Data location and access by authorities
Version 2026-11-04 · in force from 4 November 2026
This description applies to the production service and takes effect together with the terms of service. The production environment has not been set up yet, so this page also says what is already in use and what will be switched on when production is set up.
The service provider is Enarra Oy (Business ID 3664892-5, Artturintie 4, 43500 Karstula, Finland), “Enarra”. Enarra provides a software service called Enarra Memo (formerly Tarumo). This page says where the service’s data is processed and stored, who processes it, whether it can be accessed from outside the EU and the EEA, and how Enarra prevents unlawful access to it by authorities outside the EU. It meets the information duty of Article 28 of the EU Data Act (2023/2854) and describes the measures under Article 32(1). It is based on sections 10–12 of the data processing agreement and section 10 of the terms of service, which take precedence.
In short
- We commit to keeping the servers, the database, the backups, the AI and the speech recognition in the EU.
- The servers and the database are in Helsinki. The AI, speech recognition and the sending of email are in Paris.
- Not all processing happens in the EU. Our email provider’s technical support may access data from India, and messages of the Teams app may pass through Microsoft’s global services if the Customer enables the app.
- The test environment runs in Helsinki with invented sample data. No customer data is processed in it.
Services, locations and safeguards
| Task | Provider and jurisdiction | Storage and backups | Access from outside the EU and the EEA | Safeguards and status |
|---|---|---|---|---|
| Servers, the PostgreSQL database and dictation recordings | UpCloud Oy, Finland | Helsinki. The database service’s own backups are kept for at most 15 days; their location has not yet been confirmed in writing. | None known. UpCloud’s own subcontractors have not yet been confirmed. | Connections encrypted (TLS). Encryption at rest of the disks and the database has not yet been confirmed in writing; it will be confirmed and switched on before any customer data is processed in the service. |
| Enarra’s own database backups | UpCloud Oy, Finland | Helsinki (UpCloud object storage). A backup is gone at the latest 36 days after it was made. | None known. | Encrypted with Enarra’s keys before storage. Running in the test environment; the nightly production backup and the monthly restore test start when production is set up. |
| Locked copy of the backups | Scaleway SAS, France | Paris | None known. | Planned for production. Not yet in place. |
| AI models and speech recognition | Scaleway SAS, France | Paris. Scaleway stores no prompts or responses, except when a request causes an error or looks like abuse: then the request’s whole content may be kept in Scaleway’s systems for at most two weeks. | None known. | Connections encrypted (TLS). Under Scaleway’s data protection terms the content is not used to train models. |
| Sending the service’s emails, and delivery notifications | Scaleway SAS, France | Paris | None known. | Connections encrypted (TLS). |
| Enarra’s mailboxes, including support, which may receive the Customer’s personal data in support requests | Zoho Corporation B.V. (the Netherlands) | Zoho’s EU data centre | Zoho’s Indian group company Zoho Corporation Pvt. Ltd. may access the data for technical support. | EU standard contractual clauses. A draft transfer impact assessment has been prepared. We ask Customers not to send unnecessary personal data in support messages. |
| The Teams app (Azure Bot Service), only if the Customer enables it | Microsoft Ireland Operations Ltd, Ireland | The bot in the EU region. Microsoft keeps a copy of the conversation in the Customer’s own Microsoft 365 environment. | Some Bot Framework services are global. | The EU–US Data Privacy Framework and standard contractual clauses under Microsoft’s terms. The Customer’s administrator decides whether to enable it. |
| Sign-in with a Microsoft or Google account, if the Customer chooses it | Microsoft or Google, the Customer’s own provider | Under the provider’s terms | Under the provider’s terms | The Customer chooses and contracts for the service itself. |
The current list of subprocessors is in section 11 of the data processing agreement. Enarra notifies the Customer’s administrators of a new or changed subprocessor at least 30 days in advance. The subprocessor contracts are made in Enarra Oy’s name before any customer data is processed in the service.
Card payments for online orders are meant to go through Stripe, but online ordering has not been opened yet. E-invoices are meant to be sent through Maventa once e-invoicing starts; that is not in place yet either, and its contracting party, locations and transfers will be confirmed before it is used. Stripe and Maventa would process only Enarra’s own customer and billing data, never the data the Customer stores in the service. The privacy notice explains this.
Transfers of personal data outside the EU
Transfers of personal data are governed by Chapter V of the GDPR. Enarra does not itself transfer the Customer’s personal data outside the EU and the EEA. A subprocessor’s group company in a third country may, however, access the data in exceptional cases, and only on the basis of a Commission adequacy decision or standard contractual clauses with the necessary supplementary measures (section 12 of the data processing agreement):
- Zoho’s technical support may access support messages from India. The transfer is based on the EU standard contractual clauses between Zoho Corporation B.V. and Zoho Corporation Pvt. Ltd. An EU data centre alone does not remove the transfer, so Enarra has prepared a draft transfer impact assessment for it. Zoho’s data processing agreement will be concluded in the name of Enarra Oy before any customer data is processed in the service.
- Teams messages may pass through Microsoft’s global services. The basis is the EU–US Data Privacy Framework and standard contractual clauses. The Teams app is off by default.
- Microsoft and Google sign-in belong to the Customer’s own services, and their providers process sign-in data under their own terms.
You can ask for a copy of the standard contractual clauses at tietosuoja@enarra.fi.
Jurisdiction
The contracting party is Enarra Oy, a Finnish limited company. The contract is governed by Finnish law (section 18 of the terms of service). The service’s infrastructure is in Finland and France, with providers established in the EU. Their group companies may be outside the EU, as set out above.
Measures against access by authorities outside the EU
Article 32(1) of the Data Act requires Enarra to take adequate technical, legal and organisational measures to prevent authorities of countries outside the EU from accessing or transferring the Customer’s non-personal data held in the EU where that would conflict with EU or Finnish law. Our measures are:
- Contracts: the Customer’s data is stored in services located in the EU of providers established in the EU. Enarra binds its subprocessors in writing to the same obligations as the data processing agreement and is responsible for them as for itself.
- Disclosures: Enarra discloses data to an authority of a country outside the EU only where the disclosure complies with Article 32 of the Data Act. Enarra checks the legal basis of the request, discloses only what is necessary and tells the Customer about the request before disclosing, unless the law forbids it.
- Separation and access control: customers’ data is kept apart by row-level security in the database. The administration panel shows only counts and states of organisations, never the Customer’s content, and requires two-factor authentication. The servers can be reached only with personal SSH keys. Only the two founders hold technical superuser rights.
- Encryption: connections to the service and the database are encrypted (TLS), and Enarra’s own backups are encrypted with Enarra’s keys. Encryption at rest on the provider’s disks will be confirmed before production use.
Versions and questions
This page describes the current situation. Its earlier versions are kept in the site's version control, and on request we provide the version that was in force on a given day. Changes that weaken the protection of data are notified in advance under the data processing agreement. Questions about the contract can be sent to sales@enarra.fi, about data protection to tietosuoja@enarra.fi and about security to security@enarra.fi. Data export is described on the page Data export.