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Legal · Privacy (KVKK)

KVKK Privacy Notice

Effective from · 12 July 2026 Version 1.1 · Article 10 notice · English translation

In this document

  1. 01 · Data controller
  2. 02 · Data categories
  3. 03 · Purposes and legal grounds
  4. 04 · Collection methods
  5. 05 · Recipients and providers
  6. 06 · Processing abroad
  7. 07 · Retention and deletion limits
  8. 08 · Data subject rights
  9. 09 · Request channels
  10. 10 · Technical storage and updates

This notice explains how personal data is processed on the Strata website and app. Optional processing that requires explicit consent is presented separately from this notice.

01Data controller

Data controller
Lümen Eğitim Danışmanlık Yazılım Teknoloji Limited Şirketi
Tax office: Göztepe Vergi Dairesi · Tax number: 6091381177
MERSİS: 0609138117700001
Trade registry number: 1049457
Address: Fenerbahçe Mah. İğrip Sk. No: 13/1 Kadıköy / İstanbul 34726
Email: iletisim@stratacareer.com
Web: stratacareer.com

02Data categories

  • Account and contact: first name, last name, email, user ID and authentication details.
  • Profile and learning: role, seniority, goals, preferences, lesson and route progress, answers, certificates, saved notes and reflections.
  • Elenq chat: messages in standard Elenq conversations, session titles and limited profile context used to generate responses.
  • Optional coaching memory: selected summaries of career context, only with separate explicit consent.
  • CV analysis: the CV file is parsed locally on your device; the file itself is not uploaded to or stored by Strata. Extracted CV text is sent to the configured AI provider for analysis but is not stored in the Strata profile. Only the derived profile, skills and recommendations are saved.
  • Other user documents: if a document-upload feature outside CV analysis is enabled, a file you choose to upload and its metadata may be processed. Scope, retention and deletion schedules are shown before uploading.
  • Safe Zone: your text is sent to the provider to generate a response; it is not stored in your Strata account or added to permanent Elenq memory.
  • Membership and Apple payment metadata: plan, product ID, transaction/original transaction reference, entitlement status and period dates; not card numbers or security codes.
  • Technical and security: session, IP address, device/browser, error and security logs, and essential local storage/cookie identifiers.

03Purposes and legal grounds

  • Providing accounts, learning, membership entitlements and support: formation/performance of a contract and relevant legal obligations.
  • Synchronizing progress, maintaining security and resolving errors: contract performance and proportionate legitimate interests.
  • Managing disputes and legal records: legal obligations and establishing, exercising or protecting a right.
  • CV analysis and optional coaching memory: explicit consent obtained separately within the feature. Withdrawing consent stops new processing without affecting the lawfulness of earlier processing.
Information and consent are separate. Reading this notice does not mean consenting to CV analysis or coaching memory. Optional features are selected on their own screens.

04Collection methods

Data is collected electronically from information entered directly into registration, profile, lesson, note, CV, chat and support screens; progress and security records generated during app use; and limited transaction metadata supplied by Apple to verify purchases.

05Recipients and providers

Data may be processed through the following service categories to the extent needed for its purpose:

  • Supabase: authentication, database and file-storage infrastructure.
  • OpenAI and Anthropic: Elenq responses, CV analysis or AI-assisted case processing according to feature configuration. Each operation is not sent to both providers.
  • Vercel and content-delivery infrastructure: serving the web app and handling technical traffic.
  • Apple: iOS purchasing, subscription management, receipts and refunds.
  • Authorized public bodies: only when there is a legal obligation or a duly made request.

06Processing abroad

Personal data may be processed abroad where cloud and AI providers are located abroad. Such processing is addressed under the applicable transfer conditions in KVKK Article 9 and data-security obligations.

Provider locations may vary with the feature and data category. You can use the request channels to ask about recipient groups and processing purposes.

07Retention and deletion limits

  • CV: the file is parsed locally and not uploaded to Strata. Extracted text sent to the provider for analysis is not retained in the Strata profile. Derived profile, skills and recommendations are retained for up to one year from explicit consent.
  • Other user documents: if an upload feature is enabled, its retention and deletion schedule is shown before uploading.
  • Coaching memory: summary context created with explicit consent is retained for up to one year; it is removed through the relevant privacy tool if the user deletes it earlier or withdraws consent.
  • Safe Zone: content is not permanently stored in the Strata database. Closing the temporary session view leaves no conversation history on Strata’s side; the provider’s own processing records may be subject to its terms.
  • Standard Elenq chat, notes, reflections and progress: retained while the account remains open or until the user deletes the data; records covered by account/privacy deletion tools are removed on request.
  • Membership and payment metadata: retained within applicable statutory periods for managing entitlements, financial obligations and disputes.

08Data subject rights

Under KVKK Article 11, you may learn whether your data is processed; request information and recipients; learn whether processing meets its purpose; request correction, deletion or destruction; request notification to recipients; object to automated outcomes; and seek compensation for damage caused by unlawful processing.

09Request channels

You may submit a request that enables identity verification to iletisim@stratacareer.com or in writing to Fenerbahçe Mah. İğrip Sk. No: 13/1 Kadıköy / İstanbul 34726. Requests are answered according to the periods and procedures in KVKK Article 13.

10Technical storage and updates

Strata uses essential cookies or device storage for sign-in, security, theme and basic app preferences. No separate analytics-cookie system is claimed. If the policy changes, its effective date and version are updated here.

For purchase terms, see the Distance Sales Agreement and Refund and Cancellation Policy.

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© 2026 Lümen Eğitim Danışmanlık Yazılım Teknoloji Ltd. Şti.

MERSIS: 0609138117700001 · Trade Registry: 1049457 · Göztepe Tax Office: 6091381177