Privacy policy

Who is responsible

What is happening here? Gallery is the controller for the processing described here. You can contact us about privacy or request deletion at WIHHgallery@gmail.com, or write to Reguliersdwarsstraat 73, 1017 BK Amsterdam, Netherlands.

This notice covers the website and Victoria workflow described below. Separate services, such as a third-party ticketing platform, have their own privacy notices.

Information we handle

Website visits. Hosting providers process technical information needed to deliver and protect the website, including network addresses and requests for pages and images. Our website code does not include advertising trackers, analytics scripts or a contact-submission form. Hosting and security services may separately process technical information.

Victoria messages. For authorised WhatsApp senders, the application stores sender and business-phone identifiers, message identifiers, message text, timestamps, replies and processing status. It also keeps conversation state, event drafts, edit and approval records, records of AI requests, and records needed to confirm and carry out privacy maintenance. Media-message records may include a media identifier, file type, caption, filename and integrity information.

Photos and gallery content. Supported photo attachments are stored as original image files with information linking them to the right draft. The application does not remove embedded metadata. Gallery staff or contributors may supply names, biographies, event details or images concerning artists, organisers and other people. Only provide information and photos you are entitled to use, and remove unnecessary personal details or location metadata before sending a file.

Why we use information

We use personal information to operate and secure the website, recognise authorised Victoria users, respond to their instructions, prepare and review gallery content, publish separately approved content, prevent duplicate or unauthorised actions, and investigate technical problems.

For these necessary operational and editorial activities, we rely on legitimate interests under Article 6(1)(f) GDPR: running and protecting the gallery's website and managing its programme. This basis applies only where those interests are not overridden by the rights and interests of the people concerned. You may object to processing based on legitimate interests. An administrator's approval to publish is not consent from everyone shown or mentioned in the content.

Optional AI pilot processing for Victoria relies on the participating user’s consent and is limited to expressly approved users and scope. You may withdraw that consent by contacting us. Consent withdrawal does not affect processing already lawfully carried out. This notice does not itself obtain consent, enable AI, or extend an approved pilot.

We also process information where necessary to meet an applicable legal obligation, including responding to valid data-protection requests, under Article 6(1)(c) GDPR.

How Victoria uses AI

When AI replies are enabled for an authorised user, the application sends message text, a limited selection of recent conversation text and relevant draft details to the OpenAI API to help compose replies and interpret proposed draft changes. It does not send photo pixels, private-preview links or its structured sender and phone identifiers to the AI. Text you write can still contain personal information, so avoid including confidential or sensitive details that are not needed.

The application requests that responses are not stored as retrievable API response state. This is not zero retention: OpenAI's standard abuse-monitoring logs may contain prompts and responses for up to 30 days, with exceptions described in its data controls. OpenAI states that API data is not used for model training by default unless the customer opts in.

Victoria can make mistakes. AI proposes replies and draft changes; it does not itself approve publication. The current workflow does not make solely automated decisions about people that have legal or similarly significant effects.

Private previews and public content

Sending content to Victoria does not by itself publish it. Drafts and attached photos remain outside the public event listing until an authorised user separately approves publication.

Anyone holding a valid private-preview link can open that preview. Access normally expires after 15 minutes and can end sooner if the draft or approval state changes. Keep these links private.

Published event text and its original photo are accessible to website visitors. The original image may include embedded metadata. Withdrawing an event stops its public event page and image route from serving it, but does not erase stored records or recall copies already downloaded or made by other people.

Who receives information

• People authorised to administer the gallery website and content-management systems.
• WhatsApp and Meta, for WhatsApp Business messaging and media delivery. WhatsApp also processes information for its own services under its applicable terms and privacy policy.
• OpenAI, for ChatGPT Sites hosting and, when enabled, the separate API used for Victoria's AI replies. The site uses Cloudflare-backed website, database and file-storage infrastructure.
• Website visitors, for published gallery and event content, and people holding a valid private-preview link, for that preview.

Information may also be disclosed where necessary to comply with a valid legal requirement. A linked service such as Instagram, Google Maps or an event-registration website processes your visit under its own notice when you open it.

Processing outside the EEA

Our providers may process information outside the European Economic Area, including in the United States. We do not promise EU-only storage or processing.

The providers' published processing terms describe applicable transfer safeguards, including European Commission adequacy decisions and standard contractual clauses. Relevant terms include the ChatGPT Sites data-processing addendum, the OpenAI business data-processing addendum where applicable, and the WhatsApp business data-transfer addendum. Contact us if you need information about the safeguards that apply to your data or a copy of the relevant terms.

How long information is kept

Victoria uses a manual retention procedure, not an automatic deletion schedule. The procedure calls for a review at least monthly, using these deletion-review targets:

• Private workspace: messages, replies, AI proposals and unpublished drafts are reviewed together for deletion after 90 days without substantive workspace activity.
• Expired previews: stored preview records are reviewed for deletion once they are at least 7 days past expiry. Access to a private preview normally expires after 15 minutes.
• Unused private photos: unreferenced uploads are reviewed for deletion once they are at least 90 days old. Clearing an inactive private workspace also removes its unprotected source photos.

These are manual review thresholds, not guaranteed automatic maximum storage periods. The inactivity test applies to the workspace as a whole, so continuing activity can keep older private records in storage. At review, we assess whether information is still necessary and whether it can be deleted sooner. Information should not be retained without a lawful, continuing purpose. A valid erasure request can be handled before these targets are reached.

The authorised owner can review a specific selection and separately confirm its permanent deletion from Victoria's active database and private photo storage. Reviewing a selection alone does not delete it. Publishing a website update, ordinary messages, draft or preview expiry, and replacing a photo do not themselves erase stored information.

Published and withdrawn gallery content is assessed separately. Private-workspace cleanup does not delete published or withdrawn event records, their source photos or the controls needed to manage them. Our procedure calls for a separate editorial and archive review at least annually, considering the continuing purpose and the rights of people shown or mentioned. Withdrawal stops public access through the event routes; it does not erase the underlying records. Requests involving this content require separate, appropriately scoped handling.

A recorded legal hold blocks the private cleanup until it is reviewed. Any exception to deletion must be justified, for example by an applicable legal obligation or the establishment, exercise or defence of legal claims. We also retain minimal replay-prevention markers and AI budget totals to prevent old message deliveries from recreating erased content or resetting usage limits. These control records do not retain message or AI-response text or photo files. The procedure calls for an annual review of the need for replay-prevention markers. The new privacy-request and confirmation conversation remains subject to the private-workspace retention procedure.

Deleting information from Victoria's active storage does not itself erase copies held by WhatsApp, OpenAI, other recipients or infrastructure backups. Those copies require separate handling under the applicable provider arrangements and backup lifecycle. We cannot recall copies already downloaded by others. Contact WIHHgallery@gmail.com to ask what we hold or request deletion, including for information outside the private cleanup.

Your rights and choices

Depending on the circumstances, you can request access, correction, erasure, restriction of processing or a portable copy of your information. You can object to processing based on legitimate interests and withdraw consent where that is the basis used.

Send requests to WIHHgallery@gmail.com. We may need proportionate information to verify your identity. The GDPR normally requires a response within one month. A permitted extension must be explained within that first month. These rights are subject to the conditions and exceptions in the GDPR.

You can complain to the Dutch Autoriteit Persoonsgegevens or another competent data-protection authority.

Using Victoria is optional. An authorised user must provide enough information to identify and manage a requested draft; otherwise Victoria cannot perform that task. You can view the public website without messaging Victoria and contact the gallery through its published contact details.

Changes to this notice

The date above identifies this version. We will update this notice when the service or its handling of personal information changes. This notice describes the current implementation; it is not a certification of GDPR compliance.