Tubara Data Processing Explanation

What Data We Process

Parent Account Data:

Email address
Account password (encrypted)
Subscription tier
Payment information (processed by Stripe - we never see card details)

Child Profile Data:

Name and age (both encrypted at rest)
Avatar selection
Theme preferences
Age range settings
Watch history
Screen time data

Platform Usage Data:

Channel approvals and removals
Video viewing sessions (what, when, duration)
Parental control settings

Purposes of Processing:

Service Delivery - Providing access to curated YouTube content with parental controls

Child Safety - Age-appropriate content filtering, screen time management, preventing access to inappropriate content

Parental Insights - Analytics showing what children watch, learning patterns, screen time compliance

Account Management - Authentication, subscription tier enforcement, billing

Platform Security - Fraud prevention, abuse detection, session management

Legal Compliance - Meeting COPPA, GDPR, and UK data protection requirements

1.Contract (Article 6(1)(b)) - Primary basis

Processing necessary to fulfill our service agreement with you
Creating child profiles, filtering content, managing subscriptions
Example: We need your child's age to show age-appropriate content

2.Legitimate Interests (Article 6(1)(f))

Child safety measures beyond legal requirements
Platform security and fraud prevention
Improving service quality and features
Example: Analyzing patterns to improve content recommendations

3.Consent (Article 6(1)(a))

Optional features like advanced analytics
Marketing communications (if implemented)
Example: Detailed learning outcome reports

4.Legal Obligation (Article 6(1)(c))

COPPA compliance (US Children's Online Privacy Protection Act)
Data retention and deletion requirements
Responding to lawful data access requests

Special Protection for Children's Data Under COPPA and GDPR Article 8:

We treat anyone under 18 as a child
All children's data is encrypted (name, age)
No direct marketing to children
Parental consent required before creating child profiles
Parents can view, export, or delete all child data at any time
No third-party advertising or data sharing
No behavioral tracking for advertising purposes

Data Minimization Principle We only collect data essential for the service:

✅ Child's age - needed for age filtering

✅ Watch history - needed for parental analytics

❌ Child's school - not needed, not collected

❌ Child's location - not needed, not collected

❌ Child's photos - not needed, not collected

Your Rights: Parents can:

Access - View all data we hold

Rectify - Correct inaccurate information

Delete - Remove child profiles or entire account

Export - Download all data in standard format

Object - Opt out of legitimate interest processing

Restrict - Limit how we use specific data

Key Message: We process the minimum data necessary to provide a safe, parent-controlled educational video platform. Child safety is our primary concern, and parents maintain full control over their family's data.