1. Introduction

White Walls Gallery is committed to protecting your privacy in respect of Personal Data that you share with us.

This Privacy Policy explains how Deutsch Leidenschaft Incorporated, its subsidiaries and affiliates that link to this Privacy Policy, (collectively, “White Walls Gallery”, also referred as “our” or “we” or “us”), handle information collected and received in the course of your use of our websites, and services (collectively, the “Services”). It also governs the collection, use, and disclosure of your information.

2. Information we collect and receive

We may collect and receive information from you in the following situations:

• • When you register for an account with us (“Account”); or
  • When you subscribe to our email announcements.

You are under no obligation to provide the information to us. However, if you choose to withhold the information or to revoke permission for us to receive the information, we may be unable to provide certain aspects of our Services to you.

By providing us with any information relating to a third party (e.g. information of your spouse, children, parents, and/or employees), you represent to us that you have validly obtained the consent of the third party to provide us with their information for the respective purposes.

We may collect and receive the following information. Please note that not all of our Services collect all of the information listed below:

• • Account credentials such as username.
  • Profile information such as, name, gender, email address, profile photo, mobile number, date of birth.
  • Information required for payment and shipping services such as bank account, credit card, or debit card details, identification card number, address, mobile number.
  • Location information such as last known location, meet-up location.
  • Any other information disclosed by you in any of the above-mentioned methods and/or through the use of our Services.
  • Aggregate data collected through the use of our Services.
  • Any communications between you and us.

4. How we use your information

We may use the information collected and received from you for the following purposes:

• • To verify your identity, update our records and generally maintain your Account with us.
  • Provide our Services and customize the content shown to you.
  • Develop, operate, improve, deliver and maintain our Services.
  • To process transactions.
  • To process or arrange payment
  • To process shipping services.
  • To process or resolve any dispute arising from or in connection with any transactions, in accordance with our Terms of Service.
  • To detect or monitor any frauds or other prohibited content, businesses or activities.   
  • Responding to your queries and resolving complaints.
  • To facilitate, confirm and/or provide updates or notifications in relation to any transactions.
  • Carry out polls, surveys, analysis and research on how our Services are being used and how we can improve them.
  • To update you on your listings and our Services (e.g. new offers, new feedback, new comments). These updates may be sent by email or through the White Walls Gallery Viber community group wherein you can choose to unsubscribe from these updates at any time through the “unsubscribe” portion of the email.
  • To send you marketing and/or promotional materials on the latest products and services of White Walls Gallery or carefully selected third parties. These updates may be sent by email and/or through the White Walls Gallery Viber community group wherein you can choose to unsubscribe from these marketing communications via the link in the email you have received or through the “leave and delete” link of the Viber community group “chat info” settings. These marketing communications may also be communicated to you through text messages and/or voice calls. For more information on anonymous advertising, including to understand what opting-out means and your opt out choices, please see the Section 10 below.
  • To send you service-related messages including, without limitation, a welcome/confirmation email when you register your Account and to enforce our Terms of Service and other policies. These messages are not promotional in nature. These messages will be sent by text message, email and/or through push notifications and you may not opt-out of receiving service-related messages from White Walls Gallery, unless you deactivate your account.
  • Perform functions or services as otherwise notified to you at the time of collection such as to publish and/or use for our marketing purposes, your feedbacks and stories.
  • To provide you a more tailored online advertising experience. White Walls Gallery has in place, tools and services are used to create advertisements, to deliver advertisements to devices on behalf of advertisers, to monitor the success of and manage advertising campaigns, and to present you with advertisements that are more likely to be interesting and relevant to you. Delivering relevant ads that are tailored to users’ interests is known as “interest based advertising” (sometimes also referred to as “behavioral advertising”). For more information on interest-based advertising, including to understand what opting-out means and your opt out choices for your devices, including computer browsers and mobile browsers and devices, please see the Section 10 below.
  • To provide and carry out cross-application and cross-device advertising (i.e. advertising across browsers and applications on a single device, as well as cross-device advertising), advertising delivery and reporting. Information include information described above and data and collected from a particular computer, browser or device and may be used with another computer, browser or device that is linked to the computer, browser or device on which such data was collected.
  • To  generate a “Lookalike audience” or “similar audience” of prospective users through the Facebook or Google advertising platforms and/or similar service providers. This allows us to deliver targeted advertisements on their networks to potential users, where such potential users may have shared interests or similar demographics to our existing users, based on the data of these advertising platforms. We typically do this by uploading a list of email addresses in a secured manner. Facebook’s policyis to irreversibly hash (encrypt) such lists locally and prior to uploading. Facebook will then match the hashed data against their own user and generate the lookalike audience. The uploaded list will then be deleted and will note be used for any other purposes. White Walls Gallery will not have access to the identity of any user in the lookalike audience, unless such individual chooses to click on the advertisements we deliver.  If you wish to opt out of “similar audiences” in Google, you can do so through your Google Ads Settings.
  • To comply with applicable Anti-Money Laundering and Countering the Financing of Terrorism regulations and other applicable laws and regulations.

5. Disclosure of Personal Data

To the extent necessary and as permitted by law, we may share information about you in the following ways:

• • We may share the information with our subsidiaries and any affiliated companies that form a part of our group of companies for the purposes as set out in clause 4 above.
  • We may share the information with our affiliates and with third party service providers who assist us in performing certain aspects of our Services on our behalf, such as processing transactions, payment or shipping services, fulfilling requests for information, receiving and sending communications, updating marketing lists, analyzing data, providing support services or in other tasks. Such service providers will only have access to your personal information to the extent necessary to perform their functions.
  • We may share the information with our potential partners, investors and other parties with a view to a potential business partnership, collaboration, joint venture or otherwise in furtherance of our business.
  • We may share any information collected in accordance with this Privacy Policy with: (i) governmental and other regulatory authorities or the courts in any jurisdiction; (ii) any third party claimants or potential third party claimants; or (iii) your card issuing bank, financial institution and/or payment service provider, to process or resolve any chargeback, payment reversal and/or dispute arising from or in connection with a transaction using our Services in accordance with our Terms of Service.
  • In addition to other information described in this Privacy Policy, we may collect and share with third party data management platforms or advertising and analytics partners precise location information. This location information may be used by itself, aggregated, or combined with mobile identifiers (such as IDFAs and Android IDs), and shared with third parties for purposes related to advertising, analytics, attribution (e.g., measuring ad performance), analytics and market research. We have included the links to their privacy policies below.
  • We may disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or crime or to protect our Services or the rights, property or personal safety of any person.

We respect your privacy and we will not sell your personal information to any third party. We may disclose data and aggregate statistics about users of our Services and sales to prospective partners, advertisers, sponsors and other reputable third parties in order to describe our Services, deliver targeted advertisements or for other lawful purposes, but these data and statistics will not include information which can be used to identify you.

We will ensure that your information is transferred in accordance with this Privacy Policy and protected in accordance with applicable laws on personal data protection (including, but not limited to, the Personal Data Protection Act 2012 of Philippines).

7. Protecting Your Information

The security of your information is important to us. We have security measures in place to protect against the loss, misuse and alteration of the information under our control.  We also follow generally accepted industry standards to protect the information transmitted to us over the Internet, both during transmission and once we receive it. Sensitive information (such as credit card numbers) are encrypted using secure socket layer technology (SSL). However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

It is important that you protect against unauthorised access of your Account and information by choosing your password carefully, and keeping your password and Account secure (e.g. by signing out after using our Services).

8. Updating your Personal Data

You may access and update your information within our Services through the “My Account” page of your Account.

Where you provide personal information about yourself to us, you are responsible for providing accurate, not misleading, complete and up-to-date information about yourself and any other person whose personal information you provide us, and to update this personal information as and when it becomes inaccurate, misleading, incomplete or out-of-date.

In certain circumstances, you may need to provide to us personal information about someone other than yourself. If so, we rely on you to inform these individuals that you are providing their personal information to White Walls Gallery, to make sure they consent to you giving us their information and to advise them about where they can find a copy of this Privacy Policy.

If you wish to:

• • apply for a copy of the information we hold about you;
  • withdraw consent you previously provided to us to use, collect or disclose the information we hold about you; or
  • withdraw consent to any of our data processing activities,

please contact us at the contact details set out in Section 13 below.

Accessing / Updating your information: Please allow us a reasonable period of time to respond to any request and effect any change. We may ask to verify your identity and for more information about your request. Where we are legally permitted to do so, we may refuse your request and may give you reasons for doing so.

Where you have requested for a copy of the information we hold about you, we may charge a reasonable administrative fee to cover the costs of responding to your request. If we decide to do so, we will provide you with a written estimate of such fee beforehand.

Deleting your information: Please note that, in certain circumstances, We will not be able to delete your information without also deleting your Account. We may be required to retain some of your information after you have requested deletion, to satisfy our legal or contractual rights and/or obligations. We may also be permitted by applicable laws to retain some of your information to satisfy our legitimate business needs.

9. Tracking Technologies

We use tracking technologies on our Services.These enable us to understand how you use our Services which, in turn, helps us to provide and improve our Services. However, the tracking technologies do not access, receive or collect information which can be used to identify you. We have listed below some examples of the tracking technologies used on our Services:

• • A cookie is a small data file sent from a website to your browser that is stored on your device. Cookies are used for a number of purposes, including to display the most appropriate content based on your interests and activity on our Services, estimate and report our Service’s total audience size and traffic, and conduct research to improve our Services. You can configure your device’s settings to reflect your preference to accept or reject cookies. If you reject all cookies, you will not be able to take full advantage of our Services. For more information on cookies control, please see the Section 10 “White Walls Gallery Opt-Out” below.
  • Clear gifs. We employ a software technology called clear gifs (a.k.a. web beacons or web bugs) to help us better manage content on our Services by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence.
  • Flash cookies. We use Flash cookies (a.k.a local shared objects or LSOs) to store some of your viewing preferences on our Services. These are used to collect and store information, but differ from browser cookies in the amount, type and manner in which data is stored.

10. White Walls Gallery Opt-Out

We may deliver third party personalised and/or targeted advertisements (each, a “Targeted Ad”) to you in the course of your use of our Services and/or though a variety of advertising networks and exchanges.

Please note that if you choose to “opt out”, we will not use information we have collected about you to deliver Targeted Ads, but it does not opt you out of seeing advertisements. You may still see generic, non-targeted advertisements which are served without the use of any information we have collected about you. You may still be served advertisements for other reasons, such as:

• • General advertisements served to all users of our Platforms.
  • Personalized and/or targeted advertisements from other third parties and not delivered by White Walls Gallery through your mobile and/or web activities.

Please also note that even though White Walls Gallery does not share your personal data (other than hashed or device identifiers, to the extent they are personal data in some countries) with any advertising networks and exchanges without your consent or unless as specified in this Privacy Policy, when you view or interact with an advertisement via any of your devices, an advertiser or advertising network or exchanges can infer that you are within their target audience; or when you click on an advertisement, the publisher and/or advertiser will know you visited the page that you clicked on and may still be able to associate personal data collected by such third parties directly from you through their cookies and similar tracking technologies.

11. Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time and all changes will be posted here. If we believe that the changes are material, we will notify you of the changes by posting a notice on our Services or by email. You are responsible for reviewing the changes which we make this Privacy Policy. Your continued use of our Services constitutes your acceptance of the updated Privacy Policy.

12. Third Party Sites and Resources

Our Services may, from time to time, contain links to external sites or resources which are operated by third parties. We have no control over the content and privacy practices of such sites or resources. You are advised to review the privacy policies of these sites and resources operated by third parties and understand how your information may be used by those third parties.

13. Contact Us

If you have any questions, complaints, concerns or comments on our Privacy Policy, we welcome you to contact us through the following details:

Address: 2241 Chino Roces Avenue, Warehouse 12A La Fuerza Plaza, Makati City 1233, Philippines

Email: [email protected]

Telephone No: +63-2-8659-3697

You also have a right to file a complaint with the National Privacy Commission. Your indication at the subject header would assist us in attending to your email speedily by passing it on to the relevant staff in our organization. For example, you could insert the subject header as “Accessing Personal Data”.  

White Walls Gallery does not: (a) offer goods or services to, or monitor the behavior of, European Union data subjects; and (b) process and/or hold the personal data of data subjects residing in the European Union.

Effective on 8 July 2020