Privacy
Last updated: 24 July 2026
Who I am
Stratly is the trading name of Stratly Consulting Kft., a company registered in Hungary. I am the data controller for the personal data described below.
- Legal name
- Stratly Consulting Kft.
- Company registration number
- 01-09-455640
- Hungarian tax number
- 33035482-2-43
- EU VAT number
- HU33035482
- Registered seat
- Kútvölgyi út 50. 2.em. 11., 1125 Budapest, Hungary
- Privacy contact
- carlos@stratly.io
Stratly is not required to appoint a Data Protection Officer and has not appointed one. Privacy questions come directly to me.
What this covers
Personal data I handle when you complete The Datum, subscribe to Base Case, email me, book a conversation, become a client, or visit this site.
It does not cover other websites you reach through links here. When you follow a link to book a conversation or to subscribe, that service's own privacy notice applies from the moment you arrive.
The Datum
What I collect. Your email address, the answers you give to the diagnostic questions, and the information you provide about your situation. From those answers the system calculates a score for each of the six axes, an overall index, and your most exposed axis. I also record the date of your submission and whether your report has been sent.
I do not ask for your name.
Why. To produce your assessment and email it to you, and to decide whether there is a basis for a conversation.
Legal basis. Article 6(1)(b) of the GDPR, steps taken at your request before entering into a contract, for producing and sending your assessment. Article 6(1)(f), my legitimate interest in developing my business, for any follow-up.
How the scoring works. Your scores are calculated automatically from your answers using a fixed method. This produces an assessment, not a decision about you. Nothing here has a legal effect on you or affects you in a similarly significant way, so there is no automated decision-making of the kind described in Article 22.
A note on free text. Where a question lets you write freely, please share only what is relevant to your business situation. There is no need to include personal details about yourself or anyone else.
What I add later. If a submission leads to a conversation, I usually add your name, role, company and our correspondence to my records. That is covered under "My records" below.
What I record about fit. I record my own view of whether there is a fit, and what stage our conversation has reached. If you ask me for a copy of your data, you will receive that too.
Base Case, the newsletter
What I collect. Your email address, and your name if you give it. My newsletter provider records whether messages were delivered and opened.
Why. To send you the newsletter.
Legal basis. Article 6(1)(a), your consent.
You can withdraw consent at any time using the unsubscribe link in any message, or by emailing me. Withdrawing does not affect anything sent before you withdrew.
Email and booking a conversation
What I collect. Your email address, whatever you write to me, and, if you book a call, the details you enter into the booking form and the time you choose.
Why. To reply to you and to hold the conversation.
Legal basis. Article 6(1)(b) where you are asking about working together. Article 6(1)(f), my legitimate interest in responding to enquiries, otherwise.
Clients
What I collect. Contact details for you and your colleagues, whatever information you share with me during the work, and billing information.
Why. To carry out the engagement and to meet my legal and accounting obligations.
Legal basis. Article 6(1)(b), performance of our contract. Article 6(1)(c), legal obligation, for invoicing and accounting records.
What you share with me during an engagement is confidential. It is not disclosed to anyone else, apart from the service providers listed below in the ordinary course of running the business.
My records
What I collect. Name, role, company, contact details, a record of our conversations, and my notes on whether there might be a fit.
Why. To keep track of conversations and avoid asking you the same things twice.
Legal basis. Article 6(1)(f), my legitimate interest in developing my business. I have assessed that this does not override your rights: the information is limited to a business context, it is not used for automated profiling, and you can object at any time.
Visiting this site
My hosting provider records technical information such as your IP address, browser type and the pages requested, in server logs, to keep the site running and secure. The legal basis is Article 6(1)(f), my legitimate interest in operating a secure website.
This site does not use analytics. It sets no cookies and does not track you.
Who else handles your data
Each provider below processes personal data on my instructions under a data processing agreement.
| Provider | What it does | Where |
|---|---|---|
| Supabase | Stores Datum submissions | Data stored in Frankfurt, Germany |
| Vercel | Hosts this website | United States, global network |
| Buttondown | Sends the newsletter | United States |
| Calendly | Handles booking | United States |
| Notion | Holds my records of contacts and conversations | United States |
| Microsoft | Email and document storage | European Union |
Where a provider is outside the European Economic Area, the transfer is made under the EU-US Data Privacy Framework where that provider is certified, and under Standard Contractual Clauses approved by the European Commission under Article 46 of the GDPR.
I do not sell your data. I do not share it with anyone for their own marketing.
How long I keep it
| Data | Period |
|---|---|
| Datum submissions that do not lead to a conversation | 24 months from submission |
| Datum submissions that do lead to a conversation | Kept as a contact record, see below |
| Newsletter subscribers | Until you unsubscribe, then deleted within 30 days, apart from a minimal record that keeps you off the list |
| Email correspondence | 24 months from the last message, unless it forms part of an engagement |
| My records of contacts and conversations | 36 months from our last meaningful contact |
| Client records | For the duration of the engagement, then as required by law |
| Invoices and accounting records | 8 years, as required by Hungarian accounting law |
| Server logs | A short operational period set by my hosting provider for security and reliability |
Your rights
You have the right to:
- access the personal data I hold about you, and receive a copy
- correct anything wrong or incomplete
- erase your data, where the law allows
- restrict how I use it, in certain circumstances
- receive it in a portable format, where I process it by automated means on the basis of consent or a contract
- object to processing based on legitimate interests, at any time
- withdraw consent at any time where consent is the basis, without affecting anything done before
Email carlos@stratly.io to exercise any of these. I will respond within one month. If a request is complex I may extend that by two further months, and I will tell you if that happens and why. There is no charge unless a request is clearly unfounded or excessive.
Complaints
If you think I have handled your data wrongly, tell me first and I will try to put it right.
You can also complain to the Hungarian supervisory authority:
Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)
1055 Budapest, Falk Miksa utca 9-11, Hungary
Postal address: 1363 Budapest, Pf.: 9
ugyfelszolgalat@naih.hu
+36 (1) 391 1400
naih.hu
If you live or work in another EEA country, you can complain to the authority there instead.
Cookies
This site sets no cookies and uses no analytics or tracking of any kind.
If you follow a link to book a conversation or to subscribe to the newsletter, you leave this site and the cookie practices of that service apply.
Changes
If I change how I handle personal data, I will update this notice and change the date at the top. Where a change is significant and affects you directly, I will tell you.