Privacy Policy

1 Overview

This Privacy Policy explains what information Roaming the Eye (游目骋怀) collects when you visit weihuailiang.com, why we collect it, who we share it with, how long we keep it, and what choices you have. It is written to be read, not to be skimmed past; where a practice may be surprising, we have tried to say so plainly rather than bury it.

The site is a curatorial platform bringing Chinese painting to an international audience, at present centred on the work of Wei Huailiang (魏怀亮). Its activities include and may come to include exhibiting and publishing work, curatorial projects, and the sale of works to collectors and institutions. Works shown here may be available for acquisition, and we welcome enquiries.

At the time of writing, enquiries are handled by email between people; the site carries no checkout, cart or payment processing. Should that change, or should the site's activities broaden in any way that affects what we collect or why, we will update this policy before the change takes effect rather than after (see Section 22).

What will not change is this: the site carries no advertising, and it has no commercial relationship of any kind with an advertising network, a data broker, or an analytics vendor. Our commercial interest is in the paintings, not in the data about the people who look at them. That is a commitment about your data, and it holds regardless of how the rest of the business develops.

The measurement described in this policy is first-party: the code that performs it was written by us, the data it produces is sent only to our own server, and no copy of it is transmitted to any analytics company. This is an uncommon arrangement and it is the reason several sections below are shorter than they would be on a comparable site.

2 Who We Are and How to Reach Us

For the purposes of the EU and UK General Data Protection Regulation, the data controller for the personal information described in this policy is the operator of Roaming the Eye (游目骋怀).

We have not appointed a Data Protection Officer, as we are not required to do so under Article 37 GDPR. Privacy enquiries are handled directly by the people who operate the site. We have not appointed an EU or UK representative under Article 27 GDPR; our processing is occasional, does not involve special categories of data on a large scale, and is unlikely to result in a risk to the rights and freedoms of individuals.

3 Scope of This Policy

This policy applies to the public website at weihuailiang.com and its subpages. It applies to everyone who visits the site, wherever they are located.

It does not apply to:

• Websites operated by other people that we link to (see Section 21).
• Correspondence that reaches us through channels other than the address published on this site, such as social media platforms, which are governed by those platforms' own policies.
• Exhibitions, galleries, or other offline activities.

4 Information We Collect

4.1 Information you give us

If you write to us at the address published on this site, we receive whatever you choose to put in that message: your name or the name you sign with, your email address, and the content of your enquiry. We use it only to reply to you. We do not add correspondents to a mailing list, and we do not use the content of an enquiry for any purpose other than the conversation it belongs to.

Enquiries about acquiring a work. If you write to ask about acquiring a painting, the conversation will naturally involve more than a name and an address — which work you are interested in, questions of price, condition, provenance, framing, shipping and customs, and in some cases the details needed to invoice and deliver. We keep that correspondence because a transaction requires a record of what was agreed, and because tax and accounting law requires us to retain records of a sale. See Section 12 for how long.

Three things we want to be explicit about, because collectors have a reasonable interest in discretion:

• Enquiry correspondence is never joined to the visit records described below. We do not look up which pages you read before writing to us, and the two bodies of data have no key in common that would let us.
• We do not publish, share, or disclose who has enquired about or acquired a work — not in press material, not to other collectors, not to anyone — without asking you first.
• We do not sell, rent, or trade collector information, and we do not build or share mailing lists.

The website does not currently host a contact form; enquiries arrive by email. If a form is added, this policy will be updated before it goes live.

4.2 Information collected automatically

Like any web server, ours receives certain technical information with every request. The most significant of these is the IP address your browser connects from, which we keep in full. Alongside it we retain the kind of browser and device you are using, your browser's language and time zone, your screen size, and — derived from the IP address — an approximate location, ordinarily a country and sometimes a region or city. This is not precise geolocation, and we never ask your browser for its location.

Where another site has linked you here, we keep the domain of that site and nothing more. We deliberately discard the rest of the referring address, because a full referring URL can contain the words someone searched for.

We also generate a random session identifier, stored in your browser and expiring after thirty minutes of inactivity. It contains no information about you; its only job is to join the pages of a single visit together, so that five pages read by one person are not counted as five visitors.

The IP address serves a similar purpose over a longer span, and it is the only thing we hold that could in principle be traced back to a person. We use it to tell one visitor from another, to understand roughly where in the world the audience is, and to recognise automated traffic. We do not use it to identify anyone, and we do not combine it with information from any other source.

4.3 How the site is used

While you are reading, we record in outline how the site is being used: which pages are opened and in what order, roughly how long each one holds attention, how far down a page you read, and what is clicked — including the features particular to this site, such as opening a work's detail panel, turning the circular gallery, unrolling a handscroll, or running the slideshow. We also record when a page fails with a script error, and when something is clicked several times without responding, because that is how a broken interface makes itself known.

One detail about the timing is worth stating, because it cuts against us. We measure how long a page is actually visible, not merely how long it was open — the clock stops when you switch to another tab. A page left open in the background is not recorded as reading.

What we take from all of this is aggregate: which paintings hold attention, which texts are read through, which parts of the interface go unused. We are not interested in any individual visit, and none of it is used to build a profile of a person.

All of this is recorded against the IP address and session identifier described above. It is never recorded against a name or an account, because there is none, and it is never joined to enquiry correspondence (see Section 4.1).

5 Information We Do Not Collect

We state these explicitly because their absence is difficult to verify from the outside.

• We do not collect names, email addresses, or telephone numbers unless you send them to us yourself in a message.
• We do not read what you type. The measurement script never captures the contents of input fields, including text you type and then delete.
• We do not read your clipboard. We record that a copy occurred; the browser does not give us the content and we do not ask for it.
• We do not record your screen or replay your session. There is no session replay, no heatmap, and no mouse-movement trail. We know which element was clicked, not the path your cursor took to reach it.
• We do not fingerprint your device. We do not use canvas, WebGL, audio, font enumeration, or any similar technique to build a persistent identifier.
• We do not track you across websites. We have no advertising identifiers, no third-party pixels, no tag manager, and no shared cookies. We do not know, and have no means of knowing, what you do anywhere else.
• We do not request or store precise geolocation. The browser's location permission is never requested.
• We do not collect special categories of personal data within the meaning of Article 9 GDPR — racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, or data concerning sex life or sexual orientation.
• We do not knowingly collect information from children. See Section 19.

6 How We Use Information

We use the information described in Section 4 for the following purposes, and for no others.

We do not use this information for advertising, for building marketing profiles, for scoring or ranking individuals, for training machine-learning models, or for any decision that produces a legal or similarly significant effect on you.

7 Legal Bases for Processing (EEA and UK)

If you are in the European Economic Area or the United Kingdom, we process personal data on the following legal bases under Article 6(1) GDPR.

Where we rely on legitimate interests, you have the right to object under Article 21 GDPR. For the audience measurement, you do not need to write to us to exercise it — the control in Section 14 takes effect immediately and permanently for that browser.

A note on honesty: some regulators take the view that storing an identifier in a visitor's browser for analytics requires prior consent under the ePrivacy Directive, even where the analytics is first-party and the underlying processing rests on legitimate interests. We consider our measurement to fall within the narrow, non-intrusive category that several national authorities exempt, because it is strictly first-party, is never shared, never leaves our infrastructure, produces no cross-site profile, and offers an immediate opt-out. We say this openly rather than let you assume the question does not arise. If you would rather not be counted, Section 14 takes one click.

8 Local Storage and Cookies

This site sets no cookies. Not for analytics, not for advertising, not for anything else. You will not find a cookie from weihuailiang.com in your browser.

We use your browser's local storage instead, for two small values. Local storage differs from cookies in a way that matters here: it is never transmitted automatically with requests, is readable only by this site, and never reaches any other party.

Clearing your browser's site data for this domain removes all of them. None is a cookie, none is sent to any other party, and none is readable by any site but this one. Note that clearing ym_optout restores measurement, because the record of your choice is stored in the same place as everything else — we have no account to attach it to.

9 Disclosure of Information

9.1 We do not sell or share personal information

We do not sell personal information, and we do not share it for cross-context behavioural advertising, as those terms are defined under the California Consumer Privacy Act as amended by the California Privacy Rights Act. We have not done so in the preceding twelve months and we have no plans to do so. We also do not sell or share the personal information of minors under 16 years of age, because we do not knowingly collect it at all.

9.2 Service providers

The infrastructure that runs this site is operated by third parties, listed in Section 10. They process data on our instructions and for no purpose of their own in relation to this site.

9.3 Legal requirements

We may disclose information where we are required to by law, or where we believe in good faith that disclosure is reasonably necessary to comply with a legal process, to enforce our terms, or to protect the rights, property or safety of any person. We will not volunteer information to authorities absent such a requirement, and where we are permitted to notify you of a request, we will.

9.4 Business transfers

If this site or its collection were ever transferred to another custodian, information held under this policy could be transferred with it. In that event we would give notice on this page before the transfer took effect, and the recipient would be bound by terms no less protective than these.

9.5 Aggregate information

We may publish or discuss aggregate figures — for example, that a particular series was the most viewed in a given month. Aggregate figures contain no IP addresses and cannot be used to identify any individual.

10 Service Providers

The following is a complete list of the third parties that come into contact with data covered by this policy. There are no analytics vendors, advertising networks, or data brokers on it, and there never have been.

The database itself accepts connections only from the machine it runs on and is not reachable from the internet. The application account used by the website has no permission to alter the database structure and no permission to delete records.

11 International Data Transfers

Our server is located in Oregon, in the United States. If you visit this site from the European Economic Area, the United Kingdom, Switzerland, mainland China, or anywhere else outside the United States, the information described in this policy is transferred to and stored in the United States.

The United States has not been the subject of a general adequacy decision covering all transfers. Where personal data of individuals in the EEA or UK is transferred to our service providers, those transfers are made under the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum, which form part of the standard data processing terms of both Cloudflare and Amazon Web Services. We rely on those measures, on the limited and non-sensitive nature of the data, and on the technical measures described in Section 13.

You may request a copy of the relevant transfer safeguards by writing to us.

12 Data Retention

We keep information only as long as it is useful for the purposes in Section 6.

13 Security

We take the following measures. We describe them specifically rather than asserting that we use "industry-standard security", which tells you nothing.

• All traffic to the site is served over HTTPS and the site sends an HTTP Strict Transport Security header, so browsers refuse to connect insecurely.
• The database listens only on the server's loopback interface. It cannot be reached from the internet at all.
• The database account used by the website can insert and update the measurement tables. It cannot create, alter or drop tables, and it cannot delete records. A compromise of the website therefore cannot erase or silently rewrite history.
• Incoming measurement data is validated against a strict whitelist. Anything that does not match is rejected and logged rather than stored.
• Requests are rate limited per IP address.
• The application runs as an unprivileged system account under resource limits and a restricted system call profile.
• The administrative statistics interface requires a password, is served only over HTTPS, and is excluded from search engines.
• Database backups are encrypted with AES-256 before they are written to disk, and the passphrase is stored separately from the backups.

No system is perfectly secure. If a breach affecting your personal data occurs, we will notify the competent supervisory authority within 72 hours where Article 33 GDPR requires it, and will notify affected individuals where the breach is likely to result in a high risk to their rights and freedoms, or where other applicable law requires it.

14 Your Choices and Controls

14.1 Turn the measurement off

The link below stops all measurement in this browser, immediately and permanently, and removes the session identifier already stored. Nothing else about the site changes. You do not need to give a reason and you do not need to contact us.

Do not record my visits

Because we keep no account for you, this preference lives in your browser. It applies to this browser on this device, and clearing your browser's site data will clear it along with everything else.

You are also welcome simply to write to [email protected] — we will delete the records we hold and confirm when it is done. If you do, please include the IP address you were visiting from and roughly when, because that is the only thing we can search by.

14.2 Other ways to stop it, entirely in your own hands

• Block the script at /assets/js/youmu-track.js with any content blocker, or add this site to your blocker's list. This is the reliable method: nothing is sent at all. The site is built to work without it, so nothing will break, and we do not detect or work around content blockers.
• Disable JavaScript for this site. All of the writing and all of the reproductions remain readable.
• Private or incognito browsing — but be aware of what this does and does not do. Local storage is discarded when you close the window, so nothing persists and each visit is counted as a new one; the visit is still measured, because the IP address and the page requests reach our server either way. Private browsing is not an opt-out. We say so rather than let you assume otherwise.

14.3 Global Privacy Control and Do Not Track

We do not currently detect the Global Privacy Control signal or the Do Not Track header. We state this plainly because claiming to honour a signal one does not read is worse than saying so. Since we neither sell nor share personal information, a GPC signal would in any event have nothing to opt out of; the measurement described here is switched off with the button in 14.1.

15 Your Rights

Depending on where you live, you may have some or all of the following rights. We extend them to everyone who asks, regardless of location, because maintaining two standards would be more trouble than simply applying the higher one.

15.1 How to exercise them

Write to [email protected].

An important practical point. We hold no name, account, or email address attached to visit records. The only key we can search by is the IP address. To act on an access or erasure request relating to visit data, we therefore need you to tell us the IP address you visited from and the approximate date and time. If you cannot supply that, we will tell you so honestly rather than send you an empty result implying we hold nothing.

We will respond within 30 days. Where a request is complex we may extend this by a further 60 days and will tell you why within the first 30. There is no charge. We will not ask you to create an account or to supply identity documents in order to make a request about visit data; doing so would require us to collect more personal information than the request concerns.

15.2 Authorised agents

You may use an authorised agent to submit a request on your behalf. We may ask the agent for written proof of authorisation, and may ask you to confirm the authorisation directly.

15.3 Complaints

If you are in the EEA or UK and believe we have not handled your personal data properly, you have the right to lodge a complaint with your national supervisory authority. In the United Kingdom this is the Information Commissioner's Office (ico.org.uk). A list of EEA authorities is published by the European Data Protection Board (edpb.europa.eu). We would be grateful for the chance to address your concern first, but you are not obliged to come to us.

16 Notice for California Residents

This section supplements the rest of this policy and applies to residents of California under the California Consumer Privacy Act as amended by the California Privacy Rights Act.

16.1 Notice at collection

16.2 Sources and disclosure

We collect the categories above directly from you and from your device when you visit the site. We disclose them for business purposes only to the service providers listed in Section 10. Where a work is shipped, we necessarily disclose a delivery address to the carrier and, where required, to customs authorities — that is the only purpose for which it is used. We do not sell personal information and we do not share it for cross-context behavioural advertising. Selling a painting is not selling personal information; the two are unrelated and we do neither with your data.

16.3 Your California rights

You have the right to know, the right to delete, the right to correct, the right to opt out of sale or sharing (which for us is not applicable, as we do neither), the right to limit the use of sensitive personal information (also not applicable, as we collect none), and the right not to receive discriminatory treatment for exercising these rights. Submit requests to [email protected]. See the practical note in Section 15.1 about what we need in order to locate visit records.

16.4 Shine the Light

California Civil Code § 1798.83 permits residents to request information about disclosure of personal information to third parties for their direct marketing purposes. We make no such disclosures.

17 Notice for Other U.S. States

Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana and other states with comprehensive privacy statutes have rights to access, correct, delete, and obtain a copy of their personal data, and to opt out of targeted advertising, sale, and profiling in furtherance of decisions producing legal or similarly significant effects.

We do not engage in targeted advertising, do not sell personal data, and do not carry out such profiling, so those opt-outs have nothing to apply to here. The remaining rights are available to you on the same terms as in Section 15. Where a state provides a right to appeal a refused request, you may appeal by replying to our response; we will inform you of the outcome and of your right to contact your state Attorney General.

18 Notice for Residents of Mainland China

If you are in mainland China, the Personal Information Protection Law gives you rights of access, correction, deletion, portability, and explanation of our processing rules, and the right to withdraw consent.

Your personal information is transferred to and stored in the United States, as described in Section 11. We rely on your visiting a site that plainly states this, on the limited and non-sensitive nature of the data, and on the control in Section 14 which lets you stop the processing entirely. We do not process sensitive personal information as defined in Article 28 PIPL, and we do not use personal information for automated decision-making.

中文说明：你的信息会被传输到并存放在美国（见第 11 节）。我们不处理《个人信息保护法》 第 28 条定义的敏感个人信息，也不用于自动化决策。你可以随时通过第 14 节的按钮完全停止统计， 或写信给我们要求查阅、更正、删除、导出。

19 Children's Privacy

This site is intended for a general adult audience interested in Chinese painting. It is not directed to children, and we do not knowingly collect personal information from children under 13 years of age (or under 16, where local law sets that threshold).

If you are a parent or guardian and believe that a child has provided us with personal information, write to us and we will delete it. Because visit records are keyed only to IP address, please include the IP address and approximate time so that we can find them.

20 Automated Decision-Making and Profiling

We do not carry out automated decision-making that produces legal effects concerning you or similarly significantly affects you, within the meaning of Article 22 GDPR.

The one automated classification we perform is distinguishing automated clients — search engine crawlers, preview bots, monitoring tools — from human visitors, so that they can be excluded from the statistics. This classification is based on the user-agent string and similar technical signals. Its only consequence is whether a visit is counted. If a human visitor is misclassified as a bot, nothing happens to them: the site behaves identically and no access is restricted.

21 Links to Other Websites

This site may link to websites operated by galleries, museums, publications and other third parties. We do not control those sites and this policy does not apply to them. We record that an outbound link was followed (see Section 4.3) but we have no visibility into what happens after you arrive. We encourage you to read the privacy policy of any site you visit.

22 Changes to This Policy

We may update this policy as the site develops. When we do, we will change the "Last updated" date at the top of this page.

If we begin collecting a category of information not described in Section 4, or begin using information for a purpose not described in Section 6, we will update this page before that change takes effect, and where the change is material we will show the notice again so that returning visitors see it. We will not make a material change quietly and rely on the date stamp to have told you.

The same applies if the activities of the site broaden — additional artists, curatorial or publishing projects, online sales, or anything else that changes what we collect or why. The commitments in Section 9.1 and Section 10 about not selling personal information and not admitting advertising or analytics vendors are not contingent on how the business develops; if we ever intended to depart from them, we would say so here first and prominently, not adjust a sentence and hope it passes.