COOKIE POLICY

Effective Date: 1 July 2026

Version 1.0

Document Title	Cookie Policy
Issued By	Strath Africa (Strath Africa Chambers)
Website	www.strathafrica.com
Jurisdiction	Republic of Rwanda (primary)
Governing Law	Rwanda Data Protection Law No. 058/2021 & ICT Regulations
Contact	info@strathafrica.com \| +250 781 455 033
Last Updated	July 2026

1. Introduction

This Cookie Policy explains how Strath Africa (“we”, “us”, “our”, or “the Firm”) uses cookies and similar tracking technologies on our website at www.strathafrica.com (the “Website”). It should be read together with our Privacy Policy, which is available at www.strathafrica.com/privacy-policy.

By continuing to use our Website after being presented with a cookie notice, you consent to the use of cookies as described in this Policy, except where consent is not required (e.g. for strictly necessary cookies).

We are committed to transparency about the technologies we use and your right to control them, in accordance with Rwanda’s Law No. 058/2021 Relating to the Protection of Personal Data and Privacy (“RPDP Law”) and applicable guidance from the National Cyber Security Authority (NCSA).

2. What Are Cookies?

A cookie is a small text file placed on your device (computer, smartphone, tablet, or other internet-enabled device) when you visit a website. Cookies are widely used to make websites work efficiently, to improve user experience, and to provide information to website operators.

Cookies and similar technologies include:

Cookies: Small text files stored in your browser or device storage.
Web beacons / pixel tags: Tiny transparent images embedded in web pages or emails that track whether a page or email has been viewed.
Local storage objects (LSOs): Data stored in your browser beyond the standard cookie lifespan.
Fingerprinting: Techniques that identify a device based on its configuration, browser settings, and installed plugins — used only in limited circumstances for security purposes.
Session replay tools: Technologies that record mouse movements and clicks to help us understand user behaviour and improve usability.

For simplicity, we refer to all of these collectively as “cookies” throughout this Policy.

3. Types of Cookies We Use

We categorise the cookies on our Website as follows:

Category	Sub-type	Purpose	Consent Required?
Strictly Necessary	Session	Enable core Website functions such as page navigation, secure areas, and form submissions. The Website cannot function properly without these cookies.	No — exempt
Strictly Necessary	Security	Detect and prevent fraudulent activity, bot traffic, and cyber attacks. Support HTTPS connections and CSRF protection.	No — exempt
Performance & Analytics	Analytics	Collect aggregated, anonymous data on how visitors use our Website (pages visited, time on page, error messages, traffic sources). Help us improve Website content and structure.	Yes — opt-in
Performance & Analytics	A/B Testing	Test different layouts or content versions to determine which performs better for users.	Yes — opt-in
Functional	Preferences	Remember your settings and preferences (e.g. language, region, cookie consent choices) so you do not have to re-enter them on return visits.	Yes — opt-in
Functional	Chat / Support	Support live chat and contact tools embedded in our Website to help you communicate with our team.	Yes — opt-in
Marketing & Targeting	Advertising	Deliver relevant content and advertisements based on your interests across third-party platforms. Track whether you have engaged with our marketing communications.	Yes — opt-in
Marketing & Targeting	Retargeting	Enable us to show our content to users who have previously visited our Website, on third-party platforms such as LinkedIn or Google.	Yes — opt-in

4. Specific Cookies in Use

The table below lists the principal cookies currently deployed on our Website. This list is updated periodically as our technology stack changes.

Cookie Name	Provider	Category	Purpose	Expiry
PHPSESSID	Strath Africa	Strictly Necessary	Maintains your session state across page requests.	Session
csrf_token	Strath Africa	Strictly Necessary	Prevents cross-site request forgery attacks on forms.	Session
cookie_consent	Strath Africa	Strictly Necessary	Stores your cookie consent preferences.	12 months
_ga	Google Analytics	Performance	Distinguishes unique Website users for analytics reporting.	24 months
_ga_XXXXXX	Google Analytics	Performance	Stores and counts page views for GA4 analytics.	24 months
_gid	Google Analytics	Performance	Distinguishes users; expires quickly to reduce data retention.	24 hours
lang	Strath Africa	Functional	Stores your selected language preference.	12 months
_fbp	Meta (Facebook)	Marketing	Tracks visits across websites to deliver targeted Meta advertisements.	90 days
li_fat_id	LinkedIn	Marketing	LinkedIn first-party ad tracking cookie for conversion tracking.	30 days
_gcl_au	Google Ads	Marketing	Used by Google AdSense for experimenting with advertising efficiency.	90 days

Note: Cookie names and durations may vary depending on your browser and device. Third-party cookies are subject to the privacy policies of those third parties.

5. Third-Party Cookies & Services

Some cookies on our Website are set by third-party services. We do not control these cookies and their use is governed by the respective third party’s privacy policy. Third-party services we currently use include:

Google Analytics (Google LLC)	Website traffic analysis and usage reporting. Privacy policy: policies.google.com/privacy
Google Ads / Google Tag Manager	Advertising conversion tracking and tag management. Privacy policy: policies.google.com/privacy
Meta Pixel (Meta Platforms Inc.)	Social media advertising and retargeting on Facebook and Instagram. Privacy policy: facebook.com/privacy/policy
LinkedIn Insight Tag	Professional audience analytics and LinkedIn ad conversion tracking. Privacy policy: linkedin.com/legal/privacy-policy
Elementor	Website builder plugin that may set functional cookies for page rendering and form handling.
Live Chat Provider	Any embedded chat tool used to facilitate client communications — refer to the specific provider’s policy.

We periodically review our third-party integrations. Where a new third party sets cookies that require your consent, we update this Policy and our cookie consent tool accordingly.

6. First-Party vs Third-Party Cookies

First-party cookies are set directly by Strath Africa (the domain owner of www.strathafrica.com) and are used solely in connection with our own services. Third-party cookies are set by external service providers whose technologies are integrated into our Website. Both types are subject to the consent requirements described in this Policy, except where exempted as strictly necessary.

7. Session vs Persistent Cookies

Session Cookies	Temporary cookies that exist only for the duration of your browser session. They are automatically deleted when you close your browser. Used primarily for security and navigation purposes.
Persistent Cookies	Cookies that remain on your device for a set period (or until manually deleted). They enable the Website to recognise you on return visits and remember your preferences. Durations range from 24 hours to 24 months depending on purpose.

8. Your Cookie Choices & Controls

You have several options to manage cookies:

8.1 Cookie Consent Banner

When you first visit our Website, a cookie consent banner will appear. You may:

Accept All — to consent to all categories of cookies described in this Policy.
Reject Non-Essential — to permit only strictly necessary cookies.
Manage Preferences — to make granular choices by cookie category.

You can change your preferences at any time by clicking the “Cookie Settings” link in the footer of any page on our Website.

8.2 Browser Settings

Most browsers allow you to control cookies through their settings. You can typically:

Block all cookies (note: this will prevent you from using parts of our Website).
Delete existing cookies.
Set your browser to alert you when cookies are being set.

Browser-specific guidance is available at:

Google Chrome: support.google.com/chrome/answer/95647
Mozilla Firefox: support.mozilla.org/kb/enable-and-disable-cookies
Safari: support.apple.com/guide/safari/manage-cookies
Microsoft Edge: support.microsoft.com/microsoft-edge/cookies

8.3 Opt-Out Tools for Third-Party Advertising

You can opt out of interest-based advertising from participating companies through:

Google: adssettings.google.com
Meta: facebook.com/adpreferences
LinkedIn: linkedin.com/psettings/guest-controls/retargeting-opt-out
Your Online Choices (EU/Africa digital advertising): youronlinechoices.com

8.4 Do Not Track

Some browsers transmit “Do Not Track” (DNT) signals to websites. Our Website currently does not alter its behaviour in response to DNT signals as there is no universally accepted standard for how websites should respond to such signals. We will review this position as standards develop.

9. Legal Basis for Cookie Processing

Our use of cookies is grounded in the following legal bases under the RPDP Law:

Cookie Category	Legal Basis	Notes
Strictly Necessary	Legitimate Interests / Legal Obligation	No consent required. Processing is essential to deliver a functioning, secure website.
Performance & Analytics	Consent	Data is anonymised or aggregated where possible. You may opt out at any time.
Functional	Consent	Enhances your experience but is not essential. You may opt out without losing core Website access.
Marketing & Targeting	Consent	Requires explicit opt-in. Refusal or withdrawal does not affect access to our Website or services.

10. International Data Transfers via Cookies

Some third-party cookies may result in personal data being transferred to and processed in countries outside Rwanda or Kenya, including the United States and the European Union. Where such transfers occur, we rely on appropriate safeguards including:

Standard contractual clauses approved by competent data protection authorities.
Adequacy decisions, where applicable.
Certification mechanisms recognised under applicable law.

We ensure that any such transfers comply with the RPDP Law and that your data receives a level of protection equivalent to that provided under Rwandan law.

11. Data Collected via Cookies — Retention Periods

Data collected through cookies is retained for the shortest period necessary to fulfil the relevant purpose:

Strictly Necessary cookies	Duration of session, or up to 12 months for consent records
Performance / Analytics data	Up to 26 months (in line with Google Analytics defaults, reducible in settings)
Functional preference data	Up to 12 months, refreshed on each visit
Marketing / targeting data	Up to 90 days per cookie; aggregated reporting data may be retained longer in anonymised form
Cookie consent records	3 years, to demonstrate compliance with consent obligations

12. Children

Our Website is not directed at children under the age of 16. We do not knowingly use cookies to collect personal data from children. If you believe that a child under 16 has provided personal data via our Website, please contact us at info@strathafrica.com and we will take appropriate steps to delete that information.

13. Updates to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in the cookies we use, changes in the law, or updates to our Website’s functionality. The most recent version will always be available at www.strathafrica.com/cookie-policy, with the updated effective date shown at the top of the document.

Where changes are material, we will notify you through a prominent notice on the Website or, where appropriate, by email. Where renewed consent is required (e.g. for new categories of non-essential cookies), our cookie consent tool will prompt you on your next visit.

14. Contact Us

If you have any questions, concerns, or requests relating to this Cookie Policy or our use of cookies, please contact:

Data Protection Contact	Strath Africa — Data Protection Office
Email	info@strathafrica.com
Telephone	+250 781 455 033
Address	1KN Nyarugenge, Kigali, Rwanda
Website	www.strathafrica.com

If you are not satisfied with our response, you have the right to lodge a complaint with Rwanda’s National Cyber Security Authority (NCSA) at www.ncsa.rw.

Issued by Strath Africa

1KN Nyarugenge, Kigali, Rwanda

www.strathafrica.com | privacy@strathafrica.com | +250 781 455 033

COOKIE POLICY