Privacy Policy

(updated 12.10.2020)

At Dobbytec OÜ, one of our main priorities is the privacy of our visitors, customers and users. This Privacy Policy document describes types of information collected by Usetiful (a Service of DobbyTec) and how DobbyTec protects and processes this information

The Privacy Policy relates to Terms & Conditions (published here). Terms, such as, but not limited to - ”User”, ”Customer”, ”Agreement” are defined in Terms & Conditions.

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us through email at [email protected]

General Data Protection Regulation (GDPR)

Depending on the context, DobbyTec acts as a Personal Data Controller or Personal Data Processor.

I. DobbyTec - acting as a Data Processor

DobbyTec provides the software application Usetiful allowing Customers to provide guidance to their Users on how to use a Customer’s digital product and evaluate their behavior.

The data obtained by Customer via Usetiful may include the personal data of natural persons (Users). In regard to personal data that the Customer stores on our servers, we operate as a Personal Data Processor. The controller of such personal data is the Customer itself.

Notice for the Customer

By using the service Usetiful and collecting Users’ personal data, the Customer becomes a personal data controller according to Article 4 (7) GDPR and is obligated to comply with all personal data protection rules set out by the GDPR and by other legal regulations governing such issues. DobbyTec does not bear any liability for a breach of personal data protection or any other legal obligation by Customers.

DobbyTec as a processor of the personal data shall take all measures required pursuant to Article 32 of GDPR.

DobbyTec takes into account the nature of the processing, assists Customer by appropriate technical and organisational measures, insofar as this is possible, for the fulfilment of the Customer's obligation to respond to requests for exercising the data subject's rights laid down in Chapter III of GDPR.

DobbyTec assists Customer in ensuring compliance with the obligations pursuant to Articles 32 to 36 of GDPR taking into account the nature of processing and the information available to DobbyTec.

If requested by Customer, DobbyTec makes available to Customer all information necessary to demonstrate compliance with the obligations laid down in Article 28 of GDPR and allow for and contribute to audits, including inspections, conducted by the Customer or another auditor mandated by the Customer.

Why do we process personal data

For the purpose of the fulfilment of an Agreement, DobbyTec may process the following personal data: First name, Last name, E-mail address, User behavior on Customer´s digital product. DobbyTec processes these data only if a Customer explicitly sets the service Usetiful to collect them.

For the purpose of the fulfilment of an Agreement, Usetiful uses a “cookie” to identify returning Users and to identify the User’s past behavior on Customer’s digital product.

DobbyTec does store the data for Customer. DobbyTec does not modify them unless explicitly requested by Customer, does not transfer them to third parties (with the exception of state authorities and sub-processors), does not make them accessible, unless the Agreement provides otherwise. The sole purpose of the processing activities is storage and accessibility of the personal data by Customer.

Customer gives DobbyTec a prior general authorisation to engage other processors (sub-processors). Where another processor is engaged for carrying out specific processing activities on behalf of Customer, the same data protection obligations as set in this Privacy Policy shall be imposed on the other processor. If the other processor fails to fulfil its data protection obligations, DobbyTec shall remain fully liable to Customer for the performance of that other processor’s obligations. DobbyTec shall inform Customer of any intended changes concerning the addition or replacement of other processors, thereby giving Customer the opportunity to object to such changes.

How long do we keep personal data

DobbyTec processes personal data of Users for the duration of Agreement with Customer. After the Agreement is cancelled, all personal data are erased. In case Agreement defines different Retention Policy, the Agreement takes precedence.

How do we collect personal data

The personal data of Users are collected on the basis of using the service Usetiful. Service must be installed by Customer to be accessed by Users.

When using the system Usetiful, provided by DobbyTec, Customer can set up Usetiful to collect personal information of User: First name, Last name, E-mail address, User behavior on Customer’s digital product.

Who is the Data Controller

The Data Controller is a respective Customer, using system Usetiful.

The utilization of the system Usetiful, provided by DobbyTec, may be subject to the principles and rules of the given Customer. Customer is obliged to ensure that the utilization of Usetiful will meet all requirements of GDPR and any other legal requirement applicable to Customer. DobbyTec is not liable for the personal data protection principles or security procedures of Customer or any breach of Customer’s legal obligations arising from utilization of Usetiful.

Confidentiality

DobbyTec ensures that persons authorized to process the personal data are committed to confidentiality or under an appropriate statutory obligation of confidentiality.



II. DobbyTec - acting as a Data Controller

DobbyTec is the Personal Data Controller of information related to the personal data of Customers. For personal data of Users, please refer to I. DobbyTec - acting as a Data Processor.

Why do we process personal data

We process personal data of Customers for the purpose of the fulfilment of an Agreement or legal obligations.

DobbyTec collects and processes following personal information: First name, Last name, Company name, identification number, VAT number (or similar), Address of registration, Address of operations, Contact information (such as, but not limited to: email address, telephone number), payment information and number of assists per month.

DobbyTec tracks behavior of anonymous Customers within the service Usetiful, having the information anonymized and aggregated within large groups (such as country). This information is by default anonymous, but in special situations (such as a Customer being the only one in a given country) could be linked to a specific Customer. DobbyTec has an internal policy to avoid such attempts.

DobbyTec legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect the information:

  • processing is necessary for the performance of a contract between DobbyTec and Customer
  • Customer has given consent to the processing of his or her personal data for one or more specific purposes
  • processing is necessary for the purposes of the legitimate interests pursued by DobbyTec
  • processing is necessary for compliance with legal obligations to which the DobbyTec is subject

The legitimate interest of DobbyTec means:

  • processing of Customer’s personal data for the purpose of keeping evidence of the provision of the service to Customer in the event of his or her complaint
  • DobbyTec might transfer personal data information to third parties, but only to parties that comply with the personal data protection principles compliant to GDPR. Such third parties operate in the position of Personal Data Processors.

DobbyTec does not conduct profiling or automated individual decision-making.

How long do we keep personal data

The personal data of Customers is processed for the duration of the contractual relationship. After the contract is cancelled, all data is deleted - with exception of situations where legal requirements or state authority orders to act differently (such as various requirements in accounting, and many more) or where a processing is based on a legitimate interest of DobbyTec.

How do we collect personal data

We obtain personal data of Customers directly when entering into the Agreement, or later, when updated by a Customer.

Contact information:

We are a Data Controller of personal information related to Customer.

Identification and contact information of the Data Controller:

Dobbytec OÜ

Registration ID: 14414449

Sepapaja tn 6

15551 Tallinn

Estonia

(hereinafter also referred to as “DobbyTec” or “we”)

Contact email: [email protected]

Customer’s Rights:

As a data subject, a Customer has the following rights:

  • Right to request from DobbyTec access to and rectification or erasure of his or her personal data or restriction of processing concerning Customer or to object to processing as well as the right to data portability.
  • If Customer has given consent to processing, he or she has the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
  • Customer has the right to lodge a complaint with a supervisory authority in particular in the member state of his or her habitual residence, place of work or place of the alleged infringement if Customer considers that the processing of personal data relating to him or her infringes GDPR. A national data protection authority in Estonia may be reached at the following address:

    Estonian Data Protection Inspectorate
    39 Tatari St., 10134 Tallinn
    telephone (from abroad add +372) 627 4135
    e-mail info[a]aki.ee


    The provision of the personal data is a requirement necessary to enter into a contract. If Customer refuses to provide DobbyTec with the requested personal data, a contract cannot be concluded and DobbyTec cannot provide you with any services.

III. Final Provisions

Log Files

Usetiful follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services' analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users' movement on the website, and gathering demographic information.

Cookies and Web Beacons

Like many other websites, the Websites (including, but not limited to, www.usetiful.com and www.dobbytec.com) use 'cookies'. These cookies are used to store information including visitors' preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users' experience by customizing our web page content based on visitors' browser type and/or other information.

Third parties

There might also be third party cookie or web beacon located on our Services or on the Websites. As an example, this might be because we have authorized a third party (List of sub-processors) to conduct a website analysis.

Children's Information

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

DobbyTec does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our Website or in our Services, we strongly encourage you to contact us immediately and we will do our best to promptly remove such information from our records.

Online Privacy Policy Only

Our Privacy Policy applies only to our online activities and is valid for visitors to our website with regards to the information that they shared and/or collect in our Services or on our Website. This policy is not applicable to any information collected offline or via channels other than Websites or Services.