1. Introduction
Wings of Aid & Peace (WAP) respects the privacy, dignity and rights of individuals whose personal data may be processed through its website, humanitarian activities, institutional operations and related services.
This Privacy Policy explains how personal data may be collected, used, stored, shared and protected in connection with WAPGlobal.org and relevant WAP activities.
Wings of Aid & Peace operates through separately registered legal entities in France and Sudan.
Each WAP entity has its own legal personality and operates in accordance with the laws and regulatory requirements applicable in its jurisdiction.
WAPGlobal.org serves as the shared official institutional website of Wings of Aid & Peace.
The use of a shared name, logo, institutional identity and website does not, by itself, mean that the WAP entities constitute a single legal person or that both entities are automatically responsible for every processing activity.
The WAP entity responsible for a particular processing activity will be determined according to the actual purpose, context and organization of that activity.
2. Who We Are
WAP — France
Wings of Aid & Peace operates in France through a legal entity registered in accordance with applicable French law.
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
Wings of Aid & Peace operates in Sudan through a separately registered legal entity established in accordance with applicable Sudanese law.
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 Number]
Registered Address:
[Insert Official Registered Address]
Country
Sudan
Shared Institutional Website
Site officiel :
WAPGlobal.org
General Enquiries:
info@wapglobal.org
Partnership Enquiries:
partner@wapglobal.org
Privacy / Data Protection Contact:
[Insert Official Privacy Contact Once Approved]
3. Who Is Responsible for Your Personal Data?
The legal entity responsible for personal data depends on the processing activity concerned.
A WAP entity may act as a Data Controller where it determines the purposes and essential means of processing personal data.
Depending on the circumstances:
The fact that WAP France and WAP Sudan share the WAP name, identity and website does not automatically make them joint controllers.
Where a processing activity involves joint controllership under applicable law, the relevant responsibilities should be appropriately documented.
Where appropriate, the relevant WAP entity will be identified at or near the point where personal data is collected.
4. Scope of This Privacy Policy
This Privacy Policy may apply to personal data relating to:
Additional privacy information may be provided for specific activities where necessary.
5. Personal Data We May Collect
Depending on the activity, WAP may process information including:
Identity Information
Contact Information
Professional and Organizational Information
Recruitment Information
Where applicable:
Donation Information
Where donations are available:
Payment-card or banking information may be processed directly by approved payment service providers.
WAP should not request payment-card PINs, online banking passwords or comparable confidential security credentials through ordinary website forms or email.
Website and Technical Information
Depending on the site’s configuration:
Communications
6. Special Categories and Sensitive Information
Certain WAP activities may involve information requiring heightened protection.
Under applicable data-protection law, this may include special categories of personal data such as information relating to:
Humanitarian work may also involve information that is highly sensitive from a protection perspective even where it does not fall within a specific legal category.
This may include information concerning:
WAP should collect such information only where necessary, lawful and proportionate and should apply enhanced protection appropriate to the risks involved.
7. How We Collect Personal Data
WAP may collect personal data:
Directly From You
For example when you:
Through WAP Activities
Information may be collected during:
From Authorized Third Parties
Where lawful and appropriate, WAP may receive information from:
Where required by applicable law, appropriate privacy information should be provided when personal data is obtained indirectly.
8. Why We Process Personal Data
WAP may process personal data for legitimate organizational and humanitarian purposes including:
9. Legal Bases for Processing
Where the General Data Protection Regulation or other applicable data-protection law applies, WAP should rely on an appropriate legal basis.
Depending on the activity, this may include:
Contract
Where processing is necessary to enter into or perform a contract.
This may apply to certain employment, supplier, consultancy or other contractual relationships.
Legal Obligation
Where processing is required to meet an applicable legal or regulatory obligation.
Legitimate Interests
Where processing is necessary for a legitimate organizational purpose and those interests are not overridden by the rights and interests of the individual.
Vital Interests
In exceptional humanitarian or emergency circumstances, processing may be necessary to protect the vital interests of an individual or another person.
Other Applicable Legal Grounds
Where special-category or otherwise protected personal data is processed, WAP should ensure that any additional conditions required by applicable law are satisfied.
Consent should not be used as a universal legal basis where another legal basis is more appropriate.
10. Programme and Humanitarian Data
Humanitarian activities may require WAP to process personal data to assess needs, determine programme eligibility, implement activities and monitor results.
WAP seeks to apply principles of:
Programme participants should not be required to provide personal information that is unnecessary for the relevant humanitarian activity.
Personal information should not be publicly disclosed merely because an individual has received humanitarian assistance.
11. Donations
Where WAP accepts donations through WAPGlobal.org, the donation process should identify the specific WAP legal entity receiving the donation.
The recipient may therefore be:
Where WAP accepts donations through WAPGlobal.org, the donation process should identify the specific WAP legal entity receiving the donation.
The use of the shared WAPGlobal.org website does not mean that a donation is automatically made to both entities.
Payment information may be processed by authorized payment or fundraising providers.
Relevant providers and privacy information should be identified where appropriate.
WAP may process donor information to:
12. Recruitment and Volunteering
Personal data submitted for employment or volunteering should be used for legitimate recruitment and organizational purposes.
Applicants should be informed of the entity responsible for the recruitment process where appropriate.
WAP may process:
Recruitment information should not be retained indefinitely.
13. Partnerships, Suppliers and Tenders
WAP may process information relating to representatives of:
Processing may support:
The WAP entity conducting the relevant activity should be identified where appropriate.
14. Complaints, Safeguarding and Protected Reports
WAP may establish mechanisms for:
These processes may involve particularly sensitive information.
WAP should apply appropriate restrictions, confidentiality measures and need-to-know access.
WAP should not make an absolute promise that information will never be disclosed.
Information may need to be shared in limited circumstances where necessary to:
Dedicated reporting mechanisms should be used where established rather than ordinary general-contact channels.
15. Children and Vulnerable Persons
WAP recognizes the need for heightened protection when processing information relating to children and vulnerable persons.
Personal data should be collected only where necessary and appropriate.
Depending on the activity, WAP should consider:
16. Photographs, Videos and Humanitarian Stories
WAP may use photographs, videos, quotations and stories to communicate about approved humanitarian and organizational activities.
Such use should respect:
Additional safeguards should be used for children, survivors and people facing heightened protection risks.
Consent for receiving humanitarian assistance should not automatically be treated as consent for publication of photographs or stories.
17. Sharing Personal Data
WAP may share personal data only where there is a legitimate and lawful reason.
Depending on the activity, recipients may include:
Access should be limited according to purpose and necessity.
Sharing data between WAP France and WAP Sudan should not occur automatically merely because both entities operate under the WAP identity.
18. Service Providers and Processors
WAP may use external service providers to support functions including:
Where a provider processes personal data on behalf of a WAP entity, appropriate contractual and data-protection arrangements should be established where required.
WAP should maintain an internal record of relevant service providers and processing arrangements.
19. International Data Transfers
Because WAP operates in France and Sudan and may use external technology providers, some processing may involve access to or transfer of personal data across national borders.
A transfer from the European Economic Area to Sudan or another country outside the EEA may be subject to specific data-protection requirements.
Where European data-protection law applies, WAP should assess international transfers and implement an appropriate legal mechanism and safeguards where required.
WAP should maintain an internal record of relevant international data flows.
A provider being established in France does not necessarily mean that all processing, support, backups or sub-processing take place only in France.
20. Data Retention
WAP should retain personal data only for as long as reasonably necessary for:
Different categories of information may require different retention periods.
WAP should maintain an internal retention schedule.
Personal data should be securely deleted, anonymized or archived when continued identifiable retention is no longer justified.
No specific public retention period should be invented before WAP confirms the appropriate retention schedule.
21. Data Security
WAP seeks to apply appropriate technical and organizational measures to protect personal data.
Depending on the risks involved, measures may include:
No organization can guarantee absolute security, but WAP should take reasonable and proportionate measures appropriate to the nature and sensitivity of the information processed.
22. Data Breaches
Where a personal-data breach occurs, WAP should assess the incident and respond in accordance with applicable legal and organizational requirements.
This may include:
23. Cookies and Similar Technologies
WAPGlobal.org may use cookies and similar technologies.
Information concerning:
should be provided through the WAP Cookie Policy and consent mechanism.
Non-essential technologies should not be activated before consent where applicable law requires prior consent.
24. Communications and Newsletter
Individuals may choose to receive approved WAP communications where available.
Where consent is the legal basis, individuals should be able to withdraw consent.
Newsletter consent should be voluntary and should not be improperly bundled with unrelated activities such as:
Communications should include an appropriate method to unsubscribe where required.
25. Automated Decision-Making and Profiling
WAP should not state that it uses automated decision-making or profiling unless such activities are actually implemented.
At the time of final publication, WAP should verify whether any system makes decisions producing legal or similarly significant effects based solely on automated processing.
If such processing is used, additional information and safeguards may be required.
If no such processing is used, the final policy may state:
“WAP does not currently use solely automated decision-making producing legal or similarly significant effects in connection with WAPGlobal.org.”
26. Your Data-Protection Rights
Where applicable data-protection law provides such rights, individuals may be entitled to request:
These rights may be subject to legal conditions, exemptions and limitations.
WAP may need to verify the identity of a person making a rights request before acting on it.
27. How to Exercise Your Rights
Requests relating to privacy or personal data may be submitted through:
Privacy / Data Protection Contact:
[Insert Approved Privacy Contact]
Where an enquiry concerns a particular WAP entity, the request may be directed to that entity or appropriately routed within WAP.
WAP should respond within applicable legal timeframes.
28. Complaints to a Supervisory Authority
Where processing is subject to the General Data Protection Regulation, individuals may have the right to submit a complaint to the competent data-protection supervisory authority.
For processing falling within the jurisdiction of the French supervisory authority, the relevant authority is:
Commission Nationale de l’Informatique et des Libertés (CNIL)
The availability of this complaint mechanism does not prevent an individual from contacting WAP first about a privacy concern.
29. Third-Party Websites
Those websites operate independently and may have their own privacy practices.
WAP is not responsible for the privacy practices of independent third-party websites solely because a link is provided.
30. Changes to This Privacy Policy
WAP may update this Privacy Policy to reflect:
The latest approved version should be published on WAPGlobal.org.
Last Updated:
[Insert Date]
Version:
[Insert Version]
31. Contact Information
Wings of Aid & Peace (WAP)
WAP is not responsible for the privacy practices of independent third-party websites solely because a link is provided.
Site officiel :
General Enquiries:
Partnership Enquiries:
partner@wapglobal.org
Privacy / Data Protection:
[Insert Approved Privacy Contact]
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 Number:
[Insert Official Registration Authority]
Registration Authority:
[Insert Official Registration Number]
Registered Address:
[Insert Official Registered Address]
Country:
Sudan
