Strata Privacy Policy

Version

2026-10-03-draft

Effective

2026-10-03

Provider

Racelogic Limited (company no. 02743719)

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1. Who we are

1. This notice explains how Racelogic Limited (“Racelogic”, “we”) handles personal data in connection with Strata: the website at strata.stream, the dashboard, the Strata software on encoders and other devices, and our receivers and relays.

2. For the personal data described in section 3 we are the controller. Contact us about anything in this notice at privacy@strata.stream, or write to Racelogic Limited, Unit 10, Swan Business Centre, Osier Way, Buckingham, MK18 1TB, United Kingdom.

3. Data protection officer. [To be completed: confirm whether Racelogic has appointed a data protection officer; if so, give their contact details here].

4. EU representative. Because we are established in the United Kingdom and offer Strata to people in the European Union, our representative in the EU under Article 27 of the EU GDPR is [To be completed: name and address of the EU Article 27 representative (not yet appointed)].

2. Footage and other content: when we act for you

1. When you stream with Strata, the video and audio you send, the recordings we make of it, and the telemetry and logs of each run may contain personal data about the people who appear in or are heard in the footage.

2. If you use Strata for a business, your organisation is the controller of that content and we are its processor. We process it only on your organisation’s instructions, as set out in our Data Processing Addendum. Questions about footage that a Strata customer has recorded should go to that customer; if you send them to us, we will pass them on.

3. If you use Strata as a consumer, we process your content only to provide the Service to you, as your settings say, and on the retention schedule in section 6.

3. What we collect, why, and on what basis

UK and EU data protection law requires us to have a lawful basis for each use of personal data. Ours are: contract (we need it to provide Strata to you), legitimate interests (we need it to run Strata securely and reliably, and those interests are not outweighed by yours), legal obligation (the law requires it) and consent (you chose to give it). Section 6 says how long we keep each kind of data.

1. Card details. Stripe collects your card or other payment details directly. We never see or store them.

2. Cell identifiers. The cell ID and eNodeB ID your modems report can indicate roughly where a device was when it streamed. We collect them to understand the mobile networks your streams use, not to locate you, and they are kept with the run on the schedule in section 6.

3. Modem settings pages. If you open a modem’s own settings page through the dashboard, we relay the traffic between your browser and the modem. We do not store what passes through.

4. Google user data. When you connect a YouTube channel, Strata’s use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. We use it only to create and manage broadcasts you ask for, we do not transfer it to anyone else except as needed to provide that, and no person at Racelogic reads it unless you ask us to for support or the law requires it. You can disconnect the channel in Strata, or revoke our access at myaccount.google.com/permissions.

5. No selling, no advertising, no profiling. We do not sell or rent personal data, share it for cross-context behavioural advertising, or build advertising profiles. We use no analytics or advertising cookies (see Cookies and Local Storage).

6. No automated decisions. We do not make decisions about you based solely on automated processing that have legal or similarly significant effects. The automatic checks Strata does run, such as declining to start a new stream when your organisation has reached its spend cap, apply your plan and the settings your admins chose.

7. If you do not give us data. Most of the data above is needed to provide Strata. Without an email address we cannot create an account, and without device telemetry we cannot run a stream.

4. Who we share it with

1. Service providers (processors) that host and operate Strata for us, under contracts that require them to protect the data and use it only on our instructions. They are listed, with what they do and where, in Sub-processors.

2. Stripe processes payments as an independent controller, under its own privacy policy.

3. Google acts as an independent controller when you sign in with Google or connect a YouTube channel, under the Google Privacy Policy.

4. The destinations you choose. When you stream to YouTube or another destination, we send your stream there because you asked us to; the operator of that destination handles it under its own terms.

5. Other members of your organisation can see the organisation’s devices, streams and recordings according to their role, and admins can see its members.

6. Authorities and others where the law requires, or where it is needed to establish or defend legal claims, prevent fraud, or protect anyone’s safety.

7. A buyer of the business. If Strata or Racelogic is sold or reorganised, personal data may transfer to the new owner, who must continue to protect it as this notice describes.

5. International transfers

1. We are based in the United Kingdom. Strata’s servers are in the European Economic Area (Germany and Finland) [To be completed: update if Strata moves to Google Cloud’s London region], which the UK recognises as providing adequate protection. Personal data of people in the EU is transferred to the UK under the European Commission’s adequacy decision for the UK.

2. Some of our service providers are in, or may access data from, the United States or other countries. Where those countries are not recognised as adequate, we protect the transfer with:

   • the EU–US Data Privacy Framework and its UK Extension, where the provider is certified under it; or otherwise
   • the EU Standard Contractual Clauses, together with the UK Addendum to them, or the UK International Data Transfer Agreement (IDTA).

   Sub-processors says which mechanism applies to each provider. Contact privacy@strata.stream for a copy of the relevant safeguards.

6. How long we keep it

7. Your rights, and how to use them

You have the following rights over your personal data. You can use most of them yourself in the dashboard, straight away and without asking us.

1. You can also make any request by emailing privacy@strata.stream. We will answer within one month, may ask you to confirm your identity, and will not charge you unless a request is manifestly unfounded or excessive.

2. If you are a member of an organisation, its admins control the organisation’s data (its devices, streams and recordings). Deleting your account removes you from the organisation but does not delete the organisation’s recordings.

8. Complaints

1. Please tell us first at privacy@strata.stream and we will try to put things right.

2. You have the right to complain to a data protection supervisory authority:

   • in the UK, the Information Commissioner’s Office: ico.org.uk/make-a-complaint, 0303 123 1113;
   • in the EU, the supervisory authority of the country where you live or work, or where you think the problem happened. The European Data Protection Board lists them at edpb.europa.eu.

9. For people in the United States

1. We do not sell personal information or share it for cross-context behavioural advertising, and we have not done so in the past 12 months. We do not use or disclose sensitive personal information to infer characteristics about you.

2. The categories of personal information we collect, their sources, why we use them and who we disclose them to are set out in sections 3 and 4. In the terms of US state privacy laws they are identifiers (such as email and IP address), commercial information (your plan and usage), internet or network activity (sessions, logs, device telemetry), and approximate location derived from cell identifiers.

3. Depending on the state you live in, you may have the right to know what personal information we hold about you, to get a copy, to have it corrected or deleted, and not to be discriminated against for using these rights. Use them as described in section 7, or by emailing privacy@strata.stream. An authorised agent may make a request for you; we may ask them for proof of authority and ask you to confirm your identity. If we refuse a request, you can appeal by replying to our answer.

10. Children

Strata is not directed at children. You must be 18 or over to have an account. If you believe a child has given us personal data, contact privacy@strata.stream and we will delete it.

11. Cookies and local storage

We use one strictly necessary cookie, to keep you signed in, and store a few display preferences in your browser. We use no analytics, advertising or tracking cookies, so we do not show a cookie banner. Details are in Cookies and Local Storage.

12. Security

We protect personal data with measures that include encryption in transit (TLS) for the website, dashboard and device connections, encryption of every stream between encoder and receiver, encryption of stream keys and access tokens at rest, Argon2id password hashing, encrypted backups, separation of each organisation’s data, and an activity log of security-relevant actions. Racelogic staff have no access through Strata to customers’ footage, recordings or devices. The Data Processing Addendum describes these measures in more detail.

13. Changes to this notice

We will update this notice when our practices change. Each version has a version number and an effective date. If a change is significant we will tell you by email or in the dashboard before it takes effect.