Last updated: 5 October 2026
1. Who is responsible
The data controller is Norvitra AS, organisation number 927 857 642, Springarstien 17, 4021 Stavanger, Norway. Norvitra AS owns and operates GMDSS Training.
Questions about privacy can be sent to contact@gmdsstraining.com or by phone to +47 957 32 462.
2. What we collect and why
| Purpose | Data | Legal basis (GDPR) | How long |
|---|---|---|---|
| Email updates (new articles and occasional news) | Email address, time and details of sign-up and confirmation, whether emails are opened and links clicked | Consent, art. 6(1)(a). You can withdraw it at any time with the unsubscribe link in every email. | Until you unsubscribe |
| Contact form | Name, email address, your role (for example leisure boater or school) and your message | Legitimate interest in answering enquiries, art. 6(1)(f), or steps before a contract, art. 6(1)(b) | |
| User account and courses | Name, username, email address, password (stored encrypted), course enrolment, progress, results and course diplomas | Contract, art. 6(1)(b) | As long as the account is active |
| VHF simulator – voice | Your voice while you hold the push-to-talk button, converted to text | Contract or legitimate interest in providing the exercise, art. 6(1)(b)/(f) | |
| VHF simulator – exercises | The text of your radio calls, your choices in the exercise and your scorecard | As above | |
| Website operation and security | IP address, browser type and the pages requested (server logs) | Legitimate interest in running a secure website, art. 6(1)(f) |
We do not use your data for advertising, we do not sell it, and we do not use analytics or advertising cookies.
3. The VHF simulator and your voice
The simulator lets you speak into your microphone as on a real radio. Your browser only uses the microphone after you have given permission, and audio is only captured while you are transmitting.
To turn your speech into text, the audio is sent to our speech-recognition provider, Deepgram. If that service is unavailable, the simulator can use your browser’s built-in speech recognition instead; in some browsers (for example Google Chrome) this means the audio is processed by the browser maker. The text of your calls is sent to OpenAI to generate the coast station’s replies and to produce the spoken voice you hear.
GMDSS Training does not independently record or store the audio from your simulator transmissions. However, audio, transcripts and related technical data may be processed by the third-party providers involved in providing these functions. Their processing and retention practices are governed by the applicable services and agreements used by GMDSS Training.
Simulator exercise results or course progress may be stored separately where necessary to provide course functionality, track progress or completion, and issue course diplomas.
You can choose not to grant microphone access. However, simulator functions that require spoken radio communication may then be unavailable.
You can always use the simulator with text input instead of your voice.
4. Who we share data with
We use the following service providers (data processors), which process personal data on our behalf and under our instructions:
- Web hosting and email delivery: Simply.com hosts the website and sends our emails.
- Netlify (USA) – hosts the VHF simulator.
- Deepgram (USA) – speech recognition in the simulator.
- OpenAI (USA) – generates replies and synthetic speech in the simulator.
- Google – supplies web fonts used on the website and, depending on your browser, built-in speech recognition.
- AddToAny – share buttons on articles.
Some providers are located in the USA. When personal data is transferred outside the EU/EEA, we make sure there is a legal basis for the transfer, such as the EU–US Data Privacy Framework or the European Commission’s standard contractual clauses.
We may also disclose data where we are required to do so by law.
5. Cookies and local storage
The website uses cookies that are necessary for it to work, for example to keep you logged in and to remember items in a shopping cart. The simulator stores your settings, such as language and voice, in your browser’s local storage. We do not use cookies for analytics or advertising.
6. Your rights
You have the right to access the personal data we hold about you, to have incorrect data corrected, to have data deleted, to restrict or object to processing, and to receive your data in a portable format. Where processing is based on consent, you can withdraw your consent at any time.
To use your rights, contact us using the details in section 1. We will respond within one month.
If you believe we process your data unlawfully, you can complain to the Norwegian Data Protection Authority, Datatilsynet.
7. Security
We use encrypted connections (HTTPS), restricted administrator access and providers with recognised security practices to protect your data.
8. Changes
We may update this policy when our services change. The date at the top shows when it was last updated.