Privacy policy for PRO TBS

Privacy Notice for PRO TBS

SENSONEO j. s. a.

Effective as of: September 1, 2026 Last updated: September 1, 2026

1. The Purpose of This Notice. The Data Controller

1.1 Purpose of this notice

This notice explains how SENSONEO j. s. a. (“Sensoneo,” “we,” “us,” “the Company“) processes personal data in connection with PRO TBS (Professional Take-Back System), our SaaS platform for Producer Responsibility Organizations (PROs) and waste brokers. It covers the PRO TBS web Portal, the PRO Admin console, the public pickup-request form, and the Universal Mobile App used by drivers, haulers, and processing plant/HUB staff for field data collection.

This notice is addressed to:

• individuals employed by or representing our business partners (PRO Organizations, Haulers, Processing Plants/HUBS, and other partners) who use PRO TBS on their employer’s behalf;
• Collection Points (companies and Private Individuals) who submit a pickup request, whether registered or as a guest; and
• drivers and field staff who use the Universal Mobile App.

1.2 Who is the data controller

For the personal data described in Section 2 below that relates to our own business relationship with you or your employer (account administration, contracting, invoicing, support, and platform security), the data controller is SENSONEO j. s. a., with its registered seat at Kollárova 27, 841 06 Bratislava – Záhorská Bystrica, Slovak Republic, ID 50 746 057.

Important distinction — controller vs. processor: PRO TBS is a platform that PRO Organizations and waste brokers use to manage their own customers, producers, and haulers. Where a PRO Organization loads or generates personal data about its Collection Points, Producers, Haulers, or other end parties inside PRO TBS, Sensoneo acts as a data processor on that PRO Organization’s instructions, and the PRO Organization is the data controller for that data. That relationship is governed by the data processing agreement between Sensoneo and the relevant PRO Organization, not by this notice. If you are such an end party and want to exercise a data-subject right over data held about you inside a specific PRO Organization’s account, please contact that PRO Organization directly; we will assist them as their processor.

This notice covers the data for which Sensoneo itself is the controller, as described below, and separately describes the categories of data the Universal Mobile App collects in the field, since Sensoneo is a processor for most of that data but wants field staff to understand what is collected regardless of which entity is the formal controller.

1.3 What happens if data are not provided

Providing certain data (e.g., name, business contact details, employer) is necessary to enter into or perform a contract with you or your employer, to create a Portal/PRO Admin account, or to process a pickup request. Where the data is necessary for these purposes, failure to provide it may mean we cannot enter into the contract, create the account, or fulfil the request.

2. Personal Data. Processing Operations

2.1 Where the data come from

Personal data processed under this notice comes from:

• you directly (e.g., when you or your employer signs a contract, registers a Portal/PRO Admin account, or submits a pickup request);
• your employer (a business partner providing contact details of its employees/representatives);
• automatically, through your use of the PRO TBS Portal, PRO Admin console, public pickup-request form, or Universal Mobile App (e.g., login/usage records, device data, and — for the Universal Mobile App — location, photo, and signature data captured during field operations).

2.2 Categories of personal data

Unless a particular situation requires otherwise, the personal data we process includes:

We do not seek to collect any other personal data through PRO TBS, but in the ordinary course of a business relationship, additional data may incidentally become available (e.g., in free-text fields or support correspondence). We take reasonable measures to avoid processing such incidental data beyond what is necessary.

2.3 Purposes and legal basis

Where we rely on legitimate interest, we have weighed our interests against your rights and freedoms and concluded our interest is not overridden; you may ask us for more detail about a specific balancing assessment via the contact details in Section 4.2.

2.4 Retention period

We do not automatically delete or purge personal data on a fixed schedule. Removal from view (soft-delete) and permanent deletion both happen only when a user takes that action — either the responsible user removing a record from view within the platform, or an individual using the self-service permanent-deletion option below.

Self-service permanent deletion: PRO TBS provides every user with an embedded option in the Portal to request permanent deletion of their personal data at any time. When this option is used, the user’s personal data is permanently deleted, and any remaining records we are required to retain (e.g., invoicing/accounting records under the retention period above) are anonymized so they can no longer be linked to the user. This is separate from the platform’s general soft-delete behavior for business records such as Orders and Transport Assignments (removed from view, retained in the database for operational/audit continuity) — the self-service option specifically addresses an individual’s own personal data and satisfies the right to erasure described in Section 4.1.

3. Universal Mobile App — Specific Data Processing

The Universal Mobile App is used by drivers, haulers, and processing plant/HUB staff to record proof of pickup and delivery in the field. Unlike a purely informational app, the Universal Mobile App actively collects the following, and we describe it here separately so field users have clear, accurate information (rather than a generic “we collect nothing” statement, which would not be accurate for this app):

• Location: the Universal Mobile App does not use GPS or any other form of location tracking. Presence at a pickup or delivery location is confirmed without collecting geolocation coordinates.
• Camera / photos: used to capture proof of the condition and quantity of collected items and delivery. If a photo’s metadata includes an embedded location tag, that tag is stored with the photo as part of the delivery record.
• Digital signatures: captured to confirm proof of pickup or delivery.
• Offline mode: if you are working without connectivity, the above data is cached locally on your device and automatically synced to PRO TBS once connectivity is restored. Locally cached data is protected by the app’s standard device-level security controls.

Field-collection data is used to update Transport Assignment status, resolve variances, and generate delivery evidence for the relevant PRO Organization and its Collection Points. As explained in Section 1.2, Sensoneo typically processes this data as a processor on behalf of the relevant business partner (e.g., the Hauler’s or PRO Organization’s employer relationship with you governs the underlying legal basis for workplace monitoring, where applicable, under local labor law).

4. Your Rights

4.1 Data protection measures and your rights

We apply appropriate technical and organizational measures to protect your personal data. Subject to the conditions set out in applicable law, you have the following rights:

• Right to be informed — to receive clear information about how your data is processed (as set out in this notice).
• Right to access and rectification — to obtain confirmation of whether we process your data, access to that data, and correction of inaccurate data.
• Right to erasure (“right to be forgotten”) — to request permanent deletion of your personal data at any time using the self-service option embedded in the PRO TBS Portal (see Section 2.4). Upon deletion, any records we must still retain for legal or accounting purposes are anonymized so they can no longer be linked to you.
• Right to object and to restriction of processing — to object to processing based on legitimate interest, and to request that processing be restricted in certain circumstances.
• Right to data portability — to receive the personal data you provided to us in a structured, commonly used, machine-readable format, and to have it transmitted to another controller where technically feasible.

These rights may be limited in certain circumstances (e.g., ongoing legal proceedings, or where data is held by the relevant PRO Organization as controller rather than by Sensoneo — see Section 1.2). We may need to verify your identity before acting on a request.

4.2 How to exercise your rights or complain

You may exercise these rights, or raise a complaint, by contacting us at:

• E-mail: security@sensoneo.com

If you are not satisfied with our response, you have the right to lodge a complaint with the competent supervisory authority. For Slovakia, this is:

Úrad na ochranu osobných údajov Slovenskej republiky Hraničná 12, 820 07 Bratislava 27, Slovak Republic Phone: +421 2 323 132 14
E-mail: statny.dozor@pdp.gov.sk 
Web: https://dataprotection.gov.sk/uoou/

If you are located in another EU/EEA country, you may also lodge a complaint with your local supervisory authority.

5. Data Recipients. Third Parties. Transfers

5.1 Who has access

Your data may be accessed by:

• Sensoneo employees who need it to perform their duties (trained in data protection, bound by confidentiality, and subject to data-minimization principles); and
• external service providers acting on our behalf under a data processing agreement (Art. 28 GDPR), such as IT infrastructure and hosting providers.

Your data may also be shared with third parties acting for their own purposes, such as public authorities (e.g., tax authorities), or other service providers who do not process the data on Sensoneo’s behalf.

5.2 Sub-processors

Sensoneo uses the following sub-processors in connection with PRO TBS:

This list may be updated as our vendor relationships evolve; material changes will be reflected here.

5.3 International transfers

Personal data is primarily processed within the EU, EEA, and Switzerland. Where data is occasionally transferred to a country without an adequate level of protection — for example, due to the use of standardized third-party infrastructure such as Microsoft Azure — such transfers are safeguarded using Standard Contractual Clauses adopted by the European Commission or another legally recognized transfer mechanism.

5.4 PRO TBS platform data (processor role)

Where a PRO Organization or waste broker uses PRO TBS to manage its own Collection Points, Producers, and Haulers, Sensoneo processes that data solely on the instructions of, and under a data processing agreement with, that PRO Organization. Requests concerning that data should be directed to the relevant PRO Organization; Sensoneo will assist as required by that agreement.

6. Cookies and Similar Technologies

PRO TBS uses only strictly necessary cookies — for example, a cookie required to keep you logged into the Portal and PRO Admin console. These cookies do not require consent, as they are essential for the platform to operate; we disclose them here for transparency.

Our analytics sub-processor, PostHog (see Section 5.2), is currently configured to capture product usage data without setting any cookies. We do not use non-essential or tracking cookies of any kind, and no consent banner is required at this time. If this changes — for example, if an analytics or other tool begins setting non-essential cookies — we will update this notice and add a consent mechanism as required by law.

7. Miscellaneous

7.1 Changes to this notice

We may update this notice from time to time to reflect changes in our processing activities or legal requirements. The “Last updated” date at the top of this notice indicates when it was most recently revised.

7.2 Reporting non-compliance

If you believe your data has been processed in a way that does not comply with this notice or applicable law, please contact us using the details in Section 4.2 so we can investigate.

7.3 Obligations of business partners

If you are a business partner (e.g., a PRO Organization, Hauler, or Processing Plant/HUB) providing us with personal data about your employees or representatives (for example, so they can use PRO TBS or the Universal Mobile App), you are responsible for informing those individuals of this notice and, where applicable, obtaining any consents required under your own internal policies or local labor law before enrolling them.

7.4 Children

PRO TBS and the Universal Mobile App are business tools intended for use by adults acting on behalf of a business partner and are not directed at children. The public pickup-request form should not be used by anyone under the age of legal capacity to enter into a contract in their jurisdiction without appropriate parental/guardian involvement.

Contact us

SENSONEO j. s. a. Kollárova 27, 841 06 Bratislava – Záhorská Bystrica, Slovak Republic
E-mail: security@sensoneo.com