Privacy Policy

Controller

The controller is:

Data-protection and privacy requests: contact@executia.io. This is the contact channel published on our Contact page for privacy matters. Related terms: Terms of Service.

EXECUTIA LIFE service

EXECUTIA LIFE is a product of EXECUTIA AS, available at https://life.executia.io. EXECUTIA LIFE is a software service for business and financial execution, including processing information relating to customers, invoices, money, documents and actions, subject to the features available in the user’s account.

LIFE may also process account, balance and transaction data obtained through Open Banking / Account Information Services after the user gives consent, as described below. LIFE does not provide payment initiation (PIS) functionality.

Open Banking / Account Information Services

Where you choose to connect a payment account to LIFE, EXECUTIA LIFE uses Open Banking Account Information Services (AIS) to retrieve account, balance and transaction data.

That data is obtained only after your consent. You authorise access at your bank (or other account-servicing payment service provider) through the AIS consent flow. LIFE does not retrieve AIS account, balance or transaction data without that consent.

Depending on what your bank provides, AIS data may include account identifiers, account holder name, IBAN or other account numbers, balances, and transactions (including dates, amounts, descriptions and counterparties where supplied).

AIS data is processed to display and use that information in your LIFE workspace so you can review accounts, balances and transactions in LIFE. It is not processed to initiate payments. EXECUTIA AS does not sell this data.

Enable Banking as AIS infrastructure provider

Enable Banking (Enable Banking Oy) is the regulated Open Banking / Account Information Services infrastructure provider used by EXECUTIA LIFE for AIS. Enable Banking is a registered Account Information Service Provider (AISP) supervised by the Finnish Financial Supervisory Authority (FIN-FSA). Further information is published by Enable Banking at enablebanking.com.

Enable Banking provides the technical and regulated AIS connection between your bank and LIFE after you consent. EXECUTIA AS uses that infrastructure; EXECUTIA AS is not itself a licensed Account Information Service Provider (AISP).

You may review and terminate AIS data-sharing consents with Enable Banking at https://enablebanking.com/data-sharing-consents/.

Categories of personal data

Depending on how you interact with EXECUTIA, we may process:

• identity and contact details you provide (for example name, email address, organisation name);
• LIFE account data needed to operate your workspace (for example login email and workspace content you enter or import);
• information submitted through contact or pilot request forms;
• AIS account, balance and transaction data after consent, as described above;
• technical and server information, such as IP address, browser type, timestamps, requested URLs and diagnostic logs.

We do not claim to collect categories of data that are not relevant to the current website and services.

Information submitted through contact or pilot request forms

Where you choose to contact EXECUTIA or submit a pilot / collaboration request, we may process the information you provide, such as:

• name or operator name;
• email address;
• organisation name;
• sector or execution domain;
• message content or case description; and
• any other details you voluntarily include.

This information is provided by you and is processed to respond to your enquiry or request.

Technical and server information

Like most websites, our hosting and infrastructure providers may automatically process technical information when you visit executia.io or LIFE, such as IP address, browser type, approximate location derived from network data, timestamps, requested URLs and diagnostic logs. This information is typically processed for security, reliability and operational purposes and may be retained only as long as needed for those purposes.

Purpose of processing

Where applicable, personal data may be processed to:

• operate, secure and support executia.io and EXECUTIA LIFE;
• create and administer a LIFE account;
• provide AIS account, balance and transaction information in LIFE after consent;
• respond to contact and pilot requests;
• maintain business correspondence;
• improve reliability and prevent abuse; and
• comply with legal obligations.

Purpose and lawful basis for processing

Depending on the context, processing may be based on:

• Consent (GDPR Article 6(1)(a)), including your explicit consent to Open Banking / AIS access for account, balance and transaction data, and where you voluntarily submit information or where consent is otherwise legally required;
• Contract (GDPR Article 6(1)(b)), where processing is necessary to provide EXECUTIA LIFE to you;
• Legitimate interests (GDPR Article 6(1)(f)) in operating a secure website and service, responding to business enquiries, and preventing abuse, balanced against your rights and interests; and/or
• Legal obligation (GDPR Article 6(1)(c)), where applicable.

Data minimisation

We aim to collect and retain only what is reasonably necessary for the stated purposes. Please avoid including sensitive personal data in free-text fields unless it is necessary for your request.

Processors and sub-processors

Enable Banking Oy is used as the regulated AIS infrastructure provider for Open Banking account information in LIFE, as described above.

We may also use service providers to host the website and LIFE, deliver email, provide infrastructure, or support operations. Where such providers process personal data on our behalf, they act as processors under applicable data protection law and are expected to process data only on documented instructions and with appropriate safeguards.

International data transfers

Some infrastructure or service providers may process data outside Norway or the EEA. Where international transfers occur, we aim to ensure that appropriate safeguards are in place as required by applicable law.

Enable Banking is established in Finland (EEA) for the AIS infrastructure described above. Transfers connected with that infrastructure are subject to Enable Banking’s own terms and data-protection information in addition to this policy.

Storage, retention and deletion

Personal data is stored in systems used to operate executia.io and EXECUTIA LIFE, including systems operated by processors on our behalf.

Personal data is retained only for as long as reasonably necessary for the purposes described in this policy, including operating the service, correspondence follow-up, security and legal requirements, after which it is deleted or anonymised where practicable.

AIS account, balance and transaction data is stored in LIFE only after consent and only while needed to provide that part of the service, or as required by law. If you withdraw AIS consent, disconnect the bank connection, or delete your LIFE account, we will stop retrieving new AIS data and will delete or restrict AIS-derived data except where we must retain it for a legal obligation, dispute handling, or security.

Security

We apply organisational and technical measures appropriate to the nature of the website, LIFE, and the data processed, including access control and transport security on the systems we operate. No method of transmission or storage is completely secure, and absolute security cannot be guaranteed. EXECUTIA AS does not claim security certifications it does not hold.

Cookies and similar technologies

EXECUTIA aims to minimise the use of cookies and similar technologies. Please see our Cookie Policy for details. At present, EXECUTIA aims to operate without non-essential tracking on executia.io.

GDPR rights

If you are in the EEA/EU or otherwise protected by the GDPR, you may have the following rights, subject to applicable conditions and exceptions:

Right to access

You may request confirmation of whether we process personal data about you and, where applicable, access to that data.

Rectification

You may request correction of inaccurate personal data.

Erasure

You may request deletion of personal data in certain circumstances.

Restriction

You may request restriction of processing in certain circumstances.

Data portability

Where processing is based on consent or contract and carried out by automated means, you may request to receive personal data you have provided in a structured, commonly used and machine-readable format, where applicable.

Objection

You may object to processing based on legitimate interests, including where relevant to direct marketing.

Withdrawal of consent where applicable

Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

Complaint to the Norwegian Data Protection Authority (Datatilsynet)

You may lodge a complaint with Datatilsynet (the Norwegian Data Protection Authority) or another competent supervisory authority.

Withdrawal and revocation of bank consent

You may withdraw or revoke AIS / bank consent at any time. Withdrawal does not affect processing that was lawful before withdrawal.

You may:

• disconnect or revoke the bank connection in EXECUTIA LIFE where that control is available in your account;
• review and terminate data-sharing consents at https://enablebanking.com/data-sharing-consents/;
• use any revocation mechanism your bank provides; and/or
• contact EXECUTIA AS at contact@executia.io.

After revocation, LIFE will not retrieve new AIS account, balance or transaction data under that consent.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top of this page will be revised when changes are published.

Data-protection contact

For privacy-related requests or questions, including GDPR rights requests, contact EXECUTIA AS at contact@executia.io or via the channels on our Contact page. We may need to verify your identity before acting on a request.