JB Memorials is a trademark of Bejora Trading V.O.F. , hereafter referred to as Bejora Trading.

1. What information we collect and how we do it

How do we collect information about you?

During any interaction that you may have with Bejora Trading V.O.F. we collect information in two possible ways:

When you give it to us directly (Direct Data)
When you visit our website, you register for an account, you buy products from us, or you communicate with us, you can consciously choose to provide us with information – for example, by filling out textboxes, or by clicking active buttons, such as “add to shopping cart”. For all this information, a direct action from your side is needed for us to collect and/or process your data.
When our system collects information of data from you, because you are using our website. (System Data)
When you visit our website, it will automatically save information that we need for our website to function. This information is stored in the form of cookies. Below you can see which information we collect from you.

What information do we collect, why do we do this and what do we use this information for?

What are cookies?

A cookie is a small text file that is downloaded onto your device (for example your computer or your smartphone) when you visit a website. This allows the website to recognize your device and save information about your preferences or actions you have taken in the past to improve your shopping experience.

We use Cookies when you visit our website. There are 4 main types of cookies, we use 3 of these types – you can read how and why we use them here:

Cookies for site functionality – these cookies ensure you can navigate through our site and you can use our functions, like “Add to shopping cart”.
Site analytics cookies – these cookies allow us to track and analyse how our customers use the site, to improve functionality as well as your shopping experience.
Cookies for customer preferences – when you use our website, the cookies will remember your preferences (like your language or location), so we can give you a more personalised shopping experience).
Targeting or advertising cookies – we do NOT use these types of cookies.

By using our website, you agree that we can place the first three types of cookies on your device and that we use these when you visit our website in the future. If you want to delete the cookies that are already on your computer, please visit the “help” section in your browser instructions to locate the file or folder that the cookies are stored in. Take into account that by deleting or turning off future cookies, your user experience on this website may be influenced.

Our Cookies collect 2 types of information:

"Personally identifiable" information (which means it can be used to identify you specifically) or “Non-personally identifiable” information (which means the information concerns you but cannot be used to identify you personally, i.e. anonymous data like for example your unique customer number.)

In this policy (where we are explaining the different types of information we collect about you) we do our best to confirm whether it concerns personally identifiable or non-personally identifiable information.

The simplest way to explain the specific information that we collect from you, is by looking at every type of interaction with Bejora Trading V.O.F., because different types of information are collected at different stages during your visit as a user or as a customer. These points of interaction comprise of the following:

Action	Collected Information	Direct Data/System Data	Personally Identifiable Information?
Browsing our website	Whether you are logged in or not, the cookies and code on our website will track your IP-address, your location, the type of device you are using and the browser that you use. Cookies also track the date and time of your visit, the pages of the site you visit and the length of your visit to those pages.	System Data	No
Registering an account	To register for an account, you need to provide us with your name, the name of your company, an email address and a password, all of which you enter directly.	Direct Data	Yes
Logging in to your account after you have registered	When you log in, you need to fill in your email address and your password so our systems can log you in to the correct account.	Direct Data	Yes
Making a purchase (including adding/deleting items from your shopping cart)	You need to personally click on active buttons to add or delete items from your shopping cart, or to adjust the number of items in the shopping cart. This is tracked by cookies so the items stay in your shopping cart when you are navigating through the website. When you proceed to payment, you must also choose a shipping method. You must also fill in a billing address, a shipping address, and credit card-/ bank account details, depending on which payment method you have chosen. When you click “ok” to confirm your order, this information will become available in the “My Account” section.	Direct Data	The information that is collected when items are added / deleted from your shopping cart and the information about shipping methods are not personally identifiable. Payment information and shipping and billing information, however, are personally identifiable.
Contacting our customer service	When you get in touch with our customer service, we need to verify that you are the accountholder to prevent any fraudulent activity. To verify your identity, we have to ask you questions about your account that identify you personally. Information about your search can also be saved, so we can look into the matter and find a fitting solution.	Direct Data	Yes
Contacting us via Social Media	When you contact us through Social Media, we can access the information linked to your profile that you have chosen to share with us. This can be limited by your privacy settings on the platform itself. If you ask us a question about your order, we can ask for your email address and order number to verify with whom we are speaking before we release any information about the order in question.	Direct Data	Yes
Clicking on Bejora Trading-banners and hyperlinks from our paid advertisements.	If you look at emails we have sent you, or click on hyperlinks or plug-ins that we have placed on our website or on other websites, both that you clicked and which website you clicked from will be tracked. We will use this information to track and analyse how successful these emails, banners, hyperlinks or plugins are.	Direct Data	No

2. How do we use your information?

A few applications for specific types of data have already been discussed above. We often have to use many different types of information or data to ensure we can provide you with our services, however. These more fundamental goals comprise of the collective use of your information. You can also consult the processing register at the bottom of the page. Here you will find a more detailed description of which information we collect, share, with what purpose, with whom, for how long and if this happens inside or outside of the EU.

To ensure that our website-content is presented to you effectively, so you can easily navigate and perform actions, such as adding or deleting items from your shopping cart.
To contact you via telephone to ensure you are satisfied with the received products and services.
To create and manage your account, so you can place orders and we can deliver products and services, such as keeping you informed on the progress of your order and offering customer service when you need it.
To ensure that our customers are real and to ensure we get paid for the goods we ship.
To generate and send invoices.
The email address will be given to our courier service My Parcel / PostNL, who will use this information to send you updates on your order and an estimated time and date of delivery.
To send you updates on our latest products, news and special offers – if you have chosen to receive our marketing communication, we will occasionally keep you informed as to our latest products, news and special offers via email. If you want to stop receiving these communications at any time, please contact our customer service so we can unsubscribe you from these emails.
To send important notices on changes in our service, such as a change in policy, availability of delivery times, security or any other issues that may arise in the functioning of Bejora Trading. You will receive service messages even if you have unsubscribed, because they usually contain important information about your account, security or services of which we are obliged to inform you. This is the reason it is not possible to reject service emails.
To collect your feedback via polls, surveys and analysis, so we can improve the products and services we offer you.

Transfering your data

Some of the information we collect from you, can be transferred to and saved in a destination outside of the European Economic Area (EEA). This is the case for emails that are saved in the cloud at Google. This data is protected by SSL, a strong password, 2-step verifications and the data is encrypted. There is also data that is tracked by Google Analytics, this concerns anonymised data. Google Analytics does not track or save personalised data. They do not profile groups or individual clients. No shared data is shared with Google itself.

How do we share the information we collect?

To ensure the proper functioning of our company, we have to collaborate with a number of external companies such as My Parcel / PostNL for deliveries. In cases where we have to process your data through a third party, we will always protect your information and ensure that these data processers also comply with all relevant laws and regulations related to data protection.
As a company that operates across different countries, Bejora Trading is obliged to comply with legal requests for data from regulatory bodies or law enforcement agencies.
If we have reason to believe that you are involved in fraudulent or illegal activity or if you have wrong intentions with Bejora Trading, our employees or one of our customers, we will take the necessary action to protecting our security and services by working with law enforcement agencies or regulatory authorities. This can mean we share your information with these parties.

How we do NOT use your information

We will never share your data with external advertisers or advertising networks
We will never sell your data.

Your personal data will be treated as private and confidential under all circumstances and your data will not be shared with other parties outside of those in the conditions of this privacy policy, unless:

We are legally obligated to do so; or
We have explicitly asked for your permission and you have given us your permission to do so.

3. Your option and choices

Your options and choices when it comes to the data we keep about you and/or your company.

Updating your contact preferences – You can check what data you have shared with us by contacting our customer service. Our security procedures mean we can ask for proof of ID, before we release any information, such as your email address or the address of your business.
Updating your personal data – You can contact our customer service to change, correct or delete the personal data in our systems whenever you want.
Updating your marketing preferences – If you have subscribed to receive our newsletter, we will occasionally send you information via email or post related to our products or services that we think may be of interest to you, such as exclusive offers.
You can choose to opt out of marketing communication at any time.
If you only want to unsubscribe to our email marketing, take one of the following actions:

Click on the “unsubscribe” link in one of the marketing emails that we send you,

Email: info@jbmemorials.nl

As soon as you have completed one of the following actions, we will update your profile to ensure you do not receive any further marketing emails or communication.

Take into account that it could take several days before all of our systems have been updated and that you may receive a small number of emails from us while we are processing your request.

Closing your account – You can close your account by contacting our customer service. If you choose to close your account, it will be deactivated within 28 working days. Take into account that the Tax Authorities oblige us to keep registration of all transactions for 7 years, so we can use archived copies of your data for this purpose.
Requesting a copy of your personal data – You can ask for a copy of the personal data we keep about you in our systems at any time. If you would like this, please contact our customer service, who can help you with your query. We do not charge you for this, but we might have to ask you some questions to confirm your identity before we provide you with any information.

If you would like to file a complaint about the way we deal with your data and information, you can contact the Data Protection Authority (Autoriteit Persoonsgegevens).

4. Protecting your data

Protecting your data.

We always strive to protect your information. As soon as we have received your information, we use different security functions and procedures, taking into account industry norms, to try and protect the information you give us and to prevent unauthorised access to that information.

For example:

We offer secured "https" –access to all parts of our website
Access to your data on our website is secured with a password and sensitive data (such as credit card information) are protected by SSL-coding when it is exchanged between your web browser and the payment systems that we use.
We use long passwords with capitals and small letters, numbers and special characters.
Where possible we use 2-step verification to prevent access to your account in case an account might be hacked.

At Bejora Trading we do everything we can to protect your personal data. There are a number of precautions you can take to help us with this, however. You can keep your account safe by using a strong password that contains capitals and small letters, as well as numbers and special characters. We advise you not to use the same password for all or many of your online accounts.

5. Contacting us about your data.

Contacting us

If you have any questions or feedback about this declaration, or if you want us to stop processing your information or want to change the information we have about you, please do not hesitate to get in touch with our customer service. We are here to help.

E-mail: info@jbmemorials.nl

6. The Processing Register

Below you will find an overview of all data we collect when you use our website and about the data we save, as well as the data our partners save.

First Name and Surname
Processer:	When:	Goal:	Duration:	Security:	Outside EU:
CCV Shop	Order	To ensure your delivery and all communication are sent to the correct address.	7 years	SSL and strong password	No
CCV Shop	Contactform	To ensure your delivery and all communication are sent to the correct address.	7 years	SSL and strong password	No
My Parcel	Shipment	To ensure the parcel is sent to the correct address.	See agreement chapter 7	SSL and strong password	No
Sisow	Payment	To ensure the parcel is sent to the right address.	See agreement chapter 7	SSL and strong password	No
Google G Suite	Sending / Receiving Emails	We use Google G Suite for all of our email traffic and all emails are saved in the cloud there. This includes all data related to your order, name and address data that were entered when you placed your order, any communication between us and the customer and all data that a customer willingly provided us with, such as personal data in an email signature.	7 years	SSL, strong password, 2-step verification and encryption of the content of these emails.	Yes
Bejora Trading (us)	Invoice for bookkeeping	We collect all purchase and sales invoices in folders. We need to save these for bookkeeping and tax purposes.	7 years	These folders are kept in a filing cabinet that is locked away from the public.	No

Address
Processer:	When:	Goal:	Duration:	Security:	Outside EU:
CCV Shop	Order	To ensure your delivery and all communication are sent to the correct address.	7 years	SSL and strong password
My Parcel	Shipment	To ensure the parcel is sent to the correct address.	See agreement chapter 7	SSL and strong password
Google G Suite	Sending / receiving emails	We use Google G Suite for all of our emailing traffic and all emails are saved in the cloud there. This includes all data related to your order, name and address data that were entered when you placed your order, any communication between us and the customer and all data that a customer willingly provided us with, such as personal data in an email signature.	7 years	SSL, strong password, 2-step verification and encryption of the content of these e-mails.
Bejora Trading (us)	Invoice for bookkeeping	We collect all purchase and sales invoices in folders. We need to save these for bookkeeping and tax purposes.	7 years	These folders are kept in a filing cabinet that is locked away from the public.

Phone Number
Processer	When:	Goal:	Duration:	Security:	Outside EU
CCV Shop	Order	This is not a compulsory field. The client can choose themselves whether they would like to be contacted by us over the phone.	7 years	SSL and strong password	No
Google G Suite	Sending / Receiving Emails	We use Google G Suite for all of our email traffic and all emails are saved in the cloud there. This includes all data related to your order, name and address data that were entered when you placed your order, any communication between us and the customer and all data that a customer willingly provided us with, such as personal data in an email signature.	7 years	SSL, strong password, 2-step verification and encryption of the content of these e-mails.	Ja

Emailaddress
Processer:	When:	Goal:	Duration:	Security:	Outside EU:
CCV Shop	Order	To ensure your delivery and all communication are sent to the correct address.	7 years	SSL and strong password	No
CCV Shop	Contactform	To be able to answer and address a response appropriately.	7 years	SSL and strong password	No
My Parcel	Shipment	To inform the customer of the status of the delivery, a track and trace link will be sent.	See agreement chapter 7	SSL and strong password	No
Google G Suite	Sending / Receiving Emails	We use Google G Suite for all of our email traffic and all emails are saved in the cloud there. This includes all data related to your order, name and address data that were entered when you placed your order, any communication between us and the customer and all data that a customer willingly provided us with, such as personal data in an email signature.	7 years	SSL, strong password, 2-step verification and encryption of the content of these e-mails.	Yes

IP address
Processer:	When:	Goal:	Duration:	Security:	Outside EU:
CCV Shop	When you visit the website	The IP-address is saved when a customer places an order or when someone visits the website so the user can be blocked from using the website in cases of fraud or misuse of the website or our services.	See agreement chapter 7	SSL and strong password	No

Bank details
Processer:	When:	Goal:	Duration:	Security:	Outside EU:
Sisow	Payment	Sisow is our payment provider and needs this information to process the payment.	See agreement chapter 7	SSL and strong password	No

Device data and surfing behaviour
Processer:	When:	Goal:	Duration:	Security:	Outside EU:
Google Adwords and Analytics	When you visit our website	This is so we can analyse how visitors use our website and the visitor’s surfing behaviour. It allows us to track which advertisements people click on most and which ones lead to the most sales.	See agreement chapter 7	SSL, strong password, 2-step verification and encryption of the content of these e-mails.	Yes
Team Nijhuis	When you visit our website	Team Nijhuis manages our Adwords and Analytics account, they are in charge of advertisements on Google and Google Shopping. They need this data to make more targeted advertisements. All data in Analytics and Adwords is anonymised. They do not profile groups nor do they create profiles of individual clients based on this information. We do not engage in remarketing, our ads will not follow the client after they have visited our website.	See agreement chapter 7	SSL and strong password	No
CCV Shop	When you visit our website	CCV collects this information so we can analyse the visitors’ surfing behaviour. It allows us to see, for example, how many visitors we have had, which products are popular, and from which devices the visits took place.	See agreement chapter 7	SSL and strong password	No

Personal files and photos of customers.
Processer:	When:	Goal:	Duration:	Security:	Outside EU:
CCV Shop	Order	A lot of our products allow photos or fingerprints to be engraved onto them. The customer has to upload these when they place an order so we can process them.	See agreement chapter 7	SSL and strong password
Bejora Trading (us)	Order or forwarded via email	A lot of our products allow photos or fingerprints to be engraved onto them. The customer has to upload these when they place an order so we can process them. We save these for when the customer wants to order the same product again at a later date or when they want a different product, but with the same photo.	7 Months maximum. Every 6 months we delete all photos, documents and engraving- and design files from our system.	SSL, strong password, 2-step verification and encryption of the content of these e-mails. Our computers are password-protected and have a Firewall and an Anti-virus software.	When documents are sent via email, they are saved in the Google Cloud, which is outside of the EU.

7. Processing agreements third parties

CCV
Google
My Parcel
Team Nijhuis
Sisow
ING Bank
Facebook
Oracle – AddThis

8. In case of a data breach

No matter how well we do our jobs, there is always a risk of a data breach. This can happen due to a mistake on our part or entirely outside of our control. Any situation in which personal data is lost or ends up in the wrong hands, constitutes a data breach.

When we discover a data breach, we must act immediately. First we investigate which personal data it concerns. If there is any potential that the breach influences your rights and freedoms, we will report the breach to the Data Protection Authority (Autoriteit Persoonsgegevens). If there is an increased risk, you will be informed immediately.

We also thoroughly investigate the breach. We figure out what exactly happened, which data was endangered, who could be behind them, and how we can prevent it in the future. This way we can improve our security. We also carefully record all our findings about the breach, so we can learn from it at a later date as well.

Reporting the data breach

Do you suspect a breach of data? Then we would like to know as soon as possible. Including the reasons or signals that led you to believe there is a leak.

Send an email to: info@jbmemorials.nl

9. Changes in this policy

From time to time we may review and update this privacy policy. If there are important changes in the privacy policy or in how we handle your personal data, we will make that clear by communicating the changes on our website and contacting you via email to explain the changes.

This page was last updated on May 21, 2018.