Data Processing Agreement

Updated 10/2023

This Rundit Data Processing Agreement and its Annexes (“Agreement“) reflects the parties’ agreement with respect to the Processing of Personal Data by us on behalf of you in connection with the Rundit Subscription Services under the Rundit Customer Terms of Service between you (the “Company”) and Rundit Oy, a limited company incorporated in Finland, bearing registration number 2781307-9, with its registered address at Fredrikinkatu 34 B 21, 00100 Helsinki, Finland (the “Data Processor”).

Hereinafter referred to collectively as “Parties”.

This Agreement may be amended or modified only by the written agreement of all the Parties.

A)  The Company acts as a Data Controller.

B)  The Parties seek to implement a data processing agreement that complies with the requirements of the current legal framework in relation to data processing and with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

C)  The Parties wish to lay down their rights and obligations.


1. Definitions and Interpretation

1.1 Unless otherwise defined herein, capitalized terms and expressions used in this Agreement shall have the following meaning:

1.1.1  “Agreement” means this Data Processing Agreement and all Schedules;

1.1.2  “Company Personal Data” means any Personal Data Processed by a Contracted Processor on behalf of Company pursuant to or in connection with the Principal Agreement;

1.1.3  “Contracted Processor” means a Subprocessor;

1.1.4  “Data Protection Laws” means EU Data Protection Laws and, to the extent applicable, the data protection or privacy laws of any other country;

1.1.5  “EEA” means the European Economic Area;

1.1.6  “EU Data Protection Laws” means EU Directive 95/46/EC, as transposed into domestic legislation of each Member State and as amended, replaced or superseded from time to time, including by the GDPR and laws implementing or supplementing the GDPR;
1.1.7  “GDPR” means EU General Data Protection Regulation 2016/679;

1.1.8  “Data Transfer” means:  a transfer of Company Personal Data from the Company to a Contracted Processor; or  an onward transfer of Company Personal Data from a Contracted Processor to a Subcontracted Processor, or between two establishments of a Contracted Processor,
in each case, where such transfer would be prohibited by Data Protection Laws (or by the terms of data transfer agreements put in place to address the data transfer restrictions of Data Protection Laws);

1.1.9  “Services” means the reporting and portfolio management software services the Data Processor provides.

1.1.10  “Subprocessor” means any person appointed by or on behalf of the Data Processor to process Personal Data on behalf of the Company in connection with the Agreement.

1.2 The terms, “Commission“, “Controller“, “Data Subject“, “Member State“, “Personal Data“, “Personal Data Breach“, “Processing” and “Supervisory Authority” shall have the same meaning as in the GDPR, and their cognate terms shall be construed accordingly.

2. Processing of Company Personal Data

2.1 Data Processor shall:

2.1.1  comply with all applicable Data Protection Laws in the Processing of Company Personal Data; and

2.1.2  not Process Company Personal Data other than on the relevant Company’s documented instructions.

3. Processor Personnel

Data Processor shall take reasonable steps to ensure the reliability of any employee, agent or contractor of any Contracted Processor who may have access to the Company Personal Data, ensuring in each case that access is strictly limited to those individuals who need to know / access the relevant Company Personal Data and to comply with Applicable Laws in the context of that individual’s duties to the Contracted Processor, ensuring that all such individuals are subject to confidentiality undertakings or professional or statutory obligations of confidentiality.

4. Security

4.1  Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of Processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, Data Processor shall in relation to the Company Personal Data implement appropriate technical and organizational measures to ensure a level of security appropriate to that risk, including, as appropriate, the measures referred to in Article 32(1) of the GDPR.

4.2  In assessing the appropriate level of security, the Processor shall take account in particular of the risks that are presented by Processing, in particular from a Personal Data Breach.

5. Data Subject Rights

5.1  Data Processor shall implement the appropriate technical and organisational measures to ensure a level of security appropriate to mitigate security risks.

5.2  Data Processor shall:

5.2.1  promptly notify Company if it receives a request from a Data Subject under any Data Protection Law in respect of Company Personal Data; and

5.2.2  ensure that it does not respond to that request except on the documented instructions of Company or as required by Applicable Laws to which the Data Processor is subject, in which case Data Processor shall to the extent permitted by Applicable Laws inform Company of that legal requirement before the Contracted Data Processor responds to the request.

6. Personal Data Breach

6.1  Data Processor shall notify Company without undue delay upon Data Processor becoming aware of a Personal Data Breach affecting Company Personal Data, providing Company with sufficient information to allow the Company to meet any obligations to report or inform Data Subjects of the Personal Data Breach under the Data Protection Laws.

6.2  Data Processor shall co-operate with the Company and take reasonable commercial steps as are directed by Company to assist in the investigation, mitigation and remediation of each such Personal Data Breach.

7. Data Protection Impact Assessment and Prior Consultation

Data Processor shall provide reasonable assistance to the Company with any data protection impact assessments, and prior consultations with Supervising Authorities or other competent data privacy authorities, which Company reasonably considers to be required by article 35 or 36 of the GDPR or equivalent provisions of any other Data Protection Law, in each case solely in relation to Processing of Company Personal Data by, and taking into account the nature of the Processing and information available to, the Contracted Processors.

8. Deletion or return of Company Personal Data

8.1  Subject to this section 8, Data Processor shall promptly and in any event within 10 business days of the date of cessation of any Services involving the Processing of Company Personal Data (the “Cessation Date”), delete and procure the deletion of all copies of those Company Personal Data.

8.2  Data Processor shall provide written certification to the Company that it has fully complied with this section 8 within 10 business days of the Cessation Date, if requested by the Company.

9. Audit rights

9.1  Subject to this section 9, Data Processor shall make available to the Company on request all information necessary to demonstrate compliance with this Agreement, and shall allow for and contribute to audits, including inspections, by the Company or an auditor mandated by the Company in relation to the Processing of the Company Personal Data by the Contracted Processors.

9.2  Information and audit rights of the Company only arise under section 9.1 to the extent that the Agreement does not otherwise give them information and audit rights meeting the relevant requirements of Data Protection Law.

10. Data Transfer

10.1 The Data handled within the Services for investors and founders is stored within the EU/EEA.

10.2 For the Services website functions, the Data Processor uses service providers in several geographical locations, such as Google Analytics 4. As such, the Data Processor and the Subprocessors may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or the User’s domicile. The Data Processor will take steps to ensure that Users’ personal data receives an adequate level of protection in the jurisdictions in which the Data Processor processes it. The Data Processor provides adequate protection for the transfer of personal data to countries outside of the European Economic Area based on the Standard Contractual Clauses or other similar arrangements.

11. General Terms

Notices. All notices and communications given under this Agreement must be in writing and will be delivered personally, sent by post or sent by email to the address or email address set out in the heading of this Agreement at such other address as notified from time to time by the Parties changing address.

12. Governing Law and Jurisdiction

12.1 This Agreement is governed by the laws of Finland.

12.2 Any dispute, controversy or claim arising out of or relating to this Agreement, or the breach, termination or validity thereof, shall be finally settled by arbitration in the Arbitration Court of the Finnish Chamber of Commerce and Industry in Helsinki on the basis of the regulation of this arbitration court.

Annex 1 – List of Subprocessors

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