Rubelis App Privacy Policy

1. Who We Are

Rubelis OÜ (“Rubelis”, “we”, “us”, “our”) is the data controller responsible for personal data processed through the Rubelis mobile application and related Rubelis app services. This privacy policy applies specifically to the Rubelis mobile application for iOS and Android and is separate from the privacy notices governing other Rubelis website services or educational programmes.

2. What the Rubelis App Does

Rubelis is a mobile application designed for divers. The app may include features such as: personal dive logging; Beyond Reflection and situational-awareness notes; diving Insights based on recorded data; AI-assisted diving information and analysis; professional dive-record approval by registered instructors or dive leaders; PDF dive-log export; optional connection to supported dive-computer ecosystems; and account synchronization across devices. The feature set available to any individual user may vary depending on their account type and subscription status.

3. Personal Data We May Process

The following table describes the categories of personal data Rubelis may process, with examples and the purpose for which each category is used.

4. Legal Bases for Processing

Where the General Data Protection Regulation (GDPR) applies, Rubelis relies on the following legal bases:

5. AI Processing

• Rubelis may use OpenAI’s API to provide AI-assisted functionality within the app.
• Rubelis does not automatically send the user’s entire dive history to the AI provider. Only information reasonably necessary to answer the user’s specific request is sent. Relevant context may include selected dive data, relevant recent dives, Beyond Reflections, and calculated Insights.
• Unnecessary account identifiers — such as the user’s email address or authentication identifier — are not sent where not required for the AI request.
• Rubelis distinguishes between recorded dive facts, user-authored reflections, and AI-generated interpretations.
• AI-generated responses should not be treated as a replacement for a dive computer, formal training, certification standards, manufacturer instructions, or qualified professional judgment.
• OpenAI’s API business data is not used to train OpenAI models by default, unless the API customer explicitly opts into data sharing.

6. Safety-Critical Dive Information

• Rubelis AI is designed to provide information and educational context.
• Rubelis does not rely on generative AI alone as an authoritative calculator for safety-critical calculations such as decompression obligations, maximum operating depth (MOD), CNS exposure, oxygen exposure, minimum gas, gas-volume requirements, or turn pressure.
• Users remain responsible for following appropriate training, dive-computer guidance, manufacturer instructions, local rules, and established diving procedures.

7. Optional Device Connections

• Users may choose to connect supported dive-computer or dive-service ecosystems to import dive records into Rubelis.
• No external device account is connected without the user’s explicit action and authorization.
• Where OAuth or a similar authorization mechanism is used, authorization credentials are handled securely, access is limited to the scopes and data necessary for the import, and users can disconnect supported services at any time.

8. Professional Accounts and Dive Approvals

• Instructor and Dive Leader accounts are separate from standard diver accounts and are subject to a separate registration process.
• Professional registration information is used to operate the dive-approval system within Rubelis.
• A diver may voluntarily send an individual dive record to a selected Rubelis Professional for approval. The professional receives only the information needed for the approval process.
• Approved dive records may retain an immutable historical snapshot containing: the professional’s name, role, certification agency, certification title, certification number, Rubelis Professional ID, approval date, and the approved dive details. This is so that an existing approval remains historically traceable even if the professional later changes account details or deletes their Rubelis account.
• Professional identity information in Rubelis is self-declared by the account holder and is not independently verified by Rubelis unless otherwise stated.

9. QR Codes and Camera Access

• The application may request camera permission when a diver chooses to scan a Rubelis Professional QR code.
• Camera access is not required to use the standard dive log or other core features of the app.
• The QR scan function is used solely to identify the intended Rubelis Professional for a dive-approval request.
• Rubelis does not store camera images or video captured during QR scanning.

10. PDF Exports

• Users may select dive records and generate a PDF dive-log export.
• The PDF may contain: diver name, selected dive details, and approval information for approved dives.
• The user controls where the generated PDF is subsequently saved, printed, emailed or shared, through the device’s operating-system sharing features.
• Acceptance of a Rubelis-generated PDF or professional approval by a diving federation, training agency, dive centre or other organization is determined solely by that receiving organization.

11. Where Data Is Stored

• Rubelis may store information locally on the user’s device, and in Rubelis cloud infrastructure when synchronization is enabled.
• Local dive records may remain available offline, without requiring a network connection.
• When authenticated cloud synchronization is used, records can be synchronized securely between the user’s devices.

12. Service Providers

Rubelis uses the following service providers in connection with the app. Each provider processes only the data necessary for its role.

13. International Data Transfers

• Some service providers may process data outside Estonia or the European Economic Area (EEA).
• Where such transfers occur and are required to comply with GDPR, Rubelis relies on appropriate transfer mechanisms, which may include: adequacy decisions, the EU–US Data Privacy Framework where applicable, Standard Contractual Clauses, or other legally permitted safeguards.

14. Data Retention

Rubelis retains personal data only for as long as necessary for the purposes described in this policy or as required by applicable law.

15. Account Deletion

• Rubelis users can request permanent account deletion from inside the application.
• Account deletion permanently removes the Rubelis account, ordinary associated cloud data, and synchronized user-owned data as applicable.
• Local-only dives belonging to the deleted Rubelis account may also be deleted from that device after confirmation.
• Where required by app-store rules, Rubelis also provides an account-deletion route accessible from within the application settings.

16. Subscriptions

The following subscription structure is planned for the Rubelis app. Specific pricing, trial periods and billing terms will be confirmed at the time of launch and may be subject to change.

• A free trial period is planned, after which users may choose a subscription plan.
• Planned subscription options include a monthly plan (automatically renewing monthly unless cancelled) and an annual plan (automatically renewing annually unless cancelled).
• Instructor and Dive Leader professional accounts are planned to be free of charge.
• Purchase, renewal, cancellation and payment processing will be handled through Apple App Store and/or Google Play according to the user’s platform.
• Rubelis does not store full payment-card details.

17. Data Security

• Rubelis uses appropriate technical and organizational safeguards to protect personal data. These may include: encrypted HTTPS connections, secure authentication, access controls, user-level data isolation, server-side authorization, protected secrets management, offline and local data controls, and synchronization safeguards.
• No system can guarantee absolute security. Rubelis takes reasonable steps to protect personal data but cannot warrant that unauthorized access, disclosure, alteration or destruction will never occur.

18. Your Rights

Where the GDPR applies, you may have the following rights in relation to your personal data:

To exercise any of these rights, please contact us using the details in Section 22. Identity verification may be required before a privacy request can be fulfilled.

19. Supervisory Authority

The supervisory authority responsible for data protection in Estonia is:

EU and EEA residents may also contact the data-protection authority in their own country of residence where applicable.

20. Children

• Rubelis mobile accounts are intended for users who meet the minimum age required to create and manage an account under applicable law and applicable app-store rules.
• Rubelis does not knowingly use the mobile application to solicit personal data from children in violation of applicable law.
• If age eligibility requirements or a dedicated child or guardian account system are introduced in the future, this policy will be updated before that functionality is released.

21. Changes to This Policy

• This policy may be updated when app functionality changes, new device integrations are added, AI providers change, subscription processing changes, or legal requirements change.
• Material changes may be communicated through the application or other appropriate channels.
• The last-updated date at the top of this page reflects the current version.

22. Contact