Privacy & Cookies Policy

1. Who we are

Amberly Learning Ltd is the controller of personal information used to operate Amberly Learning, except where a provider acts independently for its own purposes. Our company number is 17432167 and our registered office is 48 Queen Street, Exeter, EX4 3SR, United Kingdom. Contact hello@amberlylearning.com about privacy or your rights.

This policy covers accounts, learning activities, Amberly+, communications, analytics and cookies. It distinguishes information stored by Amberly from technical information processed by providers when delivering the service.

2. Accounts and authentication

Clerk handles account registration, authentication, verification, login sessions and recovery. Depending on the sign-in methods available, it processes your email, credentials or identity-provider information, profile details and security/session information. We do not receive your plaintext password.

Our application stores your account identifier and email, account dates, teacher-mode preference and billing links. Clerk may hold profile details such as a name or avatar where supplied. Administrators can view account and membership information to operate the service.

Where Terms acceptance is collected, a provider or Amberly records the acceptance time and applicable document version. Accepting contractual terms is not consent to optional marketing or analytics.

3. Learning and progress information

Depending on the activities you use and your access, we store saved resources, learning activity and recent items, exercise attempts and results, scores, completion/progress information and settings. This includes relevant reading, grammar, flashcard, dictation, games, conversation and teacher-resource activity where those features record it.

Some preferences or in-progress activity are stored in your browser; signed-in features can attach records to your account. Activity identified only by a random session identifier is not the same as an account profile, but should not automatically be treated as irreversibly anonymous.

Authorised administrators may use activity and aggregate reports to support users, maintain resources and understand service performance. Public popularity counts do not expose your private learning history.

4. The placement test and shared results

You can take the placement test without supplying a name or email. We generate test and session identifiers and store the question selection, submitted answers and outcome, score, suggested CEFR level and relevant dates.

A test can be linked to your account when you take it signed in or explicitly claim an eligible result afterwards. It is therefore inaccurate to describe every placement-test response as entirely anonymous.

If you choose to share a result, a public link can expose the score and level to anyone with that link. Do not share it unless you want others to see those details. Test and event records also support question-quality, completion and service-performance analysis.

5. Amberly+ and payments

Stripe processes payments through hosted checkout and provides subscription-management tools. We process the account/customer link, selected offering, payment and subscription references, plan/status, amounts and currency, billing/access dates and relevant purchase information.

Billing and transaction information, including information in payment events, may also be held in our Stripe-synchronised records. Stripe collects payment-method and billing information and may process it for its own payment, fraud-prevention and legal purposes. Amberly does not store complete payment-card numbers.

Payment-related records can remain after account deletion where necessary for accounting, legal obligations, fraud prevention or disputes. Cancelling payments and deleting an account are not interchangeable.

6. Emails, support and marketing

We and our providers send account/security messages, welcome and purchase messages and other service communications where relevant. Clerk handles authentication messages; Microsoft Outlook is used for application email. Email addresses and message contents are processed to deliver these communications.

If you contact us or submit feedback, we process the information you choose to provide, your message and relevant technical context to respond and resolve the issue. Avoid sending unnecessary sensitive information or complete payment details.

Optional news, updates and offers use a separate marketing choice. Use the unsubscribe option in a marketing email or your available account preferences to stop marketing. Unsubscribing does not cancel Amberly+ or stop necessary security, service or billing messages.

7. Purposes and lawful bases

Where UK data-protection law applies, the basis depends on the processing activity. We do not treat merely creating an account as consent to every use of information.

• Contract: providing an account or paid service you request, delivering account-linked learning features, administering purchases and responding to related support requests.
• Consent: optional analytics storage and account-source attribution where permission is required, and optional marketing where consent is the applicable basis.
• Legitimate interests: proportionate security, abuse prevention, troubleshooting and service measurement where lawful and balanced against your rights. Cookieless or first-party measurement is not automatically exempt from privacy law.
• Legal obligations: required financial/accounting records, legal requests and other applicable statutory duties.

8. Analytics and cookieless measurement

We use Google Analytics 4 with Consent Mode. The Google tag loads with analytics and advertising-related storage/signals denied by default. Depending on your choice and our regional settings, our current configuration may later enable analytics storage and advertising-related consent signals together. This is separate from your choice about marketing emails.

When analytics storage is denied, Google may still receive cookieless requests and technical information associated with delivering and measuring the page. Denied storage does not mean that no information is transmitted or that no personal information can be processed.

Amberly also receives first-party page/activity events when analytics is enabled, and limited landing/test-start/test-completion measurement independently of the optional analytics choice. Those limited pings use fresh event identifiers rather than the normal persistent analytics session identifier and can include campaign/referrer and page information. They are intended for aggregate measurement, but the request still involves technical processing.

We use these reports to understand visits, activity, question quality and campaign effectiveness. They are not marketing-email consent, and anonymous acquisition records are not retrospectively used to identify your account's sign-up source.

9. Cookies and browser storage

Cookies, local storage and session storage are different ways information can be kept on your device. The categories below reflect their purposes; not all storage is optional analytics.

• Authentication/security: Clerk and the application use session and security mechanisms needed to sign in, maintain sessions and protect administrative access. Payment providers may use their own necessary payment/security storage.
• Consent preference: amberly_consent is a first-party preference cookie with a one-year expiry; cookie_consent in local storage supports the same choice. Local storage normally lasts until cleared rather than expiring like a cookie.
• Analytics: when enabled, Google may use analytics cookies and Amberly uses amberly_session in local storage for analytics sessions. Google manages its cookie identifiers and lifetimes; browser settings and provider settings can affect them.
• Learning and functional preferences: browser storage can retain language, learning activity/settings, temporary activity state and sign-up selections. These should not be confused with marketing permission.
• Acquisition context: session-scoped campaign/referrer context supports the measurement described above; account attribution has separate permission and withdrawal controls.

10. Analytics choices and regional settings

Our current regional logic shows a consent banner for visitors identified as being in the UK, EU/EEA or Switzerland, with conservative handling where location cannot be determined. In other detected regions, the current implementation may enable analytics automatically. This describes the implementation; it is not a claim that every country outside those regions permits analytics without consent.

Where shown, you can accept or decline optional analytics. Your preference is remembered in the consent cookie and local storage. Declining optional analytics storage does not disable necessary authentication or the limited cookieless measurements described above.

There is not currently a dedicated preference-reopening control on this page. You can remove the site's amberly_consent cookie and cookie_consent local-storage entry using your browser's site-data controls and reload to revisit the regional choice. Clearing all site data can also sign you out or remove locally saved settings. Contact us if you need help withdrawing or objecting to optional processing.

11. Sign-up sources and approximate country

When analytics is permitted, we may attach eligible campaign labels, a referring website domain and landing-page path to a new account to understand where sign-ups originate and how sources relate to later paid membership. This does not affect your entitlement or subscribe you to marketing.

With permission, we also record an ISO country code and observation date from the first eligible signed-in visit. This is an estimate from the connection, not nationality, a verified address or necessarily the location where an older account originally registered. The account record does not store the source IP, city or region for this feature.

The removal control below permanently removes account-source and country information and prevents it being collected again for that account, including delayed captures. It does not by itself change Google consent settings, erase independent aggregate reports or cancel membership.

12. Technical information and location

Requests necessarily expose technical information, such as an IP address, to infrastructure that handles them. Country estimation, regional pricing, security, error handling and delivery of pages/audio can involve processing this information.

Application or provider logs can contain request paths, identifiers and error/security details. A statement that we do not put an IP address in an account-country field does not mean that no provider ever processes or logs connection information. We avoid claiming complete anonymity or a universal absence of IP processing.

Country information used to select local prices is separate from optional account-source attribution. Removing account attribution does not disable necessary checks used to offer or administer a purchase. Country lookups can send an IP address to a geolocation provider, including ip-api.com or IPinfo, depending on the lookup and provider configuration.

13. Who receives information

Relevant providers include Replit for hosting and database infrastructure, Clerk for authentication, Stripe for payments/subscriptions, Microsoft for application email, Google Analytics for measurement, and Google Cloud-backed storage for files and media delivery. Providers receive the information needed for the relevant operation; not every provider receives every category of information.

Administrative content imports also use Google Sheets/Drive. That internal content workflow does not itself mean that learner account or progress records are sent to those spreadsheets.

We may disclose relevant information to professional advisers, service providers supporting us, or authorities where reasonably necessary and lawful, for example to meet an obligation or handle a dispute. We do not sell your personal information.

Providers can have their own responsibilities and privacy notices, particularly for authentication, payment security and services you use directly. Their involvement does not remove our responsibility for our own processing.

14. Use of learning information

Amberly Learning does not use users' personal information or learning records to train AI models. This is separate from using test and activity statistics to assess question difficulty, improve the service and understand learning-resource usage.

15. International processing

Our international providers may process information outside the UK or your country. Applicable data-protection law can require an adequacy decision or appropriate contractual or other safeguards for a particular transfer.

The mechanism depends on the provider, contract and destination. We do not claim a particular certification, hosting location or transfer agreement applies to every operation. Contact us for information about relevant recipients and safeguards for your data.

16. How long information is kept

We retain information for as long as reasonably necessary for its purpose, taking account of account/service use, legal and accounting obligations, security, fraud prevention and disputes. Different categories and providers have different retention needs; we do not promise an arbitrary single period for all data.

Some learning views keep a limited recent list, but that does not mean all related historical records are deleted on the same schedule. Stored test, activity, billing, message and event data may follow different rules. Contact us for information about a particular category.

Deleted data may remain in provider backups until their normal secure retention/rotation processes remove it. We do not promise immediate erasure from every historical backup or every independent provider record.

17. Account deletion

Contact hello@amberlylearning.com to request deletion or for help with any available account-deletion control. Removing an account involves the authentication account and associated local account, learning and attribution information. Cleanup can involve more than one system; retries or temporary records may be needed to finish reliably.

Deletion is not a guarantee that all billing, legal, security, support or provider records disappear immediately. Relevant records may need to remain for legitimate purposes and legal obligations. Subscription management and account deletion have different effects; check the billing instructions before deleting and contact us if you need help stopping future payments.

18. Children and younger learners

Amberly is an educational service that may be used by younger learners. We do not collect a date of birth or operate a general age-verification process in the current account flow. We do not assume that every minor requires parental consent for every type of processing.

Parents and guardians can contact us about a child's information. Contractual capacity, payment permissions and any processing that specifically requires parental authorisation depend on applicable law and the circumstances. Optional marketing is not necessary to use an account.

Please contact us if you believe a child has provided information in circumstances requiring action. We will consider the child's interests and relevant privacy rights.

19. Security and access

We use access controls and other technical and organisational measures designed to protect information, including account authentication and restrictions on administrative functionality. Only authorised access should be used to administer accounts and service records.

No online system is perfectly secure. We do not guarantee immunity from incidents or claim a security certification we have not verified. Keep your own credentials secure and tell us about suspected misuse.

20. Your rights and complaints

Depending on applicable law and the processing involved, you may have rights to access, correct, erase or obtain a portable copy of information; restrict or object to processing; and withdraw consent without affecting processing lawfully carried out before withdrawal.

Email hello@amberlylearning.com to make a request. We may need proportionate identity verification. A request is not normally chargeable, and any lawful exception will be explained. Not every right applies to every record, for example where financial records must be retained.

You can complain to the UK Information Commissioner's Office at ico.org.uk, or an appropriate local regulator where applicable. You may contact us first if you wish, but this is not a condition of exercising your right to complain.

21. Scores and recommendations

Quiz marking, CEFR suggestions and progress calculations are automated educational functions. They are not accredited decisions about admission, employment or another legal entitlement. Contact us if you want to question a result or report a scoring problem.

22. External sites, updates and contact

External sites you visit from Amberly operate under their own policies. This policy may be updated to reflect service or legal changes; the last-updated date identifies this version. We will give additional notice where appropriate for a material change.

Contact Amberly Learning Ltd at hello@amberlylearning.com or 48 Queen Street, Exeter, EX4 3SR, United Kingdom.