Effective Date: 2025-12-14
Website Operator: Henry Sung
The website https://wheniselection.com (the “Website”) is committed to protecting your privacy. This Privacy Policy explains how I, the individual operator of the Website, collect, use, disclose, and safeguard your information when you visit our Website, particularly when you access it from within the European Economic Area (EEA), the UK, and Switzerland. I am committed to complying with the EU General Data Protection Regulation (GDPR).
1. Data Controller Contact Information
For the purposes of the General Data Protection Regulation (GDPR), I am the Data Controller for this Website. You can contact me, the owner, using the details below:
Name/Entity: Henry Sung.
Address: Dublin, Ireland
Email: info@wheniselection.com
If you are located in the EEA, you have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been infringed.
2. Information I Collect
As a simple informational website, I collect minimal personal data directly from visitors. However, data is collected automatically through server logs and through third-party advertising services (Google AdSense).
A. Data Collected Automatically (Server Logs & Analytics)
When you access the Website, my servers, or third-party service providers, automatically record certain information, including:
- IP Address: The Internet Protocol (IP) address used to connect your computer to the Internet.
- Device and Browser Information: Details about your device (e.g., hardware model, operating system) and browser type (e.g., Firefox, Chrome).
- Usage Data: Information about how you use the Website, such as the dates and times of your visits, the pages you view, and the time spent on those pages.
B. Data Collected via Cookies and Tracking Technologies
I use cookies, which are small files stored on your device, to help ensure the Website functions correctly and to enable advertising.
- Essential/Functional Cookies: Necessary for the operation of the Website (Legal Basis: Legitimate Interest).
- Analytics and Advertising Cookies: Used by Google AdSense and other advertising technology providers (see Section 4) for the purposes of targeted advertising and audience measurement (Legal Basis: User Consent).
3. Legal Basis for Processing Personal Data (GDPR)
I process your personal data only when I have a valid legal basis to do so under the GDPR.
| Processing Activity | Personal Data Collected | Purpose of Processing | Legal Basis (GDPR Art. 6) |
| Website Operation & Security | IP Address, Device Data, Usage Data | To ensure the functionality, stability, and security of the Website. | Legitimate Interest (Art. 6(1)(f))—Protecting my service from abuse. |
| Non-Personalized Advertising | IP Address, General Location, Browser Info | To display general, non-personalized advertisements to fund the Website. | Legitimate Interest (Art. 6(1)(f))—Monetizing the Website to continue operations. |
| Personalized Advertising | Cookie IDs, Device Identifiers, Browsing Data | To display personalized and relevant ads (via Google AdSense) and measure ad performance. | Consent (Art. 6(1)(a))—This requires explicit consent via a banner/CMP. |
4. Third-Party Data Processing (Google AdSense and Ad Partners)
The Website uses Google AdSense to serve advertisements. Please note the following crucial points regarding the processing of data for advertising:
A. Independent Controllership
For Google AdSense, I (the Publisher, as the individual owner) and Google Ireland Limited operate as separate and independent data controllers for the personal data processed in connection with ads served on the Website in the EEA and UK. This means we are each responsible for our own compliance with the GDPR.
B. Data Collection by Google and Vendors
- Google AdSense uses cookies and similar technologies (like device identifiers) to collect data from end-users on this Website. This data is used by Google to provide and improve its ad services, including for personalized advertising.
- The data collected includes online identifiers, IP addresses, cookie identifiers, browsing activity, and information about the ads shown to you.
- Google shares data with various third-party ad technology providers (ad partners). These partners also drop cookies and collect data subject to their own privacy policies. You will be able to manage consent for these partners via our Consent Management Platform (CMP).
C. Consent Requirement
I am required to obtain your explicit consent for the storing and accessing of cookies and the subsequent collection, sharing, and use of personal data for personalized advertising and measurement by Google and its ad partners, as required by the Google EU User Consent Policy.
- By accepting cookies via the consent banner, you grant me and Google (and its participating third-party vendors) permission to use your data for personalized advertising.
- You must use a robust Consent Management Platform (CMP) on the Website to manage this consent process, including providing options to accept, decline, or customize tracking preferences.
D. Managing Google’s Use of Data
You can learn how Google processes data, and manage your preferences, by visiting Google’s dedicated partner page: How Google uses information from sites or apps that use our services.
5. Your GDPR Data Protection Rights
If you are a resident of the EEA or UK, you have the following rights concerning your personal data:
- The Right to Access (Art. 15): You have the right to request copies of your personal data.
- The Right to Rectification (Art. 16): You have the right to request that I correct any information you believe is inaccurate or incomplete.
- The Right to Erasure (Art. 17): You have the right to request that I erase your personal data, under certain conditions.
- The Right to Restrict Processing (Art. 18): You have the right to request that I restrict the processing of your personal data, under certain conditions.
- The Right to Object to Processing (Art. 21): You have the right to object to my processing of your personal data, particularly when based on my legitimate interest (e.g., non-personalized advertising).
- The Right to Data Portability (Art. 20): You have the right to request that I transfer the data that I have collected to another organization, or directly to you, under certain conditions.
- The Right to Withdraw Consent (Art. 7): Where processing is based on your consent (i.e., for personalized advertising), you have the right to withdraw that consent at any time.
To exercise any of these rights, please contact me at the email address provided in Section 1.
6. Data Retention and Security
A. Data Retention
I retain automatically collected log data only for as long as necessary for technical security and operational purposes, typically no longer than 12 months. Advertising and analytics data retained by Google is subject to their policies.
B. Security
I use commercially reasonable efforts and take appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. However, no internet transmission is 100% secure, and I cannot guarantee absolute security.
7. International Data Transfers
The Website’s primary purpose is to display global information, and the processing of data by third-party vendors (especially Google) may involve transferring and storing your personal data in countries outside the EEA or UK, such as the United States.
When this occurs, I rely on established legal mechanisms, such as Google’s adherence to standard contractual clauses (SCCs) and compliance with the EU-U.S. Data Privacy Framework, to ensure your data receives a level of protection equivalent to that offered within the EEA/UK.
8. Changes to This Privacy Policy
I may update this Privacy Policy from time to time. The revised policy will be indicated by an updated “Effective Date” at the top of this document. You are advised to review this Privacy Policy periodically for any changes.