Cookie Policy
AMFIE places particular importance on the protection of the personal data of its members, prospective clients, and website visitors. We have adopted strict principles of transparency and respect for privacy.
For this reason, we aim to provide you with clear information on how we place, use, and store cookies on your device when you visit www.amfie.org, and to present the means available to you to manage them.
1. Data Controller
The website www.amfie.org is published by AMFIE, a cooperative company incorporated under Luxembourg law. The publisher's full contact details are available in our Legal Notice.
Data Protection Officer (DPO): dpo@amfie.org
2. What Is a Cookie?
A cookie is a small file — text, image, or software — that may be placed on and read from your device when you access our website.
"Device" refers to any equipment used to browse the internet: desktop computer, laptop, smartphone, tablet, smartwatch, or any equivalent device.
Similar Technologies
In addition to conventional cookies, this policy also covers similar technologies that may be used for tracking or analytics purposes:
- Device fingerprinting
- Invisible pixels (web beacons)
- Shared objects (also known as Flash cookies)
- Identifiers generated by operating systems
In accordance with the CNPD guidelines, these technologies are subject to the same rules as cookies. The term "cookies" as used in this policy encompasses all such trackers.
Two Main Categories of Cookies by Duration
- Session cookies (or temporary cookies) are automatically deleted when you close your browser. They do not persist beyond your visit.
- Persistent cookies (or permanent cookies) remain stored on your device until their expiry date or until you choose to delete them.
What Are Cookies Used For?
Cookies serve several functions essential to the proper operation of a website and to your browsing experience. On our website, they are used in particular to:
- Authenticate you and secure access to your personal account.
- Strengthen the security of the website by preventing fraudulent access attempts and protecting your data from unauthorised access.
- Remember your preferences (display language, consent choices, interface settings).
- Analyse website traffic and how you use it, in order to improve usability, content, and performance.
- Measure the effectiveness of our communications directed at international civil servants and tailor our messaging accordingly.
3. Legal Basis for Processing
The placement and reading of cookies on your device is based on the following legal grounds:
- Strictly necessary cookies: Article 4.3(e) of the Luxembourg Act of 30 May 2005, as amended, on the protection of privacy in the electronic communications sector. These cookies do not require your consent.
- Non-essential cookies (audience measurement, marketing): Article 6(1)(a) of Regulation (EU) 2016/679 (GDPR) — your prior, freely given, informed, specific, and unambiguous consent, collected via our Axeptio platform.
4. What Information May Be Stored via Cookies?
The information that may be collected via cookies, within the limits of their retention period and according to the categories you have authorised, may include:
- The pages you have visited on our website.
- The date, time, and duration of your visits.
- The browser type, language, and operating system used.
- Your IP address (in anonymised form for our audience measurement tools).
- The source of your visit (search engine, external link, campaign).
- Unique technical identifiers, specific to each tool, which do not allow you to be identified by name.
These data may constitute personal data within the meaning of the GDPR and are processed in accordance with our Privacy Policy.
5. Our Consent Architecture
Our website relies on Google Tag Manager, configured to block by default all non-essential trackers. No audience measurement or marketing cookies are triggered until you have expressed your preference.
Your consent is collected and managed by Axeptio, our consent management platform (CMP), compliant with CNPD requirements.
We also implement Google Consent Mode v2. In practice:
- If you accept: the cookies described below are placed and our tags operate normally.
- If you decline: no tracking cookies are placed. Google may, however, receive anonymised, cookie-free signals (cookieless pings) used to produce aggregated and modelled statistics, without any individual identification or reconstruction of your browsing journey.
Your choice is stored for 6 months. After that period, the consent banner will be displayed again so you can confirm or update your preferences.
6. Which Cookies Do We Use and for What Purposes?
A. Strictly Necessary Cookies (always active)
These cookies are essential to the operation and security of the website. They do not require your consent, as disabling them would prevent the website from functioning properly. They are used in particular to maintain your active session, secure forms, and remember your consent choices.
B. Audience Measurement and Experience Cookies (subject to consent)
These cookies allow us to understand how our website is used, identify the most visited content, and detect potential usability issues, so we can continuously improve your experience. We use:
- Google Analytics 4 (GA4) to produce traffic statistics and analyse browsing journeys, based on aggregated data.
- Microsoft Clarity to analyse page usability through heatmaps and navigation indicators.
C. Marketing and Advertising Cookies (subject to consent)
These cookies help us promote our services to our target audience and measure the effectiveness of our communications campaigns. We use:
- Google Ads to measure the performance of our search engine campaigns and track conversions.
- LinkedIn Insight Tag to measure engagement with our campaigns on the professional network and tailor our communications to the international organisations sector.
7. Detailed Cookie List
| Category | Name | Provider | Purpose | Retention |
|---|---|---|---|---|
| Necessary | axeptio_cookies | amfie.org | Storage of consent preferences | 6 months |
| Necessary | axeptio_all_vendors | amfie.org | List of vendors authorised by purpose | 6 months |
| Necessary | axeptio_authorized_vendors | amfie.org | Details of authorised partners | 6 months |
| Necessary | app-language | amfie.org | Storage of display language (FR/EN) | 1 year |
| Necessary | NSC_DTWT-NZLVCFSOFUFT | www-api.amfie.org | Load balancing and session continuity (Citrix NetScaler) | End of session |
| Necessary | payload-token | www-api.amfie.org | Authentication to the member area (placed only after login) | End of session |
| Audience measurement | _ga | Google Analytics 4 | Unique GA4 identifier | 13 months |
| Audience measurement | _ga_PCMQWL1V84 | Google Analytics 4 | Session identifier linked to the GA4 property | 13 months |
| Audience measurement | _clck | Microsoft Clarity | Persistent identifier | 1 year |
| Audience measurement | _clsk | Microsoft Clarity | Grouping of actions within a session | 1 day |
| Marketing | _gcl_au | Google Ads | Conversion measurement | 90 days |
| Marketing | bcookie | Secure device identifier | 1 year | |
| Marketing | li_sugr | Advertising effectiveness and professional retargeting | 90 days |
8. Data Controllers and Data Recipients
First-Party Cookies — Placed by AMFIE
AMFIE acts as data controller for cookies placed directly from the amfie.org domain: cookies necessary for the website to function, and the Axeptio consent cookie.
Third-Party Cookies — Placed by Our Partners
The following entities act as data controllers (or joint controllers, as applicable) for the cookies they place via our website:
- Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, United States) — Google Analytics 4, Google Ads, Google Tag Manager.
- Microsoft Corporation (One Microsoft Way, Redmond, WA 98052, United States) — Microsoft Clarity.
- LinkedIn Corporation (1000 West Maude Avenue, Sunnyvale, CA 94085, United States) — LinkedIn Insight Tag.
When you authorise these cookies, these partners gain access to the information they contain and process it in accordance with their own privacy policies, over which AMFIE has no direct control.
Data Recipients
Data collected via cookies is intended for:
- AMFIE's internal teams responsible for audience analytics and communications.
- Our aforementioned technical partners, strictly within the scope of the purposes described.
AMFIE does not sell, rent, or transfer any data collected via cookies to third parties. Data is used solely for the purposes described in this policy.
9. Profiling and Automated Decision-Making
AMFIE does not carry out any automated decision-making that produces legal effects concerning you or significantly affects you on the basis of data collected via cookies.
Our marketing partners (Google Ads, LinkedIn) may, however, employ advertising profiling techniques to measure the effectiveness of our campaigns and deliver relevant content to targeted audiences (for example, by sector of activity). This profiling does not aim to make individual automated decisions concerning you.
You may object to this profiling at any time by declining marketing cookies via our Axeptio platform (see section 11).
10. Data Transfers Outside the European Union
Our service providers — Google, Microsoft, and LinkedIn — may transfer data to the United States. These transfers are governed by the following safeguards:
- EU–US Data Privacy Framework: adequacy decision adopted by the European Commission in July 2023. Google LLC, Microsoft Corporation, and LinkedIn Corporation are certified under this framework.
- Standard Contractual Clauses issued by the European Commission, as a supplementary safeguard.
The list of certified companies is available at dataprivacyframework.gov.
11. How to Manage Your Preferences
You have full control over your browsing data. You may accept, decline, or customise your choices at any time, without affecting the lawfulness of prior processing.
Via Our Consent Management Platform
Click on the "Cookie Settings" button (Axeptio icon) permanently displayed at the bottom left of your screen to update your preferences by category.
Via Your Browser Settings
You can also configure your browser to accept or reject all or some cookies: Google Chrome, Mozilla Firefox, Safari, Microsoft Edge. Blocking all cookies may impair the proper functioning of certain parts of the website.
12. Your Rights
In accordance with Regulation (EU) 2016/679 (GDPR) and the Luxembourg Act of 1 August 2018, you have the following rights over your personal data at any time:
- Right of access, rectification, erasure, and restriction of processing.
- Right to object and right to data portability.
- Right to withdraw your consent at any time, without affecting the lawfulness of prior processing.
To exercise these rights or for any questions regarding the processing of your data, please contact our Data Protection Officer (DPO): dpo@amfie.org
15, boulevard du Jazz, L-4370 Belvaux — cnpd.public.lu
For complete information on how AMFIE processes your data and on your rights, please consult our Privacy Policy.
13. Policy Updates
AMFIE reserves the right to amend this policy at any time in order to reflect legislative, regulatory, or technical developments. The date of the last update appears at the top of this page.