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Cookie & Data Protection Policy

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Last updated: February 2026

1. Introduction

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This Cookie & Data Protection Policy explains how Strategese (“we,” “us,” or “our”) uses cookies and similar tracking technologies on our website www.strategese.com, and how we protect your personal data in accordance with the General Data Protection Regulation (GDPR) and the Dutch Telecommunications Act (Telecommunicatiewet).

Strategese is operated by Lerato Tsotetsi, a sole proprietor registered in Amsterdam, the Netherlands (KVK: 90992296). We act as the data controller for personal data collected through this website.

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2. What Are Cookies?

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Cookies are small text files that can be used by websites to make a user’s experience more efficient. The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies, we need your permission.

This site uses different types of cookies. Some cookies are placed by third-party services that appear on our pages. You can at any time change or withdraw your consent from the Cookie Declaration on our website.

Learn more about who we are, how you can contact us, and how we process personal data in our Privacy Policy (www.strategese.com/privacy). Please state your consent ID and date when you contact us regarding your consent.

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3. Types of Cookies We Use

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3.1 Necessary Cookies

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. These cookies do not require your consent.

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3.2 Preference Cookies

Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. These cookies require your consent.

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3.3 Statistics Cookies

Statistics cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously. We use these insights to improve our website and services. These cookies require your consent.

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3.4 Marketing Cookies

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers. These cookies require your consent.

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3.5 Unclassified Cookies

Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies. These cookies require your consent.

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‍4. Managing Your Cookie Preferences

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When you first visit our website, you will be presented with a cookie consent banner. You can choose to accept all cookies, select specific categories, or decline non-essential cookies entirely.

You can change or withdraw your consent at any time by clicking the cookie settings link in the footer of our website, or by visiting the Cookie Declaration page.

You can also control cookies through your browser settings. Most browsers allow you to refuse cookies, delete cookies, or be notified when a cookie is set. Please note that if you disable all cookies, some features of our website may not function correctly.

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4.1 How to Manage Cookies in Your Browser

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  • Google Chrome: Settings → Privacy and Security → Cookies and other site data
  • Mozilla Firefox: Settings → Privacy & Security → Cookies and Site Data
  • Safari: Preferences → Privacy → Manage Website Data
  • Microsoft Edge: Settings → Cookies and site permissions
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5. Data Protection

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5.1 Data Controller

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The data controller for personal data collected through this website is:

Lerato Tsotetsi, trading as Strategese

KVK: 90992296

BTW: NL004856955B43

Email: hello@strategese.com

Website: www.strategese.com

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5.2 What Personal Data We Collect

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Through this website and our services, we may collect the following personal data:

  • Contact form submissions: name, email address, company name, message content.
  • Intake form submissions: name, email, company name, brand information, business goals, and other information you provide.
  • Consultation bookings: name, email, scheduling information.
  • Analytics data: IP address (anonymised), browser type, device type, pages visited, referral source, time on site.
  • Cookie data: as described in Section 3 above.

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5.3 Legal Basis for Processing

We process your personal data on the following legal bases under Article 6 of the GDPR:

  • Consent (Art. 6(1)(a)): For non-essential cookies, marketing communications, and form submissions.
  • Contractual necessity (Art. 6(1)(b)): For processing data needed to deliver consulting services you have engaged us for.
  • Legitimate interest (Art. 6(1)(f)): For website analytics (anonymised), improving our services, and business development.
  • Legal obligation (Art. 6(1)(c)): For record-keeping required by Dutch tax and commercial law.

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5.4 How We Use Your Data

We use your personal data to:

  • Respond to enquiries submitted through our contact form.
  • Process intake forms and prepare for consultations.
  • Deliver consulting services as agreed in our Consulting Agreement.
  • Send project-related communications (timelines, invoices, deliverables).
  • Improve our website and services based on anonymised analytics.
  • Comply with legal and tax obligations.

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5.5 Who We Share Your Data With

We do not sell your personal data. We may share your data with the following categories of recipients, only to the extent necessary:

  • Hosting and website: Webflow (website hosting), Cloudflare (CDN and security).
  • Analytics: Google Analytics (anonymised website usage data).
  • Cookie management: Cookiebot (consent management).
  • Communication: Google Workspace (email), Calendly or similar (scheduling).
  • Payment: ABN AMRO (bank transfers). We do not store payment card details.‍
  • Tax and legal: Our accountant and legal advisors, as required by Dutch law.
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5.6 International Data Transfers

Some of our service providers (such as Google and Webflow) may process data outside the European Economic Area (EEA). Where this occurs, we ensure appropriate safeguards are in place, including EU Standard Contractual Clauses (SCCs) and adequacy decisions by the European Commission.

5.7 Data Retention

We retain your personal data only for as long as necessary for the purposes described in this policy:

  • Contact form submissions: Deleted within 12 months if no engagement follows.
  • Intake form data: Retained for the duration of the engagement, then archived for 5 years (legal requirement).
  • Project data: Retained for 5 years after project completion, in accordance with Dutch tax law (Article 52 AWR).
  • Analytics data: Anonymised and aggregated. Individual data retained per cookie expiry periods listed in Section 3.
  • Cookie consent records: Retained for the duration of your consent (up to 12 months), then renewed.

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5.8 Your Rights Under GDPR

Under the GDPR, you have the following rights regarding your personal data:

  • Right of access (Art. 15): You can request a copy of the personal data we hold about you.
  • Right to rectification (Art. 16): You can ask us to correct inaccurate or incomplete data.
  • Right to erasure (Art. 17): You can ask us to delete your data, subject to legal retention obligations.
  • Right to restrict processing (Art. 18): You can ask us to limit how we use your data.
  • Right to data portability (Art. 20): You can request your data in a structured, commonly used format.
  • Right to object (Art. 21): You can object to processing based on legitimate interest.
  • Right to withdraw consent: You can withdraw consent at any time without affecting the lawfulness of prior processing.

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To exercise any of these rights, email us at hello@strategese.com. We will respond within 30 days.

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5.9 Right to Lodge a Complaint

If you believe we have not handled your personal data in accordance with the GDPR, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):

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Autoriteit Persoonsgegevens

Bezuidenhoutseweg 30

2594 AV The Hague

The Netherlands

Website: www.autoriteitpersoonsgegevens.nl

Phone: +31 70 888 85 00

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6. Data Security

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We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or destruction, including:

  • SSL/TLS encryption on all website pages.
  • Secure hosting through Webflow and Cloudflare.
  • Access controls on all tools and platforms we use.
  • Regular review of data processing activities.
  • Confidentiality obligations in our Consulting Agreement and General Terms and Conditions.

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7. Third-Party Links

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Our website may contain links to third-party websites (e.g., social media profiles, scheduling tools). We are not responsible for the privacy practices of these websites. We encourage you to read their privacy policies before providing any personal data.

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8. Changes to This Policy

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We may update this Cookie & Data Protection Policy from time to time. The “Last updated” date at the top of this page indicates the most recent revision. If we make material changes, we will notify you via our website or by updating the cookie consent banner.

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9. Cookie Declaration

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10. Contact

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If you have any questions about this policy, your personal data, or how we use cookies, please contact us:

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Lerato Tsotetsi

trading as Strategese

Email: hello@strategese.com

Website: www.strategese.com

KVK: 90992296

BTW: NL004856955B43

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