Privacy Policy

Sterling Learn (“the Platform”, “we”, “us”) is the online learning service of Sterling College London (“the College”). The data controller for the personal data described here is Sterling College (London) Limited, registered with the Information Commissioner's Office under reference ZB567113. Its registered office is Onega House, 112 Main Road, Sidcup, Kent DA14 6NE. You can reach us about anything in this policy, including any request about your data, at admin@sterlingcollegelondon.com.

This policy covers the Platform at sterlinglearn.com. In-person study at the College is covered separately by the College's own privacy notice.

We do not ask for special category data, and you should not include health, religious or similar sensitive information in AI tutor conversations or uploaded work.

Lessons are presented by Emma, our AI teacher, and the conversation tutor is an AI system. Your tutor conversations are stored so you can see your corrections and progress.

Conversations are not routinely read by staff. A conversation is placed in a review queue only where the system flags a possible safeguarding concern — for example, something suggesting that you or another person may be at risk. Where that happens, a member of College staff reviews it, and we may act on it, including contacting appropriate services where someone appears to be at risk of harm.

The AI tutor provides language practice only. It is not a source of professional, medical, legal or immigration advice, and it can make mistakes.

We use a small number of cookies, and no third-party advertising or analytics tags on our pages. Where we do measure things, the measurement happens on our own servers rather than in your browser.

• Sign-in session — keeps you signed in. Essential; the Platform cannot work without it.
• sl_placement — holds your placement test result for up to 30 days so it survives until you create an account. Signed and readable only by our server. Essential, because it delivers a result you asked for.
• sl_consent — remembers whether you agreed to the marketing cookie, so we do not ask again on every page. Essential; without it we could not honour a refusal.
• sl_attr — set for up to 90 days only if you agree, and only when you arrive from an advert carrying campaign parameters. It records the campaign, the click identifier supplied by Google or Meta, the site that referred you and the page you landed on. It is never set during ordinary browsing of the site, and it is a marketing cookie rather than an essential one.

We measure page traffic using Vercel Web Analytics, which does not use cookies and does not build a profile of you.

Your choice. The first time you visit we ask whether you agree to the marketing cookie. It is not set unless you say yes, and refusing takes exactly one click, the same as accepting. We remember your answer for six months and then ask again. Refusing does not limit anything on the Platform — it only means we cannot tell which advert brought you here.

You can change your mind at any time: Change your cookie choice. You can also delete cookies in your browser. Deleting the sign-in cookie will sign you out; deleting the others has no effect on your learning.

We do not sell your personal data. We use a small number of service providers, who act on our instructions:

• Stripe — takes your payment. Card details go directly to Stripe and are never held by us. We store the order and a payment reference.
• Mux — hosts and streams the lesson videos.
• Vercel and Neon — host the Platform and its database.
• Anthropic — provides the language model behind the AI tutor. Your messages to the tutor are sent to it in order to generate a reply.
• Resend — sends service emails such as verification and password resets.
• PostHog — measures how the free English level test is used, so we can see where people abandon it. Our server sends three events (the test was started, completed, or its result attached to a new account), the level scored, and whether the person was signed in. If you are signed in your account identifier is included; if you are not, the events carry no identifier for you at all. The data is held in the European Union, and PostHog sets no cookies on your device.
• Google and Meta — where you arrived from one of their adverts and went on to buy, we may send them the click identifier and the fact that a purchase occurred, so their advertising reporting is accurate. We do not send them your name, email address or anything about your learning.

Some of these providers operate outside the UK. Where personal data is transferred overseas, it is protected by the safeguards required under UK data protection law, such as the UK International Data Transfer Addendum.

• Your account and learning record — while your account is open, and for up to two years afterwards so that we can reissue a certificate or answer a query.
• Purchase and accounting records — six years, as UK tax law requires.
• AI tutor conversations — kept while they are useful to your learning and then deleted, except where a safeguarding concern has been recorded, which we keep for as long as is necessary to meet our safeguarding duties.
• Marketing attribution cookie — 90 days on your device; the campaign fields stamped on an order are kept with the order.

Under UK data protection law you have the right to:

• ask for a copy of the personal data we hold about you;
• have inaccurate data corrected;
• ask us to delete data, where we do not have to keep it;
• ask us to restrict how we use it, or object to our use of it;
• ask for your data in a portable format;
• withdraw consent at any time, where we relied on consent.

Email admin@sterlingcollegelondon.com and we will respond within one month. If you are unhappy with how we have handled your data you can complain to the Information Commissioner's Office — ico.org.uk, or Wycliffe House, Water Lane, Wilmslow SK9 5AF, telephone 0303 123 1113 — though we would ask you to raise it with us first.

Passwords are stored hashed, never in readable form. Access to learner data is restricted to College staff who need it, and significant actions are recorded in an audit log.

The Platform is for learners aged 16 and over, and we ask for date of birth at registration to enforce that. Where a learner is under 18, a parent or guardian may exercise these rights on their behalf.

If we change how we use your data we will update this page and change the effective date above. Where a change is significant we will tell account holders by email.