Privacy Policy

Last Updated (March 2021)
In the following text kindly find our last “Privacy Policy Documentation”

1. Important Information

Our brand under defaro OÜ located in Tallin, Estonia with any alternative labels and names (collectively, “defaro” / “platform”/ “we” / “our” / “us” ) are strongly committed to respecting and keeping your privacy. You can download this as file here.

2. Purpose of Privacy Policy

Our privacy policy (“Privacy Policy”) is provided below. Hence you can go through to see the all details of this policy and its applications. Privacy Policy comes into action as “Agreement” with our customer, intermediary of user and entities that we call it “client”.

defaro explains here how to collect and use your personal and company data according to Privacy Policy. This Privacy Policy sets out how we collect and process your personal data as Customer or User of platform or who submitted the data on our platform.

3. Our responsibility over personal data

References in this Privacy refers to the “entity” who has entered into the Accordance and Agreement as employer or client with us. You will typically be an employer, employee, officer, university or government affiliation, contractor or consultant, temporary customer of any time of customer relationship with defaro OÜ.

4. Our data protection responsibility

The employer (The company whom you work for) is the main data controller and user for the purposes of personal data processed under this Privacy Policy. The defaro OÜ will process your personal data or processor on behalf of your employer and according to lawful and GDPR (KKVK) instructions. The information you provide to us and/or upload to the website or platform (whether or not it constitutes personal data) will be valid or governed by the Agreement.


We in defaro as a data processor and collector, We will collect and process the following personal data about you:

A. Information we are collectıng about you. We will use and administer this information:

  • to report to your employer relating to the use of the Platform required under the Agreement;
  • to demo, show and sell our features to you as client.
  • for our internal operations including data analysis, research, statistical tests, gap analysis, skill board or any required data for the features.
  • to use the platform, share you data for learning from others, to make skill boards and scheduling the learning meeting. We can follow any lawful action in case a third user violate your personal data respecting your security and privacy. You can manage your data via our platform to avoid the miscellaneous and violations.
  • to keep the Platform safe and secure and stable;
  • to compile reports, analysis or any algorithmic usages (without any misuse of personal identification) on Platform.

B. The information we receive directly from you as user. Alternatively saying, YOU GIVE THIS IFORMATION to us.

using or consenting the Platform sections and functions, completing forms, completing your personal and working data, skills, job titles, positions, resume or any related data you need to complete for using our Platform. You employer can set the information or giving us directly as data of your skills, your activity, personnel. This information may include your name and surname, personal photo, your age, business email, department, your team, job or position title, level of seniority, department, skills as soft or hard, role skills, tools you use in company, your work interest, your learning data, your location, comments, feedback or learning activity, meetings, calendar, your project information and data, information regarding your employer performance review, skill gap, or completing any survey, demo form or service form to use and purchase the platform.

C. Other Information we may receive from other sources.

We may aggregate the data or any receıved information from other resources with the information you give to us or we collect about you.

In relation or in addition to the above usages, we shall process your personal data on the legal basis determined by your employer or where it’s necessary for the purposes of our legitimate interests, including:

  • to deliver our service based our contract obligations and accordance under the Agreement as client or customer;
  • to compare you data with large data sets (learning data sets, skill data sets, labor market data sets or any required and valid data sets we use and notify you);
  • to deliver secure and safe service and features;
  • to maintain the security and safety of our platform;
  • for any system issues as troubleshooting, debugging, defending of possible attacks
  • to update our platform features or product and its infrastructure
  • to improve user experience and user interface of the Platform;
  • to protect and defend our legal rights;
  • for data analysis, data reporting, machine learning operations, testing and research purposes.

6. How to share and process your personal data

We may share your personal data with other services, product providers, companies and infra-structure services where in order to maintain the service and provide the provision of services to you as user or your employer as admin of our product.

We may also share your personal data with selected third parties according to our policy, as follows:

  • Amazon Web Services (AWS), Mail Chimp, Google Workspace, WordPress; who provide cloud hosted infrastructure and services used by us to operate and execute the Platform as a hosted solution; and
  • Google LLC, Notion, Whereby, Miro, Slack, Rstudio who provide product tools and functionality used by us in delivery of the Platform and associated services.
  • Service providers (for example of IT services), business partners and/or suppliers of your employer (Agreement)
  • government or other law enforcement agencies or other legal entities (this may include your location information).

We require all our third party service providers and all other companies to maintain strict security measures to protect your personal data in line with our policies. We do not permit and allow to other third service providers to use your data for their own purpose or benefit and for any other purposes unless under our accordance in line with our policy.

7. Our Security and Safety

We have transparency culture and honest manner with you to provide the safety and security provided by our team, third party service and our company. We shall remind you that the transmission of information via the internet is not completely secure and there is probability of any cybersecurity issues. We are very clear about what we should we do and we will do our best to protect your personal data, although there is no guarantee of 100 percent to provide the security of your data transmitted to the Platform and you acknowledge that any transmission is at your own risk. We take our strict responsibility to provide the security and safety.

Please keep in mind you acknowledge the responsibility of choosing or working with the passwords or any security module on your system such as browsers, passwords collector apps, devices, operation systems you use, firewall etc.

8.Rights of User (Your rights)

We are transparent about your right of personal data. We respect the user rights regarding the items we elaborate in detail in the following. Please keep in touch with your employer as Agreement party or approach us if you would like to make clear rights. (other than a change to your marketing preferences, which should be notified directly to us).

  • Right of processing. You have the right to object to processing of your personal data. This process normally will undertake by us on the basis of our (or a third party’s) legitimate interest. You also have the right to object at any time to the processing by us of your personal data for direct marketing purposes.
    • Access. You have the right to access information about the personal data we hold about you.
    • Erasure. regarding the extent for protection data and lawful considerations, you have the right to request that we delete temporary or permanently any personal data that we hold about you, including the withdrawal of your consent (where our processing of that data is undertaken on the basis of your consent). This right does not include non- personal data.
  • Request to restriction of processing. you can require us to restrict the processing of your personal data under certain circumstances.
  • Analysis and reports You have the right to not seen of any part of your working data based on your preference like skill gap, interest etc unless your company may hurt due to the Agreement. We follow the company agreement and we can provide facility regarding our Terms of use condition. Every single analysis will be exposure to you and your employer (regarding the request and our agreement). Your personal data analysis can be effective for any working related or employer-side decision where Platform has not any intervention like promotions, performance management, learning and development planning, lay-offs, furloughing, renewing or canceling temporary or permanent agreement or any job-related agreements.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data.

Please note that if you exercise any of the above rights to require us to restrict or cease processing or to delete personal data, and this type of processing is required in order to facilitate your use of the Platform, you will no longer be able to use the Platform following the date on which we action your request.  This does not include your right to object to direct marketing which can be exercised at any time without restriction. Please allow at least 5 working days for your request to be actioned.

Save as set out above, your rights detailed above can be exercised free of charge in accordance with applicable data protection laws.

You dont need to pay a certain fee to access your personal data. However, we may charge a reasonable fee if your request for access for extra service. Alternatively, we may refuse to comply with the request in such circumstances.


You will give your consent by clicking, submitting, ticking the consent box provided Where consent is required for our use of your personal data, by ticking the appropriate consent box or otherwise communicating your consent to us (whether by phone, email or other means), you consent to our use of that personal data as set out in this policy. If you disclose someone else’s personal data to us, you confirm that you have their consent to disclose this to us and for us to use and disclose it in accordance with this policy.


Cookies are text files with small pieces of data — like a username and password —so your computer can be identified to receiver personalized action. Specific cookies known as HTTP cookies are used to identify specific users and improve web browsing experience. (Adopted by We classify cookies into the following categories:

  • Necessary Cookies: These types of cookies we need for the overall operation of our website. including cookies that enable you to log into our website. You can set your browser to impede or receive notifications upon this category of cookies, but some parts of the website may not work if you block it. These cookies do not store any personal related information.
  • Target and functional Cookies: making our website personalized to you or for advertising display related to your interest we keep the recordings of logs. These cookies may be set through our website by third parties. We use functional cookies to personalize our content website to you. This help us to recognize you when you return to our website.

You can manage, deactivate and delete cookies in your browser. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our website. More information on how to manage, deactivate and delete cookies can be found in the help function of your browser.

11.Duration we keep your data or asking to delete your account and data.

We will retain your personal data for a little longer than period of Agreement by your employer or any supplier of platform to you like universities, government or any client who provide service to you as there a chance to renew the subscriptions. You have the right of deleting permanently via requesting upon your contact. Please notify us any issue you may encounter to provide you the details and any question may come up in your mind. We provide the service under subscriptions agreement to our customer and after this period, your personal data will be anonymised (or deleted). You and your company have the right to amend or correct your data.

12.Changes or Updating Privacy Policy

Any updating or amendment of our Privacy Policy will be posted on this page and will be notified to you by email or or notifications on the Platform. Please regularly check our Privacy Policy to see lastest changes and updates. You can find in the Important Information or at the sub-title the last updated date of our privacy policy.

13.Contact Us

Please contact any issue you may have via We strongly feel committed to resolving any privacy concerns you may face. Feel free to address any issue via this email or our contact by mail post address. Estonia, Tallin.