Beyond Junior — Rubelis OÜ
Children's Privacy Notice
Last updated: August 2026
This notice explains how data relating to children enrolled in the Beyond Junior programme is processed. It supplements our General Privacy Policy and does not replace it.
1. What data we collect
For a child enrolled in Beyond Junior, we process the following data held in the programme records: the child's name; date of birth (day, month, and year); calculated age group; programme progress, including completed modules and their completion dates; earned badges and their award dates; the selected diver profile used for the digital passport; certificate information, where a certificate is issued, including the certificate number, issue date, programme title, age group, verification token, and revocation status; completion and enrolment status; and related technical record metadata, including the enrolment identifier, parent-account identifier, programme locale, payment status and provider, legal entity, and record creation, enrolment, and update timestamps. The full date of birth is required to accurately determine the child's age group; the programme serves different age groups within the 8–14 range, and the year alone does not provide sufficient precision. The parent's own account details (email address, name) are covered by the General Privacy Policy.
2. Why we collect it
To deliver the correct content level for the programme and to maintain a record of the child's progress and completion.
3. Legal basis
Explicit consent given by the parent or legal guardian at the point of registration.
4. How we do not use it
The child's data is never used for marketing, profiling, or advertising purposes, and is never shared with third-party advertising networks.
5. How long we retain it
Child personal data is retained only for as long as necessary to deliver the Beyond Junior programme and fulfil the purposes for which it was collected. Specifically:
- Learning progress and completion records are kept for as long as the programme is being delivered to the child and the associated account is active.
- Certificate and credential records may be retained for longer where necessary to support verification of a genuine Beyond Junior certificate or to preserve the integrity of the completion record.
- Transaction, accounting, and legally required records associated with the parent or legal guardian's account are retained for as long as Rubelis OÜ is required to do so under applicable legal obligations.
- Support correspondence or records related to a legal claim are kept only for as long as necessary for the relevant request, dispute, or legal obligation.
When the purpose for retention has ended and no other legal obligation requires us to keep the data, personal data is deleted or anonymised.
6. Parental rights
A parent or guardian may request access to, correction of, or deletion of their child's data by contacting us at [email protected].
7. Who we share it with
The child's name and date of birth are not shared with payment processors. Stripe is used for payments on the English-language platform and Garanti BBVA is used for payments on the Turkish-language platform; each processor handles only the parent or legal guardian's payment transaction information, such as payment identity and order reference, and has no access to the child's personal data. Hosting infrastructure processes data only as needed to operate the platform. No data is shared with any third party for advertising purposes.
8. Contact
Rubelis OÜ, Tartu mnt 67/1-13b, 34149 Tallinn, Estonia
[email protected]