Data processing addendum: accounting connection

1. Parties and scope

This addendum supplements the Plana terms of service. The Customer (the company that holds the Plana account) is the controller. Kasvu SK Oy (business ID 3143367-7, "Plana") is the processor. This addendum applies when the Customer creates an accounting connection through which an accounting firm or accounting system chosen by the Customer reads data from Plana.

2. Subject matter, nature and purpose of processing

Through the connection, Plana provides read-only access to data about the Customer's employees for payroll and bookkeeping. Plana does not calculate pay or file reports to the Incomes Register through the connection. Processing starts when the Customer creates the connection and ends when the connection is revoked or expires.

3. Categories of personal data and data subjects

Data subjects: the Customer's employees. Data is provided according to the connection's permissions:

• employees: name, contact details, employee number, terms of employment and of the employment contract, pay criteria;
• hours: working hours by type, absences and annual leave;
• identity (only when selected separately): personal identity code, bank account number, address and nationality.

Health data (for example doctor's certificates) is not provided through the connection.

4. Customer's instructions

Creating a connection, choosing its permissions and revoking it are the Customer's documented instructions. Plana processes the data only in accordance with these instructions.

5. Customer's responsibilities

The Customer is responsible for having a legal basis for the processing, for informing its employees of the processing, and for having its own agreement with the accounting firm. The accounting firm is the Customer's processor, not Plana's. Plana is not responsible for processing carried out by the accounting firm.

6. Plana's obligations

• Confidentiality: the data is processed only by persons bound by a duty of confidentiality.
• Security: the key is shown only once and only its hash is stored; access is limited to the selected permissions; every call is logged without the data content; connections are encrypted (TLS); the connection can be revoked at any time.
• Assistance: Plana assists the Customer in responding to data subjects' requests to exercise their rights and in investigating personal data breaches.
• Personal data breaches: Plana notifies the Customer without undue delay after becoming aware of a breach.

7. Sub-processors and transfers

Plana uses the sub-processors listed in the privacy notice. The database is located in the EU (Supabase, Stockholm). The service's web functions run on UpCloud (UpCloud Oy, Finland) servers in the EU (Stockholm). The standby server (Netlify) used during outages may process data in the United States; such transfers rely on mechanisms approved by the European Commission (the Data Privacy Framework or standard contractual clauses). Plana notifies the Customer of changes to sub-processors in advance.

8. Retention and deletion

Once the connection is revoked or expires, no further data is provided. The change log (which employee and which data area changed, without values) is deleted after 400 days. Call logs are retained as described in the privacy notice.

9. Audits

On request, Plana provides the Customer with the information needed to demonstrate compliance with this addendum.

10. Term

This addendum remains in force for as long as the Customer has a valid or unrevoked accounting connection.

11. Governing law

This addendum is governed by the laws of Finland. Limitations of liability are determined by the Plana terms of service.