GTS Privacy Policy

ReachLMS Mobile Application and Online Learning Platform

Version 1.0

Effective 4 August 2026

Gulf Theological Seminary (“GTS”, “we”, “us”, “our”) is committed to protecting the privacy of its students, faculty, staff and other users. This Privacy Policy explains what personal information we collect through the GTS ReachLMS mobile application (the “App”) and the associated online learning platform, why we collect it, how we use and protect it, who we share it with, and the rights you have over it.

This Policy applies to the App on iOS and Android devices and to the web version of the learning platform. It does not apply to third-party websites or services that you may reach through links within the App. By creating an account or using the App, you confirm that you have read and understood the Policy.

01Who we are and how to contact us

Gulf Theological Seminary is an institution of theological higher education based in Dubai, United Arab Emirates. GTS is responsible for, and decides how and why we use, the personal information described in this Policy.

02Information we collect

Information you provide to us

  • Identity and contact details: full name, preferred name, student identification number, email address, telephone number, postal address, date of birth, nationality and country of residence.
  • Enrolment and academic records: program of study, courses taken, enrolment status, attendance, assignments and submissions, assessment marks, grades, grade point average, transcripts and academic standing.
  • Account credentials: your username and password, and the information used to authenticate you when you sign in.
  • Content you submit: assignment files, discussion posts, messages, comments, quiz and examination answers, and any documents or images you upload.
  • Profile information: profile photograph, short biography and display preferences, where you choose to provide them.
  • Correspondence: messages you send to instructors, administrators or support staff through the App.

Information we collect automatically

  • Device and technical information: device model, operating system and version, unique device identifiers, application version, and your language and time zone settings.
  • Usage information: the courses and pages you view, the features you use, the dates and times of access, and the actions you take within the App.
  • Log and diagnostic information: internet protocol (IP) address, error reports and crash logs, used to diagnose faults and improve reliability.
  • Push notification tokens, where you have chosen to enable notifications.

We do not collect precise location data. We do not use your information for advertising or behavioral tracking, and we do not sell personal information to anyone.

03Permissions the App may request

The App may ask your permission to use certain features of your device. You may decline any of these, or withdraw permission later in your device settings; some features of the App may then be unavailable to you.

  • Camera and photo library: to upload a profile photograph or to submit assignment work.
  • Files and documents: to attach and submit coursework.
  • Microphone: to record audio submissions, where a course requires it.
  • Notifications: to alert you to announcements, messages, due dates and released grades.
  • Calendar: to add course dates to your device calendar, where you choose to do so.

04Why we collect your information and how we use it

We use personal information only for the purposes set out below.

Purpose Information used
To create and administer your account and confirm your identity Identity and contact details, account credentials
To deliver courses and give you access to learning materials Enrolment records, usage information
To set, receive and mark assessments, and to record grades Content you submit, academic records
To maintain official academic records, transcripts and certificates Identity details, academic records
To communicate with you about your studies, deadlines and seminary announcements Contact details, notification tokens
To provide technical support and answer your enquiries Correspondence, device and log information
To keep the App secure and prevent unauthorized access or misuse Device, log and usage information
To improve the reliability, accessibility and usefulness of the App Usage, diagnostic and crash information
To meet our legal, accreditation, audit and regulatory obligations Identity details, academic records

05Our legal basis for processing

We process personal information where one or more of the following applies:

  • it is necessary in order to perform our agreement with you as an enrolled student, applicant, or member of faculty or staff;
  • it is necessary for our legitimate interests in operating the seminary, maintaining accurate academic records and keeping our systems secure, provided that your rights and interests do not override those interests;
  • we are required to process it by law, or by accreditation, audit or regulatory requirements; or
  • you have given us your consent, for example to an optional device permission or to receive seminary announcements. Where we rely on your consent, you may withdraw it at any time.

06How we share your information

We share personal information only where it is necessary, and only with the following:

  • GTS faculty and staff who need the information in order to teach, advise, assess or administer your studies.
  • Our technology providers, who host and support the App and the learning platform on our behalf under written contract. These include the developer of the App, the provider of the underlying learning management system, and the mobile application distribution platforms (Apple and Google).
  • Accrediting bodies, examination boards and partner institutions, where this is required in order to verify or transfer academic credit, and where you have been informed or have given consent.
  • Government, judicial or regulatory authorities in the United Arab Emirates or elsewhere, where we are required to disclose information by law, or where disclosure is necessary to protect the rights, safety or property of GTS, our students or others.

Our providers act only on our documented instructions and are required to keep your information confidential and secure. We do not sell personal information, and we do not share it for advertising purposes.

07Transfers of information outside the UAE

GTS operates in the United Arab Emirates. Some of our technology providers store or process information on servers located outside the UAE. Where information is transferred outside the country, we take reasonable steps to ensure that it remains protected by appropriate contractual safeguards and by a standard of protection comparable to that required under UAE law.

08How long we keep your information

We keep official academic records, including enrolment records, grades and transcripts, permanently. This is normal practice for an educational institution and is necessary so that we can issue transcripts and verify credentials for our graduates throughout their lives.

Other information is kept only for as long as it is needed:

  • Account and sign-in information: for the duration of your association with GTS, and for a reasonable period afterwards.
  • Coursework submissions and discussion content: for the duration of the course and for a further period sufficient to allow for appeals, moderation and accreditation review.
  • Technical logs and diagnostic data: normally no longer than twenty-four months.

09How we protect your information

We use reasonable administrative, technical and physical safeguards to protect your information. These include encrypted connections between the App and our systems, password-protected accounts, access limits so that staff can see only the information their duties require, and regular review of who holds access.

No system can be guaranteed to be completely secure. However, we take this responsibility seriously, and where the law requires it, we will notify you and the competent authority of any breach affecting your personal information.

You are responsible for keeping your password confidential and for telling us promptly if you believe your account has been used without your authorization.

10Your rights

Subject to UAE Federal Decree-Law No. 45 of 2021 concerning the Protection of Personal Data, and to any other law that applies to you, you have the right to:

  • ask what personal information we hold about you and receive a copy of it;
  • ask us to correct information that is inaccurate or incomplete;
  • ask us to delete information, where we are not required to keep it;
  • ask us to restrict, or object to, certain uses of your information;
  • ask that information you gave us be transferred to another organization, where this is technically possible;
  • withdraw your consent, where our use of your information is based on consent; and
  • make a complaint to the competent data protection authority.

To exercise any of these rights, please write to us at info@gulfseminary.com. We will respond within thirty days. Please note that we may not be able to delete official academic records, because we are required to retain them.

11Children and minors

The App is intended for students enrolled at GTS and for its faculty and staff. It is not directed at children. Where an applicant or student is under the age of 18, we require the consent of a parent or legal guardian before an account is created. If you believe that a child has given us personal information without the required consent, please contact us and we will take appropriate steps.

12Links to other services

The App may contain links to third-party websites, readings or resources that are not operated by GTS. We are not responsible for their content or for their privacy practices, and we encourage you to read their own privacy policies before giving them any information.

13Changes to this Policy

We may update this Policy from time to time to reflect changes in our practices or in the law. The current version will always be published at https://www.gulfseminary.com/privacypolicyreachlms/. Where a change is significant, we will tell you through the App or by email. The version number and effective date shown at the top of this Policy indicate when it was last revised.

14Contact and complaints

If you have any question, concern or complaint about this Policy, or about the way GTS handles your personal information, please contact us:

We take every concern seriously and will do our best to resolve it promptly.

Connect with us

Gulf Theological Seminary is a ministry of The Evangelical Church in Abu Dhabi and Redeemer Church of Dubai.