Lord Sterling

Privacy Policy

Version 2026-09-19.draft-1 · Not yet effective: draft for review

Draft information notice reflecting the current application. This notice is not a request for blanket consent. Outstanding operational decisions are identified below.

Controller and contact

Lord Sterling is a digital product operated by Clean & Craft, a Dutch sole proprietorship (eenmanszaak), registered with the Dutch Chamber of Commerce under KVK number 42119058. VAT ID: NL005509262B11. Address: Leijsterbeslaan 4, 4171 AS Herwijnen, Netherlands. Support and privacy: cleanandcraftnl@gmail.com. Telephone: +31 6 51769200. Clean & Craft operates the platform and is the contact for questions about its processing of personal data.

Account and profile information

The application uses email-based authentication, account identifiers, display name and optional bio. Authentication is provided by Supabase. Do not put sensitive information in your bio or conversations unnecessarily. The platform does not collect passports, identity documents or biometrics and does not use an age-verification provider.

Activity and personalisation

Preserves, discovery interaction events, explicit Interests, feed preferences and optional submitted-search evidence support the archive, activity summaries and personalised Discover ordering. Only submitted eligible searches may be retained for personalisation when you select that option; typing is not logged as search evidence. Personalisation can be disabled without erasing account history. Recommendation ranking is separate from Sterling Score.

Conversations and AI processing

Counsel and Companion conversations are stored to support continuity. Companion requests include server-resolved discovery context; conversation history and relevant context are sent to OpenAI to generate a response. Profile/coaching context may be used by the existing Counsel workflow. Do not assume AI conversations are confidential professional communications. Provider processing terms, retention and international transfer safeguards require confirmation before publication of the effective policy.

Preferences and agreement records

We store mature-content enabled state and versioned, account-owned policy acknowledgement or Terms agreement timestamps. These records are not independent age verification. Privacy information is kept distinct from agreement to Terms; not all processing relies on consent.

Purposes and legal bases

Account access, requested archive features and conversations serve provision of the service. Security and limited service measurement may involve legitimate interests, while some obligations require legal compliance and some optional processing may require consent. The controller must confirm the appropriate Article 6 basis for each actual purpose, any legitimate-interest assessment and any special-category implications. This draft does not assert that every activity is consent-based.

Providers and infrastructure

The repository integrates Supabase for authentication and data, OpenAI for AI responses, and Vercel hosting with production Vercel Web Analytics. Public support uses the published Gmail address. External source links have their own operators. Exact processor contracts, hosting regions, subprocessors and transfer mechanisms are operational facts requiring confirmation; no claim of EU-only storage is made.

Retention and deletion

The current application stores account history and preferences; a complete retention schedule and verified account-deletion procedure have not yet been approved. Search evidence used in ranking is limited to a 90-day window, which is not a deletion schedule. Contact the privacy address to request deletion or information. Retention periods, backup treatment and justified legal exceptions must be documented before this draft becomes effective.

Your rights

Depending on the circumstances, GDPR rights include access, rectification, erasure, restriction, portability and objection; consent may be withdrawn where processing relies on it. Contact cleanandcraftnl@gmail.com. Appropriate identity confirmation may be needed, but this platform does not provide an identity-document upload facility. You can complain to the Dutch Autoriteit Persoonsgegevens or the competent supervisory authority. We must assess requests under the applicable statutory rules.

Cookies and measurement

See Cookie Information for session cookies, the Day/Midnight preference and existing production Web Analytics. No advertising integration or new tracker is introduced by this release. Cookie-free measurement still warrants a privacy assessment; it is not automatically outside data-protection law.