The rules governing tracking technologies cover not only cookies in the strict sense, but also technologies that store information on a user’s device or access information already stored on it. These rules apply regardless of whether the information accessed constitutes personal data.
A cookie is a small file that may be stored on a user’s device when they visit a website.
The term “tracker” also covers other mechanisms for storing or accessing information on a device, including certain local storage items.
2. Cookie Management on MyRadar
On the first visit, the consent management interface must present clear choices and make accepting or refusing trackers that require consent equally straightforward. A user’s failure to take action must not be interpreted as acceptance.
Consent must be specific to the purposes concerned and capable of being withdrawn at any time. Appropriate evidence of the choices expressed should be retained without using unnecessary trackers solely for that purpose.
The website uses Complianz GDPR to collect and retain users’ choices regarding cookies and trackers.
Trackers that are strictly necessary for the website to function may be used without prior consent. Other trackers must only be loaded after the user has given consent. The French data protection authority, the CNIL, provides exemptions for trackers used to remember users’ choices and those enabling expected interface customisation, such as the selected language. CNIL guidance, in French
Users must be able to accept or refuse trackers with equal ease and change their choices subsequently. CNIL guidance, in French
3. Strictly Necessary and Functional Cookies
The exemption from consent applies only to operations that are strictly necessary to provide a service expressly requested by the user or to transmit an electronic communication. A tracker’s classification must therefore be based on its actual use, rather than solely on the category assigned by its provider.
Complianz
Complianz uses cookies to remember users’ preferences regarding the different categories of trackers.
Purpose: Remembering cookie choices.
Consent: Not required, as these trackers are necessary to retain the choices expressed.
Polylang
Polylang may place a cookie to remember the language selected by the user.
Purpose: Remembering the website’s display language.
Consent: Not required where the cookie is used exclusively to provide this functionality requested by the user.
4. Turnstile
Turnstile’s actual configuration must be checked to identify any operations that read information from or write information to the user’s device. An additional feature, such as “pre-clearance”, may change the trackers used and must be included in the technical inventory.
Turnstile is used to secure the form and distinguish legitimate users from automated submissions.
The service analyses certain technical signals necessary for bot detection. By default, the Turnstile widget generates a single-use token. A cf_clearance cookie may also be used if the pre-clearance feature is enabled. Cloudflare documentation
Purpose: Form security and prevention of spam and bots.
Provider: Cloudflare.
Category: Security / strictly necessary.
Consent: Given its purpose of protecting against bots, and provided that its configuration remains strictly limited to that purpose, it may be treated as a mechanism necessary to secure the form. Cloudflare itself states that Turnstile signals are strictly necessary to detect and block bots.
5. YouTube
The tracker names listed below form an inventory based on the checks described in the original document. Their presence and retention periods must be reassessed whenever the player, its settings or Google’s services change.
Information about these trackers must remain accessible before they are activated and enable visitors to understand the purpose of the video integration and the consequences of their choices.
YouTube videos are embedded on the website.
Technical checks have identified YouTube-related items including:
| Tracker identified | Provider | General purpose | Consent required |
|---|---|---|---|
VISITOR_INFO1_LIVE | YouTube | Operation and management of video delivery | Yes |
VISITOR_PRIVACY_METADATA | YouTube | Storage of privacy-related settings | Yes |
YSC | YouTube | Video functionality and interactions | Yes |
__Secure-ROLLOUT_TOKEN | YouTube | Technical management and rollout of YouTube features | Yes |
__Secure-YNID | YouTube | Operation of YouTube services | Yes |
| YouTube local storage | YouTube | Player functionality and storage of technical data | Yes |
These trackers were observed during checks carried out on the website. Their exact retention periods may change depending on YouTube’s technical choices.
YouTube videos must remain blocked if cookies are refused and until the user has given consent.
The fact that a video is embedded using Elementor does not change the legal requirements if loading it results in YouTube trackers being read or placed on the user’s device. The CNIL requires prior consent where embedded third-party content triggers trackers that are not exempt from consent. CNIL guidance, in French
6. Google Tag Manager
Consent must be technically enforced before any non-essential tag is triggered. Simply displaying a cookie banner is insufficient if requests or trackers requiring consent are already being activated in the background.
Google Tag Manager may be used to manage tags on the website.
Its installation must not allow users’ choices expressed through Complianz to be bypassed.
All analytics, advertising or marketing tags requiring consent must remain blocked until the user has accepted the corresponding category.
The analytics and marketing tools actually enabled, together with their purposes and retention periods, must be added to this policy once confirmed by the marketing service provider and before they are put into use.
7. Refusal and Withdrawal of Consent
The preference management tool must remain easily accessible after the initial choice, for example through a permanent link in the footer. Withdrawing consent must prevent the relevant trackers from subsequently reading or storing information, without affecting the lawfulness of processing carried out before consent was withdrawn.
The period for remembering users’ choices must be defined and configured. The CNIL recommends six months as a reference period for renewing choices, to be adapted according to the circumstances and any changes in purposes.
Users may refuse non-essential cookies without losing access to the website’s main content.
They must also be able to change their choices at any time through the cookie management tool available on the website.
Refusing cookies must be as easy as accepting them. CNIL guidance, in French