About Time Holding B.V., About Time Software B.V. and About Time B.V., trading as About Time (hereinafter: AT, we, us or our) has a website (www.about-time.eu), a webshop, an Online Condolence Register and an application.

At About Time, you can enter all information about your farewell and estate in the application.

Your loved ones will then have a handy overview of all your wishes.This privacy statement tells you what personal data we process about you and what we do with it.

Our privacy and cookie statement, in short 'your privacy', is very important to us.We therefore comply with the General Data Protection Regulation (AVG).

This means that we:

• Clearly define our purposes before we process your personal data, through this privacy and cookie statement.
• To store as little personal data as possible for our own purposes (being able to provide you with the right service). You then decide what else you want to store for your confidants and next of kin. Please note that you are responsible for this yourself at all times.
• Explicitly request permission to process your personal data, should permission be required.
• Take the necessary security measures to protect your personal data.
• We also impose these obligations on parties processing personal data for us.
• Respect your rights, such as the right to inspect, correct or delete your personal data processed by us.

We obtain various personal data from you. For each purpose, we indicate which process these data and for how long they are kept.

If you have any questions or want to know exactly what we keep track of you, please contact us or check here for the frequently asked questions (at the bottom you will find the contact form).

When you fill in the contact form on the website or contact us in another way, you accept our offer to get in touch with us (execution of the agreement).

For this purpose, we process the following personal data:

• Name
• Contact details (e-mail address and telephone number)
• Any information you enter yourself as content of a message. We store these contact moments with the personal data provided by you for the purpose of carrying out the contact and possibly handling your question/comment/complaint. We store this information for as long as necessary for this contact or up to 2 years after we last had contact with you, because we want to make sure we have handled your question or complaint properly.

You can download our mobile application from the App Store or from Google Play.

We have no influence on which personal data the provider (Apple or Google) processes these and for what purpose.

We therefore recommend that you read the relevant privacy and cookie declarations of the relevant provider.

Through the app, you can use our services (performance of the agreement).

For this purpose, we process the following data:

• Name
• Login data
• Contact details (e-mail address and telephone number)
• Location data. We store your data for as long as you have a valid credit for using the application or for up to 1 month after your credit expires because we will then assume that you no longer want to use our services.

Or we keep your data until you delete your account. We keep some data longer if we are legally obliged to do so (e.g. because of the 7-year tax retention obligation).

It is possible to create an account on our website, for the Online Condolence Register and via the application. If you have an account, you can then use our services. We need your data to provide the services (execution of the agreement).

For this purpose, we process the following personal data:

• Account data
• Your name
• Gender
• Contact details (e-mail address and telephone number)
• Purchase details, such as type of product and date of purchase. Payment is made via Google and/or Apple, payment details may also be recorded there.
• Messages, texts and wishes that can be included in the mobile application
• All information in the context of a farewell
• All information in the context of a legacy
• Music
• Visual material
• Logging of (all) activities
• Click and viewing behaviour website and application, but not traceable to an individual.

Within your account, you can specify which confidants you appoint, but also, for example, which people you would like to have at your funeral. You can enter data about others in the mobile application. This means that we also process their personal data. We process that data based on the legitimate interest, namely us.

To this end, we process the following personal data:

• Name
• Gender
• Contact details (e-mail address and telephone number)
• Messages, texts and wishes that can be included in the application
• All information in the context of a farewell
• All information in the context of a legacy
• Images (commercial) messages. Through our website and application, you can subscribe to AT's newsletter (consent).

We periodically send a newsletter by e-mail containing news items about arranging a farewell and estate. When you use our application, you can choose to have us send you notifications. For example, you can receive a notification when a new message is ready for you within the application.

This notification will then appear on your device. We process the following personal data for this purpose:

• Name
• E-mail address
• Unique user ID

We keep your data until you unsubscribe from receiving (commercial) messages. User experiences and reviews. You have the opportunity to share your experience about our service.

You can also leave a review, this allows us to improve our services, and you inform others about our services. We process your personal data on the basis of legitimate interest.

This is because we have a commercial interest in improving our services.

Our commercial interest prevails over your privacy interest, given that you decide whether you want to share your experiences or leave a review, and what information you provide.

For this purpose, we process the following personal data:

• Name
• E-mail address

Content of the user experience/review. We keep this data for a maximum of 10 years after you have shared your experience or left the review.

Would you like to bring your company to the attention of our users? Then you can promote your company through our network (execution of the agreement).

To do this, we process the following personal data:

• Name
• Contact details
• Job title
• Business data
• Address data
• Invoice details
• Any information you enter yourself as message content

We store this data for the duration of the cooperation, or 2 years after you have indicated that you want to become a cooperation partner.

We keep some data longer if we are legally obliged to do so (e.g. because of the tax retention obligation of 7 years).

When are we allowed to share your personal data with third parties?

AT only shares your data with third parties when this is permitted under current legislation.

We may provide your personal data to third parties because:

• we have engaged them to process certain data;
• we have a legal basis to do so;
• we are legally obliged to do so (e.g. if the police require this in case of suspected crime).

The parties that process personal data on our or your behalf are:

• IT suppliers
• Cookie service providers
• Payment service providers
• Marketing companies
• Tax authorities
• Insurance companies
• Third parties involved in a farewell, funeral or estate
• Partners and external consultants

Some of our suppliers are located outside the European Economic Area ("EEA"). In such cases, we ensure that appropriate safeguards are in place to protect your privacy.

This privacy and cookie statement applies only to AT's services.

We are not responsible for the privacy practices of other websites, which can be accessed via a link on our website. We are also not responsible for the privacy policies of Apple or Google, where the app can be downloaded via the stores.

On our website we use social media buttons, which direct you to the relevant social media platforms.

This gives you the option to follow us and share content within the network. You will also see advertisements on your social media page.

The buttons work because of pieces of code coming from the social media networks.

If you want to know what the social media platforms do with your personal data, please read the relevant privacy statement:

• Facebook (Privacy Policy Meta)
• X (Privacy Policy)
• Instagram (Data Policy)
• Pinterest (Privacy Policy)
• YouTube (Privacy Policy)
• LinkedIn (Privacy Policy)

On our website, we use cookies from ourselves and from third parties.

Cookies are information files that can be automatically stored on or read from the visitor's device (such as PC, tablet or smartphone) when visiting a website.

This is done via the web browser on the device.

We use the following types of cookies:

• Functional cookies: these cookies have a functional role within the website. The cookies ensure that the website functions properly.
• Analytical cookies: these cookies give us insight into how our website is used. Based on this information, we can make our website more user-friendly.

The cookies may collect the following data from you, among others:

• Cookie ID
• Website and click behaviour
• Referrer URL

When you visit our website for the first time, we display a message explaining cookies.

To the extent required, we will ask for your consent to the use of cookies.

You can click on the Cookie icon at the bottom left of the site at any time, then you can adjust your cookie settings and also see which cookies have all been set in your case.

PV/MARKETING

These cookies are used to record the website visitor's actions on the website after viewing or clicking on ads.

The purpose is to measure effectiveness and show (personalised) ads.

Maximum 6 months Turning cookies on and off Your web browser allows you to set it to accept the storage of cookies only if you agree.

For more information, please consult your browser manual. Please note that many websites do not work optimally when cookies are disabled.

Deleting cookies

Most cookies have an expiry date. If an expiry date is set, the cookie is automatically deleted when the expiry date expires. You can also choose to delete cookies manually before the expiry date. Please consult your browser manual to do so.

Personal data security is very important to us.

We therefore take appropriate technical and organisational measures with regard to the processing of personal data to be performed, against loss or against any form of unlawful processing (such as unauthorised access, impairment, modification or disclosure of the personal data).

We constantly update security and pay close attention to what can go wrong.

• Right to inspection: you have the right to inspect the personal data we process about you.

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  Right to rectification: you have the right to correct or supplement the personal data we process about you if it is inaccurate or incomplete.

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  Right to object: you can object to the processing of your personal data, including direct marketing.

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  Right to erasure: you can request us to delete your personal data.

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  Right to withdraw your consent: if you have given us consent to process personal data, you can withdraw this consent at any time.

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  Right to data portability: if it is technically possible, you have the right to have the personal data we process about you transferred to a third party.

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  Right to restrict processing: in some cases, you can request us to restrict (temporarily or otherwise) the processing of your personal data. When making your request, we may ask you to identify yourself. For this purpose, we request data to ensure that you are the correct person to whom the personal data belongs. In principle, we will comply with your request within one month. However, this period may be extended for reasons related to specific privacy rights or the complexity of the request. If we extend this period, we will notify you in good time.

If you wish to exercise any of your rights, you can notify us via this form. 

When our services change, we naturally also have to amend the privacy and cookie statement. So always note the date at the top of this document and check regularly for new versions.

If you have any questions or would like to make a complaint about the use of your personal data, please use this form.

We handle and respond to every question and complaint internally and communicate this further with you.

If you feel we are not helping you in the right way, you have the right to lodge a complaint with the regulator, the Personal Data Authority.

For the correct procedure and details, see the website of the Personal Data Authority.

https://www.autoriteitpersoonsgegevens.nl/contact