A legal disclaimer

Effective from August 1, 2026

Welcome to Ray Global Digital’s Privacy Policy!

Privacy Policy - the basics

1. Introduction

Ray Global Digital Oy ("Ray Global Digital", "we", "our", or "us") is committed to protecting your privacy and processing personal data responsibly, transparently, and in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable Finnish data protection legislation.

This Privacy Policy explains how we collect, use, store, protect, and share personal information when you use our products and services, including but not limited to:

HERITAGE language learning platform
GAJÙ adaptive learning engine
Mobile applications
Websites
Beta programmes
Parent and Guardian Portal
Tutor Portal
Institutional services
Educational APIs
Community programmes
Events
Newsletters
Customer support

By accessing or using our services, you acknowledge that you have read this Privacy Policy.

2. Data Controller

The controller responsible for processing your personal data is:

Ray Global Digital Oy

Business ID: 3639901-7

Espoo, Finland

Email:
ray@rayglobaldigital.com

3. Our Mission

Ray Global Digital Oy develops sovereign educational technology, language infrastructure, and adaptive learning systems designed to preserve and strengthen underrepresented languages through responsible digital innovation.

Our flagship platform, HERITAGE, combines educational technology, behavioural learning analytics, cultural intelligence, and future AI capabilities to create engaging learning experiences for children, families, educators, and institutions.

Protecting the privacy and security of our users—especially children—is fundamental to our mission.

4. Information We Collect

Depending on how you interact with our services, we may collect the following categories of information.

4.1 Information You Provide

You may provide information including:

Name
Parent or guardian details
Child's first name or nickname
Email address
Telephone number
Country of residence
Preferred language
Payment information
Customer support enquiries
Survey responses
Beta programme feedback
Newsletter subscriptions
Job applications
Event registrations

4.2 Children's Information

HERITAGE is designed for children aged approximately 4–12.

We only collect children's personal information with the knowledge and consent of a parent or legal guardian where required by law.

Depending on the service, we may collect:

Child nickname or first name
Age range
Learning level
Lesson progress
Gameplay progress
Learning achievements
Virtual class participation
Educational performance

We do not knowingly collect unnecessary personal information from children.

4.3 Educational Learning Data

As learners interact with HERITAGE, we collect educational information including:

Lesson completion
Learning progression
Mastery indicators
Quiz responses
Language exercises
Pronunciation attempts (where applicable)
Cultural learning activities
Achievement milestones

This information enables personalised educational experiences.

4.4 Behavioural Learning Analytics

HERITAGE uses adaptive educational technology that analyses learning behaviour rather than simply recording correct or incorrect answers.

Depending on the platform, behavioural information may include:

Response timing
Interaction patterns
Session duration
Learning pathways
Confidence indicators
Progress consistency
Adaptive recommendations
Navigation behaviour

These behavioural learning signals improve educational outcomes and support adaptive learning.

4.5 Technical Information

When using our websites or applications we may collect:

Device type
Operating system
Browser type
IP address
Language settings
Crash reports
Application diagnostics
Security logs
Authentication information

5. How We Use Your Information

We process personal information to:

Provide our services
Deliver educational content
Personalise learning experiences
Improve adaptive learning
Support customer service
Process purchases
Manage subscriptions
Communicate updates
Maintain platform security
Prevent fraud
Improve accessibility
Develop new educational features
Conduct research and development
Meet legal obligations

6. Educational Analytics & Artificial Intelligence

HERITAGE has been designed as an educational intelligence platform.

We may use anonymised or aggregated educational information to:

Improve adaptive learning models
Develop educational analytics
Validate learning pathways
Improve curriculum design
Train educational recommendation systems
Improve future artificial intelligence capabilities
Conduct educational research
Improve language preservation technologies

Where possible, research datasets are anonymised or pseudonymised before analysis.

We do not use children's personal information for advertising profiling.

7. Legal Basis for Processing

We process personal data under one or more of the following legal bases:

Performance of a contract
Compliance with legal obligations
Legitimate interests
Consent
Protection of vital interests where applicable

Where consent is required, it may be withdrawn at any time.

8. How We Share Information

We do not sell personal information.

We may share information only where necessary with:

Cloud hosting providers
Payment processors
Email communication providers
Customer support providers
Technology service providers
Professional advisers
Educational partners (where authorised)
Government authorities where legally required

All third-party processors are required to comply with GDPR and appropriate security standards.

9. International Data Transfers

Where personal information is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, including:

European Commission Adequacy Decisions
Standard Contractual Clauses (SCCs)
Other safeguards recognised under GDPR

10. Payment Information

Payments may be processed through trusted third-party payment providers.

Ray Global Digital Oy does not store complete payment card information.

Payment providers process payment information in accordance with their own privacy policies and applicable financial regulations.

11. Cookies and Similar Technologies

Our websites may use:

Essential cookies
Functional cookies
Security cookies
Performance analytics
Preference cookies

Where legally required, we will obtain consent before placing non-essential cookies.

Users may manage cookies through their browser settings.

12. Data Security

We employ appropriate technical and organisational measures to protect personal information, including:

HTTPS encryption
Secure cloud infrastructure
Access control
Authentication procedures
Data encryption where appropriate
Regular security monitoring
Backup systems
Role-based permissions

While we take reasonable steps to protect information, no system can guarantee absolute security.

13. Data Retention

We retain personal information only for as long as necessary to:

Provide services
Meet contractual obligations
Comply with legal requirements
Resolve disputes
Improve educational services
Protect our legitimate interests

When information is no longer required, it is securely deleted or anonymised.

14. Children's Privacy

Protecting children's privacy is central to HERITAGE.

Parents or legal guardians may:

Review their child's information
Request corrections
Request deletion
Withdraw consent
Close accounts
Request copies of personal data

Where consent is withdrawn, access to certain services may no longer be available.

15. Beta Programme

Participation in HERITAGE Beta programmes may involve additional collection of:

Diagnostic information
Crash reports
Feature usage
User feedback
Gameplay analytics
Learning performance metrics

This information helps improve stability, usability, accessibility, and educational effectiveness before public release.

16. Your Rights

Under GDPR, you may have the right to:

Access your personal information
Correct inaccurate information
Request deletion
Restrict processing
Object to processing
Withdraw consent
Request data portability
Lodge a complaint with a supervisory authority

Requests may be submitted to: ray@rayglobaldigital.com

17. Third-Party Services

Our services may contain links to third-party websites or services.

We are not responsible for the privacy practices of external organisations.

Users should review the privacy policies of those organisations separately.

18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect:

Legal changes
Regulatory requirements
New technologies
New services
Product improvements

The latest version will always be available on our website.

19. Contact Us

If you have questions regarding this Privacy Policy or how we process personal information, please contact: