Introduction

This Privacy Notice describes how United Training Services Pte. Ltd. (“UTS”, “we”, “us”, “our”) collects, uses, discloses, and protects your Personal Data when you use our digital services, including the UTS Platform, e-Sea Mobile Application, Customer & Training Centre Portals, and our websites. It also explains your privacy rights under applicable laws, including the Singapore Personal Data Protection Act (PDPA) and, where relevant, the EU General Data Protection Regulation (GDPR).
By using our Services, you agree to the collection and use of information in accordance with this Privacy Notice.

1. Interpretation and Definitions

Interpretation

Words with capitalised first letters have meanings defined below. Definitions apply whether in singular or plural.

Definitions

Account – A unique account created for you to access our Services.
Company / UTS – Refers to United Training Services Pte. Ltd., Singapore.
Cookies – Small data files stored on your device used to remember preferences and track activity.
Country – Singapore
Device – Any device that accesses the Service, including mobile phones, laptops, or tablets
Personal Data – Any data that can identify an individual.
Service –

UTS Platform
e-Sea Mobile Application
UTS Training Center Portal
UTS Website and related digital services

Service Provider – Third-party companies engaged by UTS to provide hosting, analytics, development, or customer support (e.g., Microsoft Azure, ME-ICT Philippines).
Usage Data – Data collected automatically through platform usage (e.g., IP address, device details, activity logs).
You – The individual using our Service, or the organisation on whose behalf such individual uses the Service.

2. Collecting and Using Your Personal Data

2.1 Types of Personal Data We Collect

Personal Data you provide

Name
Email address
Phone number
Rank/role (for seafarers)
Training records, certificates, and compliance data
Information submitted through forms or support requests

Personal Data collected automatically (Usage Data)

IP address
Device information
Browser type/version
Pages visited and time spent
Mobile device identifiers
Diagnostic data

Information from Third-Party Services

If you log in using Single Sign-On (SSO) or submit certificate validation via a training centre, we may receive Personal Data such as:

Name
Email address
Employment details
Training centre enrolment and completion data

3. Cookies and Tracking Technologies

We use Cookies, beacons, and similar technologies to:

Enable essential platform functions
Maintain user sessions
Improve user experience
Analyse usage for security and performance

Types of Cookies

Essential Cookies – Required for using the platform.
Preference Cookies – Remember language, login settings.
Analytics Cookies – Used only with consent (where required).

You may manage your cookie preferences through your browser or our cookie settings page.

4. How UTS Uses Personal Data

We use Personal Data for the following purposes:

To provide and maintain our Service

User authentication
Managing accounts
Training and certificate management
Booking training courses
Platform security and fraud detection

To manage your account and your relationship with UTS

To perform our contract with you

Deliver training and competency services
Process payments or agreements (if applicable)

To communicate with you

Email notifications
Training updates
System alerts and safety notifications
Support and service messages

For analytics and service improvement

Usage trends
Performance optimisation
Feature enhancements

For business operations

Auditing
Security monitoring
Backup and disaster recovery
Compliance with ISO 27001 controls

For legal or regulatory purposes

PDPA compliance
Maritime training centre obligations
Security investigations

We do not sell or trade your Personal Data.

5. Sharing Your Personal Data

We may share Personal Data with the following:

Service Providers

Including but not limited to:

Microsoft Azure (cloud hosting)
ME-ICT Corp. (development partner)
Email and SMS service providers
Analytics or monitoring tools

Training Centres and Employers

If required to provide training, certification, or compliance reporting.

Business Partners

When using the training marketplace or booking training services.

Legal Requirements

We may disclose Personal Data to comply with:

Court orders
Government authorities
Legal investigations

Business Transfers

In case of mergers or acquisitions, Personal Data may be transferred to the new entity.

6. Legal Basis for Processing (GDPR Where Applicable)

For EU and EEA users, UTS processes data under:

Performance of Contract
Consent (e.g., marketing)
Legitimate Interests
Compliance with Legal Obligations

7. Your Rights

Under Singapore PDPA

You have the right to:

Request access to your Personal Data
Request correction of inaccurate Personal Data
Withdraw consent (where applicable)
Request information about how your data is used

Under GDPR (for EU/EEA users)

You also have rights to:

Erasure (“Right to be Forgotten”)
Restriction of processing
Data portability
Object to processing
Lodge a complaint with your local authority

For EU users, supervisory authority contact:
https://edpb.europa.eu/
For Singapore users:
PDPC – https://www.pdpc.gov.sg/

8. Data Retention

UTS retains Personal Data only for as long as necessary to:

Provide the Service
Fulfil contractual obligations
Comply with legal retention requirements
Support maritime compliance and auditability
Resolve disputes or enforce agreements

Usage Data is retained for a shorter period unless required for security or system improvement.

9. International Data Transfers

UTS operates globally. Your data may be transferred to:

Singapore (primary jurisdiction)
Philippines (development support)
European Union (training partners)
Microsoft Azure regions

Transfers are protected by:

Standard Contractual Clauses (SCCs)
PDPA safeguards
Maritime training contractual obligations
ISO 27001 security controls

10. Security of Your Personal Data

UTS applies strong technical and organisational controls, including:

Azure-based encryption (in transit + at rest)
Multi-Factor Authentication (MFA)
Role-based access control (RBAC)
Regular vulnerability scanning
Incident management (ISO 27001 A.16)
Strict access approvals via CISO and CTO

No system is 100% secure, but we apply best practices to safeguard all data.

11. Children’s Data

The Service is not intended for children under 13.
We do not knowingly collect Personal Data from minors without consent where required by law.

12. Links to External Sites

UTS is not responsible for the privacy practices of third-party websites.
We recommend reviewing their privacy notices separately.

13. Changes to This Privacy Notice

We may update this policy periodically.
Material changes will be published prominently on our website.

Effective once posted on this page