INFORMATION ON THE PROCESSING OF PERSONAL DATA

INTRODUCTION

The new General Data Processing Regulation (EU Regulation no. 2016/679 also known as "GDPR") establishes very important rules for the protection of personal data that we undertake to follow.

1) WHO IS THE HOLDER OF THE TREATMENT?

FIELD (hereinafter, "FIELD"), is the owner of the processing of personal data collected through the fieldleaders.org website.

2) WHY DO WE PROCESS YOUR DATA?

There are various reasons why FIELD may process your personal data.

First of all, the personal data you want to communicate to us are processed to follow up on your requests and for activities connected and instrumental to browsing the Sites (for example, the registration and use of the various services provided by FIELD through the Sites). For example, we may collect information about you (usually your name, surname, email address; but in relation to certain initiatives we may also collect other information such as your telephone number or home / residence address) in the context of requests for information or as part of subscriptions to campaigns or other FIELD initiatives.

In theory, FIELD may become aware of information regarding your political views and philosophical beliefs. This information will be processed by FIELD only for the purposes of FIELD and will not be disclosed outside the company without your consent.

Through the Sites we also manage the information that you may send us in your CV and / or in a motivational letter where there is any open position or in any case you intend to submit your application to the attention of FIELD. For this purpose, FIELD processes your personal data on the basis of its legitimate interest and, in any case, to follow up on your pre-contractual request.

Like all companies, we are subject to legal obligations and, sometimes, to requests for information from the competent authorities, therefore we are required to process and store certain information to follow up on what the applicable legislation requires. Furthermore, we may process your personal data for organizational and administrative-accounting purposes on the basis of our legitimate interests.

Your personal data may also be processed in the context of any company events (liquidation, merger, etc.), due diligence, in the event of the defense of a right in court and in relation to the related prodromal activities.

In all cases in which FIELD has decided to resort to the legal basis of legitimate interest to carry out certain processing operations of your personal data, evaluations have been carried out by FIELD which has considered that its legitimate interests do not override your fundamental rights and freedoms.

3) WHAT DATA DO WE PROCESS?

When applying for membership to the fieldleaders.org site, if approved, a user profile is created using your email address. At this stage we collect your name, surname, email, telephone and information relating to joining a certain list, organization or candidate that might indicate your political or philosophical opinion: this last information will be processed by FIELD only for the purposes of FIELD and on the basis of your consent. FIELD, subsequently, could collect further information whose conferment is entirely optional. Should the information in question not be provided, there will be no consequence. We refer to the city and region of residence, the full address of residence or domicile as well as any other information that you may upload to the Site (for example, your user profile photo, gender identity, age, activity working). In addition, FIELD also collects anonymized information that does not directly reveal your identity such as: information on your browser and on your access device (for example, smartphone, personal computer, tablet, etc.), which version of the browser and operating system, technical attributes, source Internet protocol address, etc.

Furthermore, if you send us your CV and / or motivational letter, FIELD will be able to process the information contained therein for the purposes relating to the management of applications for job positions on the Site or to manage any spontaneous application. In general, the job positions on the Site are such that they do not require you to send (and therefore the processing by FIELD) of sensitive data, for example relating to health conditions or belonging to a specific trade union. Therefore, we invite you not to communicate such information which, in any case, will not be treated by FIELD.

4) HOW ARE THE DATA PROCESSED?

In relation to the aforementioned purposes, the data will be processed both through the use of electronic tools and on paper and in any case with suitable tools to ensure security and confidentiality. In any case, the data will be processed on the basis of the principle of necessity and minimization so that the least number of personal data possible is used in relation to the various pursued and admissible purposes.

5) WHO IS THE DATA COMMUNICATED TO?

The personal data provided by users will be processed exclusively by personnel authorized by FIELD. Your personal data will not be disclosed.

6) HOW LONG DO WE KEEP YOUR DATA?

Your data will be kept, in accordance with the provisions of current legislation on the subject, for a period of time not exceeding that necessary to achieve the purposes for which they are processed. The criteria for determining the data retention period take into account the permitted processing period and the applicable laws on taxation, prescription of rights and legitimate interests where they constitute the legal basis of the processing. In particular, in relation to the management of the existing relationship, the data will be kept for the times defined by the reference legislation and, upon termination of the relationship, for the applicable limitation period. At the end of the retention period, the data will be deleted, anonymized or aggregated in such a way as not to allow your identification.

7) IS THE DATA TRANSFERRED ABROAD?

Your personal data will not be transferred outside the European Economic Area ("EEA") by FIELD.

In any case, if this happens and therefore if FIELD transfers your personal information to third parties based outside the EEA, FIELD undertakes to:

• include standard data protection contractual clauses approved by the European Commission for the transfer of personal information outside the EEA in your contracts with such third parties; or

• ensure that the country in which the personal information will be handled has been deemed "adequate" by the European Commission; or

• (where we need to transfer your personal data to a recipient in the United States) FIELD will inform you of the transfer and the recipient as well as the specific risks, if any, arising from the transfer of the data to that State.

For more information on the rules for data transfers outside the EEA, including the mechanisms on which we rely, please consult the website of the European Commission.

8) WHAT ARE YOUR RIGHTS? HOW CAN YOU EXERCISE THEM?

You can contact FIELD at any time and free of charge to request:

• grant access to any personal information in our possession that concerns you;

• update any of your personal information that is out of date or incorrect;

• delete any of your personal information held by us;

• restrict the way we process your personal data;

• prevent the processing of their personal information for direct communication purposes;

• provide your personal information to third parties, exercising the right to data portability;

• provide a copy of your personal information held by us; or

• consider any validly raised objection regarding the use of your personal information.

Furthermore, you have the right to withdraw consent to the processing of your personal data (where provided), at any time, without prejudice to the lawfulness of the processing based on the consent given prior to the withdrawal.

To exercise your rights, you can send a request to our email address: info@fieldleaders.org. FIELD will consider all such requests and respond within a reasonable time (and in any case within the time limits required by applicable law). However, some personal information may be exempt from such requests in certain circumstances.

In case of application of an exception, we will notify you in response to your request. FIELD reserves the right to ask you to provide the information necessary to confirm your identity before responding to any inquiries. Pursuant to the GDPR, FIELD is not authorized to charge costs to fulfill one of the requests set out in this paragraph, unless they are manifestly unfounded or excessive, and in particular are repetitive. In cases where you request more than one copy of your personal data from us or in cases of excessive or unfounded requests, FIELD may (i) charge a reasonable fee, taking into account the administrative costs incurred to fulfill the request or (ii) refuse. to satisfy the request. In these cases, FIELD will inform you of the costs before processing the request.

Without prejudice to any other administrative or judicial appeal, you will also have the right to lodge a complaint with a supervisory authority, if you believe that the processing that concerns you is carried out in violation of the GDPR. In any case, FIELD invites you to contact directly through the channels indicated above, before contacting the Supervisory Authority, so as to resolve any dispute regarding the protection of personal data amicably and as soon as possible.

WHAT COOKIES ARE

“Cookies” are small files that are stored by the browser on your computer or mobile device. They allow websites to remember certain information, such as user preferences, the type of device used and other information, ensuring a more efficient operation of the site, enriching the visiting experience and providing information to the owners of the site.

Cookies are information saved on the hard disk of the user's terminal and which are sent by the user's browser to a Web server and which refer to the use of the network. Consequently, they allow you to know the services, the sites visited and the options that, while surfing the net, have been shown. In other words, cookies are small files, containing letters and numbers, which are downloaded to the user's computer or mobile device when you visit a website. The cookies are then sent back to the original site on each subsequent visit, or to a other website that recognizes these cookies. Cookies are useful because they allow a website to recognize the user's device.

This information is therefore not provided spontaneously and directly, but leaves traces of the user's browsing on the net.

Cookies perform various functions and allow you to navigate between pages efficiently, remembering user preferences and, more generally, improving your experience. They can also help ensure that the advertisements shown while browsing are of interest to you and that the marketing activities carried out comply with your preferences, avoiding unwelcome promotional initiatives or not in line with the user's needs.

While browsing a site, the user can also receive cookies on his terminal that are sent from different sites or web servers (so-called "third parties"), on which some elements may reside (eg: images, maps, sounds, specific links to pages of other domains) present on the site that the same is visiting. Therefore, in this respect there can be:

1. Direct cookies, sent directly from this site to the user's device

2. Third party cookies, coming from a third party but sent on our behalf. This site uses third-party cookies to facilitate the analysis of our website and their use (as described below).

Furthermore, according to the purpose of use of cookies, these can be divided into:

1. Technical cookies: they are used to allow the transmission of a communication over an electronic communications network or to provide a service expressly requested by the user. They are not used for other purposes. In the category of technical cookies, the use of which does not require the user's consent, the following are distinguished:

2. Navigation or session cookies: they guarantee the normal navigation and use of the website (eg: to authenticate and access restricted areas). The use of these cookies (which are not stored permanently on the user's device and are automatically deleted when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow the safe and efficient exploration of the site.

3. Analytics cookies: if they are used only to collect information in aggregate form, on the number of users who visit the site and how they visit it

4. Functional cookies: allow the user to browse based on a series of selected criteria (eg: language or services to which one has subscribed) to improve the service provided to the user.

5. Profiling cookies: they are aimed at creating profiles relating to the user and used to send targeted promotional messages according to the preferences expressed while surfing the net. These cookies can be used for these purposes only with the user's consent.

COOKIE POLICY