Privacy policy

The website evaluation.ee, the application at app.evaluation.ee and the Evaluation.ee apps for iPhone and Android are operated by Weirix OÜ (registry code 12596481, Tallinn, Estonia), below we. This page sets out what personal data we process, on what basis, who receives it, how long we keep it, and what you can ask of us.

We process personal data under Regulation (EU) 2016/679 of the European Parliament and of the Council (the General Data Protection Regulation) and the Estonian Personal Data Protection Act. Two documents sit beside this one: the terms of use and the data processing agreement.

Two roles, and the difference decides whom to ask

For some data we decide what is collected and why. There we are the controller and the answer is ours to give: user accounts, billing details, messages sent to us, and web server logs.

For the content of evaluations the controller is the customer — the team that wrote the questionnaire and added you as an assessor. There we are the processor: we hold the data and do with it what the customer instructs. If you want to know why your work is being assessed, who sees the results, or how long they are kept, the answer is with your employer and not with us. That relationship is governed by the data processing agreement.

The website evaluation.ee

The website is static: there is no form on it, no account, and nothing to type in.

• There are no cookies. There is no cookie banner either, because there is nothing to ask consent for.
• There is no web analytics, no ad network, no tracking pixel and no social media button.
• The fonts are served from our own server rather than from a font network — opening the page sends your browser to no third party at all.

What remains is the web server log: IP address, time, the address requested, the response code and the browser identifier. We use it to find faults and attacks, keep it for 14 days, and link it to no user account. The legal basis is our legitimate interest in keeping the service working and secure (Article 6(1)(f)).

The application: app.evaluation.ee and the phone apps

The iPhone and Android apps are the same service as app.evaluation.ee, with the same account; everything in this section applies to both. What only the phone apps add is described under The phone apps below.

User account

Name (optional), e-mail address, language preference, role in the team, and a hash of the password. We never see the password itself and it is not readable to us. We ask for no telephone number, no address, no personal identification code and no date of birth, on any field.

If you choose to sign in with Google or Apple, all we receive is your name, your e-mail address and an identifier for your Google or Apple account, which is how we recognise you the next time. Apple may give us a private relay address in place of your real one, and a name only the first time. Such an account has no password and we create none.

Evaluations

Answers, points, percentage, the date and time of the visit, the location and the assessor. The controller for this data is the customer, not us.

Free text written by an assessor is the one field where anything at all may end up — somebody's name included. That is why we recommend writing observations about behaviour rather than about a person: “there was no greeting” says everything that needs to be known without making a named record of anyone.

Billing

Company name, registry code, VAT number, address and the e-mail address the invoice goes to, together with the history of invoices and payments. Here we are the controller.

Correspondence

If you write to info@evaluation.ee, the message is kept until the matter is settled, and then for as long as it may be needed as evidence.

No cookies; what stays in the browser and on the phone

The application sets no cookies. Signing in gives your browser or phone a sign-in key, which it sends with every request. The key ends when you sign out, when you sign out of every device or change your password, and after 90 days without use.

Besides that key, the application keeps a few things in your browser's or the app's own storage. They never reach us, and you can clear them from your browser settings or by removing the app:

• the chosen theme (light or dark) and language;
• an unfinished evaluation, so that a locked phone does not erase an hour of work. It is cleared when the evaluation is saved, when you sign out, or after two weeks;
• during registration or a password reset, the step you are on — in that tab only, until it is closed.

Where Google sign-in is offered, the sign-in page shows Google's own button, which your browser loads from Google — so opening that page tells Google your IP address and browser, even if you do not use the button. Apple's sign-in loads only when you press its button.

The phone apps

The iPhone and Android apps add the following:

• Push notifications. If you allow them, your phone gets a delivery address from Google's Firebase Cloud Messaging and we keep it, together with whether the phone is an iPhone or Android and when the app last reported in. We use it to tell you about an invitation to a team, a member leaving your team, a team being offered to you, and the weekly overview. A notification carries a short sentence — a team's name and a person's name — and nothing from evaluations. You can switch them off in your profile or in your phone's settings; signing out or removing the app ends them, and an address Google reports as gone is deleted.
• The app's version. Every request says which app it comes from and its version number, so that an app too old to work correctly can be asked to update. It is kept only in the logs, for 14 days.

The apps use no location, no camera or photos, no contacts and no advertising identifier, contain no analytics or advertising code, and do not track you across other apps or websites.

On what legal basis

• Performance of a contract (Article 6(1)(b)) — creating and holding an account, signing in, providing the service, preparing and sending invoices, customer support.
• Legal obligation (Article 6(1)(c)) — accounting source documents and matters relating to VAT.
• Legitimate interest (Article 6(1)(f)) — the security of the service, preventing abuse, finding faults, and defending legal claims. We weighed each against your interests and collect as little as the job allows.

None of our processing rests on consent, because none of it is an optional extra: we send no newsletter, keep no marketing list and do no profiling.

Who receives the data

We do not sell personal data and we trade it with nobody. We use no ad networks. We do not use customer data to develop our product, to analyse it, or to train models.

The data reaches only the companies without which the service does not run:

• the hosting provider, on whose servers the application runs;
• the e-mail sender, which delivers confirmation codes, password resets, invitations, invoices and weekly summaries;
• for the phone apps, Google's Firebase Cloud Messaging, which delivers push notifications — on iPhones through Apple's push notification service.

The current list, with their locations, is Annex 3 of the data processing agreement, and that is the only place it is kept. We give 30 days' notice before adding a new sub-processor.

Two recipients are not sub-processors, because they do not act on our behalf:

• Google Ireland Limited and Apple Distribution International Ltd — only if you choose to sign in with Google or Apple (and, for Google, the sign-in page's button described above). Neither sees evaluation data.
• The European Commission's VIES — checking that a VAT number is valid. We send the number alone, and only for business customers.

Beyond that we disclose data where the law requires it — at the demand of a court or a supervisory authority. We meet such a demand as narrowly as it can be met, and tell the customer where we are allowed to.

If the company were ever to change hands or merge, the data would pass across with the contracts. We would give notice beforehand, and the new owner would be bound by at least the obligations set out here.

Where the data is held

All data is held and processed in the European Economic Area. We transfer none of it to third countries. Were that ever to change, it would be a change of sub-processor: 30 days' notice, and the legal basis for the transfer stated.

The one exception is a push notification to a phone app: Google and Apple deliver it through their own networks, which are not confined to the EEA. That is why a notification carries only the short sentence described above.

How long the data is kept

• User account — until you delete it, which you can do yourself at any time (see Deleting your account).
• A phone's push delivery address — until you sign out on that phone, remove the app, or its sign-in lapses after 90 days unused.
• Evaluation data — until the subscription ends and for a further 90 days, so that it can be downloaded. We then delete it. On written request we delete it sooner. That is the customer's decision, not ours.
• Invoices, payments and other accounting source documents — seven years from the end of the financial year in which the document was entered, as the Accounting Act requires. These cannot be deleted on request.
• Application and web server logs — 14 days.
• Confirmation codes and password reset codes — minutes. A code is deleted when used, when it expires, or after too many wrong attempts.
• Correspondence — until the matter is settled, and then for as long as it may be needed as evidence.

Your rights

The General Data Protection Regulation gives you the following rights:

• Access — to learn whether and what data we process about you, and to receive a copy of it.
• Rectification — to have inaccurate data corrected and incomplete data completed. Your name, e-mail address and language you can also change yourself, from your profile.
• Erasure — to have data deleted where there is no longer a basis for processing it. Your account you can delete yourself.
• Restriction — to require that data only be stored, for instance while a dispute is unresolved.
• Objection — to object to processing that rests on our legitimate interest.
• Portability — to receive the data you provided in a machine-readable form, or to have it transmitted directly.

Write to info@evaluation.ee. We answer within one month. Before answering we have to be sure who you are — we may ask for more information to establish that, but no more than establishing it needs.

If your data is inside a team — your answers, points, comments — those decisions are not ours to make. We pass the request to the customer and help them with it, but the answer is theirs. That is what Article 28 provides for.

Deleting your account

You can delete your account yourself, in app.evaluation.ee or in the phone app: open your profile and choose Delete account. You confirm it with your password, or by typing your e-mail address if the account has none.

While you belong to a team you leave it first; the owner of a team first hands it over to another administrator, who has to accept. The profile lists what is in the way.

Deleting the account at once and for good removes:

• your name, e-mail address and password;
• the link to your Google or Apple account;
• every sign-in, on every device, and every phone registered for notifications;
• your notifications, and invitations sent to your address;
• your name and address from the teams' change history.

The evaluations you recorded stay with the teams you recorded them for, because they belong to those customers, and show the author as Deleted user with nothing that identifies you. If you cannot sign in to delete the account yourself, write to info@evaluation.ee from the account's address and we will do it.

Automated decisions

We make no automated decisions with a legal or similarly significant effect on you, and we do no profiling. An evaluation percentage is addition and division over what was ticked on a questionnaire; what an employer does with that number is the employer's decision.

Security

The measures we apply — TLS on all traffic, hashed passwords, encrypted backups, access by role and separated by team, rate limits, security headers — are listed in Annex 2 of the data processing agreement. That list is kept in one place only, so that two lists cannot drift apart.

To report a security flaw, write to info@evaluation.ee; see also security.txt.

No system is perfect. If a breach occurs that is likely to put people's rights at risk, we notify the Estonian Data Protection Inspectorate within 72 hours and, where necessary, the people themselves. Where the breach concerns a customer's team data, we notify the customer and further notification is their decision.

Children

The service is meant for work and is bought by a company. We do not offer it to children and we do not knowingly collect children's data. In Estonia the age limit for information society services is 13; if we learn that an account belongs to somebody younger, we delete it.

Links elsewhere

A questionnaire template may carry a link to its source — the page of a regulator or a standards body. These open in a new window and we have no control over their content, their privacy policies or their practices.

Complaints

If you believe we are processing your data wrongly, tell us first — most things are put right faster that way. You also have the right, at any time, to turn to the supervisory authority:

Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)
info@aki.ee
www.aki.ee

Changes

We may change this document. We give at least 30 days' notice by e-mail of any significant change, as we do for the terms of use. Smaller clarifications take effect on publication, and the date at the foot of the page says when it was last changed. An earlier version can be requested from info@evaluation.ee.

Contact

Weirix OÜ, registry code 12596481, Tallinn, Estonia.
E-mail: info@evaluation.ee

We have appointed no data protection officer — our processing does not fall under Article 37 — but writing to that address reaches a person who knows the answer.