Personal data record

1. Paying, tracking and auditing vulnerability rewards related to the WithSecure Vulnerability Reward Program (a.k.a. Bug Bounty Program) 
2. Informing the Finnish Tax Administration of vulnerability reward payments

Data subjects are recipients of vulnerability reward payments (a "recipient", below) and are asked to provide the following information.

1. Name of the recipient

2. Postal address of the recipient

3. Birth date of the recipient

4. Depending on the recipient's financial institution and its location, either

1. The International Bank Account Number (IBAN) and the Bank Identifier Code (BIC) of the recipient, or

2. IBAN (optional), BIC (optional), account holder name, account number, and bank branch details of the recipient

5. For recipients taxed in Finland, their Finnish personal ID number ("henkilötunnus")

We need to collect and process the above data to be able to perform our part of mutual contract created upon your participation to our Vulnerability Reward Program.

Data is provided by the recipient of the reward upon request.

We store the above data for 6 months, after which we will delete it, except where we are required to store information on outgoing payments.

• 1. The financial institution(s) that are used to perform the payment. For Single Euro Payments Area (SEPA) payments, this includes data items 1, 2, and 4.1; for non-SEPA payments, data items 1, 2, and 4.2 from the Registry content list.

  2. Finnish Tax Administration.
  For recipients taxed in Finland, this includes data items 1, 2, and 5; for recipients not taxed in Finland, this includes data items 1, 2, and 3 from the Registry content list.

Some of WithSecure's affiliated companies are located outside the European Economic Area (EEA). Where personal data is transferred from the EEA to outside of the EEA, WithSecure undertakes to safeguard the security and integrity of processing by appropriate safeguards as required by the law by imposing appropriate contractual safeguards towards such data importers, e.g., by using data transfer clauses approved by the European Union.

Physical Security

The data files are physically secured in an internal and/or external fully classed data centers/facilities, which require full identification by relevant security personal for authorized personnel staff on register, before being able to access the physical data files.

Information Security

Only authorized personnel on register with correct user id and password are allowed and able to access the relevant information systems. Log auditing is in place and always activated.

We strongly suggest that the reward recipients send the information to us in an encrypted email.

You have the right to the data that we have on you. In particular, you have the following rights to the personal data that we hold on you:

• 1. Access and rectification 
  You have the right to ask us what personal data we have on you and to get a copy of the data that we can identify pertaining to you in this context. Should you find any errors (e.g. obsolete information) in such data, we urge you to contact our customer care to resolve the issue. Some of our service portals allow you to update your customer information. For such, you should update any changes to your personal data, for example, change of address or email address. If you cannot update the changes yourself, you may inform us of the necessary changes.

  2. Right to be forgotten
  You also have the right to request us to cease storing your personal data and erase it. In this case you need to establish a legally valid rationale for your request.

  3. Portability 
  You also have the right to ask for personal data that you yourself have provided – pursuant to a contract or your consent. You may request the data in a structured, commonly used and machine-readable format and further that the data is transmitted to another controller, where technically feasible.

  4. Restriction
  If you establish that the data we have on you is incorrect or we have no legal right to use it, you may request us to cease any further processing of your personal data, and merely keep it in store, until the issue is resolved.

Note that there may be situations where our confidentiality obligations, our right of professional secrecy, and/or our obligations to provide our services (e.g. to your employer) may prohibit us from disclosing or deleting your personal data or otherwise prevent you from exercising your rights.

If you have any complaints about how we process your personal data, or would like further information, please contact us at any time. If you feel that we are not enabling your statutory rights, you have the right to lodge a complaint with a supervisory authority. In most cases, this authority is the Finnish Data Protection Ombudsman (tietosuoja.fi).

WithSecure reserves the right to change this description of a file from time-to-time to comply with its legal obligations.

Data subjects have the legal rights to access their data as defined in the applicable Finnish data protection legislation.