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1. Registrar

Ninjou Ltd., later mentioned also as “Ninjou”

Business ID 2543310-1

2. Contact person

Jani Puustinen

admin@ninjou.fi

3. The name of the registry

Ninjou Oy’s personal information, marketing and customer register.

4. Purpose of processing personal data

Ninjou Ltd.’s uses personal data in it’s payroll and billing service. In addition, Ninjou analyzes the users information on Ninjou Ltd.’s internal and external marketing planning and product development.

5. Information content of the register

Ninjou Ltd. collects the following information from users of the service:

– The persons whole name

– Social security number

– Home address

– Phone number

– E-mail address

– Bank account number

– Tax card information

– Billing information

– User’s customer register

– Salary calculations

– Age

– User activity in Ninjou Ltd.’s extranet including the current IP address from which pages were browsed

6. Regular sources of information

In its operations, Ninjou Ltd. uses information collected from users as mentioned in section 5. External sources of information include insurance companies, tax and enforcement authorities, as well as other authorities that, according to Finnish law, may transfer information to Ninjou Ltd. and from whom Ninjou Ltd. is legally required to receive information.

7. Data recipients, disclosure of information

Ninjou Ltd.’s personal data is processed by only natural persons employed by Ninjou Ltd.

a) Ninjou Ltd. will only disclose to third parties the personal data of point 5, at the request of the Finnish authorities, according to Finnish law, the following information:

– The persons whole name

– Social security number

– Home address

– Phone number

– E-mail address

– Bank account number

– Tax card information

b) Ninjou uses data collected from its users in digital analytics services. The user can not be identified in this context because the information used does not contain personal information. Analytic services store the following information:

– Billing information

– User’s customer register

– Salary information

– Users activity in Ninjou Ltd. including mouse pointer movement, edited fields, session time, browser type and current IP address from which pages were browsed

– Time stamps

8. Transfer of data outside the EU or EEA

Ninjou Ltd. does not disclose information outside the EU. The data to be associated with an individual user will be disclosed only at the request of the Finnish authorities.

9. Principles of registry protection

Customer and personal data are stored in the registrar’s premises that are locked.

Access to the register is restricted to persons working for Ninjou Ltd. who need information in their duties. Digital user data is technically protected by isolating data repositories from the public network and the service through which access can be accessed is protected by firewall and access rights. Information is only transmitted via a secure connection.

Paper documents are mainly transferred to digital format and stored in a strong security cloud service. Accounting and other material stored in paper form are kept in a locked storage.

10. Storage time

Section 7 b analytics information is stored for up to 120 days in an outside analytics service. Digital billing and salary information under the Accounting Act will be kept for a maximum of 6 years unless the customer terminates the customer relationship before that date. The billing and salary information in paper form is stored for 6 years.

11. General rights of a registered person

A private individual registered with the Ninjou Service has the right to view, modify and delete their personal data freely. Ninjou does not guarantee the functionality of the service if the following data is deleted:

-Account Number

-Tax percentage

-Address

-Telephone number

-Email address

12. Other Registered Rights

The user has the right to transfer his / her own data to a third party.

The user has the right not to be subjected to automated decision-making. You will need to inform the customer service by email at admin@ninjou.fi

A registered user of the Ninjou Service has the right to become completely forgotten after the termination of the customer relationship. Below you will find instructions on closing customer relationships and getting forgotten.

Customer relationship can be terminated in writing by sending an e-mail at admin@ninjou.fi. After one calendar month after the end of the customer relationship, Ninjou removes all digital user information that is unique in its service. After this period, the user can not retrieve earnings certificates or other documents from the service, nor can Ninjou provide them to the user. In the form of paper, unique billing and payroll information is kept under the Finnish Accounting Act for 6 years.