Politique relative aux cookies

Master — Technical And Legal Verification Required Before Publication

Last Updated: [Insert Date]
Version: [Insert Version]

1. Introduction

WAPGlobal.org is the shared official institutional website of Wings of Aid & Peace (WAP).

Wings of Aid & Peace operates through separately registered legal entities in France and Sudan.

This Cookie Policy explains how cookies and similar technologies may be used on WAPGlobal.org, why they may be used, how visitors can manage their preferences, and how responsibility for the related processing is determined.

This Cookie Policy should be read together with:

The cookies and similar technologies described in the final published version of this Policy must correspond to the technologies actually operating on the production website.

2. About Wings of Aid & Peace

Wings of Aid & Peace operates through separately registered legal entities in France and Sudan.

Each entity:

The entities may share:

The shared use of the WAP identity and website does not, by itself, make both legal entities automatically responsible for every cookie, tracker or data-processing activity.

3. WAP Legal Entities

WAP France

Legal Entity Name:

[Insert Exact Registered Legal Name]

Legal Form:

[Insert Verified Legal Form]

Registration Number:

[Insert Offical Registration Number]

Registered Address:

[Insert Official Registered Address]

Country:

France

WAP Sudan

Legal Entity Name:

[Insert Exact Registered Legal Name]

Legal Form / Status:

[Insert Verified Legal Form or Status]

Registration Authority:

[Insert Official Registration Authority]

Registration Number:

[Insert Official Registration Authority]

Registered Address:

[Insert Official Registered Address]

Country:

Sudan

4. Responsibility for Cookies and Similar Technologies

Responsibility for cookies, trackers or similar technologies depends on the actual service and processing arrangement.

Depending on the circumstances:

WAP France may be responsible for a particular technology;
WAP Sudan may be responsible for a particular technology;
One entity may operate the website infrastructure on behalf of the wider WAP institutional website;
The entities may be jointly responsible where they jointly determine the purposes and essential means of a relevant processing activity;
A third-party provider may process information on behalf of a WAP entity; or
A third-party provider may have its own independent legal responsibilities.

The final technical configuration should be reviewed before publication so that the appropriate responsibilities are accurately described.

5. What Are Cookies?

Cookies are small pieces of information that may be stored on or accessed from a user’s device when the user visits a website or uses an online service.

Depending on their purpose, cookies and similar technologies may help:

Operate essential website functions;
Maintain security;
Remember user preferences;
Manage sessions;
Support accessibility;
Measure website performance;
Understand website usage;
Enable approved third-party functionality.

Similar technologies may include other identifiers, local storage mechanisms, pixels or technologies performing comparable functions.

6. Our Approach to Cookies

WAP seeks to use cookies and similar technologies according to the following principles:

Necessity;
Transparency;
Data minimization;
Purpose limitation;
Appropriate user choice;
Security;
Proportionate retention;
Compliance with applicable law.

WAP should not activate optional tracking merely because a plugin or external service makes it available by default.

Only technologies needed for an approved and documented website purpose should be enabled.

7. Consent and Essential Technologies

Some cookies or similar technologies may be necessary for the operation of WAPGlobal.org or for a service expressly requested by the visitor.

Other technologies may require prior consent.

Where applicable law requires consent, the relevant technology should not be activated or accessed before valid consent has been obtained.

Strictly necessary technologies may be used without consent where permitted by applicable law.

The classification of a technology as “necessary” must be based on its actual function rather than the label assigned by a plugin or service provider.

8. Cookie Categories

Cookies are small pieces of information that may be stored on or accessed from a user’s device when the user visits a website or uses an online service.

8.1 Strictly Necessary Cookies

These technologies support functions required for the website or a service requested by the user.

Examples may include:

Website security;
Network management;
Cookie preference storage;
Session management;
Authentication where applicable;
Form security;
Load balancing;
Other essential technical functionality.

They must not be used for unrelated advertising, profiling or unnecessary tracking purposes.

8.2 Preference and Functionality Cookies

These technologies may remember choices made by visitors.

Examples may include:

Whether consent is required should be assessed according to the actual purpose and applicable law.

8.3 Audience Measurement and Analytics

WAP may use analytics technologies to understand website use and performance.

Depending on the technology and configuration, this may include:

Some audience-measurement technologies may qualify for an exemption from prior consent only where all applicable exemption conditions are met.

WAP should not assume that an analytics service is exempt merely because it is used for statistics.

Where the conditions for an exemption are not satisfied, the relevant technology should not be activated before the required consent has been obtained.

8.4 Embedded Media and External Content

WAPGlobal.org may include approved external content such as:

External content may cause third-party technologies to be activated.

Where prior consent is required, the embedded service should remain blocked until the appropriate consent is provided.

Where technically appropriate, visitors may first be shown a placeholder allowing them to choose whether to activate external content.

8.5 Donation and Payment Technologies

Where WAP provides donation functionality, approved fundraising or payment providers may use necessary technologies for purposes such as:

The relevant donation page should identify the WAP legal entity receiving the donation.

Where a payment or fundraising service uses optional tracking beyond what is necessary for the transaction, those technologies should be separately assessed.

8.6 Newsletter and Communication Technologies

Where WAP provides a newsletter or communication subscription service, the relevant provider may use technical mechanisms required to:

Any additional tracking functionality should be assessed separately and should not be activated automatically where consent is required.

8.7 Social Media Technologies

Ordinary links to WAP social-media pages should be distinguished from:

WAP should not enable social-media tracking technologies unless there is an approved purpose and the appropriate legal requirements are satisfied.

8.8 Advertising and Marketing Cookies

WAP should not state that it uses advertising, behavioural targeting or retargeting technologies unless such technologies have actually been approved and implemented.

If WAP does not use advertising tracking, these technologies should remain disabled.

If introduced in the future, the Cookie Policy, consent system and Privacy Policy should be reviewed before activation.

9. Cookie Inventory

The final production website must undergo a technical cookie and tracker review.

The public Cookie Policy should contain an accurate inventory of relevant cookies and technologies.

For each relevant item, WAP should record where appropriate:

Name:

[Verified Cookie / Technology Name]

Provider:

[Verified Provider]

Purpose:

[Verified Purpose]

Category:

[Verified Category]

Duration:

[Verified Duration]

First Party / Third Party:

[Verified Classification]

Consent Required:

[Yes / No / Verified Exemption]

Responsible Entity / Controller Where Relevant:

[Verified Entity or Provider]

The website should not publish invented cookie names, providers or retention periods.

10. First-Party and Third-Party Technologies

A first-party technology is generally associated directly with WAPGlobal.org.

A third-party technology may be provided by an external service integrated into the website.

The distinction does not, by itself, determine whether consent is required.

The purpose, function and applicable legal rules must also be considered.

11. Cookie Banner

Where non-essential technologies are present, WAPGlobal.org should provide an appropriate consent interface.

The first level of the consent interface should clearly explain the main purposes of the technologies concerned.

Where applicable, users should be provided with meaningful options such as:

Accept Optional Cookies

Reject Optional Cookies

Manage Preferences

Accepting optional cookies should not be made artificially easier or more prominent in a way that improperly influences users compared with rejecting them.

The cookie banner must be connected to the actual technical consent mechanism.

12. Rejecting Cookies

Where consent is required, visitors should be able to refuse optional cookies as easily as they can accept them.

A refusal must be technically effective.

Optional technologies that require consent should remain disabled after the user has refused them.

13. No Consent Through Continued Browsing

Merely continuing to browse WAPGlobal.org should not be treated as valid consent for optional cookies or trackers where valid consent is legally required.

Consent should result from a clear affirmative choice.

14. Managing Preferences

Visitors should be able to manage relevant cookie preferences.

The website should provide an accessible mechanism such as:

Cookie Settings

Manage Cookie Preferences

This mechanism should remain reasonably accessible from the website after the visitor’s initial choice.

15. Withdrawal of Consent

Where optional cookies are based on consent, visitors should be able to withdraw consent at any time.

Withdrawing consent should be as straightforward as providing it.

Withdrawal should stop future use of the relevant technologies to the extent technically applicable.

Withdrawal does not affect processing lawfully carried out before consent was withdrawn.

16. Proof and Records of Consent

Where WAP relies on consent for cookies or similar technologies, the website’s consent-management system should be capable of appropriately recording user choices where required.

WAP should be able to demonstrate that a valid consent mechanism was in place.

Consent records should not themselves be retained longer than appropriately necessary.

17. Audience Measurement Exemption

Some audience-measurement technologies may be used without prior consent only where they satisfy the applicable conditions for exemption.

WAP should verify the exact analytics configuration before relying on such an exemption.

Relevant considerations may include whether the technology:

Is strictly limited to audience measurement;
Is used on behalf of the website publisher;
Is limited to the relevant website or service;
Does not improperly combine data with other datasets;
Does not enable unrelated tracking across websites;
Uses appropriate privacy protections;
Applies appropriate retention controls;
Provides required information and objection mechanisms.

If these conditions are not satisfied, the analytics technology should be treated according to the normal consent rules.

18. External Providers

WAP may use external service providers for website functions.

These may include, where actually used:

Hosting;
Security;
Analytics;
Email;
Newsletter management;
Donations;
Payments;
Embedded content;
Forms;
Content delivery;
Other digital services.

WAP should maintain an internal provider register recording relevant data-protection and technical information.

19. Provider Register

The internal provider register should include, where relevant:

Provider name;
Service;
Purpose;
WAP entity using the service;
Categories of data involved;
Cookies or trackers used;
Server or processing location;
Sub-processors;
International transfers;
Retention;
Security arrangements;
Contract / Data Processing Agreement status;
Privacy documentation;
Responsible internal owner.

This internal register does not necessarily need to be published in full.

20. Hosting and Infrastructure

WAP should verify the actual production hosting environment for WAPGlobal.org.

Relevant matters include:

Hosting provider;
Primary server location;
Backup locations;
Content delivery networks;
Security services;
Remote support access;
Sub-processors;
Other technical integrations.

A provider’s country of registration does not by itself prove that all processing takes place in that country.

21. International Data Transfers

Some external technologies may involve access to or transfer of personal data outside the European Economic Area.

Where European data-protection law applies, relevant international transfers should be assessed and appropriate legal safeguards implemented where required.

The WAP Privacy Policy provides additional information about international data transfers.

22. WAP France and WAP Sudan

The use of WAPGlobal.org by both WAP France and WAP Sudan does not automatically mean that website technology data should be shared between the two entities.

Any sharing of personal data generated through cookies or website technologies should have a defined and lawful purpose.

Where access from Sudan or transfer to the Sudanese entity constitutes an international transfer under applicable European data-protection rules, the appropriate transfer requirements should be assessed.

23. Data Generated Through Cookies

Depending on the technology, information generated through cookies or similar technologies may include:

IP address;
Device identifiers;
Browser information;
Technical session information;
Pages viewed;
Time of access;
Website interaction data;
Cookie preferences;
Security information.

Where such information constitutes personal data, it should be handled in accordance with the WAP Privacy Policy.

24. Retention

Cookies and similar technologies should not remain active or retain information longer than appropriate for their defined purpose.

The retention or lifetime of each relevant technology should be verified from the actual production configuration.

WAP should not publish arbitrary or assumed durations.

25. Children and Vulnerable Persons

WAP recognizes the need for heightened care in digital services involving children or vulnerable persons.

Unnecessary tracking technologies should not be used in connection with services specifically directed toward children.

If WAP develops digital services specifically involving children, the privacy and cookie arrangements should undergo an additional review before launch.

26. Website Security Cookies

Security technologies may be necessary to help:

Where a security technology is classified as strictly necessary, its use must remain limited to the relevant essential security purpose.

27. Browser Settings

Visitors may also use browser controls to manage or delete cookies.

Browser settings may allow users to:

Blocking essential cookies may affect certain website functions.

Browser settings operate separately from WAP’s own consent interface.

28. Changes to Website Technologies

WAP may introduce, remove or change website technologies over time.

Before introducing a new technology, WAP should assess:

Purpose;
Necessity;
Data collected;
Responsible entity;
Provider;
Consent requirements;
International transfers;
Security;
Retention.

The Cookie Policy and consent mechanism should be updated where necessary.

29. Changes to This Cookie Policy

WAP may update this Policy to reflect:

Changes in website technologies;
Changes in providers;
Changes in legal requirements;
Changes in WAP's organizational structure;
Changes in consent arrangements;
Improved privacy practices.

The latest approved version should be published on WAPGlobal.org.

Last Updated:

[Insert Date]

Version

[Insert Version]

30. Relationship With Other WAP Legal Documents

This Cookie Policy should be read together with:

Politique de confidentialité

Explains how WAP processes and protects personal data.

Conditions d'utilisation du site Web

Sets out general rules governing use of WAPGlobal.org.

Legal Information / Legal Notice

Provides verified information concerning the WAP legal entities, website publisher and hosting arrangements.

Where a particular online service has additional terms or privacy information, those specific notices may also apply.

31. Contact

Privacy / Data Protection Enquiries

Email:

[Insert Approved Privacy/Data Protection Contact]

General Enquiries

Email:

info@wapglobal.org

Site officiel

WAPGlobal.org

WAP France

Legal Entity Name:

[Insert Exact Registered Legal Name]

Registration Number:

[Insert Official Registration Number]

Registered Address:

[Insert Official Registered Address]

Country:

France

WAP Sudan

Legal Entity Name:

[Insert Exact Registered Legal Name]

Registration Authority:

[Insert Official Registration Number]

Registration Number:

[Insert Official Registration Authority]

Registered Address:

[Insert Official Registered Address]

Country:

Sudan

Cookie Ploicy - Closing ststement

WAP seeks to operate WAPGlobal.org in a transparent and privacy-conscious manner. WAP France and WAP Sudan are separately registered legal entities operating under the shared institutional identity of Wings of Aid & Peace. The shared use of WAPGlobal.org does not automatically make both entities responsible for every cookie, tracker or related processing activity. Cookie and tracking responsibilities should be determined according to the technologies actually used, their purposes, the relevant WAP entity and the applicable legal framework. Optional cookies and similar technologies should not be activated before valid consent where prior consent is legally required.