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Personal Data Processing Agreement

Last updated April 23rd, 2019.


1. Introduction

This Personal Data Processing agreement (”Annex”) is an inseparable part of the agreement between Miradore Oy (”Provider”) and the Customer to whom Miradore provides the Service (”Customer”) (”Agreement”).

The purpose of this Annex is to agree on the privacy and data protection of the Personal Data of the Controller in the services of the Provider. This Annex constitutes a written agreement in accordance with the EU General Data Protection Regulation (679/2016) (“Regulation”) concerning the processing of personal data.

If the terms concerning the Processing of Personal Data of the Annex and the Agreement are in conflict, the parties shall primarily apply the terms of this Annex.


2. Definitions

In accordance with the EU General Data Protection Regulation, the terms below are defined as follows:

Controller” shall mean the Customer or the Customer’s client, who shall define the purposes and methods of Personal Data Processing.

Processor” shall mean the Provider, who shall Process Personal Data on behalf of the Controller based on the Agreement.

Processing” or “Processing Activities” shall mean any operation or set of operation which is performed on Personal Data or sets of Personal Data using automated means or manually, such as data collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Personal Data” shall mean any information relating to an identified or identifiable natural person, hereafter ”Data Subject”; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal Data Breach” shall mean a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise Processed.


3. Data Protection and Processing Personal Data


3.1. Obligations of the Provider and the Customer

The Provider shall process the Personal Data of the Controller on behalf of, and commissioned by the Customer, on the grounds of the Agreement. The Personal Data that the Provider Processes may relate to, e.g. employees or customers. The Customer or the Customer’s client shall be the Controller and the Provider shall be the Processor of the Personal Data Processed in the service. The parties undertake to abide by the legislation, decrees and authority orders and guidelines concerning Processing of Personal Data in force from time to time both in Finland and EU.

The Controller shall be liable for having the necessary rights and justifications, and for having obtained the necessary consents for the Processing of Personal Data. The Controller shall be liable for drafting the privacy policy and informing the Data Subjects. The Customer is responsible for the validity of the personal data is has delivered to the Provider.

The Controller is entitled and obligated to define the purpose and methods of the Processing of Personal Data. The subject, character and purpose of Processing is defined in more detail in the Agreement. The types of Personal Data and sets of data subjects Processed in the services have been defined in the Annex 1.

The Provider is entitled to Process the Personal Data and other data of the Controller only on the grounds of the Agreement, this Annex and according to the written guidelines of the Customer and only to the extent and in such a manner that is necessary in order to provide services. The Provider shall notify the Customer if any conflict with the data protection legislation of EU or Finland is detected in the guidelines and in such a case, the Provider may immediately decline and stop the application of the guidelines of the Customer.

The Provider shall maintain the service description or other record of the Processing Activities of the service in cases where it is required to do so by the EU General Data Protection Regulation. The Provider is entitled to collect anonymous and statistic data of the use of the services pursuant to the Agreement, that does not specify the Customer nor data subjects and uses it for analyzing and developing its services.


3.2. Deletion or Returning of Data

After the expiry of the Agreement, the Provider shall return or delete, according to the guidelines of the Customer, all the personal data of the Controller and delete all duplicates, unless applicable legislation requires the retention of the Personal Data.


3.3. Subcontractors

The Provider may use subcontractors for Processing the Controller’s Personal Data. The Provider is responsible for its subcontractor’s actions as for its own and shall draft written agreements with the subcontractors concerning the Processing of Personal Data. If requested, the Provider shall inform the Customer beforehand of subcontractors the Provider intends to use in processing the personal data pursuant to the Agreement. The Customer is entitled to oppose the use of a new subcontractor on reasonable grounds. If the Parties are unable to reach an agreement concerning the use of a new subcontractor, the Customer is entitled to terminate the Agreement with thirty (30) days’ notice, in so far as the change of subcontractor affects the Processing of Personal Data pursuant to the Agreement.


3.4. Provider’s Obligation to Provide Assistance

The Provider shall immediately forward all requests to inspect, rectify, erase or object to the Processing of Personal Data or other requests received from the Data Subjects, to the Customer. If requested by the Customer, the Provider shall support the Customer in fulfilling the requests of the Data Subjects.

The Provider is obligated, taking into account the nature of the Processing of Personal Data and the data available, to assist the Customer in ensuring that the Customer complies with its legal obligations. These obligations may include requirements related to data security, notifying of data breaches, data protection impact assessments as well as obligations regarding prior consultations. The Provider is obligated to assist the Customer only to the extent that applicable legislation obligates the Processor of Personal Data. Unless otherwise agreed, the Provider is entitled to invoice reasonable expenses incurred from action pursuant to this section 3.4.

The Provider shall forward all inquiries made by data protection authorities directly to the Customer and shall await further guidance from the Customer. Unless otherwise agreed, the Provider is not authorized to represent the Customer or act on behalf of the Customer in relation to the authorities supervising the Customer.


4. Processing Taking Place Outside EU/EEA

The Provider and its subcontractors do not process personal data outside the EU/EEA.


5. Auditing

The Customer or an auditor authorized by the Customer (however, not a competitor of the Provider) is entitled to audit the activities pursuant to the Annex. The Parties shall agree on the time of the auditing and other details ahead of time and at latest 30 days before the inspection. The auditing shall be carried out in a way that does not impede the obligations of the Provider or its subcontractors in regard to third parties. The representatives of the Customer and the auditor must sign conventional non-disclosure commitments.

Both parties shall be responsible for the costs that they have themselves incurred in relation to the audit. If the inspection proves that the Provider has breached this Annex in an essential way, the Provider shall compensate the Customer for the costs incurred from the auditing.


6. Data Security

The Provider shall implement the appropriate technical and organizational measures to protect the Personal Data of the Controller, taking into account all the risks of Processing, especially the unintentional or illegal destruction, loss, alteration, unauthorized disclosures or access to Personal Data that has been transferred, saved or otherwise Processed. This includes, for example, firewalls, password protection and other access and authentication controls. We use TLS technology to encrypt data during transmission through the public Internet, and we also employ application-layer security features to further anonymize Personal Data. When organizing the security measures, the technical options and their costs shall be assessed in relation to the special risks of the Processing at hand and the sensitivity of the Personal Data Processed.

The Customer shall be obligated to ensure that the Provider is notified of all the circumstances concerning the Personal Data the Customer has delivered, such as risk assessments and the Processing of special sets of Data Subjects that affect the technical and organizational measures pursuant to this Annex. The Provider shall ensure that the personnel of the Provider or a subcontractor of the Provider shall abide by the appropriate non-disclosure commitments.


7. Data Breaches

The Provider must notify the Customer of all Personal Data Breaches without undue delay after receiving information of the breach or after a subcontractor of the Provider has received information of the breach.

If requested by the Customer, the Provider shall, without undue delay give the Customer all relevant information concerning the data breach. In so far as the information in question is available to the Provider, the Provider shall describe at least the following to the customer:

a) the occurred data breach,
b) if possible, the sets of data subjects and the number thereof, as well as the sets of personal data types and estimated numbers,
c) a description of the likely consequences caused by the data breach, and
d) a description of reparative measures, that the Provider has implemented or shall implement in order to prevent data breaches in the future, and if necessary, the measures to minimize the harmful effects of the data breach.

The Provider shall document and report the results of the inquiry and the implemented measures to the Customer.

The Customer shall be liable for the necessary notifications to the data protection authorities.


8. Liabilities

If any tangible or intangible damage is caused to a person due to a breach against the EU General Data Protection Regulation or the Annex, the Provider shall be liable for the damage only in so far that it has not explicitly abided by the obligations directed to Personal Data Processors in the EU General Data Protection Regulation or this Annex.

Both parties are obligated to pay only the part of the damages or administrative fine that corresponds to the liability for damage confirmed in the final decision of a data protection authority or a court of law. In all cases the liability of the parties shall be determined pursuant to the Agreement.


9. Other Provisions

The Provider shall notify the Customer in writing of all changes that may affect its ability or chances to abide by this Annex and the written guidance of the Customer. The Parties shall agree on all additions and amendments to this Annex writing.

This Annex shall enter into force when the Customer enters in to the Agreement. The Annex shall remain in force (i) as long as the Agreement is in force or (ii) the parties have obligations concerning personal data processing activities towards one another.

Those obligations that due to their nature are meant to survive the expiry of this Annex shall remain in force after the expiry of the Annex.



  1. Processing specification form




This Processing specification form is an inseparable part of the Annex concerning Personal Data Processing. The Processing Specification Form specifies a processing assignment the Processor performs for the benefit of the Controller in the manner provided for in the Agreement and this Annex.

1. Services The Processing shall concern the following services:

Device management service offered through, and

2. Subcontractors The following subcontractors are used in the provision of the service:

Microsoft Azure Germany

3. Geographical Location of Personal Data The Personal Data is Processed1 in the following countries or areas:


4. Sets of Data Subjects The Personal Data Processed concerns the following sets of Data Subjects:
  • End users of the Service;
  • Users of the devices managed with the Service.
5. Types of Personal Data The Personal Data Processed in the service consists of the following types of Personal Data:
  • customer data and the suppliers’ data, such as name, title, home address, telephone number, e-mail address, customer number, purchasing and service use history
  • employee and personnel data
  • IT and device management data, such as system data concerning offered service, including technical identification, user names, location, contact information, and technical actions concerning offered services, such as system and application log data and security log data, premises and system surveillance data and data of data security breaches.


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