Published pursuant to EU Data Act (Regulation (EU) 2023/2854), Article 25.
1. Introduction
This page sets out the information required by Article 25 of the EU Data Act (Regulation (EU) 2023/2854) regarding the switching of service provider for the Bricknode Financial Systems (BFS) platform provided by Done Investments AB ("SUPPLIER").
Customers who wish to switch to a different data processing service provider, migrate to an on-premises ICT infrastructure, or erase their exportable data are entitled to do so in accordance with the terms of their Master Subscription Agreement (MSA) and the EU Data Act.
This page should be read together with the MSA. In the event of any inconsistency between this page and the MSA, the MSA prevails.
2. How to Initiate a Switch
To initiate the Switching Process, CUSTOMER shall submit a written switching request to SUPPLIER at the contact address set out in section 9 below. The request should specify:
- the desired action (switch to another provider, migrate to on-premises infrastructure, or erase exportable data);
- where applicable, the name and contact details of the new data processing service provider; and
- whether the switch relates to all Services or only specific parts.
SUPPLIER will acknowledge receipt of the switching request without undue delay.
3. Timeline
The following timeline applies to the Switching Process:
| Phase | Duration |
|---|---|
| Switching Notice Period | 2 months from receipt of written switching request |
| Transitional Period | 30 calendar days commencing after the Switching Notice Period |
| Extension of Transitional Period | CUSTOMER may extend once for any period it considers appropriate |
| Data Retrieval Period | 30 calendar days commencing after the end of the Transitional Period |
| Data Deletion | Upon expiry of the Data Retrieval Period, subject to any retention obligations applicable to SUPPLIER under law. |
4. Exportable Customer Data
The following categories of Customer Data can be ported during the Switching Process. This constitutes the Standard Export of Data, provided without additional charge (one export):
| Category | Description |
|---|---|
| Customer / Client records | Client accounts, contact details, and KYC data registered in BFS as at the date of export. Historical changes and audit trails are not included. KYC documents stored as uploaded files (e.g. PDFs) are not included in the Standard Export. |
| Account data | All account structures, account types, and account holdings |
| Transaction history | All executed transactions, orders, and settlements recorded in BFS |
| Portfolio data | Current and historical portfolio positions |
| Instrument data | Instruments and financial product data registered by CUSTOMER in BFS, as at the date of export. Historic price data is not included. |
| User and access records | User accounts and role configurations (excluding passwords and credentials) |
4.1 What is not included in the Standard Export
The following categories are not included in the Standard Export of Data, as they constitute proprietary components of the BFS platform or are technically not exportable without additional work:
- Historic market prices and instrument reference data sourced from third-party data providers;
- Files and documents uploaded and stored within the BFS document management functionality;
- System configuration, workflow settings, and platform customisations that form part of the BFS software itself;
- Derived or aggregated data generated by SUPPLIER's systems that does not directly identify or relate to CUSTOMER;
- Data held exclusively by SUPPLIER's sub-processors in formats not accessible through BFS's standard export functionality; and
- Reports stored as uploaded files.
5. Porting Methods and Formats
The Standard Export of Data is provided in comma-separated values (CSV) format, delivered via secure download from the BFS production environment. Alternative formats may be available upon request and agreement and will be subject to additional engineering fees as set out in the MSA.
6. Costs
One Standard Export of Data is provided without additional charge. No switching charges will be imposed in accordance with EU Data Act Article 29.
Any data extraction, format conversion, or migration assistance beyond the Standard Export of Data is subject to SUPPLIER's standard engineering fees as set out in the MSA.
7. SUPPLIER's Obligations During the Switching Process
SUPPLIER's obligations during the Switching Process are set out in the MSA.
8. Legal Basis
This page is published pursuant to Article 25 of Regulation (EU) 2023/2854 of the European Parliament and of the Council of 13 December 2023 on harmonized rules on fair access to and use of data (EU Data Act).
The switching rights described on this page are statutory rights that cannot be waived or restricted by contract. They apply in addition to, and do not replace, any termination rights set out in the MSA.
9. Contact
| Switching requests | legal@doneinvestments.com |
|---|---|
| Postal address | Done Investments AB, Lögegatan 11, 541 30 Skövde, Sweden |
| Last updated | September 2026 |
Done Investments AB · Org. nr. 559040-5709 · doneinvestments.com