I hardly stored any PII. Also, this was a high profile site that you know: if it was hacked, they would probably try to deny access and extort: it would make a lot of monetary sense. We would also have lost our merchant accounts very quickly (although CC numbers were not stored, only MD5s, but i suppose they could have been captured from the application's memory after TLS decryption but before MD5 hashing, although this would have been a difficult task even on a rooted server). I am 99.999% confident by observing and recording loads, traffic, logs and other parameters of all servers that there were no intrusions. I understand that there's market size and appeal for bureaucracy and certifications, but i have my own data.

MD5(CC#) is trivially reversed, so I hope that’s not what you were doing.

Omg. cft should not be allowed anywhere near credit card numbers.

Do you save logs? If yes, there's your PII.

Thankfully, the servers were not in Europe! I said "hardly". It's genuinely amusing how people downvote facts, simply because they don't fit the zeitgeist.

Nobody mentioned Europe, except you. If you are referring to GDPR this still applies if you host outside of Europe.

We disagree webserver logs contain 'hardly any PII'. You may find it insignificant PII, but it does not constitute 'hardly'. IMO its a circumstantial goldmine.

In the US at least one court found that IPs were not PII

https://www.huntonprivacyblog.com/2009/07/10/washington-cour...

I am curious who "we" are- a royal plural?

And in EU, it is.

We referred to you and me.

Not to mention that a successful compromise could be used to serve malware to the users.