Privacy Policy

1. Accountability

Arch Capital Inc. has designated a Privacy Officer responsible for compliance with this policy and with Canadian privacy legislation, including PIPEDA, Quebec's Act Respecting the Protection of Personal Information in the Private Sector (as amended by Law 25), Alberta PIPA, and BC PIPA.

Privacy Officer: David Turnbull, Director, Arch Capital Inc.
Contact: [email protected]

2. What Sterling processes on your device

Sterling processes your voice input, text input, and file contents locally on your hardware. The AI model (DeepSeek R1, open-weights, MIT-licensed), speech recognition (faster-whisper), and text-to-speech (Kokoro) all run on your GPU and CPU. None of this data leaves your machine during normal conversational use.

Conversations are stored as SQLite database files and plain text in your user profile directory (%USERPROFILE%\.sterling\). You can open, copy, or delete these files at any time using any file manager or text editor.

Memory (things Sterling remembers about your preferences) is stored locally using ChromaDB in the same .sterling directory. You can clear all memory from the Settings page, or delete the folder directly.

Voice audio is processed locally on your device for speech recognition. Audio is held only in memory during transcription and is not written to disk, transmitted, or retained. Voice is not used to identify you biometrically.

3. Network connections Sterling makes

Sterling is a local-first application. During normal conversational use, your prompts, transcripts, voice audio, and memory database remain on your device and are not transmitted to Arch Capital or to any third party. Sterling does make the following network connections:

• (a)Model downloads at first run. Sterling downloads AI model weights from Ollama's public registry the first time it runs. This is a one-time download. After installation, the model runs entirely offline.
• (b)License validation at activation. When you activate Sterling with your license key, a one-time validation request is sent over TLS to our licensing server. The request contains only your license key and a hardware identifier. No conversation data is transmitted.
• (c)Update checks. Sterling checks for available updates over TLS. Only the current and latest version numbers are exchanged. Updates are never installed without your explicit consent.
• (d)Web search (user-initiated only). When you ask Sterling to search the web, your search query is sent to DuckDuckGo's API. This happens only when you explicitly request a web search. DuckDuckGo's privacy policy applies to those queries.

If any of these connections are not applicable to your installation, they do not occur. No other outbound connections are made during normal use.

4. What we collect when you visit mysterling.ai

Web server logs: IP address, browser type, and pages visited. Retained for 30 days and used only for security and debugging.

Cookies and tracking: mysterling.ai does not use analytics, tracking cookies, advertising pixels, or session-replay tools. No non-essential cookies are placed on your device.

5. What we collect when you purchase Sterling

Your name, email address, and payment information are processed by our payment provider, Stripe, Inc. We receive your name, email, and transaction details. We never see or store your full credit card number.

6. Third parties that process personal information

The following third parties process personal information on our behalf:

(a) Stripe, Inc.(United States) — payment processing, under Stripe's standard data processing addendum. Stripe handles your payment under PCI-DSS Level 1 controls.

We do not use crash reporting services, analytics tools, or third-party customer support platforms at this time. If this changes, we will update this policy and notify you.

7. Cross-border transfers

Your purchase and billing information is processed by Stripe, Inc. in the United States. Before engaging Stripe, we conducted a privacy impact assessment under Quebec Law 25 article 17 and concluded that the protection afforded by Stripe's security controls, contractual commitments, and the regulatory framework applicable to Stripe is adequate. You may request a summary of that assessment by emailing [email protected].

8. Data retention

• •Purchase and billing records: Retained for six years from the end of the calendar year of the transaction, as required by the Canadian Income Tax Act.
• •License key records: Retained for the life of the license plus six years.
• •Support correspondence: Retained for two years.
• •Web server logs: Retained for 30 days.
• •Sterling data on your device: Retained indefinitely under your control. You may delete it at any time.

9. Data security

Personal information in transit is protected with TLS 1.2 or higher. Payment data is handled by Stripe under PCI-DSS Level 1 controls; Arch Capital does not store your full credit card number. Website traffic uses HTTPS with HSTS.

10. Automated decisions

License key validation is performed automatically by our server. If your license is determined invalid, you may contact [email protected] to request human review of the decision and to correct any personal information used in the determination.

11.What we don't do

• •We don't train AI models on your conversations.
• •We don't sell, share, or rent your personal information.
• •We don't serve advertisements.
• •We don't collect usage analytics from the desktop application.
• •We don't have access to your files, conversations, or memories stored in Sterling.

12. Breach notification

If a confidentiality incident affects your personal information and poses a risk of serious injury (Quebec Law 25) or a real risk of significant harm (PIPEDA section 10.1), we will notify you and the relevant regulator(s) as required by law. We maintain an internal incident register as required by Quebec Law 25.

13. Your rights

Your Sterling data is on your computer. You have full access at all times. To delete everything, remove the %USERPROFILE%\.sterling\ folder.

Purchase data: To request access, correction, or deletion of your purchase records, email [email protected]. We will respond within 30 days.

Data portability: You may request a copy of any personal information we hold about you in a structured, commonly-used format by emailing [email protected].

Canadian residents: Your rights under the Personal Information Protection and Electronic Documents Act (PIPEDA) apply. You may file a complaint with the Office of the Privacy Commissioner of Canada.

Quebec residents:Your rights under the Act Respecting the Protection of Personal Information in the Private Sector (as amended by Law 25) apply, including rights of access, correction, deletion, and portability. You may file a complaint with the Commission d'accès à l'information du Québec.

European residents:If you are located in the European Economic Area or United Kingdom, you have rights under the GDPR / UK GDPR including access, rectification, erasure, restriction, portability, and objection. Because Sterling processes data locally on your device, most GDPR obligations are satisfied by architecture — we simply don't have your data. For purchase-related inquiries, email [email protected]. We will respond within 30 days, as required by GDPR Article 12(3). The lawful basis for processing purchase data is Article 6(1)(b) (performance of contract).

14.Children's privacy

Sterling is not directed at children under the age of 16. We do not knowingly collect personal information from children under 16. Purchases require the buyer to be at least 18 years of age (19 in BC, NB, NL, NS, NT, NU, and YT).

15. Changes to this policy

We will notify you by email of any material changes to this Privacy Policy at least 30 days before they take effect. The notice will show each changed provision and the effective date. If a change is material and you do not accept it, you may contact us for options including a pro-rata refund of any paid but unused period.

Non-material changes (formatting, clarifications that do not alter your rights) will be posted on this page with an updated date.

16. Succession

If Arch Capital Inc. is acquired, merged, dissolved, or if Sterling is discontinued, we will notify you in advance and your personal information will be handled in accordance with this Privacy Policy or a successor policy no less protective. Purchase records will be retained or destroyed in accordance with Canadian tax law.

17. Commercial electronic messages

We send transactional emails only (purchase confirmation, license key delivery, renewal notices, security notices). We will not send marketing or promotional emails without your express opt-in consent. Every commercial electronic message includes our contact information and an unsubscribe link, in compliance with Canada's Anti-Spam Legislation (CASL).

18. Contact

Privacy Officer: David Turnbull, Director
Email: [email protected]

Arch Capital Inc.
London, Ontario, Canada

19. French-language availability

A French-language version of this Privacy Policy is available at mysterling.ai/fr/privacy. For Quebec residents, the French version is presented first in accordance with the Charter of the French Language.