Privacy Policy

(updated 30.04.2020)

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

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.

The data obtained by Customer may include the personal data of natural persons. 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, the Customer becomes a personal data collector 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 by Customers.

Why do we process personal data

For the purpose of the fulfillment of an Agreement, DobbyTec processes 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 fulfillment 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 handling such information is their storage and accessibility by Customer.

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. We cannot be liable for the personal data protection principles or security procedures of Customer.

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 fulfillment 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). 

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:

  • Dobbytec OÜ needs to perform a contract with you
  • You have given Dobbytec OÜ permission to do so
  • Processing your personal information is in Dobbytec OÜ legitimate interests
  • Dobbytec OÜ needs to comply with the law

DobbyTec might transfer personal data information to third parties, but only to parties that comply with the personal data protection principles compliant to GDPR or Privacy Shield. 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).

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


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

Contact email:

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you.
  • The right of rectification.
  • The right to object.
  • The right of restriction.
  • The right to data portability
  • The right to withdraw consent

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, and 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 (such as Microsoft Corporation or Google Inc.) 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.


By using our Website or Services, you hereby consent to our Privacy Policy and agree to its terms.