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1 Purpose

1.1 Nuuka Data Protection Principles

Information security and privacy are important to us and are central to our success. Our Information Security Management and its goals are, therefore, aligned to our business objectives and strategy.

1.2 Nuuka Information Security Policy

This top-level policy aims to define the purpose, direction, principles, and basic rules for Information Security Management and to establish a general approach to information security.

This document is the external version of our Information security policy to be shared with customers, suppliers, partners, and other stakeholders. That way, we can keep our Information Management System producing the desired output. Nuuka is keen to ensure that all users – within Nuuka or not - understand their responsibilities for protecting the confidentiality and integrity of the data that they handle.           


2 Key points in the information security policy

2.1 Suppliers, Partners, and Customers Documents

We require NDA from customers, suppliers, and partners before discussing any business-critical information, after conducting a background check on them. We expect them to handle NDA for their personnel and partners, as well as comply to GDPR and other legal requirements. 

We have a process to manage and limit the access only to systems needed by suppliers and customers. We categorize data based on whom it can be communicated.

We expect our partners, customers, and suppliers to promptly inform us on any changes on services or use of Nuuka software that may impact security and privacy of the services in question, and we may require to conduct a review of their potential impact to Nuuka information security. Also, we may time-to-time review contracts and policies and update them.

2.2 IT security

We require strong passwords, non-shared passwords, non-write-down passwords, anti-virus protection, and authorization to systems on a need basis only. We require clean desk and screen policy. In addition, we require appropriate locking and handing the mobile devices. Finally, we demand the use of a VPN, when accessing internet with company devices, outside of our offices. For sake of clarity, these requirements apply to partners and suppliers having any access to Nuuka IT systems.

2.3 Incident process

All information security incidents need to be reported immediately to Information Security Officer and CEO. This includes compromised computing resources, information gathering attempts, Availability (DDos etc.), malicious code, and any other security incidents that compromise security, integrity or availability of the data.

We expect our partners to inform us in case they

2.4 Data Security

a. Nuuka Solutions ensures that all collected data, personal and other is stored securely using modern software that is kept-up-to-date.
b. Access to personal data is limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.


3 Nuuka Personal Data Protection Principles

Nuuka Solutions is committed to processing data in accordance with our responsibilities under the GDPR.

We align with the (Article 5 of the) GDPR and secure any personal data we have shall be:

a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

Our principles include also Data minimization, Accuracy and Archiving and Removal.

Minimization: We ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Accuracy: We take all reasonable steps to ensure personal data is accurate. And where necessary, for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

Archiving and Removing: To ensure that personal data is kept for no longer than necessary, we have an archiving policy for each area in which personal data is processed and review this process annually.