Privacy

Totalhost Oy, Y-tunnus 3630955-2, c/o Triple Check Oy, Mikael Lybeckin tie 4 B, 02700 Kauniainen, Finland, is the controller for your contact, contract and identification data, and for the data of anyone who visits this website or writes to us.

The personal data in your accounting material, including details about guests and suppliers, is processed on your behalf. There you are the controller and we are the processor, under the data processing agreement that is Annex 1 to version 1.3 of the agreement.

We have not appointed a data protection officer. For anything on this page, write to info@totalhost.fi.

This website sets no cookies and stores nothing in your browser. There is no consent banner because there is nothing here to consent to.

We do count visits, which pages get opened and how often, using Cloudflare Web Analytics. It works without cookies and without a device fingerprint, so it cannot follow you between sites and cannot identify you, which is why no consent is required for it.

That counter is the only request this site makes to anything outside this domain. The typefaces are served from here rather than from a font service, and there are no tracking pixels, no advertising tags and no social embeds.

Cloudflare, which serves the site, also keeps ordinary request logs, including IP addresses, in order to deliver and protect it. Those logs are Cloudflare's, are short-lived, and are not joined to anything else we hold. Cloudflare's network is worldwide, so a visit to these public pages may be served from a point outside the EU. That is the only place this notice describes where data can leave the EU, it concerns visits to this website and nothing else, and it is covered by Cloudflare's data processing terms, which include the EU standard contractual clauses.

Email to any @totalhost.fi address lands in our Microsoft 365 mailbox, and that is where it is kept. If you ask about the service, we hold your name, your contact details and what you told us about your business for as long as the conversation is live. The legal basis is that you asked, and that we have a legitimate interest in answering. If you become a client, that correspondence becomes part of your client file. If you do not, we delete it once it is clear that no agreement will follow.

If you book a call, the booking page asks for your name, your email address and, if you give it, your phone number. The booking and those details are kept in Microsoft 365, through Microsoft Bookings, and are handled the same way as an email: part of your client file if you become a client, deleted once it is clear that no agreement will follow if you do not.

We do not use your details for marketing. If that ever changes, this page changes first, and it will say how to say no.

Six kinds of thing:

• You and your company. Name, email address, phone number, the form you operate in, your business ID, your VAT status and filing period, the addresses and identifiers of the properties you have us keep books for, and the order form you signed.
• Identification records. A bookkeeping service is required by law to identify its clients. So we hold how, when and from which document you were identified, that document's number and, where you sent us one, a copy of it; the same for anyone acting on your behalf; the beneficial owners of your company, each with name, role, date of birth and ownership share; the dates and outcomes of politically-exposed-person and sanctions checks; and a risk assessment with its reasoning.
• The accounting material you send us. The receipt or invoice file itself, its filename, type, size and checksum, and the email it arrived in. Then the values read off it: date, total, VAT and counterparty, each with how confident that reading was. Also the bank statements and booking settlements you send us, with the transactions in them.
• The books. Entries, periods, VAT figures and returns, statements, per-property profit, and the invoices we send you and whether they are paid.
• A record of who did what. Which action, on which record, by whom, when, and from which IP address. For some actions it also holds a short note of what changed, which can include a figure such as an amount or a total. Your own login shows neither that note nor the IP address.
• The service's own logs. Operational logs that can contain email addresses and account identifiers, but not the contents of your books.

We do not connect to your booking accounts or your bank. The booking exports and statements you send us include details about your guests. We keep only what your books need from them, not guests’ full names. We may also use property data in anonymised form, which no longer identifies anyone, to improve the service.

Almost all of it comes from you: what you tell us, the order form, and the files you send. Three things do not. Company and beneficial-owner details may be checked against the public registers that hold them. Politically-exposed-person and sanctions checks are made against public sources. And a guest or a supplier appears in your material because you put them there; under the data processing agreement, you are responsible for telling them that we keep your books.

• To do the work you engaged us for. Keeping your books, producing your figures, filing your returns, invoicing you. Legal basis: our contract with you.
• Because the law requires it. The Finnish Accounting Act for the material and the books, the VAT Act for the figures, and the Act on Preventing Money Laundering and Terrorist Financing for the identification records. Legal basis: legal obligation.
• To keep the service secure and its history honest. The audit record, the logs and the access controls. Legal basis: our legitimate interest in a bookkeeping system that can be trusted and audited.

The money-laundering act requires us to tell you two things plainly. Identifying you is a condition of the service: if we cannot identify you, we cannot take you on. And the identification data, and any other personal data we collect under that act, may be used for preventing, detecting and investigating money laundering and terrorist financing, and for nothing incompatible with that.

Nothing on this page rests on consent, so there is no consent to withdraw. We do not sell data, we do not share it for advertising, and nothing here is used to make automated decisions about you.

The service runs in the European Union. Six companies process data for us, each for the job stated. This is the list of sub-processors that section 4.1 of the data processing agreement refers to.

• Amazon Web Services. The application, the database, the stored receipt files and the mail they arrived in, the address receipts reach the service through, sign-in, and the email the service sends you. Frankfurt, Germany (eu-central-1).
• Microsoft Azure Document Intelligence. Reads the text and figures off a receipt file so that they can be checked. The file is sent, read, and the result returned; Microsoft deletes both within 24 hours and uses neither for anything else. Sweden Central.
• Microsoft 365. Our email and files: every message to an @totalhost.fi address, which today includes the addresses clients send receipts to before they are passed to the service, the folders that hold order forms and copies of identity documents, and the calls booked through our booking page. Stored in the EU.
• Docue. Where the order form is signed and, where we require it, where you identify yourself with bank credentials or a mobile certificate. A Finnish company; servers in the EU.
• Procountor. Our own bookkeeping and invoicing: your name, business ID and address, and what you have been invoiced and have paid. A Finnish company; data in the EU/EEA.
• Cloudflare. Serves this website and counts visits to it. No client data passes through it.

Each of them is bound to us by a data processing agreement. Amazon, Microsoft and Cloudflare have parent companies in the United States; the data itself is stored and processed in the EU as stated above, and their terms include the EU standard contractual clauses as the safeguard should any support access ever reach it from outside.

If we change these providers, clients are told at least 30 days in advance and may object on reasonable grounds, as the data processing agreement sets out. Client data is not transferred outside the EU/EEA. If that ever has to change, this page changes first, and only with a transfer mechanism the GDPR allows.

Some others receive data because the work requires it, and they decide for themselves how they handle it. The Finnish Tax Administration receives your VAT returns and the figures behind them, which a person at Totalhost files on your behalf under the mandate you give us. Your bank and the booking sites you use hold their own records in their own systems; we do not connect to them. The money-laundering act can require us to report to the Financial Intelligence Unit, and forbids us from telling you if we have. Beyond that, we hand data to an authority only when the law obliges us to.

• Accounting material and the books. The periods the Accounting Act sets: six years from the end of the year in which the financial year ended for receipts and other vouchers, and ten years from the end of the financial year for the books and the financial statements.
• Identification records. Five years after the client relationship ends, as the money-laundering act requires. Then they are deleted.
• Your contact and contract data. For the life of the agreement, and as long after it as a claim under it could still be made.
• Backups. A daily backup is kept for 35 days. A monthly backup is kept for seven years, the longest of the accounting periods above.
• The service's own logs. Currently kept without a fixed limit.

When an agreement ends, we hand your books and material over to you, and from then on keeping them for the periods above is your responsibility. We remove them from the service 90 days after handover, apart from what the law still requires us to keep.

One consequence is worth stating plainly: the ledger is append-only, and while your books are with us, receipts are not deleted during their retention period. A correction is a reversing entry, not an edit; a receipt we decline is marked rejected and the file stays. That is what makes the books auditable, and it means we cannot erase financial records on request while their retention period runs. Data that is not part of the accounting record can be corrected or removed in the ordinary way.

Encryption in transit and at rest, multi-factor sign-in, separation between clients enforced in the database rather than in application code, backups, and a record of every action. The detail is on Trust.

If a breach ever affects your data, we tell you without undue delay and within 48 hours of learning of it, as the data processing agreement says, and the supervisory authority within 72 hours where the law requires it.

You can ask what we hold about you and get a copy; have inaccurate details corrected; ask for data to be erased or its use restricted, within the limits the retention rules above impose; object to processing we base on legitimate interest; and receive the data you gave us in a portable form. We may ask you to confirm who you are before we answer.

Two limits are set by law rather than by us. Financial records cannot be erased while their retention period runs, and identification records collected under the money-laundering act cannot be erased at your request while we are required to keep them. The law also limits what we may tell you about anything done under that act's reporting duty.

Those rights cover your own details, where we decide what is held. Your books are the other way round: there you decide and we act on your instructions, so a request from a guest or a supplier about something in them comes to you, and we help you answer it.

Write to info@totalhost.fi and we will answer within a month. If you think we have handled your data wrongly you can complain to the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto, tietosuoja.fi). We would rather you told us first.

If what we do with data changes, this page is updated before the change takes effect, and the date at the top changes with it. Clients are told directly about anything that materially affects them.