Privacy Policy

Last updated: 11 October 2026

1. Who is responsible for your data

Gravenzorg.be is a service of Milenst BV. Milenst BV is the data controller for all personal data processed through this website and in the course of our services.

• Milenst BV, Krommelei 1A, 2110 Wijnegem, Belgium
• Company and VAT number: BE 1011.071.778
• E-mail: [email protected]
• Telephone: 0456 99 08 42

2. What this policy covers

This policy explains which personal data we collect when you submit a request or become a customer of Gravenzorg, why we do so, on which legal basis, how long we keep the data, where it is stored and what your rights are. It applies to the website gravenzorg.be and to our grave maintenance services.

3. What data we collect

Identification and contact details

• Name and contact details (address, telephone number, e-mail address)
• Billing and payment details

Grave-related data

• Cemetery and grave number
• Name of the deceased, solely to identify the grave
• Your specific wishes regarding the maintenance
• Photographs of the grave, before and after the work

Data about our communication

• E-mails and messages you send us and our replies
• Telephone calls, recorded only when you agree beforehand
• Feedback and answers to satisfaction surveys

Your own statement for a discount scheme

• Your statement that you are a member of a partner organisation or hold an insurance policy that entitles you to a discount. This statement serves only to apply the correct discount. We do not verify it with the organisation concerned, we receive no membership file from them, and we do not pass your statement on to them.

4. Why we use your data and on what basis

We process your data only for the purposes listed below, each time on the legal basis stated, as set out in Article 6 GDPR.

• Handling your request and drawing up a quotation — performance of the contract or steps taken at your request prior to entering into it (Art. 6.1.b).
• Carrying out and following up the maintenance, including photographs of the grave as a record of the work performed — performance of the contract (Art. 6.1.b).
• Invoicing, payment follow-up and accounting — performance of the contract (Art. 6.1.b) and compliance with our statutory accounting and tax obligations (Art. 6.1.c).
• Customer service and answering your questions — performance of the contract (Art. 6.1.b), or our legitimate interest in answering enquiries (Art. 6.1.f).
• Improving our services on the basis of feedback and aggregated figures — our legitimate interest in a well-functioning service (Art. 6.1.f).
• Website statistics — our legitimate interest (Art. 6.1.f): the measurement without cookies described in section 10.
• Recording a telephone call, where this occurs — your consent (Art. 6.1.a).

We do not take decisions about you based solely on automated processing, and we do not carry out profiling.

5. Where your data is stored

All personal data you entrust to us — your contact and billing details, the grave data and the photographs — is stored in the EU region of our service providers. No transfer of this data takes place to a country outside the European Economic Area.

Website statistics work without cookies and are described in section 10.

6. Who we share data with

We do not sell your data and do not pass it on for third-party commercial purposes. We share it only with:

• Our staff and field team, limited to what they need to carry out the maintenance;
• Cemetery administrators, where this is necessary to gain access to the cemetery or the grave;
• Service providers acting for us as processors: the platform hosting our customer application, our e-mail and telephony provider, our accounting and payment provider, and the supplier that delivers this website. A data processing agreement has been concluded or is being concluded with each of them, and they may use your data only for the task we assign to them. The current list of names is available on request at [email protected];
• Public or judicial authorities, where the law requires us to do so.

Partnerships with partner organisations

Where we work with a partner organisation that offers its members or customers a discount, that partner receives no personal data from us. The reporting we provide to such a partner contains aggregated figures only: the number of requests and orders, the revenue and the geographical area, whereby a postal code is only reported from five orders in the period concerned onwards and is otherwise rolled up to provincial level. Names, addresses, contact details, cemetery, grave number, the name of the deceased and photographs of the grave do not appear in that reporting.

7. How we secure your data

• Encrypted connections (TLS) for all communication with the website and the customer application
• Encrypted storage of data at our service providers
• Access limited to those who need the data for their task
• Regular back-ups
• Physical documents kept in a locked room
• An internal procedure to assess a possible data breach and, where the law requires it, to report it within 72 hours to the Data Protection Authority and, where necessary, to you

8. How long we keep your data

• Customer data: for the duration of your annual contract
• Administrative, billing and accounting data: 7 years after termination, as required by law
• Photographs of graves: up to 2 years after the end of the service
• Data from a request that does not lead to a contract: 12 months after the last contact
• Recorded telephone calls: 3 months at most

Once these periods have elapsed, the data is deleted or irreversibly anonymised.

9. Your rights

Under the GDPR you have the right of access to your data, to rectification of inaccurate data, to erasure, to restriction of processing, to data portability, and to object to processing based on our legitimate interest. Where you have given consent, you may withdraw it at any time, without affecting processing that took place beforehand.

You may exercise these rights via [email protected]. We respond within one month. We may ask you for an additional detail to make sure the request comes from you.

10. Cookies

This website does not place cookies. We measure use without cookies, as described below. More in our Cookie Policy.

Visitor measurement and company identification

We measure how this website is used, with our own software and without cookies. For every page you open, we record:

• which page, when, and the website or search engine you came from;
• the country and city linked to your internet connection, the type of device, the screen size, and the language and time zone of your browser;
• how long the page was open, how far you scrolled and whether you used a mouse, keyboard or touch screen. This lets us tell real visitors apart from automated programs (bots);
• the organisation behind the network you use. To do this, we look up your IP address, at the moment of the visit, in public registers (the RIPE register and reverse DNS), and then look up that organisation in the Belgian Crossroads Bank for Enterprises. If you browse through the network of a company, school or public body, we see that organisation. If you browse from home or on your mobile plan, we only see your internet provider.

We do not store your IP address. We turn it into a key that changes every day, so we can see which pages belong to the same visit within one day, but we do not recognise you from one day to the next.

Personal links. A link to our website in an e-mail from us can contain a personal code (for example ?r=k7f2q9ab). If you click it, we know it is you and which pages you viewed that day. If you do not want that, remove the code from the address or go to the website directly. If you leave your details in a form, we link them to the pages you viewed that day.

Why: to improve the website and to see which organisations are interested in our services, so we can follow up with them. Legal basis: our legitimate interest. We keep the impact on your privacy as small as possible: no cookies, no stored IP addresses, no recognition across days without a personal link, and we do not sell or share this data. Retention: 13 months. Processors: Cloudflare (hosting and database); look-ups are made with RIPE NCC and Cloudflare DNS. Objection: e-mail [email protected]; we will then delete the data we can link to you.

11. Changes to this policy

We update this policy when our services or the applicable rules require it. The date at the top shows when that last happened. Where a change materially affects you, we will inform you.

12. Contact and complaints

Questions about this policy or about your data: [email protected] or 0456 99 08 42.

If you are not satisfied with our response, you have the right to lodge a complaint with the Belgian Data Protection Authority, Drukpersstraat 35, 1000 Brussels, [email protected], www.dataprotectionauthority.be.