Privacy Policy
Last updated: 2026-11-05
1. Data Controller
The controller of the personal data collected through this site is New Stratege.
For any question regarding your personal data: newstratege@gmail.com.
2. Data Collected and Purposes
The personal data collected depends on the features you use. The exhaustive list is in the Subprocessors section below, where each recipient indicates precisely what data they process and for what purpose.
3. Legal Basis for Processing
The processing of your data relies on one of the legal bases set out in the applicable personal data protection regulation depending on the context: contract performance, legitimate interest, consent, or legal obligation.
4. Subprocessors and Recipients
To provide this service, we work with third-party subprocessors. Each subprocessor only handles the data strictly required for their task, under a data processing agreement compliant with the applicable regulation.
Vercel Inc.
440 N Barranca Ave #4133, Covina, CA 91723, USA
- Purpose
- Website hosting, serverless functions (Frankfurt region - fra1) and storage of the photos published on the site (Vercel Blob)
- Data processed
- IP addresses
- Server logs
- Private area session cookie
- Photos published on the site
- Retention
- 30 days for logs; photos kept while they are published
- Legal basis
- New Stratege’s legitimate interest in running its website (Togolese Law No. 2019-014)
- Transfer / details
- Standard Contractual Clauses (SCC). US legal entity; the functions run in the EU (Frankfurt)
- More info
- Privacy policyData Processing Agreement (DPA)
Databricks, Inc. (Neon)
160 Spear Street, 13th Floor, San Francisco, CA 94105, USA
- Purpose
- PostgreSQL database hosting
- Data processed
- New Stratege team accounts (name, username, protected password)
- Website texts and contact details
- Retention
- Account lifetime (deletion on request)
- Legal basis
- New Stratege’s legitimate interest in managing its website (Togolese Law No. 2019-014)
- Transfer / details
- Standard Contractual Clauses (SCC). Database hosted in the EU (Frankfurt, aws-eu-central-1 region)
- More info
- Privacy policyData Processing Agreement (DPA)
5. Your Rights
Under the applicable personal data protection regulation, you have the following rights over your data:
- Right of access and rectification
- Right to erasure (right to be forgotten)
- Right to data portability
- Right to object and to restrict processing
- Right to withdraw your consent at any time (when processing is based on consent)
- Right to lodge a complaint with the Togolese data protection authority, the Instance de Protection des Données à Caractère Personnel (IPDCP), created by Law No. 2019-014 on the protection of personal data
To exercise your rights: newstratege@gmail.com. We commit to responding within a maximum of one month.
6. Cookies
By default, this site only uses cookies strictly necessary for its operation (session, preferences). No advertising or profiling cookie is set without your explicit consent.
The website uses no audience measurement and no advertising cookie. Only the private area for the New Stratege team sets a session cookie, which is needed to sign in.
7. Modifications
This policy may be updated to reflect changes to the services and subprocessors used. The last update date is shown at the top of this page. Substantial changes will be notified by email to registered account holders.