1. Information We Collect

We collect the following types of personal data:

Audio recordings of lessons or coaching sessions uploaded by users.
Transcripts generated from those recordings.
User account information, including name, email address, school or institution, and professional role.
Usage data, including access logs, session duration, and user interactions with the platform.
Feedback or coaching preferences, if provided.

2. How We Use Your Information

We use the collected information for the following purposes:

To generate transcriptions and coaching reports.
To provide insights for professional development and reflection.
To send reports and feedback via email.
To improve our platform through aggregated, anonymised usage analytics.
To comply with legal obligations or respond to lawful requests.

3. Legal Basis for Processing

Our processing of your personal data is based on:

Your consent, which you may withdraw at any time.
Performance of a contract, where applicable (e.g. with schools or MATs).
Legitimate interests in improving teaching practice and educational outcomes.
Compliance with legal obligations.

4. Sharing and Disclosure

We may share data with:

Service providers who support our platform (e.g. transcription and AI analytics services).
School administrators or MAT leaders, with your consent or as part of a school-wide implementation.
Regulatory bodies or authorities, when legally required.
Trusted partners, in the form of aggregated and anonymised data, for purposes such as educational research, product improvement, or commercial insights.

All third parties are contractually obligated to handle data securely and only for the purpose intended.

Schools, individual accounts and leaving a school

Where you use Starlight as a member of a school or trust, the school is the Data Controller for recordings made under its licence and we process them on its instructions. If you leave the school, or the school removes you (for example after renewing with fewer licences), those recordings stay with the school and are no longer shown in your account. Your account, and anything you recorded outside a school, is kept, and you may continue on an individual plan. Individual subscribers who record their own pupils remain responsible for the lawful basis and notices for those recordings.

5. Data Retention

Audio files and transcripts are stored securely.
Recordings, transcripts and reports are retained for as long as the account or school contract they belong to is active, unless the teacher deletes them first. Deleting a recording removes the audio file and permanently redacts the transcript and reports generated from it.
When a school's contract ends, its data is deleted or returned within 90 days in line with our Data Processing Agreement.
Aggregated and anonymised data may be retained indefinitely for statistical and improvement purposes.

6. Your Rights

Under UK GDPR and applicable laws, you have the right to:

Access your personal data.
Rectify inaccuracies.
Request deletion (right to be forgotten).
Object to or restrict processing.
Lodge a complaint with the Information Commissioner's Office (ICO).

To exercise these rights, contact us at: info@starlightmentor.com

7. Data Security

We implement appropriate technical and organisational measures to protect your data, including:

End-to-end encryption of audio uploads.
Secure cloud storage with access controls.
Role-based access for authorised personnel only.
Regular security audits and compliance checks.

8. International Data Transfers

If data is processed outside the UK, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses or UK adequacy decisions.

9. Updates to this Policy

We may update this policy to reflect changes in technology, legal requirements, or our practices. We encourage you to review it regularly.

Contact Us

If you have questions about this Privacy Policy or our data practices, please contact:

STAR21 Data Protection Officer
Email: info@starlightmentor.com

Privacy Policy for STAR21