams and data channel messages are transmitted directly between peer browsers using WebRTC protocols. Media streams are encrypted end-to-end. Morgan Wheatley Technologies Ltd does not store, intercept, record, monitor, or possess the cryptographic keys or technical ability to decrypt your live streams or private messages.
• Ephemeral Signaling: To establish peer connections, devices exchange temporary session handshakes (SDP offers/answers and ICE network candidates) through our signaling infrastructure (Cloudflare Workers & Durable Objects). This handshake data is held in volatile memory solely for the duration of the connection attempt and is discarded immediately once connected or when the room expires (maximum room lifespan: 4 hours).
• "AS IS" Supply: To the maximum extent permitted under the Consumer Rights Act 2015 and English law, the platform is provided strictly on an "AS IS" and "AS AVAILABLE" basis without warranties of uninterrupted uptime, bandwidth availability, or device hardware compatibility.

3. Mandatory Age Requirement (Strictly 18+)

4. Peer-to-Peer Routing & Public IP Address Disclosure

GhostLink operates on a direct Peer-to-Peer (P2P) Mesh architecture to prevent central servers from intercepting your video or audio. A fundamental, inescapable technical characteristic of P2P networking is that connecting devices must exchange network packets directly with one another.

By connecting to a room on GhostLink, you acknowledge that your public IP address will be visible to other participants connected in that same room. If you require IP address masking from other room participants, you must utilize an independent Virtual Private Network (VPN) or proxy before accessing the Service.

5. Prohibited Conduct & Zero Tolerance Safety Policy

You agree not to use GhostLink for any unlawful purpose. In compliance with English law and the UK Online Safety Act 2023, the following conduct is strictly prohibited:

• Child Sexual Exploitation and Abuse: Any creation, solicitation, possession, transmission, or display of Child Sexual Abuse Material (CSAM/CSAS) is subject to an absolute zero-tolerance policy. Such activities will be immediately reported to the National Crime Agency (NCA) and relevant statutory child protection authorities.
• Non-Consensual Recording & Sharing: Recording, screen-capturing, archiving, or disseminating video, audio, or communications of other users without their prior, express, informed consent is strictly prohibited.
• Harassment, Hate Speech & Threats: Engaging in stalking, doxxing, harassment, extortion, black-market commercial solicitations, or incitement of violence or terrorism.
• Malicious Code & Abuse of Infrastructure: Deploying automated flood bots, script injectors, denial-of-service (DDoS) tools against our signaling servers or Durable Objects, or reverse-engineering rate limiters.

6. Paid Host Only Model, Passes & Subscriptions

GhostLink operates strictly on a Paid Host Only commercial SaaS model. To ensure sustainable independent infrastructure and prevent bot abuse, creating a meeting room requires a paid host authorization pass.

• Single Meeting Pass (£1.00): Grants the purchasing host the right to instantiate one (1) disposable encrypted meeting room with up to four (4) continuous hours of room duration. The pass is consumable upon room creation.
• Pro Host Subscription (£4.00 / month): Grants the purchasing host the right to host one (1) concurrent live meeting room at any given time, with unlimited meeting room creations per month during an active billing cycle. Subscriptions automatically renew each month until cancelled via your customer portal or by contacting support.
• 100% Free Guest Access: Any participant invited by an authorized host enters, participates, and exits the meeting completely free of charge. Guests are never required to pay, provide payment details, create an account, or download native software.
• Statutory Cancellation Waiver (Consumer Contracts Regulations 2013): Under the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, you have a statutory right to cancel certain digital purchases within 14 days. However, because GhostLink delivers immediate access to digital meeting infrastructure upon checkout, by purchasing a pass or subscription you expressly consent to the immediate supply of digital services and acknowledge that you waive your statutory 14-day right of withdrawal once digital supply has commenced.
• Payment Processing: All payments, billing details, and card authentications are handled securely by Stripe Payments Europe, Ltd. Morgan Wheatley Technologies Ltd never stores or has access to full credit card or debit card numbers on its servers.
• Strict Prohibition on Commercial Adult Entertainment: In compliance with Stripe's Restricted Business Policy and UK legal standards, GhostLink is engineered exclusively for business, professional, educational, and personal teleconferencing. Any use of GhostLink for commercial adult entertainment, pay-per-view webcam modeling, escort services, or unlawful broadcasting is strictly prohibited. Violations will result in immediate, non-refundable termination of service and permanent IP banning.

7. Statutory Notice-and-Takedown Protocol

8. Limitation of Liability & Financial Cap

To the maximum extent permitted under the Consumer Rights Act 2015 and English law:

• Exclusion of Consequential Losses: In no event shall Morgan Wheatley Technologies Ltd, its directors, employees, or contractors be liable for any indirect, incidental, special, punitive, or consequential damages, including loss of data, unauthorized interception by external third parties on your local network, actions of other room participants, or service interruption.
• Monetary Liability Cap: The total aggregate financial liability of Morgan Wheatley Technologies Ltd arising out of or related to GhostLink—whether in contract, tort (including negligence), breach of statutory duty, or otherwise—shall be strictly limited to the total fees paid by you to us in the preceding twelve (12) months, or £10.00 (ten pounds sterling), whichever is greater.
• Statutory Exceptions: Nothing in these Terms limits or excludes liability for death or personal injury caused by negligence, fraud or fraudulent misrepresentation, or any other liability that cannot be excluded under the laws of England and Wales.

Part 2: Privacy Policy

GhostLink is built around an uncompromising Zero-Knowledge privacy model. We do not operate user accounts, do not use persistent tracking cookies, do not sell user data, and have zero visibility into your live communications.

1. Data Controller Information

• Data Controller: Morgan Wheatley Technologies Ltd (Company No. 17465315), registered at 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.
• Data Protection Inquiries: Communications regarding privacy practices may be submitted via our Contact Page.
• Supervisory Authority: Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (ico.org.uk).

2. Data We Do NOT Collect

3. Data We Process Temporarily

• Signaling Metadata: To connect your browser with a peer, WebRTC session descriptions (SDP offers, SDP answers) and network routing candidates (ICE) are temporarily routed via Cloudflare Durable Objects. This signaling data is strictly ephemeral and is purged automatically when peers disconnect or when the 4-hour room timer expires.
• Peer-to-Peer Transmission: Because GhostLink uses WebRTC P2P mesh architecture, your device transmits packets directly to connected peers, revealing your IP address to those room participants.
• Contact Enquiries: If you voluntarily reach out via our contact form, we process your submitted email address and message solely to respond to your inquiry.

4. Lawful Bases for Processing (UK GDPR Article 6)

• Contractual Necessity (Art. 6(1)(b)): Routing transient signaling data and room tokens to establish and maintain the real-time communication session you requested.
• Legitimate Interests (Art. 6(1)(f)): Mitigating automated DDoS attacks, enforcing ephemeral room limits, and securing network infrastructure.
• Legal Obligation (Art. 6(1)(c)): Fulfilling statutory duties under applicable UK legislation, including the Online Safety Act 2023 and child protection reporting obligations.

5. Sub-Processors & Infrastructure

We rely strictly on industry-standard infrastructure providers adhering to stringent UK/EU adequacy and privacy standards:

• Cloudflare, Inc. (Global / UK / EU): Edge routing, Cloudflare Pages hosting, Workers, and Durable Objects for ephemeral WebRTC signaling and STUN/TURN relays.
• Stripe Payments Europe, Ltd. (Ireland / UK): Secure payment processing, card verification, and statutory fraud prevention for host pass purchases and subscriptions.
• Resend / Email Relay: Used strictly for inbound and outbound contact form dispatch if you reach out via `/contact`.

6. Your Statutory Rights (UK GDPR & DPA 2018)

Under the UK GDPR and Data Protection Act 2018, you possess rights including the Right of Access, Right to Rectification, Right to Erasure, and Right to Restrict Processing.

Because GhostLink maintains zero accounts, zero databases of chat logs, and zero persistent user profiles, we typically hold no personal data linking to your real-world identity once an ephemeral room is closed. Where identifiable personal data is held (such as an archived support email), you may exercise your statutory rights by contacting us via our Contact Page.

You have the right to lodge a complaint at any time with the Information Commissioner's Office (ICO) at ico.org.uk.