This policy explains what personal data Strata processes, why, and what you can do about it. It applies to the Strata app and to this website when you use them in English. If you are in Türkiye, the Turkish KVKK notice is the operative document for you. Read its English translation.
01Who controls your data
The controller is Lümen Eğitim Danışmanlık Yazılım Teknoloji Limited Şirketi, trading as Stratify, registered at Fenerbahçe Mah. İğrip Sk. No: 13/1 Kadıköy / İstanbul 34726, Türkiye. Trade registry number 1049457; MERSIS 0609138117700001. Reach us at iletisim@stratacareer.com.
02What we process
- Account and contact: your name, email address, user identifier, authentication data and, if you sign in with Apple or Google, the identity details that provider passes to us.
- Profile and learning: your role, seniority, goals, language and other preferences; lesson and route progress, answers, notes, reflections and certificates.
- Elenq conversations: the messages in a standard Elenq session, session titles, and the limited profile context used to produce a reply.
- Optional coaching memory: summarised career context, held only where you have given separate, explicit consent inside the feature.
- CV analysis: your CV file is parsed on your own device and is never uploaded to or stored by Strata. The extracted text is sent to our AI provider for analysis but is not retained in your profile; only the derived profile, skills and recommendations are stored.
- Other documents you upload: if a document upload feature other than CV analysis is enabled, the file you choose to upload and its metadata; the scope, retention and deletion schedule are shown before you upload.
- Safe Zone: what you write is sent to the provider to generate a reply. It is not stored on your Strata account and never joins your coaching memory.
- Feedback and support: what you write to us through the in-app feedback form or by email, with the screen and device context you include.
- Membership and payment metadata: your plan, product identifier, transaction and original transaction references, entitlement status and period dates. We never see your card number or security code.
- Notifications: if you turn on push notifications, the device token Apple issues for delivery and your notification preferences.
- Technical and security: session, IP, device and browser information, error and security logs, AI usage logs kept for cost and rate limiting, and the local storage entries the service needs to function.
03Why, and on what legal basis
- Performing our contract with you (GDPR Art. 6(1)(b)): providing your account, the learning experience, your membership entitlement, notifications you have turned on, and support.
- Our legitimate interests (Art. 6(1)(f)): keeping the service secure, diagnosing faults, enforcing usage limits, and preventing abuse. We balance this against your interests and do not use it for profiling or advertising.
- Legal obligation (Art. 6(1)(c)): tax, accounting and record-keeping duties, and responding to lawful requests.
- Your explicit consent (Art. 6(1)(a) and, for any data revealing health or similar categories you choose to enter, Art. 9(2)(a)): CV analysis and optional coaching memory. You can withdraw consent at any time; withdrawal stops further processing and does not affect what was lawful before it.
- Establishing or defending legal claims (Art. 6(1)(f), Art. 9(2)(f)) where a dispute arises.
04How we collect it
Directly from you when you create an account, use the app, or write to us; automatically from your device as you use the service; from Apple or Google when you choose to sign in with them; and from Apple, which reports the subscription status behind an in-app purchase. Apple does not pass us your payment details.
05Who processes it with us
We use a small set of processors, each bound by a data processing agreement and each limited to what its function requires:
- Supabase for authentication, database and file storage, hosted in Frankfurt, Germany.
- OpenAI and Anthropic for Elenq replies, CV analysis and case generation. Each request goes to one provider according to the feature's configuration, never to both.
- Vercel and content delivery infrastructure for serving the web app and this site.
- Resend for transactional email such as sign-in, membership and reminder messages.
- Apple for in-app purchases, subscription management, receipts, refunds and push delivery, and Google where you sign in with Google.
- Public authorities, only where a legal obligation or a valid request requires it.
We do not sell personal data, and we do not share it for advertising.
06Processing outside your country
Strata is operated from Türkiye. Your account, learning and membership data are stored in the European Economic Area (Frankfurt, Germany). Our AI and email providers process data in the United States, and our own team accesses the service from Türkiye. Where personal data leaves the European Economic Area, we rely on the safeguards in Chapter V of the GDPR: standard contractual clauses with the processor concerned, or an adequacy mechanism such as the EU-US Data Privacy Framework where the processor is certified under it, together with the technical measures described in this policy. You can ask us for the specific mechanism applied to a given processor.
07How long we keep it
- Account, profile, progress, notes and reflections: for as long as your account exists, or until you delete the item.
- Elenq conversations: until you delete the session or your account.
- CV-derived data and coaching memory: one year from the consent, or until you withdraw consent or delete it, whichever comes first.
- Other uploaded documents: the schedule shown before upload.
- Safe Zone content: not retained by Strata at all. The provider's own processing records are subject to its terms.
- Feedback: for as long as needed to act on it and, at most, the life of your account.
- Membership and transaction records: for the period our tax and commercial law obligations require.
- Security, error and AI usage logs: a short operational window, then deletion.
Deleting your account removes your personal data from the live service on the schedule above. Backups age out on their own cycle and are not used to restore deleted accounts.
08Your rights
Under the GDPR you have the right to:
- be told what we process and get a copy of it (Art. 15);
- have inaccurate data corrected (Art. 16);
- have data erased where the grounds in Art. 17 apply;
- have processing restricted in the cases in Art. 18;
- receive your data in a portable form and have it transmitted onward (Art. 20);
- object to processing based on our legitimate interests (Art. 21);
- withdraw a consent you have given, at any time (Art. 7(3));
- lodge a complaint with a supervisory authority in your country of residence or work (Art. 77).
We do not make decisions producing legal or similarly significant effects about you by automated means alone. Elenq generates suggestions; it does not decide anything about your account, your entitlement or your standing.
09How to exercise them
The fastest route is the app: the Account screen lets you export your data, delete your Elenq history, reset your learning data and delete your account outright, without writing to anyone. For anything the app does not cover, write to iletisim@stratacareer.com. We may ask you to confirm your identity. We answer within one month, and tell you if we need longer, as Art. 12(3) allows.
10Children
Strata is built for working professionals and is not directed at children. We do not knowingly create accounts for anyone under 16. If you believe a child has an account with us, write to us and we will remove it.
11Cookies and local storage
Strata uses only the cookies and on-device storage the service needs to work: your session, security, theme, language and basic app preferences. We do not run analytics or advertising cookies, and we do not track you across other sites or apps.
12Changes to this policy
We update this policy when the processing it describes changes. The effective date at the top always reflects the current version, and we tell you in the app before a change that materially affects you takes effect.