Version 1 (Nov. 2025)
Data processing
1. Reference to the assignment agreement
The parties have entered into an agreement for the provision of accounting services (“The Service Agreement”) as of the date of signature. This appendix describes how the Accounting Firm processes personal data in connection with the Service Agreement. The Accounting Firm is the data processor and processes personal data on behalf of the Customer, who is the data controller, in accordance with the Personal Data Act and the Service Agreement.
2. Categories of data subjects
Categories of data subjects and purposes of the personal data:
Employees, temporary workers and consultants
Salary, benefits, A-meldings, pension, tax withholding, sick pay, leave compensation, etc.
Shareholders
Customer due diligence, dividends, corporate advisory, shareholder register notification, reporting, general meeting minutes, etc.
Board members
Correct information, annual accounts, benefits and deductions.
Customers
Invoicing, bookkeeping, etc.
Suppliers
Invoicing, payment, etc.
3. Categories of personal data
The accounting firm will process the following types of personal data on behalf of the Customer.
Types of personal data and the purpose of the personal data:
Identity information
See assignment specification point 1, marketing purposes.
Bank information
See assignment specification point 1, marketing purposes.
Salary information, including any salary deductions
See assignment specification point 1, marketing purposes.
Tax withholding information
See assignment specification point 1, marketing purposes.
Transaction information, payments and information about debt relationships
See assignment specification point 1, marketing purposes.
The accounting firm does not process personal data beyond what is stated in the Assignment Agreement between the Parties or special legislation.
4. Special categories of personal data
The accounting firm will process the following special categories of personal data on behalf of the Customer.
Type of personal data and purpose of the personal data:
Information about sick leave and self-certified absence
A-melding, ensure correct employment percentage and salary payment.
Information about payment of deductions for union dues
Ensure correct benefits and deductions.
The specific legal basis for processing special categories of personal data is the Customer's consent, cf. GDPR Article 9(2)(a). Such consent is deemed to exist upon signature of the Assignment Agreement.
5. Subcontractors
Upon entering into the Service Agreement, the Accounting Firm uses the following subcontractors.
Visma AS
Processing location: Norway
Transfer basis: The country is approved by the EU.
Sticos AS
Processing location: Norway
Transfer basis: The country is approved by the EU.
Signicat AS
Processing location: Norway
Transfer basis: The country is approved by the EU.
Supabase Inc
Processing location: Norway
Transfer basis: The country is approved by the EU.
Google Cloud EMEA Limited
Processing location: Norway
Transfer basis: The country is approved by the EU.
If there are changes in subcontractors, an updated list of subcontractors is sent to the Customer.
6. Deletion and storage of personal data
The accounting firm stores accounting records containing associated personal data in accordance with what is stated in the Assignment Agreement and the mandatory requirements for retention of accounting documentation, etc. The Parties shall in good faith agree on the practical implementation of such statutory retention obligation, which safeguards both Parties’ need to comply with statutory requirements and ensure day-to-day operations.
Upon termination of the assignment, the personal data will be deleted or returned to the Customer in accordance with the Standard Assignment Terms, section 9.3. Where the assignment involves storage of accounting records, the personal data will be retained for the legally required retention period.