This document is for your information only. The “Company”, “PSOhub”, “us”, “we” or “our” refers to PSOhub B.V., the owner of PSOhub, a company incorporated in Amsterdam, The Netherlands.
Please review the following carefully so that you understand our privacy practices.
“Consent” of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
By “Content” we mean the audio and visual information, documents, software, products and services contained or made available to you by the Company in the course of using PSOhub.
By “Company technology” we mean all of Company’s proprietary technology (including software, hardware, products, processes, algorithms, user interfaces, know-how, techniques, designs and other tangible or intangible technical material or information) made available to you by us.
“Controller” is given the same meaning as in the GDPR, which we summarize as the party that determines the purposes and means of the processing of personal data – the customer is the controller with respect to it’s personal data.
By “Customer data” we mean any data, information or material provided or submitted by you to PSOhub in the course of using PSOhub.
By “Intellectual property rights” we mean unpatented inventions, patent applications, patents, design rights, copyrights, trademarks, service marks, trade names, domain name rights, mask work rights, know-how and other trade secret rights, and all other intellectual property rights, derivatives thereof, and forms of protection of a similar nature anywhere in the world.
By “License term(s)” we mean the period(s) during which you are licensed to use PSOhub pursuant to this Agreement and any applicable order form(s).
“Personnel” refers to those individuals who are employed by or are under contract to perform a service on behalf of one of the parties. Personnel may have rights in their personal data (including business contact information) if they reside in the EU. It is important to be clear about how personnel’s rights are protected.
“Data Subjects” refers to those individuals residing in the EU who are consumers or users of Company goods or services (also “consumers”), as well as any personnel who reside in the EU.
“Personal Data” is given the same meaning as in the GDPR which we summarize here as: any data relating directly or indirectly to an identifiable data subject. Personal data does not include any data that is anonymized, aggregated, de-identified and/or compiled on a generic basis and which does not name or identify a specific individual, directly or indirectly.
“Processing” is given the same meaning as in the GDPR, which we summarize as including: collecting, recording, using, storing, amending, adapting, disclosing, transferring or transmitting, structuring, using, combining, deleting or destroying, personal data (“Process” and “Processed” shall have similar meanings).
“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
“Pseudonymisation” is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
“Restriction of processing” is the marking of stored personal data with the aim of limiting their processing in the future.
“Processor” is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
“Recipient” is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
“Third party” is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
By “User” we mean an individual authorised to use PSOhub and have been supplied user identifications and passwords (or by Company at your request or the applicable Administrator’s request).
You provide us information about yourself, such as your name and email address, when you register. If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.
In addition, tracking information is collected as you use PSOhub and/or our website. To help us serve your needs better, we use “cookies” on our website to store and sometimes track user information. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. Cookies can be disabled or controlled by setting a preference within your browser.
Log file information is automatically reported by PSOhub and /or to our website by your browser each time you access PSOhub and/or our website. When you register with PSOhub and/or you view our site, our servers automatically record certain information that PSOhub and/or your web browser sends whenever you use PSOhub and/or visit any website.
PSOhub may collect a series of both general and special personal data, when a data subject logs in to PSOhub or receives and opens an e-mail form PSOhub. This general and special personal data are stored in the server log files. Collected may be the following personal data:
Stored in database
Hubspot userid (if applicable)
Access level to PSOhub
History off timesheet related data from calendar/gps integration
Stored in Intercom (see image below)
Browser , version and language
Number of sessions
Temporarily stored in user session / cache
Current device type
Current session Id
Current user (logged in the current session)
Stored but cleaned up at set intervals
Calendar and GPS retrieved raw data
E-mail Hubspot user data
Tracking information (opened, clicks, device)
An example of the way the collected general and special personal data is presented in PSOhub, is given in the printscreen from our demo-account below:
When using these general an special personal data and information, we do not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the services of PSOhub correctly, (2) optimize the content and functionality of PSOhub (3) ensure the long-term viability of our information technology systems and the PSOhub technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.
Therefore, PSOhub analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
The PSOhub website collects a series of general data and information when a data subject or automated system calls up the website or web application. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time (so-called timestamp) of access to the Internet site, (6) an Internet protocol address (IP address), and (7) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, we do not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website and webapp correctly, (2) optimize the content of our website (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, PSOhub analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
The newsletter of PSOhub contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, we may see i.e. if and when an email was opened by a data subject, and which links in the email were called up (clicked on) by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to continuously adapt the content of future newsletters to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. We automatically regard a withdrawal from the receipt of the newsletter as a revocation. After revocation the user will not receive any newsletter e-mails.
PSOhub shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is prescribed by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
We use the personal information you submit to operate, maintain, and provide to you the features and functionality of PSOhub. Any personal information or content that you voluntarily disclose by posting to us becomes available to the other users in your network. If you remove user content, copies may remain viewable in cached and archived pages, or if other users have copied or stored your user content.
By providing us with your email address and ticking the opt-in checkbox on the signup form or in your Profile Settings in our Web Application, you consent to our using the email address to send you PSOhub related notices, including any notices required by law. You may use settings at any time to opt-out of PSOhub related communications.
We may also use your email address to send you other messages, such as newsletters, changes to features within PSOhub, or special offers. If you do not want to receive such email messages, you may opt-out at any time from your Profile Preferences
The data subject has the possibility to register (sign up for a free/paid account) on the PSOhub website with the indication of personal data. Which personal data are transmitted to us is determined by the respective sign-up form used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by us, and only for our own purposes. We may request transfer to one or more (sub)processors that also use personal data for an internal purpose which is attributable to us.
By registering on the PSOhub website, the IP address—assigned by the internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable PSOhub to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.
PSOhub shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, PSOhubr shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. .
The personally identifiable information we collect is securely stored within our database, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers – 256 bit) for protecting your information.
We cannot, however, ensure or warrant the security of any information you transmit to PSOhub and you do so at your own risk. Once we receive your transmission of information, PSOhub makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
Protecting the privacy of young children is especially important. Since our content and services are not directed towards kids, children under 16 are not allowed to register with our website or to participate in public posting areas on our website. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 16 is allowed to provide any personal information to or on PSOhub. If we discover that we have collected personal information from a child under the age of 16 without parental consent, PSOhub will delete that information as soon as possible, no later than in 30 days.
Your user content is kept private in your Network. PSOhub does not monitor the user content you post on the site. We do not have administrative tools to view our users’ messages, and access to the database is only granted to our technicians on a case-by-case basis to troubleshoot specific technical issues, or as may be required by law.
PSOhub will not rent or sell your personally identifiable information to others. PSOhub may store personal information on its own servers or databases hosted in a secured environment behind an advanced firewall.
As you use our site, you may interact with our business partners. In order to provide you with additional support, your name and email address may be shared with partners who created report templates or connectors that you’ve used.
As we develop our business, we may buy or sell assets or business offerings. Customer and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer such information in the course of corporate divestitures, mergers, or dissolution.
We may, however, perform statistical analysis of customer usage in order to measure interest in, and use of, the various parts of the Website, and may share that information in the course of our business, but such shared information shall be in aggregated form only (statistics, etc.), and will contain no personally identifiable information whatsoever.
In general, we use the information collected to provide you with a great overall experience interacting with us and when using the PSOhub website and web application and to help us understand who uses our products, for internal operations such as operating and improving the PSOhub website and application and our help desk services, to contact you for customer service and billing purposes and to facilitate the delivery of PSOhub advertising in some cases, including using your email to send information to you about our services.
We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to PSOhub or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.
The rights you have to request updates or corrections to the information PSOhub collects depend on your relationship with PSOhub. Personnel may update or correct their information as detailed in our internal company employment policies.
You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal information stored in databases we actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable.
If you are an end user and wish to update, delete, or receive any information we have about you, you may do so by contacting us.
You should be aware that if you voluntarily disclose personal information in public areas, on public bulletin boards, or in public classified advertisement areas within the Website, that information might be collected and disseminated by third-parties, and result in, among other things, unsolicited inquiries, messages, and offers from third-parties. Please understand that any information that is disclosed in these areas becomes public information and this third-party conduct is out of the control of PSOhub. Please also be aware that if you voluntarily disclose personal information in the Messages, Groups or your Profile page within the Website, all users who are authorized to access such areas will have access to such personal information, and that information might be collected and disseminated by those users, and result in, among other things, unsolicited inquiries, messages, and offers from such users. PSOhub urges you to exercise caution when deciding to disclose any personal information on the Website, in either public or private areas of the Website.
You may, of course, decline to submit personally identifiable information through PSOhub, in which case PSOhub may not be able to provide certain services to you. You may update or correct your account information and email preferences at any time by logging in to your account. You can review and correct the information about you that PSOhub keeps on file by contacting us.
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
PSOhub may also contain links to other websites. We are not responsible for the privacy practices or the content of such third party websites.
However, we will not make changes that result in significant additional uses or disclosures of your personal information without notifying you of such changes via email at least 14 days before such changes would apply.
By email: email@example.com
In case you are not satisfied with the way we have handled your request and/or complaint you can contact the Dutch Privacy Authority (Autoriteit Persoonsgegevens) at www.autoriteitpersoonsgegevens.nl
At PSOhub, we take data protection seriously and have taken the necessary steps to comply with the GDPR (General Data Protection Regulation) compliant. In addition to meeting GDPR standards, we are applying policy and software updates to all users (including those outside the EU) and are committed to making future enhancements to ensure data is protected to the highest degree possible.
Connect with us by emailing dataprotection@PSOhub.com and we’d be happy to answer any additional questions you have about PSOhub and the GDPR.
How has PSOhub as implemented the regulations of the GDPR?
We’ve ensured our vendors and data providers are also GDPR compliant.
We’re updating Account Settings so our users can easily manage or opt-out of communication from PSOhub.
Nothing is more important than protecting our customers’ data. We adhere to enterprise-class security levels and highest encryption standards to keep customer data secure at all times. We apply GDPR rules for all customers.
PSOhub runs on the Mendix Cloud, that is hosted on best-in-class servers in Amazon AWS data centers located in Germany, Europe. All Amazon AWS services are GDPR compliant. Customer data is always protected and never leaves data centers.
Servers are configured as bastion hosts with each server containing only the services it absolutely needs. No other software is added to the host to lessen the security penetration surface.
Network security follows a multi-layered approach:
At the top we use Mendix utilizing its own security measures and principles
Security groups are assigned to each instance type, permitting only networks and ports absolutely needed for each instance type to function
Each instance has its own system firewall to protect its services even further
At the single network point of entry, the network intrusion detection & prevention system is installed, with active monitoring, filtering and alerting system.
Every connection to our hosts is SSL encrypted using a proven, peer-reviewed and open source encryption algorithms to prevent network sniffing, injecting and other attacks
Data at rest is encrypted via AES-256 encryption using the services AWS provides and/or native Linux tools.
We use on-site and off-site monitoring and alerting tools 24/7. We try to detect every anomaly which could affect our services, before it becomes an issue. Personnel is always available for urgent issues, which are escalated up the chain as necessary.
We strive for 99.99% uptime for all our products.
Although our services are regularly upgraded, configured and monitored, regular penetration tests are employed to identify and remedy potential security issues. We try to perform such penetration tests at least on quarterly basis.
Internal IT Security
Critical passwords are secured in a virtual vault, using strong encryption protocols. Access is granted to authorised and qualified personnel only, on need-to-know basis.
Data protection, Disaster Recovery & Data Continuity
Production data is mirrored to multiple servers in a master/slave fashion. In case of an instance failure, other instances take over the load. New instance is launched, which then resyncs data and rejoins the cluster.
Backups are taken on a daily basis, some more often, depending on sensitivity of data. Backups are securely stored on encrypted storage in a GDPR compliant datacenter.
We test our recovery operations and backup quality by regular data recovery. Minimum data recovery is seven days, up to 30 days of retention. GDPR requirements are followed.
As all software and customer data resides only in the Amazon Webservices infrastructure, Amazon Webservices security certification compliance applies. Amazon Webservices is certified with the following certificates, among others:
ISO 27001: Information Security Management Systems (ISMS)
ISO 27017: Cloud-specific security control guidance
ISO 27018: Protection of Personally Identifiable Information (PII) in public clouds
ISO 9001: Quality management systems
PCI DSS 3.2
All Amazon’s AWS services are GDPR ready.
More info is available on the following links: