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LEGAL

Finnish Trust Network Terms of Service

1. Introduction

The terms and conditions set out in this Appendix constitute Idura’s Finnish Trust Network Terms of Service (“E-ID Terms of Service”), which govern the provision and use of Idura’s Finnish identification services (“E-ID Services”).

This Appendix supplements the Idura service agreement, the Idura Terms of Service and the relevant appendices (the “Agreement”) entered into between the parties, and must be interpreted accordingly.

2. Validity and Scope

Idura offers the E-ID Services as a registered broker in the Finnish Trust Network (”FTN”). To offer the identification services to customers, Idura cooperates with Telia Finland Oyj (“Telia”) that operates as a separate registered broker in the FTN.

The applicability of these E-ID Terms of Service is limited to the provision of the E-ID Services from Idura to the customer, and these E-ID Terms of Service, the Idura Terms of Service and the terms and documents referred to herein shall exhaustively and expressly apply to the E-ID Services (and provision thereof).

The scope of the E-ID Services is defined in the Agreement and the Telia Service Description.

2.1 Order of Precedence

With regard to the provision of E-ID Services, the following order of precedence shall apply in case of conflict between different terms and documents, with the terms or documents with a lower number prevailing over the terms or document with a higher number:

  1. The Idura Service Agreement
  2. Idura Terms of Service
  3. These E-ID Terms of Service
  4. Idura's FTN Service Description
  5. Telia Service Description concerning Telia Tunnistus (“Telia Service Description”) as available from time to time on Telia’s website, cf. Exhibit 1.
  6. Telia’s General delivery terms of the Telia Identification service for business customers (“Telia Terms”) as available from time to time on Telia’s website, as provided in Exhibit 2.

The terms and documents listed above form an integral and inseparable part of the Agreement.

3. The Services

Subject to the order of precedence set out in Section 1.1 above, the parties’ obligations, warranties and liabilities relating to the E-ID Services are specified in the Telia Terms and the Telia Service Description. Accordingly, as regards the E-ID Services, the Telia Terms and the Telia Service Description shall apply mutatis mutandis between Idura and the customer, meaning that the customer shall be deemed as the customer and Idura shall be deemed as Telia, to the extent the context can reasonably and logically be so applied.

For the sake of clarity, references to “agreement” or “Agreement” in the Telia Terms and Telia Service Description mean references to the Agreement (for the part the E-ID Services are provided under the Agreement).

For further clarity, descriptions of Telia’s own service or operation or activities in the Telia Service Description do not apply in the contractual relationship between Idura and the customer, as applicable and reasonably apparent from the context.

For clarity, and without limiting the applicability of Telia Terms, Idura shall be entitled to use and replace any third-party as Idura’s subcontractor with regard to the E-ID Services provided under the Agreement or to fulfil its other obligations under the Agreement.

3.1 Service Availability

As regards the E-ID Services, Idura commits to the service availability and service level as provided in Section 1.5.1 of the Telia Service Description.

3.2 Changes to the Services

Without otherwise affecting the applicability of the Telia Terms, Idura may discontinue the provision of the E-ID Services or certain features of it in accordance with Section 4.3 of the Telia Terms, and Idura will inform the customer thereof in writing at least fifty (50) days before the effective date of such discontinuation.

If the customer does not accept the replacement service offered pursuant to Section 4.3 of the Telia Terms, the customer shall notify Idura in writing within twenty (20) days of receiving the discontinuation notice. Failure to provide timely notice shall constitute acceptance of the replacement service. If the customer validly objects, Idura shall use best efforts to propose an alternative replacement.

In addition, in case Telia adds or removes identification devices and services from its service provision, or otherwise changes its service provision, Idura is entitled to make corresponding changes to the E-ID Services upon prior written notification.

Idura shall be entitled to change the customer identifiers when required by law, an order by the authorities or other reasons attributable to the customer, service provision or information security or a corresponding reason. Idura will inform the customer of any changes in the identifiers no later than one (1) month before the changes take effect unless the change requires immediate action.

4. Registration

In order for Idura to provide the E-ID Services, the customer must register on Idura’s website signing up to the E-ID Services. During the registration process, the customer shall provide:

  • the name of the customer’s company,
  • the customer’s EU VAT ID
  • a statement stating whether the customer’s company is a public or private entity.

Based on the information provided, Idura shall perform know your customer ("KYC") verification of the customer.

In addition to the use restrictions applicable to the E-ID Services as set out below, the customer shall provide a unique identifier for its account domain. The customer may invite individuals authorised by the customer to use the E-ID Services (“Authorized Users”) through the dashboard after logging into the customer’s account at the designated URL.

The customer represents and warrants that all registration information provided by the customer and by Authorized Users is true, accurate and complete, and that the customer shall maintain and update such information to ensure its continued accuracy.

The customer shall be solely responsible for maintaining the confidentiality of its user accounts, including the accounts of Authorized Users and their end users, and for any use or misuse thereof. The customer shall promptly notify Idura of any requirement to deactivate an Authorized User.

The customer shall be liable to Idura for any and all acts or omissions of the Authorized Users and shall indemnify Idura for any losses arising therefrom.

4.1 Customer Requirements and Use Restrictions

For clarity, and without limiting the applicability of any other customer requirements, as regards the E-ID Services, the customer shall adhere to and comply with any and all customer technical requirements prescribed in Telia Service Description (see, in particular, Section 1.7 Subsection “Technical requirements for introduction”).

The customer must comply with OpenID Connect requirements but not with SAML requirements set out in the Telia Service Description.

Further, and without limiting the applicability of any other use requirements or use restrictions, the customer shall adhere to and comply with use requirements and restrictions set out in the Telia Terms and Telia Service Description, particularly as set out in sections 6 and 7 and 9 of the Telia Terms. Additionally, section 1.2 of the Telia Service Description shall also apply unrestricted in the use of the E-ID Services.

For example, without limiting applicability of any other use requirement or restriction, the customer may not use E-ID Services contrary to good practice and must follow all of the applicable rules for identification devices. For the avoidance of doubt, the E-ID Services are only available for customers within the EU.

Additionally, with respect to the Section 6.1 c) of the Telia Terms, the customer shall ensure, among others, that customer’s transaction services do not jeopardise Telia’s security, the security of the user using the customer’s service, Idura and the identification device provider, as provided in the said Section.

4.2 Prohibited practices

The customer shall not (and shall ensure that any users of the E-ID Services or third parties do not) reverse engineer, decompile, or otherwise attempt to discern the source code or interface protocols of the E-ID Services in violation of these E-ID Terms of Service or applicable laws, or in violation of the Agreement.

Furthermore, the customer shall ensure that unauthorized use of and access to the E-ID Services is prevented, and the customer shall ensure that no software, virus, “back door,” trojan horse, or similarly harmful code is introduced to the E-ID Services. The customer is permitted to monitor the usage of the E-ID Services (e.g., counting the volume usage of the E-ID Services).

5. Prices

For clarity, Telia’s price list referred to in the Telia Terms (inter alia in Sections 8.1, 5.3 and 5.7 of Telia Terms) shall not apply as regards the E-ID Services and Idura’s prices and price lists referred to in the Agreement shall apply.

Notwithstanding the foregoing, in the event that Telia updates its prices as set out in the Telia Terms, Idura shall be entitled to make corresponding adjustments to the prices of the E-ID Services under the Agreement. Idura shall use best efforts to notify the customer of any such price adjustments as soon as reasonably practicable prior to the effective date thereof.

6. Maintenance Work

The E-ID Services may be temporarily unavailable due to maintenance, information security or other alteration work carried out by Idura, Telia or any identification device provider, regardless whther such work is scheduled within or outside a designated maintenance window.

In such cases, Idura shall notify the customer of any such maintenance work carried out by Idura, Telia any identification device provider immediately upon becoming aware of such maintenance work.

For scheduled maintenance work Idura will be carried out on Mondays during 00:00-04:00, unless the nature of the maintenance work is such that it cannot be postponed. Idura may change the change the timeslots of the maintenance windows, by notifying the customer at least three (3) business days in advance.

Irrespective of the nature of the maintenance work performed by Idura, Telia or any identification device provider, including whether it is performed within or outside a scheduled maintenance window, the E-ID Services may not be available and Idura shall not be responsible for the availability or functionality of the E-ID Services during such maintenance work, or if servicing and maintenance cannot be performed at the agreed time for reasons attributable to the customer. Further, Idura is not responsible for any third-party or customer networks, or for faults that these may cause to the E-ID Services.

7. Customer Support and Communication

Without otherwise limiting the applicability of Telia Terms and Telia Service Description, as regards to the E-ID Services, the customer shall use Idura’s support service in relation to the provision of the E-ID Services, and in other communications to Idura.

Idura will mainly use email and Slack (or equivalent) for communication with the customer.

8. Disturbance reporting

In accordance with Section 1.8 of the Telia Service Description, the customer shall immediately inform Idura in writing of any information security threats, disturbances and data protection violations in their own transaction services or devices, and in Idura’s E-ID Services. Such notification shall include a description of the threat or disturbance, the measures the customer has available to counter such threats and risks, the estimated expenses incurred by these measures and any other information reasonably required by Idura to fulfil its statutory reporting obligations.

9. Privacy

Without otherwise limiting the applicability of Telia Terms and Telia Service Description, references to Telia’s privacy policies or Telia’s privacy statements in Telia Terms and Telia Service Description shall be replaced with references to Idura’s privacy policy.

For clarity, and as set out in the Telia Terms, the parties act as an independent controller in respect of the processing of personal data related to the identification event (identification data).

In accordance with Section 11.3 of the Telia Terms and Traficom's recommendation 216/2022 S, the customer is responsible for: (i) informing users of the disclosure of personal data from the identification device provider to Telia, Idura and the customer when the identification event takes place and an identification assignment is made; (ii) fulfilling its obligations under applicable data protection legislation, including the GDPR, with respect to informing users about the processing of their personal data; and (iii) ensuring that any further processing of personal data obtained in connection with the provision of the E-ID Services is carried out only where the customer has a lawful basis for such processing.

In addition to general personal data protection regulations applying to the parties, Idura and the customer shall comply with relevant data protection related requirements specified in Section 1.8 of Telia Service Description and in Section 11 of the Telia Terms.

10. Liability

The limitations of liability set out in Idura’s General Terms of Service shall apply unrestricted to the E-ID Services provided by Idura under these E-ID Terms of Service.

Notwithstanding the foregoing, where any liability arises in connection with the E-ID Services from circumstances relating to, or caused by, any component of the E-ID Services that is outside Idura’s control and is provided or performed by a third party, Idura's aggregate liability to the customer under the Agreement in respect of such liability shall in no event exceed the amount of compensation actually recovered by Idura from such third party under the agreement between Idura and that third party.

Any claim by the customer for remedies relating to the E-ID Services, including claims for damages, must be submitted in writing no later than two (2) months after the relevant delay, defect or damage was discovered or ought reasonably to have been discovered.

With respect to Sections 5.4 and 5.8 of the Telia Terms, where a defect in the E-ID Services is relates to a service, component or software provided by a third party, Idura’s sole obligation shall be to use best efforts to procure rectification from the relevant third party in accordance with its agreement with such party.

With respect to Sections 13.2–13.8 of the Telia Terms, to the extent that a third-party claim or legal action alleging that the E-ID Services infringe third-party intellectual property rights relates to, derives from, or concerns a part of the E-ID Services that is outside Idura's control and is provided by, or relates to a service, software, or component provided by, a third party, Idura’s liability in respect of such alleged infringement shall be limited to:

  1. indemnifying the customer for all damages incurred as a result of such infringement, subject to the limitation of liability set out in this section 9;
  2. using best efforts to provide information regarding the alleged infringement to the relevant third party whose component, software, or service the allegation concerns; and
  3. cooperating with such third party to facilitate resolution of the matter, at the discretion of such third party.

11. Specific Termination Terms

Without limiting the applicability of the Idura Service Agreement or the Telia Terms, in the event that the agreement between Idura and Telia is terminated by either party for any reason, Idura shall be entitled to terminate the E-ID Services, in whole or in part, by providing written notice to the customer and such termination shall be effective no later than the date on which the agreement between Idura and Telia terminates.

The customer’s termination rights follow the notice periods and requirements set out in the Idura Service Agreement.

For clarity, in case customer or Idura exercises its right (if any) to terminate or cancel agreement or remove services from the scope of the agreement by following terms in the Telia Terms or Telia Service Description, this termination shall not mean the termination of the Agreement and the termination is limited to the termination of the respective E-ID Services, meaning the removal of the respective E-ID Services from the scope of the Agreement.

12. Changes to the terms

Idura reserves the right to remove, replace, supplement or modify the applicable terms of service or service descriptions or other documents attached to the Agreement that apply to the provision of the E-ID Services (e.g., Telia Terms (as applied to these terms), Telia Service Description (as applied to these terms), Idura Service Description or these E-ID Terms of Service).

Idura will notify the customer of any such changes two (2) weeks prior to such changes entering into force. In the event of material changes, or changes that degrade the E-ID Services, render them unusable, or result in additional costs to the customer, the customer shall have the right to terminate the respective E-ID Services within one (1) month of receiving notice of such change, and upon such termination, the terminated E-ID Services shall be removed from the scope of the Agreement.

In the event that the Telia Terms or the Telia Service Description are modified by Telia during the term of the Agreement, Idura shall notify the customer of any such modifications as soon as Idura becomes aware of them. The applicable Telia Service Description and Telia Terms shall be automatically replaced by the modified versions as made available on Telia’s website from time to time, effective as of their respective effective dates. Without prejudice to Section 20.2 of the Telia Terms, the customer's termination rights set out in Section 11.2 above shall apply.

13. Miscellaneous

For the avoidance of doubt, Sections 17 (Order of interpretation), Section 18 (Notifications) and Section 19 (Applicable law and dispute resolution) of Telia Terms shall not apply.

In addition, in the inter partes relationship Idura and the customer agree to the following changes to the Telia Terms:

In section 13.9 the following wording shall be deleted: “Telia and the identification device provider shall be entitled to publish the customer’s name in their communication concerning the service, identification device and trust network agreement for the specific identification device. The communications must comply with the customer’s instructions on presenting the trademark or other logo.”

In section 14.2 the following wording shall be deleted: “Telia shall also not be liable for the customer’s liability to any third party, other than those referred to in section 13.2.” Section 10 of Idura’s General Terms of Service will apply for third party claims.

In case it is not clear whether a term or requirement, obligation, description or any section or paragraph included in the Telia Terms or Telia Service Description applies, or it is not clear what is the content of the same or how it should be interpreted, the customer must consult Idura on the interpretation of the same, with Idura and the customer having the obligation to in good faith discuss and conclude on a reasonable and foreseeable interpretation of the same.

Exhibit 1: Telia Service Description

When these E-ID Terms of Service reference any sections in the Telia Service Description, it refers to the following documents part of the agreement between Idura and Telia entered into on 10 June, 2025.

  • Service agreement Date 28.5.2025 Agreement number 5250527176943
  • Customer specific terms Date 27.5.2025 Appendice to the service agreement 5250527176943
  • Service description Date 27.5.2025 Appendice to the service agreement 5250527176943
  • Price list Date 27.5.2025 Appendice to the service agreement 5250527176943

Exhibit 2: Telia Terms

When these E-ID Terms of Service reference any sections in the Telia Terms, it refers to the sections of “This General delivery terms of the Telia Identification service for business customers” attached to the agreement between Idura and Telia entered into on 10 June, 2025.