1. Who we are
Whole Life Story is run by VirtualCup Solutions, Dona Aurora 3rd Street, Block 3, Digos City, Davao del Sur, Philippines. We decide how the personal information described here is used, which makes us its personal information controller under the Data Privacy Act.
2. Whose information this covers
A memorial page is about someone who has died, but the people around the page are living, and this policy is mostly about them:
- people who order a memorial piece;
- family members who have an account and help look after a page;
- people who leave a message or light a candle on a page;
- staff of funeral homes, memorial parks and other partners who work with us;
- anyone who visits a page.
The Data Privacy Act lets the lawful heirs of a person who has died exercise that person’s rights. Section 10 explains how to reach us.
3. What we collect and why
If you order a memorial piece
- Your name and phone number, to confirm the order, arrange delivery and collect cash on delivery. When the claim code from your order is redeemed, we notify this number.
- Your email address, if you give one.
- The delivery address and any delivery notes, such as where the wake is.
- What you ordered, the text to engrave, and the proof you approved, with who approved it, when and how. This is our record if an engraving is ever disputed.
- Payment records: the method, amount and status, and for online payments the reference from our payment provider. We never receive your card details.
- The version of this policy shown to you when you ordered.
If you have an account
- Your name and email address, and your phone number if you give one.
- The pages you are a member of and your role on each, and the invite link you joined through.
- For each sign-in, the IP address and browser it came from, to keep your account secure.
- When you accepted these terms and this policy, and which versions.
What families add to a page
The story, dates, photos, recordings, documents, video links, captions and milestones. For every photo we keep the file exactly as it was uploaded, because it may be the last full-resolution copy, along with a smaller copy for display. Any details your phone or camera stored inside the original file, such as when or where a photo was taken, stay in that file.
If you leave a message or light a candle
- For a message: your name, how you knew the person if you say, and your message. Your email address is optional. It is never shown on the page and never included in the family copy.
- For a candle: your name, if you give one. It is shown only to the page’s family members. Everyone else sees only how many candles were lit.
- A scrambled form of your IP address, and for messages your browser type, to stop spam and abuse. We scramble the address with a secret key (a keyed hash), so it can’t be turned back into the original address.
- For messages, the version of this policy shown to you.
If you visit a page
We limit how often a page can be requested from one connection, using the same scrambled form of your IP address. We count page views and QR code scans as totals, not per person. If a page fails to load, our error reporting receives technical details about the failure, such as the page address and browser.
The record of changes
Every change to a page is recorded: what changed, when, and who made it. Each entry keeps a copy of that person’s name and email address and the scrambled form of their IP address. The record can’t be edited or deleted, and entries stay even if the person later deletes their account, because it is how disagreements about a page are settled.
Partners and feedback
For partners we keep the business’s name and location and a contact name and phone number. Orders and pages record which partner brought them in, so commissions are paid from records. If you send us feedback, we keep your message and your email address if you give one.
4. Why we are allowed to use it
- Your consent, when you create an account, order a piece or leave a message. We record which version of this policy you agreed to.
- Our agreement with you, to make and deliver what you ordered and to keep the page you manage.
- Legitimate interests: keeping accounts secure, stopping spam and abuse, and keeping the record of changes that settles disagreements.
- Legal obligations, such as keeping order and payment records for tax purposes.
5. Who can see what
The person’s name, portrait, dates, epitaph and resting place are always visible to anyone with the page’s address or code. They repeat what is written on the headstone.
Every other section, such as the story, photos, milestones, recordings and messages, has its own setting, chosen by the family:
- Public: anyone who opens the page.
- Family: members of the page, and anyone who enters the page’s family code. The family code is short, so it can be said aloud at a wake. We store it encrypted, so members can read it back to relatives, and we limit how many times it can be tried. Some pieces that stay with one person, such as a pendant, can be set so that scanning them also opens the family sections.
- Members: only signed-in members of the page.
- Hidden: not shown on the page at all.
A page’s address is made from the person’s full name, so anyone can guess it. The section settings, not the address, are what keep private material private.
Pages are unlisted unless the family chooses otherwise: we tell search engines only about pages a family has made public. Messages appear only after the family approves them.
Our own staff can see what they need to run the service: to make and deliver orders, help families, and settle disagreements.
7. How long we keep it
- When something on a page is deleted, such as a photo, a message or the whole page, it can be restored for 90 days. After that it is deleted permanently.
- When a whole page is deleted, we keep its web addresses, which are made from the person’s name, and its QR codes, so they keep showing a notice that the page was taken down and are never given to anyone else.
- Accounts are kept until you delete yours. Deleting it removes your membership of every page. Entries about you in the record of changes stay, as described in section 3.
- Sign-in records are kept while the sign-in is active.
- Order and payment records are kept for as long as tax and accounting law requires.
- The scrambled IP addresses used to limit requests expire within minutes. Those stored with a message or candle are kept with it.
8. The family copy and the public copy
The family copy
The owner of a page can download a copy of all of its content at any time, as a ZIP file, including sections kept private, because the content is the family’s. It doesn’t include other people’s personal information that the family doesn’t need, such as the email addresses of people who left messages or scrambled IP addresses.
The public copy
We keep a simple copy of every page’s public sections on plain file storage, so the pages can stay online even if Whole Life Story ever closes or is sold. It holds public sections only. Sections a family keeps private are never published there. The copy is updated as the page changes, and when a section stops being public, it is removed from the copy.
9. How we protect it
- Connections to Whole Life Story are encrypted.
- Family codes are stored encrypted.
- IP addresses are stored only in scrambled form, except in sign-in records, which keep your account secure.
- Invite links and claim codes are stored only in scrambled form, so a copy of our database can’t be used to redeem them.
- Family codes, sign-ins, messages and QR scans are all limited in how often they can be tried.
10. Your rights
Under the Data Privacy Act you have the right to:
- be told how your personal information is used, as this policy does;
- see the personal information we hold about you;
- have it corrected;
- object to how it is used, or withdraw consent you gave;
- have it deleted or blocked;
- receive a copy of it in a format you can reuse;
- complain to the National Privacy Commission, and claim damages if your rights were violated.
To exercise a right, contact us using the details in section 13. Some things we can’t delete, such as entries in the record of changes and order records the law requires us to keep. We will tell you when that applies.
12. Changes to this policy
When this policy changes in a way that matters, we publish a new version and update the version and date at the top of this page. We record which version each person agreed to, and we may ask you to agree to the new one.
13. Contact us
VirtualCup Solutions
Dona Aurora 3rd Street, Block 3, Digos City, Davao del Sur, Philippines
Not decided yet
Who our Data Protection Officer is, and their contact details, has not been confirmed. Until it is, this section is a placeholder and nothing in it is policy.