PRIVACY POLICY

 

This Privacy Policy has been drawn up in accordance with the General Data Protection Regulation (GDPR – EU 2016/679) and the Dutch Implementation Act (UAVG). We process your personal data exclusively in a lawful, fair and transparent manner.

Zavory B.V. attaches great importance to the protection of your privacy and the careful handling of your personal data. In this Privacy Policy we explain what personal data we collect, why we process it, how long we retain it and what rights you have.

This policy applies to all personal data we process in connection with:

•        Visiting our website.

•        Creating an account or placing an order.

•        Contacting our customer service.

•        Receiving our newsletter or marketing communications.

We are the data controller within the meaning of the GDPR. This means we determine which personal data is collected and for what purpose.

 

Zavory manages this store and website, including all related information, content, features, tools, products and Services, to provide you, the customer, with a personalised shopping experience (the 'Services'). Zavory is Powered by Shopify, enabling us to provide the Services to you. This Privacy Policy describes how we collect, use and disclose your personal information when you visit, use or make a purchase or other transaction through the Services, or otherwise communicate with us. If there is a conflict between our Terms of Service and this Privacy Policy, this Privacy Policy will prevail with respect to the collection, processing and disclosure of your personal information. Please read this Privacy Policy carefully. By using and accessing the Services, you indicate that you have read this Privacy Policy and that you understand the collection, use and disclosure of your information as described in this Privacy Policy.

2.1 Data You Provide Directly

We collect personal data that you actively provide to us, for example when placing an order, creating an account or contacting us:

•        First and last name

•        Email address

•        Phone or mobile number

•        Billing and delivery address

•        Payment details (encrypted and processed via our payment provider)

•        Account details (username, password — stored encrypted)

•        Content of messages sent via our contact form or by email

2.2 Data Collected Automatically

When you visit our website, we automatically collect certain technical data:

•        IP address and device information (browser type, operating system)

•        Pages visited and click behaviour on our website

•        Search terms used on our website

•        Date and time of your visit

•        Referring website (referrer URL)

•        Cookie IDs and similar tracking technologies (see our Cookie Policy)

2.3 Data from Third Parties

In some cases we receive personal data from third parties, for example:

•        Address verification data from payment providers (e.g. Stripe, Mollie, PayPal).

•        Data from social media if you sign in via a social media account (e.g. 'Sign in with Google').

•        Fraud prevention information from payment processors.

2.4 Sources of Personal Information

We may collect personal information from the following sources:

•        Directly from you including when you create an account, visit or use the Services, communicate with us, or otherwise provide us with your personal information;

•        Automatically through the Services including from your device when you use our products or Services or visit our websites, and through the use of cookies and similar technologies;

•        From our service providers including when we engage them to facilitate certain technology and when they collect or process your personal information on our behalf;

•        From our partners or other third parties.

2.5 How We Use Your Personal Information

Depending on how you interact with us or which of the Services you use, we may use personal information for the following purposes:

•        Providing, customising and improving the Services. We use your personal information to provide you with the Services, including to perform our agreement with you, to process your payments, to handle your orders, to remember your preferences and items you are interested in, to send you notifications related to your account, to process purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange shipping, to facilitate any returns and exchanges, to enable you to post reviews, and to create a tailored shopping experience for you, such as recommending products related to your purchases. This may include using your personal information to better customise and improve the Services.

•        Marketing and advertising. We use your personal information for marketing and promotional purposes, such as sending marketing, advertising and promotional communications by email, SMS or post, and to show you online advertisements for products or Services on the Services or other websites, including based on items you have previously purchased or added to your shopping cart and other activities on the Services.

•        Security and fraud prevention. We use your personal information to verify your account, to provide a secure payment and shopping experience, to detect, investigate or take action against potentially fraudulent, illegal, unsafe or malicious activities, to protect public safety and to secure our Services. If you choose to use the Services and register an account, you are responsible for keeping your account login credentials secure. We strongly advise you not to share your username, password or other access credentials with anyone else.

•        Communicating with you. We use your personal information to provide you with customer support, to respond to you, to provide you with effective Services and to maintain our business relationship with you.

•        Legal reasons. We use your personal information to comply with applicable law or to respond to valid legal processes, including requests from law enforcement or government agencies, to investigate or participate in civil discovery, potential or actual litigation or other adversarial legal proceedings, and to enforce or investigate potential violations of our terms or policies.

2.6 How We Disclose Personal Information

In certain circumstances, we may pass your personal information to third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:

•        With Shopify, vendors and other third parties that perform Services on our behalf (e.g. IT management, payment processing, data analytics, customer support, cloud storage, fulfilment and shipping);

•        With business and marketing partners to deliver marketing Services and to advertise to you; for example, we use Shopify to support personalised advertising with third-party Services based on your online activities across different merchants and websites. Our business and marketing partners will use your information in accordance with their own privacy notices. Depending on where you live, you may have the right to ask us not to share information about you to show you targeted advertising and marketing based on your online activities across different merchants and websites.

•        When you instruct us, request or otherwise consent to us providing certain information to third parties, such as to ship your products or through your use of social media widgets or login integrations.

•        With our affiliates or otherwise within our group of companies.

•        In connection with a business transaction such as a merger or bankruptcy, to comply with applicable legal obligations (including responding to subpoenas, search warrants and similar requests), to enforce applicable Terms of Service or policies, and to protect or defend the Services, our rights and the rights of our users or others.

2.7 Relationship with Shopify

The Services are hosted by Shopify, which collects and processes personal information about your access to and use of the Services in order to provide and improve the Services for you. Information you submit to the Services will be transmitted to and shared with Shopify, as well as third parties that may be located in countries other than where you reside, to provide and improve the Services for you. Additionally, to help protect, grow and improve our business, we use certain Shopify enhanced features that contain data and information derived from your interactions with our store, together with other merchants and with Shopify. To provide these enhanced features, Shopify may use personal information collected about your interactions with our store, together with other merchants and with Shopify. In these circumstances, Shopify is responsible for processing your personal information, including responding to your requests to exercise your rights regarding the use of your personal information for these purposes. To learn more about how Shopify uses your personal information and about any rights you may have, please visit the Shopify Privacy Policy for customers at https://www.shopify.com/legal/privacy/app-users. Depending on where you live, you may exercise certain rights regarding your personal information at the Shopify Privacy Portal: https://privacy.shopify.com/en.

2.8 Third-Party Websites and Links

The Services may contain links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated with or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed in the Services.

The table below provides an overview of the personal data we process, including the purpose, legal basis and retention period.

 

Category	Data	Purpose	Retention Period
Order data	Name, address, email, payment	Performance of contract	7 years (statutory)
Account data	Name, email, password	Account management	Until account deletion
Customer contact	Name, email, message content	Customer service	2 years
Newsletter	Email address, name	Direct marketing	Until unsubscribe
Website visits	IP, browser, click behaviour	Analytics & security	13 months
Fraud prevention	Payment & device data	Legitimate interest	5 years

We process your personal data solely on the basis of one of the following legal grounds under the GDPR:

4.1 Performance of a Contract (Art. 6(1)(b) GDPR)

We process your data to perform the purchase agreement with you: processing your order, arranging delivery, processing payment and handling returns.

4.2 Legal Obligation (Art. 6(1)(c) GDPR)

We are legally required to retain certain data, such as invoice records for the Tax Authority (statutory retention obligation of 7 years).

 

4.3 Legitimate Interests (Art. 6(1)(f) GDPR)

We process certain data on the basis of our legitimate interests, such as improving our website, fraud prevention and securing our systems. We always weigh these interests against your privacy interests.

4.4 Consent (Art. 6(1)(a) GDPR)

For processing activities for which no other legal basis applies — such as sending newsletters or placing non-essential cookies — we ask for your explicit consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5.1 Processors

We use external parties (processors) that process personal data on our behalf. We have concluded a data processing agreement with all processors in accordance with Art. 28 GDPR. We share data with:

•        Shopify Inc. — our e-commerce platform (server location: US/EU, Standard Contractual Clauses apply)

•        Payment providers (e.g. Mollie, Stripe, PayPal) — for processing payments

•        Shipping partners and suppliers — for fulfilling deliveries (dropshipping)

•        Email marketing services (e.g. Klaviyo, Mailchimp) — for newsletters and transactional emails

•        Analytics services (e.g. Google Analytics) — for website statistics (anonymised)

•        Customer service software (e.g. Gorgias, Zendesk) — for support requests

5.2 Transfers Outside the EEA

Some of our processors are located outside the European Economic Area (EEA), such as Shopify (Canada/US). In such cases we ensure an adequate level of protection by means of:

•        Standard Contractual Clauses (SCC) approved by the European Commission, and/or

•        Transfers to countries with an adequacy decision from the European Commission.

5.3 No Sale of Data

We never sell your personal data to third parties. We share data solely for the purposes described in this Policy and only with parties that have concluded a data processing agreement with us or are otherwise bound by confidentiality.

We do not retain your personal data longer than necessary for the purposes for which it was collected, or as long as legally required. After the retention period expires, data is securely deleted or anonymised.

Specific retention periods:

•        Order and invoice data: 7 years (statutory retention obligation).

•        Account data: until you delete your account.

•        Customer service correspondence: 2 years after the request is closed.

•        Newsletter data: until you unsubscribe.

•        Website analytics data: maximum 13 months (anonymised).

•        Fraud prevention data: maximum 5 years.

Under the GDPR you have the following rights with regard to your personal data. You can exercise these rights by contacting us at info@zavory.nl.

7.1 Right of Access (Art. 15 GDPR)

You have the right to know what personal data we process about you, for what purposes and for how long we retain it.

7.2 Right to Rectification (Art. 16 GDPR)

You have the right to have inaccurate or incomplete personal data corrected.

7.3 Right to Erasure (Art. 17 GDPR)

You have the right to have your personal data deleted ('right to be forgotten'), unless we are legally required to retain it.

7.4 Right to Restriction of Processing (Art. 18 GDPR)

You have the right to restrict the processing of your data, for example while an objection is being assessed.

7.5 Right to Data Portability (Art. 20 GDPR)

You have the right to receive your personal data in a structured, commonly used and machine-readable format so that you can transfer it to another service provider.

7.6 Right to Object (Art. 21 GDPR)

You have the right to object to the processing of your data based on legitimate interests or for direct marketing purposes. If you object to direct marketing, we will immediately stop processing for that purpose.

7.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. This does not have retroactive effect.

 

We will respond to your request within 1 month of receipt. If your request is complex or extensive, we may extend this period by a maximum of 2 months, of which we will inform you in a timely manner. Exercising your rights is free of charge, unless your request is manifestly unfounded or excessive.

We take appropriate technical and organisational measures to protect your personal data against loss, theft, unauthorised access, disclosure or alteration. Our security measures include:

•        SSL/TLS encryption for all data transfer via our website (HTTPS).

•        Encrypted storage of passwords (bcrypt hashing).

•        Restricted access to personal data on a need-to-know basis.

•        Regular security audits and updates to our systems.

•        Use of PCI DSS-certified payment providers for the processing of payment data.

Despite our efforts, no security measure can guarantee absolute protection. In the event of a data breach that poses a high risk to your rights and freedoms, we will notify you as soon as possible in accordance with Art. 34 GDPR.

Our website uses cookies and similar technologies. We distinguish the following categories:

•        Necessary cookies — required for the functioning of the website (no consent required).

•        Functional cookies — to remember your preferences (e.g. language setting, shopping cart).

•        Analytical cookies — to measure website usage (e.g. Google Analytics, anonymised).

•        Marketing cookies — for personalised advertising (only with your consent).

On your first visit, we will ask your consent for non-essential cookies via our cookie banner. More information can be found in our separate Cookie Policy on our website.

Our website and services are not directed at persons under the age of 16. We do not knowingly collect personal data from minors. If you discover that a minor has provided us with personal data without the consent of a parent or guardian, please contact us at info@zavory.nl so that we can delete this data.

Do you have a complaint about the way we handle your personal data? Please first contact us at info@zavory.nl. We aim to handle your complaint within 4 weeks. If you are not satisfied with our response, you have the right to lodge a complaint with the competent supervisory authority:

 

Dutch Data Protection Authority

www.autoriteitpersoonsgegevens.nl

 

Phone

+31 (0)88 180 52 50

 

Postal Address

P.O. Box 93374, 2509 AJ The Hague, the Netherlands

 

We reserve the right to amend this Privacy Policy at any time, for example due to changes in legislation or adjustments to our working practices. The most current version is always available on our website. In the event of significant changes, we will inform you by email or via a prominent notice on our website.

For questions, requests or comments about this Privacy Policy or the processing of your personal data, please contact us:

 

Privacy Email

info@zavory.nl

 

Response Time

Within 1 month (statutory deadline)

 

If we are legally required to appoint a Data Protection Officer (DPO), the contact details of the DPO are the same as stated above, unless otherwise indicated.