Channel 16 Privacy Policy

Version: 2026-09-26 · Last updated: September 26, 2026

1. Controller and scope

FLEXSELL INTERNATIONAL W.L.L, CR 149517-1, Flat 115, Building 1527, Road 2004, Block 2123, Hidd, Kingdom of Bahrain ("FlexSell", "we", "us") is the data controller for Channel 16 (also written "CH-16"), a voice-based pilotage examination trainer available as an iOS app, an Android app and a web app at ch-16.com (together, the "Service").

This Policy explains what personal data the Service processes, why, who receives it, how long we keep it and the rights you have under the Kingdom of Bahrain Personal Data Protection Law (Law No. 30 of 2018, the "PDPL"). It applies to trainees, examiners and administrators who use the Service.

2. How the Service works

Channel 16 is an oral examination tool. When you start an exam, an AI examiner reads a question from the organisation's question bank aloud, listens to your spoken answer through your device microphone, scores the answer against a marking rubric and moves to the next question. There is no text chat, no social feature and no advertising. Accounts are created by your training organisation's administrator; the app has no self-service sign-up.

3. Data we process

• Account data: email address, display name, role (trainee or administrator), organisation, account status, sign-in timestamps and password material held by the identity provider (we never see your password).
• Profile picture (optional): an image you choose from your photo library or take with the camera, stored as a resized avatar.
• Voice-exam audio: your spoken answers are streamed live to the examiner during a session and a recording of the session is stored so that an administrator can replay it and so that scores have evidence.
• Transcripts and scores: a machine transcript of each session, the questions asked, the rubric components marked, points awarded and your progress and review schedule.
• Usage and billing data: session start and end times, duration, the AI processing consumed by your sessions (tokens, minutes) and the daily quota applied to your account.
• Technical and diagnostic data: app version, platform and OS version, device model, language, network type, connection quality signals, error and crash reports (see section 6). Crash reports are not linked to your name; they may include your account identifier so we can reproduce a problem you report.

We do not collect precise location, contacts, advertising identifiers or any data for advertising or tracking purposes.

4. Sources

We obtain data from you (your voice, your profile picture, your interaction with the app), from your organisation's administrator (account creation, role, question bank) and automatically from your device and our servers (technical data).

5. Purposes and lawful bases

• Providing the examination service — running the voice session, scoring answers, keeping your history and progress: performance of the contract between your organisation and FlexSell, and our legitimate interest in delivering the Service you asked for.
• Evidence and quality of assessment — storing recordings and transcripts so an examiner can verify a score, handle a dispute or audit the AI examiner: legitimate interest of you and your organisation in fair, verifiable assessment.
• Security, abuse prevention and quota enforcement — rate limits, daily spend caps, audit trail of AI tool calls: legitimate interest and legal obligation to keep the Service secure.
• Reliability — crash and performance reports: legitimate interest in a working product.
• Legal compliance — responding to lawful requests and keeping records the law requires.

Where consent is the basis (microphone, camera and photo-library access), you give it through the operating-system permission prompt and can withdraw it at any time in your device settings. Without microphone access the exam cannot run.

6. Recipients and processors

We share personal data only with processors that act on our instructions, and only to the extent needed to run the Service:

• Amazon Web Services, Inc. (region US East, N. Virginia) — hosting, identity (Amazon Cognito), databases (Amazon DynamoDB), file storage for recordings, transcripts and question images (Amazon S3), content delivery (Amazon CloudFront) and the real-time media server (LiveKit, self-hosted on AWS).
• OpenAI, L.L.C. — speech recognition, the AI examiner's reasoning and speech synthesis. Audio and transcripts of your session are sent to OpenAI's API to produce the examiner's responses. OpenAI processes API data under its API data-usage terms and does not use it to train its models.
• Functional Software, Inc. (Sentry) — crash and error reporting and performance monitoring.
• Your training organisation's administrators — they can see your account, progress, scores, session recordings and transcripts because they run your examination programme.

We do not sell personal data and we do not share it with advertisers or data brokers. We may disclose data if required by law or to protect the rights, safety and security of users or the Service.

7. International transfers

Our servers are in the United States (AWS US East). OpenAI and Sentry also process data in the United States. Transfers outside the Kingdom of Bahrain rely on contractual safeguards with each processor and on the processor's own security programme, in line with the PDPL's transfer rules. By using the Service you acknowledge that your data is processed in these locations.

8. Retention

• Account data: for as long as your account exists, then deleted when your administrator removes the account or on your request (section 11).
• Recordings and transcripts: kept while your account is active so that scores remain verifiable; recordings older than 90 days are moved to archival storage. They are deleted with the account or on request.
• Scores, history and progress: for the life of the account.
• Usage and audit logs: session records expire automatically; tool-audit entries expire automatically; billing and usage summaries are kept for up to 24 months for accounting.
• Crash reports: 90 days at Sentry.

9. Security

All traffic between the app and our servers is encrypted in transit (TLS; WebRTC media is encrypted with DTLS-SRTP). Data at rest is encrypted by AWS. Access to production systems is limited to named FlexSell staff. Sign-in tokens are held in your device's secure storage (iOS Keychain / Android Keystore) and are excluded from device backups. Administrative actions and every AI tool call are recorded in an audit trail.

10. Your PDPL rights

Subject to the conditions in the PDPL you may: access the personal data we hold about you and receive a copy; ask us to correct inaccurate data; ask us to erase your data or restrict its processing; object to processing based on legitimate interest; and withdraw consent where consent is the basis. You may also lodge a complaint with the Personal Data Protection Authority of the Kingdom of Bahrain.

To exercise a right, email us at the address in section 15. We will verify that you are the account holder and respond within the period the PDPL requires.

11. Account and data deletion

Accounts are provisioned by your training organisation, so the app has no in-app sign-up or self-delete button. To have your account and all associated data (profile, recordings, transcripts, scores, history) permanently deleted, ask your administrator or email us directly — see Delete my data. Deletion is completed within 30 days; anonymised billing totals that contain no personal data may be retained.

12. Microphone, camera and photos

Microphone: used only while an exam session is running, to send your voice to the examiner and record the session. The app shows an active-session screen and a mute control whenever the microphone is live. Camera / photo library: used only if you choose to set a profile picture. The app does not read your photos otherwise. The app does not use device tracking, advertising identifiers or third-party analytics SDKs.

13. Children

The Service is a professional training tool for maritime personnel and is not directed at children under 18. Accounts are created only by an organisation's administrator for its trainees.

14. Automated assessment

Scores are produced by an AI examiner applying the rubric your organisation defined for each question. Every score is recorded together with the transcript and recording so that a human examiner can review and, where your organisation allows, override it. You may ask your administrator for a human review of any score.

15. Changes to this Policy

We will post any change on this page with a new version date. Material changes will also be announced in the app or to your organisation before they take effect.