Privacy Notice

Last updated: May 1, 2021


  • PSquared-HR

PSquared-HR means PSquared-HR srl, Via Tortona 33, 20144 Milano.

  • GDPR
    General Data Protection Regulation Act.

  • Data Controller
    Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
  • Data Processor
    Data Processor means any natural or legal person who processes the data on behalf of the Data Controller.
  • Data Subject
    Data Subject is any living individual who is using our Service and is the subject of Personal Data.


This Psquared-HR Privacy Notice (“Privacy Notice”) describes how we collect, use, disclose, transfer, and store your personal data for the activities described below, including when you visit a Psquared-HR website that links to this Privacy Notice (“Kheper”) and for our business account management. This Privacy Notice describes your choices and rights related to your personal data.

Psquared-HR is the data controller for the personal data discussed in this Privacy Notice, except as noted in the “Psquared as a Service Provider” section below.


PSquared-HR as a Service Provider

PSquared-HR customers are organizations such as businesses and schools, who use our services to help them manage personnel, students, and applicants. PSquared-HR processes personal data in these services only according to our customers’ instructions. If you have questions about personal data you have entered into a PSquared-HR service used by one of our customers, or want to exercise any of your rights regarding your personal data, our customer contract requires that we redirect your inquiry back to that Psquared-HR customer.

 Principles for processing personal data

Our principles for processing personal data are:

  • Fairness and lawfulness. When we process personal data, the individual rights of the Data Subjects must be protected. All personal data must be collected and processed in a legal and fair manner.

  • Restricted to a specific purpose. The personal data of Data Subject must be processed only for specific purposes.

  • Transparency. The Data Subject must be informed of how his/her data is being collected, processed and used.

Personal Data We Collect

Personal Data We Collect Directly from You


As a visitor to the Website you may choose to provide us with your personal data such as:

  • First name
  • Last name
  • Business email
  • Phone number
  • Company name and address
  • Job level

Account Management
We collect business contact information for account management purposes related to the use of Kheper software-as-a-service applications or professional services.

Cookies, Web Beacons, and Other Similar Technologies
Psquared-HR may use website tracking technologies to observe your activities, interactions, preferences, transactional information, and other computer and connection information (such as an IP address) relating to your use of our websites and services. We may also use log files, cookies, and similar technologies to collect information about the pages you view, links you click, and other actions you take when accessing our website or emails.

Personal Data Obtained from Third-Party Sources

Psquared-HR may also collect business contact information about you from other sources including publicly accessible websites, such as your company’s website, professional network services, or press releases. Business contact information may include:

  • First name
  • Last name
  • Business email
  • Phone number
  • Company name
  • Job level
  • Functional role
  • Business street address

In some instances, Psquared-HR may combine personal data you have provided to us with personal data collected from other sources as described above. We process this data to update, expand, and analyze our existing marketing records; identify new customers; create more tailored advertising or website experiences; and send marketing emails.

How We Use Your Personal Data

To Contact You
PSquared-HR uses the data we collect about you to provide PSquared-HR websites, services, and support. For example, if you provide data to us in a “Contact Us” form, we will use your data to respond to the request. 

Psquared-HR uses your personal data and information about your activity on our websites to contact you for marketing purposes in accordance with your marketing preferences, including telemarketing calls, and to send marketing emails that we believe may be of interest to you, such as product announcements, newsletters, educational materials, and details on upcoming events. We also use it to send administrative information, such as notices related to products, services, or policy changes.

To Plan and Manage Events
Psquared-HR uses your data for event planning and management, including registration, billing, and connecting with other event attendees, or to contact you further about relevant products and services. Any information you provide about emergency contacts or dietary preferences would be used for your safety and health purposes.

For Improvement Purposes
Psquared-HR uses the data we collect to understand how our websites and services are being used and to make improvements. For example, we may solicit your feedback about your experience using our services, and ways that we can improve those services.

For Security and Investigations
PSquared-HR may use your information to diagnose website technical problems, as well as to prevent, detect, mitigate, and investigate potential security issues, as well as fraudulent or illegal activity.

To Personalize Your Experience
PSquared-HR also may use your data to personalize your experience on our websites. PSquared-HR or our service providers use website tracking technologies to display products, features, or content that are tailored to your interests and to present advertising on other sites. For more information on these technologies see the “Cookies and Tracking technologies” section below. For more information on managing your choices in relation to cookies, please click “Cookie Preferences” in the footer of this page.

Legal Basis for Processing Personal Data

Our legal grounds for collecting and using your personal data as described in this Privacy Notice fall into the following four categories.  

Consent: In some cases, we ask you for your consent to process your personal data, such as when we need your consent for marketing purposes. You can withdraw your consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn. If you would like to withdraw your consent, you can do so by emailing 

Legitimate Interest: We process certain data for the legitimate interests of PSquared-HR, our affiliates, our partners, or our customers. These legitimate interests include, for example, contacting you to provide support or sending you marketing information (subject to applicable law); detecting, preventing, and investigating illegal activities and potential security issues; and maintaining and improving the Kheper and mobile applications. We will rely on our legitimate interests for processing personal data only after balancing our interests and rights against the impact of the processing on individuals.

Performance of a Contract: Sometimes we process personal data to perform our obligations under an agreement with you.

Other Legal Bases: In some cases, we may have a legal obligation to process your personal data, such as in response to a court or regulator order. We also may need to process your personal data to protect vital interests, or to exercise, establish, or defend legal claims.

Disclosure of Data

Affiliates and Service Providers
PSquared-HR may share data with PSquared-HR affiliates and third-party service providers or vendors contracted to provide services on our behalf. These third-party service providers or vendors may use data we provide to them only as instructed by PSquared-HR.

Additional Disclosures
If PSquared-HR goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal data may be among the assets transferred.

PSquared-HR does not sell personal data that we collect or process under this Privacy Notice.

Data Retention

PSquared-HR will retain your personal data at least as long as necessary to fulfil the service that you have requested, comply with any laws or regulations, resolve disputes, and enforce our agreements. PSquared-HR may retain your data longer for a legitimate business interest where business benefit is not outweighed by your personal rights and freedoms. Data entered into a PSquared-HR enterprise service is retained in accordance with any applicable agreement between PSquared-HR and its customer.

Cookies and Tracking Technologies

PSquared-HR or PSquared-HR service providers may observe your activities, interactions, preferences, transactional information, and other computer and connection information (such as an IP address) relating to your use of PSquared-HR websites. We may collect and store this data and combine this data with other personal data provided to PSquared-HR.

PSquared-HR uses cookies and other similar technologies, such as web beacons, HTML5 Local Storage, local shared objects, tags, and scripts on our websites and in email communications. We use these technologies to authenticate your access to various areas of our websites, understand your interests, analyze web traffic, combat fraud, provide interest-based advertising, improve our products and services and tailor content to your preferences. In emails we send, we may use these technologies to track their effectiveness.

You can configure your browser settings to manage certain tracking technology interactions. For some tracking technologies, you may need to take additional steps to manage their use and removal. Please review your browser privacy settings.

Online advertising may use data collected about your web browsing behavior, such as the pages you have visited or the searches you have conducted. This data may be used to display more relevant advertisements and content to you on non-PSquared-HR websites. The data used for targeted advertising may come from PSquared-HR or through third-party ad networks.

For additional information about the cookies and the tracking technologies PSquared-HR uses on our and sites, and to manage your preferences, please click “Cookie Preferences” in the footer of this page.

Data protection rights

Depending where you are located, you may have certain legal rights over the personal data we hold about you, subject to local privacy laws. These may include the right to:

  • Access the personal data we hold about you
  • Have incorrect personal data updated or deleted
  • Have your personal data deleted
  • Restrict the processing of your personal data
  • Object to the processing of your personal data carried out on the basis of our legitimate interests or for direct marketing purposes
  • Receive a copy of your personal data in an electronic and machine-readable format
  • Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects or otherwise significantly affects you (“Automated Decision-Making”). Workday does not perform Automated Decision-Making as part of the processing activities covered by this Privacy Statement. 
  • Receive the categories of sources from whom we collected your personal data
  • Opt out of marketing communications at any time by clicking on the “Unsubscribe” or “Opt out” link in marketing emails we send you or by contacting us
  • Complain to a regulator or data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

You, or an authorized individual that we can verify is acting on your behalf, can exercise the applicable rights by contacting us using the contact details at the bottom of this Privacy Notice.

If your personal data has been submitted to us by or on behalf of a PSquared-HR customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable customer directly.


We use technical and organizational measures that provide a level of security appropriate to the risk of processing your personal data. However, the security of information transmitted through the internet can never be guaranteed. You are responsible for maintaining the security of your password or other form of authentication involved in accessing password-protected or secured resources.


Changes to this Privacy Notice

This Privacy Notice may be amended or revised from time to time at the discretion of PSquared-HR. Changes to this Privacy Notice will be posted on the Website and links to the Privacy Notice will indicate that the statement has been changed or updated. We encourage you to periodically review this Privacy notice for the latest information on our privacy practices.

How to Contact Us

If you have any questions about this Privacy Notice, or wish to exercise your rights, please contact us at or one of the mailing addresses below:

PSquared-HR srl
Via Tortona 33,
20144 Milano (IT)