How We Collect, Use, Disclose, and Protect Your Personal Data

Effective Date: May 24, 2026

Version: 2.0 (supersedes the Privacy Policy dated January 14, 2025)

Issued By: Seaker System Technologies Inc. (Company Reg. No. 2024080163452-00; NPC Registration No. PIC-001-840-2025) (“SEAKER,” “Company,” “we,” “us,” or “our”)

This Privacy Policy explains how SEAKER collects, uses, discloses, and protects your personal data in connection with the SEAKER Platform and its related services. It applies to all users — seafarers, platform partners, and visitors — and should be read together with the SEAKER Seafarer Terms of Use, the SEAKER Seafarer Data Sharing Consent Terms, and the SEAKER Terms of Use for Platform Partners, as applicable.

1.  Who We Are & Our Role

1.1  Identity — Seaker System Technologies Inc. (“SEAKER”) is the Personal Information Controller (PIC) responsible for your personal data processed through the SEAKER Platform. We are registered with the National Privacy Commission of the Philippines (NPC Registration No. PIC-001-840-2025).

1.2  Platform — The SEAKER Platform is a digital ecosystem serving seafarers, manning agencies, maritime schools and training providers, property hosts, and media publishers (collectively, the “Platform”). For seafarer-specific data flows, including data sharing with schools and accredited manning agencies, please also refer to the SEAKER Seafarer Data Sharing Consent Terms.

1.3  PIC and PIP relationships — Where Platform Partners process personal data they collect from Users through the Platform, those Partners act as independent Personal Information Controllers (PICs) for their own processing. Where SEAKER processes data on a Partner’s documented instructions under a Data Sharing Agreement (DSA), SEAKER acts as a Personal Information Processor (PIP) and the DSA governs.

2.  Scope of this Policy

2.1  This Policy applies to all personal data collected or processed by SEAKER through the Platform, including via the SEAKER Mobile App, website, APIs, and related services, wherever you are located.

2.2  It covers three categories of data subject:

•       Seafarers and individual users — persons who use the SEAKER Mobile App to manage their professional profile, seek employment, access training, find accommodation, or use welfare features.

•       Platform Partners — manning agencies, training providers, property hosts, and media publishers registered on the Platform.

•       Visitors — persons who visit our website or interact with us without registering.

2.3  This Policy does not apply to third-party websites linked from the Platform; those are governed by their own privacy policies.

3.  Definitions

•       “Personal Data” or “Personal Information” means any information relating to an identified or identifiable natural person, consistent with the definitions in R.A. 10173 (Data Privacy Act of 2012) and the GDPR.

•       “Sensitive Personal Information” means personal data about an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical, or political affiliations; health, education, genetic or sexual information; proceedings for offenses; and government-issued identifiers such as social security numbers, as defined in §3(l) of the DPA.

•       “Processing” means any operation performed on personal data, including collection, recording, organization, storage, updating, retrieval, use, disclosure, or erasure.

•       “PIC” (Personal Information Controller) means a person or entity that controls the collection, holding, processing, or use of personal data.

•       “PIP” (Personal Information Processor) means a person or entity to whom a PIC outsources personal data processing.

•       “Consent Terms” means the SEAKER Seafarer Data Sharing Consent Terms.

•       “NPC” means the National Privacy Commission of the Philippines.

•       “DPA” means Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations.

•       “GDPR” means the EU General Data Protection Regulation 2016/679.

4.  Personal Data We Collect

4.1  Data you provide directly

•       Identity and contact data: full name, date of birth, nationality, gender, civil status, address, email address, and mobile number.

•       Account credentials: username, password (stored in encrypted form), and security information.

•       Professional and seafarer data: passport and seaman’s book numbers, STCW certificates, flag-state endorsements, sea-service records, rank, vessel types, training records, and employment history.

•       Financial data: bank account or card details for payment processing.

•       Platform Partner data: corporate registration details, DMW license numbers, accreditation records, and authorized representatives’ information.

•       Communications: messages, feedback, support requests, and survey responses you send us.

4.2  Data we collect automatically

•       Device and usage data: IP address, device type and identifiers, browser type, operating system, referring URLs, and pages visited.

•       Location data: approximate or precise location, where you grant permission, for features such as accommodation search and welfare check-ins.

•       Log data: server logs, timestamps, and activity data relating to your use of the Platform.

•       Cookies and similar technologies: as described in Section 12.

4.3  Data we receive from third parties

•       Accreditation and verification data from the DMW, MARINA, STCW-issuing authorities, and other regulatory bodies.

•       Reference and employment data from manning agencies or employers you authorize to share such data.

•       Publicly available professional directories.

4.4  Voluntary provision

Providing your personal data is generally voluntary. However, certain data is necessary to deliver specific services. Where personal data is mandatory, we will indicate this at the point of collection. If you do not provide mandatory data, we may be unable to provide the relevant service.

5.  Sensitive Personal Information

5.1  Some data we collect qualifies as Sensitive Personal Information under the DPA. This includes health information (e.g., pre-employment medical examination results), government-issued identifiers (passport number, seaman’s book, social security details), and, in certain welfare contexts, information about your physical condition or whereabouts.

5.2  We process Sensitive Personal Information only: (a) with your explicit consent; (b) as necessary for employment, seafarer certification, or regulatory compliance purposes; or (c) to protect your vital interests or those of others in an emergency, in accordance with §13 of the DPA and Article 9 of the GDPR.

5.3  Sensitive Personal Information is subject to stricter access controls, additional encryption, and heightened retention and disposal procedures.

6.  Lawful Bases for Processing

We rely on the following lawful bases under the DPA (§12) and the GDPR (Art. 6) to process your personal data:

 Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing already carried out. See Section 15 for how to exercise your rights.

7.  How We Use Your Personal Data

7.1  Seafarers

•       Creating and maintaining your seafarer profile and document wallet.

•       AI-assisted job matching and CV validation (internal matching only; your data is not used to train external AI models).

•       Enabling Find Seaman discovery (read-only) and Manning Agency full-profile access subject to your Lock-In consent under the Consent Terms.

•       Alumni tracing and OBT monitoring for your school, subject to your school-visibility consent.

•       Welfare monitoring, emergency check-ins, and coordination of support, subject to your welfare consent.

•       STCW compliance scoring and certificate verification.

•       Blockchain-based record integrity (Hyperledger Fabric) for employment and credential records.

•       Processing payments for any paid features.

7.2  Platform Partners

•       Onboarding, accreditation verification, and account management.

•       Enabling access to the recruitment pipeline, training management, property listings, and media publishing tools.

•       Processing subscription and transaction payments via PayMongo or other approved processors.

•       Compliance verification (DMW license checks, data-sharing agreement administration).

7.3  All users

•       Responding to inquiries, support requests, and feedback.

•       Platform security, fraud detection and prevention, and abuse monitoring.

•       Analytics and product improvement (using aggregated or de-identified data where practicable).

•       Legal and regulatory compliance.

•       Corporate transactions (merger, acquisition, sale of assets) where personal data may be transferred as part of business continuity — subject to notification and applicable law.

8.  Marketing & Promotional Communications

8.1  With your separate, freely-given consent, we may send you alerts, newsletters, updates, promotional materials, event invitations, and partner offers by post, telephone, SMS, or email.

8.2  You may withdraw your marketing consent at any time by clicking the “Unsubscribe” link in any marketing email, by adjusting your in-app notification settings, or by contacting the DPO. Withdrawal does not affect the lawfulness of prior marketing communications.

8.3  We will not condition your access to core Platform features on your acceptance of marketing communications, and we will not charge a higher fee if you decline marketing consent.

8.4  We will not share your personal data with third-party advertisers for their independent marketing without your explicit consent.

9.  Disclosure to Third Parties

9.1  We do not sell your personal data. We may share it only in the circumstances described below.

9.2  Service providers and sub-processors

We engage trusted third-party service providers who process data on our behalf under written agreements that impose data-protection obligations no less protective than this Policy:

•       Cloud infrastructure: Amazon Web Services (AWS), Asia Pacific – Singapore region (ap-southeast-1).

•       Blockchain integrity layer: Hyperledger Fabric.

•       Payment processing: PayMongo and other approved processors.

•       IT infrastructure, software development, and security service providers.

•       Professional advisors: legal, financial, and audit professionals bound by confidentiality.

9.3  Platform Partners (for seafarer data)

We share seafarer data with accredited Manning Agencies, schools, and training providers only subject to your specific consents under the Consent Terms, the Lock-In/Lock-Out mechanism, and the terms of the applicable Data Sharing Agreement.

9.4  Regulatory and governmental bodies

We may disclose data to the NPC, DMW, MARINA, the Bureau of Immigration, courts, law enforcement, or other authorities where required by law, regulation, or legal process.

9.5  Corporate transactions

In the event of a merger, acquisition, reorganization, or asset sale, your personal data may be transferred to the successor entity, subject to equivalent privacy protections and prior notice where required by law.

10.  Cross-Border Data Transfers

10.1  Our primary hosting is on AWS ap-southeast-1 (Singapore). Some of our service providers and Platform Partners are located outside the Philippines. When we transfer personal data outside the Philippines, we rely on one or more of the following safeguards in accordance with §21 of the DPA and Art. 44–49 of the GDPR:

•       Standard Contractual Clauses (SCCs) approved by the relevant authority.

•       Transfer Impact Assessments (TIAs) where required.

•       Your explicit consent, where obtained.

•       Adequacy decisions or determinations by the NPC or European Commission where applicable.

10.2  Executed Data Sharing Agreements with Platform Partners contain SCC-equivalent provisions and TIA requirements for any onward transfer of seafarer data outside the Philippines or the EEA.

11.  Automated Decision-Making & AI

11.1  We use automated processing, including AI-assisted tools, for the following purposes on the Platform: CV validation (flagging document completeness and STCW compliance issues); job-matching recommendations (ranking seafarer-to-vacancy compatibility); and STCW compliance scoring.

11.2  These automated tools produce recommendations and scores to assist human decision-makers — they do not make final decisions about your employment, rejection, or placement. Manning Agencies and SEAKER personnel retain human oversight over all outcomes that significantly affect you.

11.3  Your personal data is not used to train external or third-party AI models. Matching and validation models operate internally to SEAKER’s systems.

11.4  You have the right to request human review of any automated recommendation that significantly affects you, to express your view, and to contest the result. Contact the DPO to exercise this right.

12.  Data Retention

Upon expiry of the applicable retention period, personal data will be securely deleted, anonymized, or disposed of in accordance with our data disposal procedures. You may request early deletion subject to Section 13 and lawful retention requirements.

13.  Cookies & Similar Technologies

13.1  We use cookies, pixel tags, local storage, and similar technologies on our websites and App to: keep you signed in; remember your preferences; analyze usage patterns; and deliver relevant content.

13.2  Types of cookies we use:

•       Strictly necessary: required for the Platform to function; cannot be disabled.

•       Functional: remember your preferences and settings.

•       Analytics: help us understand how the Platform is used (e.g., pages visited, session duration).

•       Marketing: used only with your consent to deliver relevant promotions.

13.3  You may manage or disable non-essential cookies through your browser settings or the in-app cookie preferences panel. Disabling strictly necessary cookies may affect Platform functionality.

14.  Security

14.1  We implement technical, organizational, and physical security measures appropriate to the sensitivity and volume of personal data we process. These include access controls and role-based permissions; encryption of data in transit (TLS) and at rest where appropriate; multi-factor authentication for administrative systems; blockchain-based integrity verification for employment and credential records; and regular security assessments.

14.2  Data Breach Notification — In the event of a personal data breach that is likely to result in serious harm, SEAKER will: (a) notify the NPC within seventy-two (72) hours of becoming aware, in accordance with NPC Circular 16-03 and Art. 33 GDPR; and (b) notify affected data subjects without undue delay where the breach is likely to result in a high risk to their rights and freedoms, in accordance with §20 of the DPA and Art. 34 GDPR. Notifications will include the nature of the breach, categories and approximate number of data subjects affected, likely consequences, and measures taken or proposed.

15.  Your Data Subject Rights

Subject to applicable law and certain exceptions, you have the following rights under the DPA and the GDPR:

To exercise any of these rights, submit a written request to the Data Protection Officer using the contact details in Section 17. We will respond within thirty (30) calendar days or within the period prescribed by law. We may ask you to verify your identity before processing your request.

Note on fees: SEAKER will not charge a fee for routine requests. We reserve the right to charge a reasonable fee for manifestly unfounded or excessive requests, as permitted by law.

16.  Children & Minors

16.1  The Platform is not directed at persons under 18 years of age. We do not knowingly collect personal data from minors.

16.2  If you are a parent or legal guardian and believe that a minor in your care has submitted personal data to SEAKER without your consent, please contact the DPO immediately for erasure. If a minor’s data is inadvertently collected, we will delete it promptly upon becoming aware.

16.3  Where a minor’s data has been provided with parental or guardian consent, the consenting guardian assumes responsibility and is bound by this Policy.

17.  Third-Party Links & Services

The Platform may contain links to third-party websites, applications, or services. SEAKER is not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third-party service you access through the Platform.

18.  Changes to this Policy

18.1  We may update this Policy from time to time. When we do, we will revise the version number and effective date above and post the updated Policy on the Platform.

18.2  For material changes that significantly affect how we process your data or your rights, we will provide prominent notice through the App or by email, and where required by law we will seek fresh consent.

18.3  Your continued use of the Platform after the effective date of a revised Policy constitutes acceptance of the changes, except where fresh consent is required.

19.  Contact — Data Protection Officer

For any questions about this Policy, to exercise your data-subject rights, or to report a privacy concern:

Data Protection Officer

Seaker System Technologies Inc.

5F W. Deepz Bldg., 1033 MH Del Pilar St., Ermita, 1000 City of Manila, NCR, Philippines

Email: dpo@seaker.ph

You also have the right to lodge a complaint directly with the NPC:

National Privacy Commission

5th Floor, Delegation Building, PICC Complex, Vicente Sotto Street, Pasay City, Metro Manila

Website: www.privacy.gov.ph

— End of Privacy Policy —