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Processing of personal data: Novus Victoria Oy EU General Data Protection Regulation (GDPR) 2016/679 · Prepared: May 2026 This policy describes how Novus Victoria Oy processes personal data in connection with the funding application process. Personal data is collected only for the purpose of preparing funding applications and is not disclosed to third parties without the client’s consent. Company: Novus Victoria Oy Business ID: 3130717-9 Address: Lämmittäjänkatu 6, 00880 Helsinki Person responsible for data protection: Jukka Hilmola, CEO Email: jukka@novusvictoria.fi Name of the register: Novus Victoria Oy’s client register. Personal data is processed for the following purposes: – Preparing funding…

Processing of personal data: Novus Victoria Oy

EU General Data Protection Regulation (GDPR) 2016/679 · Prepared: May 2026

This policy describes how Novus Victoria Oy processes personal data in connection with the funding application process. Personal data is collected only for the purpose of preparing funding applications and is not disclosed to third parties without the client’s consent.

  1. Controller

Company: Novus Victoria Oy

Business ID: 3130717-9

Address: Lämmittäjänkatu 6, 00880 Helsinki

Person responsible for data protection: Jukka Hilmola, CEO

Email: jukka@novusvictoria.fi

  1. Name and purpose of the register

Name of the register: Novus Victoria Oy’s client register.

Personal data is processed for the following purposes:

– Preparing funding applications and submitting them to funders on the client’s instructions

– Compiling the mandatory background information required by funders (ownership structure, beneficial owners, personal data)

– Managing the client relationship and communication

– Complying with statutory obligations

  1. Legal basis for processing

The processing of personal data is based on the following grounds under the GDPR:

– Performance of a contract: the processing of personal data is necessary to provide the service under the client agreement

– Legal obligation: funders (Business Finland, elinvoimakeskus (regional development centre), Finnvera) require personal data as part of the application process

– Consent of the data subject: the collection of sensitive personal data, such as personal identity codes, is based on the explicit consent given by the client

  1. Personal data processed

The following personal data is collected in connection with the funding application process:

From all clients:

– Names, roles and ownership shares of the company’s owners

– Contact details: email address and telephone number

Additionally, for Finnvera applications:

– Personal identity code

– Date of birth

– Home address and postcode

– Nationality

– CV or an equivalent description of education and work history

– Information on other companies and roles in them

  1. Sources of data

Personal data is obtained primarily from the data subject themselves through the client information form and the personal data form. In addition, basic company information may be checked from public sources such as the Trade Register and the YTJ service (Finnish Business Information System).

  1. Disclosure and transfer of data

Personal data is disclosed to third parties only in the following situations:

– To funders (Business Finland, elinvoimakeskus, Finnvera and other public funders) as part of a funding application, on the client’s instructions and with their consent

– To authorities in order to comply with a statutory obligation

The data is not sold, rented or disclosed for marketing purposes. The data is not transferred outside the EU or the EEA.

  1. Data retention period

As a rule, personal data is retained for 5 years from the end of the client relationship. Data required under the Accounting Act is retained for 6 years from the end of the financial year. After the retention period, the data is deleted or anonymised.

  1. Data security

Personal data is stored in the Google Workspace service, which complies with EU data protection legislation. Access to the data is restricted to Novus Victoria Oy staff who need to process the data for their work duties. Sensitive personal data is collected through a secure form connection.

  1. Rights of the data subject

Under the GDPR, the data subject has the right to:

– Obtain information on the processing of their personal data (right of access)

– Request the rectification of inaccurate data

– Request the erasure of data if there is no longer a basis for processing

– Restrict the processing of data

– Transfer the data to another controller

– Withdraw consent at any time, in which case the withdrawal does not affect processing carried out before it

Requests concerning the exercise of these rights should be sent by email to jukka@novusvictoria.fi. Requests will be answered within one month.

  1. Right to lodge a complaint with a supervisory authority

The data subject has the right to lodge a complaint with the Data Protection Ombudsman if they consider that their personal data has been processed in breach of data protection legislation.

Office of the Data Protection Ombudsman: www.tietosuoja.fi

Telephone: 029 566 6700

Address: PL 800, 00531 Helsinki

Questions about data protection jukka@novusvictoria.fi · novusvictoria.fi

Novus Victoria Oy · Business ID 3130717-9 · Lämmittäjänkatu 6, 00880 Helsinki · Updated May 2026

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