Date of entry into force: January 1st, 2022

Stratego Services SRL, route de Longwy 370, L-1940 Luxembourg, Luxembourg (“Stratego”) respects your privacy and is committed to protecting your personal data.

This privacy notice (the “Privacy Notice”) relates to all personal data that you provide to Stratego in the context of your use of the Stratego website. This Privacy Notice provides you with information on how Stratego collects and processes your personal data. By using the Stratego website and services provided by Stratego, you consent to the data practices described in this Privacy Notice.

What kind of personal data do we collect?

Personal data means any information about an individual from which that person can be identified such as:

• name, address, email address, telephone number and other contact information

• date and place of birth

• nationality

• gender

• employment details

• marital status

• copies of identity documents (such as passport, national ID cart, driver’s license, employee identification numbers)

• source of wealth

• utility bills, bank statements

• tax residency

• details of shareholdings and other assets which are legally or beneficially owned by the data subject

• details of people and organisations which may be connected to the data subject (by family or otherwise)

Please note that the list is not exhaustive and that Stratego may also collect and process personal data to extent this is useful or necessary for the provision of our services.

How does Stratego collect personal data?

Stratego may collect or obtain personal data directly from you:

We collect personal data directly from (prospective) clients, business partners and intermediaries for the purposes of entering into a contract or a service agreement and/or to meet certain legal requirements.

Stratego may collect or obtain personal data from third parties:

We also collect and process personal data from publicly accessible sources such as internet, social networks, World-Check or commercial registers.

Furthermore we may receive personal data from third parties as part of the service we provide to you or to people which are connected to you (including but not limited to organisations in which you have a shareholding or by which you are employed) or in connection with legal requirements that are applicable to us.

Stratego does not intentionally collect any particularly sensitive categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) and, if collected, Stratego does not use or disclose those sensitive personal data without your explicit consent.

Stratego encourages you to review the privacy statements of websites you use to link to Stratego so that you can understand how those websites collect, use and share your information. Stratego is not responsible for the privacy statements or other content on websites outside of the Stratego website.

How do we use your personal data?

Purpose for which Stratego will use your personal data

The majority of the personal data processed by Stratego is necessary for the performance of a contract to which the data subject is a party or to comply with the request of the data subject prior to entering into a contract.

Stratego also processes personal data in order to comply with our legal and regulatory obligations.

We may furthermore process personal data for the purposes of the legitimate business interests pursued by Stratego.

Such legitimate interests include general research and development (including statistical research or as a basis to analyse our current security measures), administration of our business and systems, including IT, billing and invoicing systems or to develop and improve our services or to strengthen our relationship with you.

We may provide you with communications or information regarding our service offering which we think will be interesting for you.

When we process your personal data for our legitimate business interests, or where consent to process personal data was received, we will consider and balance any potential impact on you and your rights under the relevant data protection and any other relevant law. Whenever we process personal data for these purposes you have the right to object to this way of processing.

Transfer and disclosure of personal data

Stratego does not sell, rent or lease personal data collected from the Website to third parties.

Stratego may disclose or transfer personal data to subcontractors, intermediaries or external advisors for the purpose of the proper performance of the services we provide to our clients. It may, for example, disclose or transfer such personal data to third party service providers who provide administrative, computer, payment, data processing, debt collecting or other services. We enter into data processing agreements with such subcontractors to ensure that they process your data, on our behalf, with the same level of security and confidentiality as applied by Stratego.

Stratego may furthermore disclose or transfer personal data when we received your consent to do so. 

Stratego website will disclose your personal data, without notice, only if required to do so by law or if such action is reasonably necessary to: (a) defend claims; (b) protect and defend the rights or property of Stratego; and, (c) act under emergency circumstances to protect the personal safety of users of Stratego, or the public.

As provided for under the applicable data protection laws and regulations, you are entitled to request access, correct or erase your personal data or restrict the processing of your personal data, as well as the right to data portability. To exercise these rights, please contact Stratego at info@stratego.lu.

You also have the right to lodge a complaint with the competent data protection authority, being in Luxembourg the “Commission Nationale pour la Protection des Données (CNPD)”.

Data retention

Stratego will process and store the relevant personal data for the duration of our services or for the duration of the business relationship. Stratego may also store the data for as long as it is necessary or required in order to fulfil legal, contractual or statutory obligations and, or for the establishment, exercise or defense of legal claims, and in general where it has a legitimate interest for doing so.

How we protect personal data?

Stratego is committed to ensuring the security of your personal data. Stratego takes appropriate commercially reasonable technical, physical and organisational measures to prevent unauthorised or unlawful processing of your personal data or accidental loss or destruction of your personal data.
Stratego will ensure a level of security suitable to the identified risks and pursuant to applicable Data Protection Laws and, where the processing concerns personal data of EU residents, shall take measures required pursuant to article 32 GDPR.

Employees of Stratego are trained to handle personal data securely and with utmost respect and they will treat your personal data strictly confidential. Staff members shall be authorized to access personal data only to the extent necessary to serve the applicable legitimate purposes for which the data are processed by Stratego and to perform their job.

Stratego will not divulge client information to a third party unless we have received explicit client authorisation or we are required to do so by law.

Change to this notice

Stratego will occasionally update this notice to reflect company and users feedback. Stratego advise you to periodically review this Privacy Notice to keep up to date in relation to how Stratego is protecting your information.

Contact information

Stratego welcomes your comments regarding this Privacy Notice. If you believe that Stratego has not adhered to this Privacy Notice, please contact Stratego GDPR Manager, Johel Blanchard, via the general email address info@stratego.lu.

We will use commercially reasonable efforts to promptly determine and remedy the problem.