Privacy Policy PSM25 - Groundtone

Version: 1.0
Last updated: 10 December 2025

PSM25 - Groundtone is the data controller responsible for processing personal data as described in this privacy policy.

Contact details

• Postal address: Torenstraat 31, 4161CN, Heukelum, The Netherlands
• Email: info@groundtone.nl
• Chamber of Commerce (KvK): 98654845
• VAT number: NL005346784B38

Data Protection Officer (DPO): Frank Riesenbeck.

This privacy policy explains how PSM25 - Groundtone handles personal data on groundtone.nl (hereinafter: “the website”) and all related domains.

“Personal data” refers to any information that can identify an individual, such as name, customer number, and personal contact details. Data that is not personal by itself, but can lead to identification when combined with other data, is also considered personal data.

This privacy policy applies to all visitors of the website and anyone communicating with the website (hereinafter: “the user”).

PSM25 - Groundtone adheres to the General Data Protection Regulation (Regulation (EU) 2016/679 – GDPR) and the Dutch GDPR Implementation Act.

PSM25 - Groundtone implements appropriate technical and organisational measures to protect collected and processed personal data.

For questions regarding this privacy policy or any privacy-related inquiry, please contact us at: admin@groundtone.nl.

You may also contact the Data Protection Officer directly via the contact form on the website (select: Admin).

1. Personal data processed

When using the website or the services of PSM25 - Groundtone, the following personal data may be collected and processed:

• Birth first name
• Preferred name
• Middle name / name prefix
• Birth surname
• Date of birth
• Place of birth
• Country of birth
• Biological sex
• City of residence
• Country of residence
• Email address

2. Purpose of data processing

Personal data is processed solely to generate and deliver the user’s final Groundtone result.

In accordance with Article 6 GDPR, the processing is based on the following legal grounds:

• The user has given consent for the processing of their personal data (Art. 6(1)(a));
• Processing is necessary for the performance of a contract with the user (Art. 6(1)(b));
• Processing is necessary to comply with a legal obligation (Art. 6(1)(c));
• Processing is necessary to protect vital interests (Art. 6(1)(d)).

3. Recipients of personal data

Personal data may be shared with third parties when this is necessary for the purposes stated in this privacy policy. PSM25 - Groundtone is not obliged to disclose personal data to any third party unless legally required.

Data will only be shared to the extent necessary for fulfilling a task assigned by PSM25 - Groundtone and will never be sold or used for commercial purposes.

4. Retention period

Personal data is not kept longer than necessary for the purposes for which it was collected.

Data is kept only for as long as the user wishes to continue using our services. Upon request, all personal data of the user will be permanently deleted.

After the retention period expires, data will be anonymised or destroyed.

5. User rights

Users may exercise their rights under the GDPR at any time.

Requests can be submitted through the contact details provided in this privacy policy.

a. Right to be informed

The user has the right to clear and transparent information about data processing activities.

b. Right of access

The user has the right to access their personal data. A copy will be provided within one month of the request.

c. Right to rectification

The user may request correction or completion of inaccurate or incomplete personal data.

d. Right to erasure (“right to be forgotten”)

Users may request deletion of their personal data when one of the grounds listed in Article 17 GDPR applies.

e. Right to restriction of processing

Users may request restriction of processing under the conditions outlined in Article 18 GDPR.

f. Right to data portability

Users have the right to receive their data in a structured, commonly used and machine-readable format and to transmit it to another controller.

g. Right to object

Users may object at any time to the processing of their personal data, including profiling.

h. Right to lodge a complaint

Users may lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

6. Automated decision-making

PSM25 - Groundtone uses automated decision-making to calculate numerology frequencies and generate the Oertoon.

Users retain the right to request human intervention and to object to decisions made solely on automated processing.

7. Use of cookies

PSM25 - Groundtone uses cookies only where necessary for website functionality and sales-page analytics.

The registration and user environment use essential cookies only.

8. Changes to this privacy policy

This privacy policy may be updated in response to website developments or legal obligations. The most recent version is available on the website and includes the latest revision date.