Privacy Policy

1. Controller

The controller is EUROPE SOFTWARE PARTNER AND PAYMENT SOLUTIONS OÜ, Narva mnt 5, 10117 Tallinn, Harju maakond, Estonia, represented by Markus Scherreik. Privacy contact: privacy@traweso.com.

2. Website access and technical logs

When you access traweso.com or the learning platform, we process technically necessary connection data such as IP address, time, requested URL, HTTP status, referrer where transmitted, browser and operating-system information. This is necessary for delivery, stability, error analysis and abuse prevention. The legal basis is Art. 6(1)(f) GDPR.

The website and learning platform are operated on server infrastructure in Germany. Technical logs are retained only as long as required for operation, security and troubleshooting; security incidents may require longer retention for investigation.

3. Registration and account

When you register, we process in particular your email address, name or display name, password hash, language, account status and technical security data. This is required to create and administer the account and provide free or purchased learning products. The legal basis is Art. 6(1)(b) GDPR.

4. Personalization and placement

TRAWESO may process learning goals, prior knowledge, professional context, preferred depth and available learning time. Diagnostic and knowledge-check results are used to adapt learning paths, examples, repetition and difficulty. The legal basis is Art. 6(1)(b) GDPR. Voluntary profile details can be changed or removed unless they are required for an active learning record.

5. Progress, assessments and certificates

We process enrollments, viewed learning objects, progress, answers, attempts, scores, skill and mastery values, hints used and completion data. These data are necessary to save progress, enforce mastery gates, provide adaptive remediation and issue certificates. The legal basis is Art. 6(1)(b) GDPR.

Public certificate verification only displays information required to verify authenticity. Certificates may be revoked or public verification disabled where there is a legal or factual reason.

6. AI tutor and AI-assisted learning

When you actively use AI features, your inputs, current lesson context, relevant task text and minimized information about your learning status or previous errors may be processed to generate explanations, exercises or feedback. Direct account identifiers are not intentionally sent to model providers as such where avoidable.

The currently intended default provider for generative model functions is DeepSeek, operated by Hangzhou DeepSeek Artificial Intelligence Co., Ltd., China. External AI services may therefore process data outside the EEA. Such transfers are made only where the requirements of Chapter V GDPR are met or the data have first been anonymized so that they are no longer personal data. TRAWESO does not activate production transfers of identifiable learner data to a third-country model provider without a valid data-protection basis.

Do not enter passwords, payment data, special-category personal data or confidential third-party information into AI fields unless strictly necessary for the learning task.

Provider information: DeepSeek Privacy Policy.

7. Purchases and Stripe

For paid courses we use Stripe to process payments. Depending on payment method, Stripe may process name, email address, billing information, payment information, IP address and fraud-prevention data. TRAWESO generally does not receive full card or bank-account details. Processing is necessary for the contract and payment (Art. 6(1)(b) GDPR); Stripe may also process data to comply with law and prevent fraud.

Stripe may process data internationally through affiliates and service providers. Its privacy information is available at stripe.com/privacy.

8. Email and support

For email verification, password resets, purchase confirmations, access and certificate notices and support, we process your email address, message contents and required account data. Contract-related messages rely on Art. 6(1)(b) GDPR; security communication may also rely on Art. 6(1)(f) GDPR. Marketing email is sent only with separate consent.

9. Cookies and local storage

TRAWESO uses technically necessary session, security and language settings where required for login and platform operation. At launch we do not use marketing cookies or Google Analytics, and we do not create cross-site advertising profiles. If optional analytics or marketing services are introduced later, the consent mechanism and this notice will be updated before activation.

10. Recipients

Recipients may include hosting and infrastructure providers, email/SMTP infrastructure, Stripe, contracted technical service providers and enabled AI model providers, in each case only as required. Public authorities receive data only where legally required.

11. Retention

Account and learning history are generally stored for the lifetime of the account or contract. Payment and invoicing data may be retained longer where required by law. Support and security data are deleted once no longer required for handling, security or legal claims. After account deletion, personal data are deleted or anonymized unless legal retention duties or rights apply.

12. Automated learning-path adaptation

TRAWESO may automatically adapt content based on test results, skill signals and usage context. These decisions determine which explanation, exercise or lesson is suggested or unlocked next. They do not produce legal or similarly significant effects within the meaning of Art. 22 GDPR.

13. Your rights

Subject to statutory conditions, you may have rights of access, rectification, erasure, restriction, portability and objection. Consent can be withdrawn at any time for the future. You may complain to a competent data-protection authority; for the controller's establishment, the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) is one possible authority.

14. Minors

Persons under 18 may use TRAWESO only in accordance with the rules applicable where they live and, where required, with the consent of their legal representative. Paid purchases by minors require valid parental or guardian consent or approval.

15. Changes

We update this notice when processing activities, providers or applicable law change materially. The current version is published on traweso.com.