Privacy Policy

Last updated: 2 March 2026

1. Who we are

Stroma Consulting (Pty) Ltd (Reg. 2026/076918/07) is a South African consultancy specialising in web performance diagnostics and advisory, based in Johannesburg, Gauteng, South Africa. Full registered address available on written request to hello@stroma.design.

In this policy, "Stroma", "we" and "us" refer to Stroma Consulting (Pty) Ltd.

2. What personal information we collect

When you submit a Snapshot request through our website, we collect the following:

Required fields:

• Your name
• Email address
• Website URL
• Your primary market/region
• Business vertical

Optional fields (if you choose to provide them):

• Company name
• Your role
• How you found us
• Preferred currency
• Monthly website sessions
• Average order value
• Overall conversion rate
• Desktop and mobile conversion rates

Providing the required fields is necessary to generate and deliver your report. Your name and email allow us to address and send the report. Your URL is the site we analyse. Your market/region and business vertical determine which device tiers, networks, data costs and industry benchmarks we test against. If you do not provide these, we cannot process your request. All other fields are voluntary. Omitting optional business metrics means we will use industry benchmarks instead of your specific data, which may reduce the precision of the revenue-impact estimates in your report.

We do not collect passwords, payment details or government-issued identifiers.

3. Why we collect it

Your information is used to:

• Generate your Snapshot report, including performance analysis and revenue-impact modelling tailored to your market and vertical
• Deliver the completed report to you by email
• Notify our team internally so we can review and quality-check your report before delivery
• Produce anonymised, aggregate industry benchmarks and insights (no personal information or identifiable details are included in published material)

We do not use your information for marketing, profiling or automated decision-making unless you separately opt in to receive communications from us.

4. Legal basis for processing

Under the Protection of Personal Information Act (POPIA), we process your personal information on the following grounds:

• Consent: by submitting the request form, you voluntarily provide your information for the stated purpose
• Legitimate interest: internal workflow notifications to ensure timely report delivery, and production of anonymised aggregate benchmarks and industry insights. This processing is necessary for pursuing the legitimate interests of the responsible party (POPIA Section 11(1)(f))

5. Where your data is stored

Your data is processed and stored using the following services:

These services are provided by Google LLC (United States) and Resend Inc (United States). Your data may be processed outside of South Africa. Both providers maintain their own security and privacy practices. Google's privacy policy is available at policies.google.com/privacy and Resend's at resend.com/legal/privacy-policy.

6. International users and the GDPR

If you are based in the European Economic Area (EEA), your personal data is protected under the General Data Protection Regulation (GDPR) in addition to POPIA. The legal basis for processing is consent (Article 6(1)(a)) and legitimate interest (Article 6(1)(f)).

Your data is transferred to the United States via Google LLC and Resend Inc. Google participates in the EU-US Data Privacy Framework. For Resend, transfers are governed by Standard Contractual Clauses.

In addition to the rights listed under POPIA below, EEA residents have the right to lodge a complaint with their local data protection supervisory authority and the right to data portability.

7. Third-party data sources used in your report

To generate your Snapshot, we query the following public data sources using only your submitted URL (no personal data is shared with these services):

• Google PageSpeed Insights API (lab performance metrics)
• Google Chrome UX Report API (real-user field metrics)
• Google BigQuery (industry benchmark data)

All analysis is performed by our own deterministic software. No personal data is sent to any artificial intelligence or large language model service.

8. Who has access to your data

Access to your submitted information is limited to the Stroma founder and any authorised team members involved in report generation and delivery. We do not sell, rent or share your personal information with third parties for their own purposes.

9. Data retention

We retain your submission data and report files for the duration of our business relationship plus 12 months. After this period, or at any time upon your request, we will delete your personal information from our systems (Google Sheets, Google Drive and email records).

10. Cookies and tracking

We use Google Tag Manager and Google Analytics to understand how visitors interact with our website. This involves the use of cookies to collect anonymised information about your visit, such as the pages you view and the time spent on the site. This data helps us improve our service and user experience.

All fonts and assets remain self-hosted on our servers to minimise third-party requests where possible.

11. Your rights under POPIA

As a data subject under the Protection of Personal Information Act, you have the right to:

• Confirmation of whether we hold personal information about you
• Access the personal information we hold about you
• Correct any inaccurate or incomplete information
• Delete your personal information from our records
• Object to the processing of your personal information
• Withdraw consent at any time

To exercise any of these rights, email hello@stroma.design. We will acknowledge your request within 7 days and respond substantively within 30 days.

If you believe we have not handled your information appropriately, you may lodge a complaint with the Information Regulator of South Africa:

12. Changes to this policy

We may update this policy from time to time. Material changes will be noted on this page with an updated date. Continued use of the site after changes constitutes acceptance of the revised policy.

13. Contact & Information Officer

For any questions about this policy, how we handle your data, or to contact our Information Officer:

14. PAIA Manual

In accordance with the Promotion of Access to Information Act (PAIA), our PAIA Manual is available upon request by contacting hello@stroma.design.