Epsilon PS e.K.

Datenschutz-Folgenabschätzung

Die englische Version der gesetzlichen Vereinbarungen und Richtlinien gilt als die einzige aktuelle und gültige Version dieses Dokuments. Jede übersetzte Version wird nur als Service bereitgestellt, um das Lesen und Verstehen der englischen Version zu erleichtern. Übersetzte Versionen sind nicht rechtsverbindlich und können die englischen Versionen nicht ersetzen. Im Falle von Meinungsverschiedenheiten oder Konflikten haben die englischsprachigen rechtlichen Vereinbarungen und Richtlinien Vorrang.

A Privacy Impact Assessment (PIA) is required under GDPR for data-intensive projects, and is a living document which must be made accessible to all involved with a project. It is the process by which we discuss, audit, inventory, and mitigate the privacy risks inherent in the data we collect and process.

Like all GDPR documentation, a PIA can be requisitioned by a data protection regulator in the event of a privacy concern or data breach. 

This document was last updated August 2024.
 

1. Data collection and retention
  1. What personal data is processed?
    We collect the following data during signup: Name (first and last), Address, City and Zipcode, Country of residence, Email, Phone and VAT ID if applicable. In addition we log the IP address of the user.
     
  2. How is that data collected and retained?
    Data is collected using HTML forms or written digital documents and transmitted via an encrypted (SSL) HTTPS connection to the Epsilon PS e.K. data lake. The user password is encrypted and not known by us.
     
  3. For how long is data stored, and when is the data deleted?
    Data is stored for as long as customers have an active account. If a customer deletes their account, all personally identifiable information is deleted with the exception of certain network and traffic logs which may persist for up to a year. Please see our Third Party Information sharing page for details on which services we share data with.
     
  4. Is the data collection and processing specified, explicit, and legitimate?
    Yes.
     
  5. What is the process for granting consent for the data processing, and is consent explicit and verifiable?
    Consent is a pre-requisite for signing up with Epsilon PS e.K.
     
  6. Is the data minimized to what is explicitly required?
    We do not gather any more data than required in order to comply with EU law and for the purposes of billing.
     
  7. Is the data accurate and kept up to date?
    We can only verify certain information and do so rarely. Information is kept up to date by the customer themselves.
     
  8. How are users informed about the data processing?
    Users are informed about the data processing through our data protection and privacy policies and notices available on our website.
     
  9. What controls do users have over the data collection and retention?
    Partly. Customers can modify or delete their information via the Epsilon PS e.K. support systems.
2. Technical and security measures
  1. Is the data encrypted?
    All data is encrypted during transit, but only passwords are encrypted at rest.
     
  2. Is the data anonymized or pseudonymized?
    No.
     
  3. Is the data backed up?
    Yes. Daily.
     
  4. What are the technical and security measures at the host location?
    Stringent security protocols protect the server and running services. Server is continuously kept up to date. Passwords are very secure. Firewall is stringent and tools such as Fail2Ban are implemented. We continuously monitor all activity on the central server.
3. Personnel
  1. Who has access to the data?
    All Epsilon PS e.K. support staff and engineers.
     
  2. What data protection training have those individuals received?
    Basic GDPR training. Most employees are highly technically proficient and have deep insight into IT security.
     
  3. What security measures do those individuals work with?
    Network and systems monitoring, encryption and more.
     
  4. What data breach notification and alert procedures are in place?
    Automated alerts are set up for unusual activity as seen in system logs. Unusual traffic is logged and flagged to Epsilon PS e.K. engineers.
     
  5. What procedures are in place for government requests?
    Standard procedures are in place for such requests, and we have a published Warrant Canary.
4. Subject access rights
  1. How does the data subject exercise their access rights?
    By contacting Epsilon PS e.K. support at
     
  2. How does the data subject exercise their right to data portability?
    By contacting Epsilon PS e.K. support at
     
  3. How does the data subject exercise their rights to erasure and the right to be forgotten?
    By contacting Epsilon PS e.K. support at
     
  4. How does the data subject exercise their right to restrict and object?
    By contacting Epsilon PS e.K. support at
  1. Are the obligations of all data processors, including subcontractors, covered by a contract?
    Yes.
     
  2. If the data is transferred outside the European Union, what are the protective measures and safeguards?
    Epsilon PS e.K. utilises Stripe as its payment processor. Please see our page on Third Party Information Sharing.
6. Risks
  1. What are the risks to the data subjects if the data is misused, mis-accessed, or breached?
    Data listed in section 1.1 could be exploited. As we only gather otherwise publicly accessible information, our assessment of the privacy impact is that it is moderate.
     
  2. What are the risks to the data subjects if the data is modified?
    None personally. Malicious 3rd parties may, by virtue of hacking their account, gain access to servers and information therein which is outside the purview of Epsilon PS e.K.
     
  3. What are the risks to the data subjects if the data is lost?
    They may loose access to their account. Unless all backups and duplications of our control backend is lost as well, we will always be able to re-construct a user account. If a user actively deletes their account, or if a malicious 3rd party does so, user data would be lost in the course of 3 weeks, unless we are made aware of this happening.
     
  4. What are the main sources of risk?
    Zero-day exploits of our CMS and/or toolchain which includes but is not limited to: Linux kernel (Ubuntu), Apache/Nginx, PHP, MySQL, SSH and related services.
     
  5. What steps have been taken to mitigate those risks?
    As outlined in sections 2.4 and 3.4 we pro-actively and defensively keep our systems up to date, monitor intensively and review security frequently.