PIF privacy notice

COLLABORATE WITH US — PIF PRIVACY NOTICE CONTROLLER AND CONTACT Focus Europe ETS, Via Giovanni Verga 10, 95041 Caltagirone (CT), Italy, is the data controller. For information about personal data processing, profile updates and requests concerning your rights: privacy@focuseurope.org. For information about activities and cooperation: info@focuseurope.org. This notice covers the “Collaborate with us” PIF form and its restricted archive on rete.focuseurope.org. PURPOSE The PIF (Partner Identification Form) enables bodies and organisations, including non-members, to introduce themselves to Focus Europe and express their availability to collaborate. We use the information to manage a profile in a restricted archive, assess whether the declared skills and interests correspond to project needs within our network, and contact the representative for clarification and possible collaborations. Submitting a PIF does not create membership, subscribe anyone to a newsletter, place the profile in a public directory or guarantee participation in a project. DATA PROCESSED We process the organisation and representative details supplied in the form: organisation name, type, country and location, website and any PIC/OID; the representative's name, position, work email and optional telephone number; working languages; areas of interest, skills, target groups, availability and geographical areas; description, project experience, links and proposed ideas. We also record the submission date and reference, the privacy notice version and consent given. Authorised staff may add relevant notes on profile assessment and contacts with the representative. Identity documents and attachments are not requested. Use your own work contact details as the representative. Do not provide unnecessary personal data about other people, health or other special-category information about individuals, or children's personal data. LEGAL BASIS AND VOLUNTARY SUBMISSION Managing the profile and contacting the representative about possible collaborations rely on specific consent given through an unticked checkbox under Article 6(1)(a) of Regulation (EU) 2016/679. Submission is voluntary. Marked fields are necessary to receive a usable profile and contact its representative: without this information or consent, the PIF cannot be added to the archive through this form. Focus Europe can also be contacted using its published contact details. Consent may be withdrawn at any time by writing to privacy@focuseurope.org, without affecting the lawfulness of processing carried out before withdrawal. TECHNICAL DATA, SECURITY AND COOKIES When the service is used, access and navigation data, such as IP addresses and technical information about requests, may be processed to operate the portal, prevent misuse and address technical problems. The portal also uses temporary session data and pseudonymised identifiers to limit repeated submissions. These technical operations rely on Focus Europe’s legitimate interest in the security and continuity of the service under Article 6(1)(f) GDPR; any processing required by law relies on Article 6(1)(c). They are not used to assess the organisation’s merits. The form uses a technical session cookie needed to complete and protect the submission. The PIF form does not include analytics, advertising or social media tracking tools. The institutional website, app and external services have notices covering their respective services. ACCESS, ASSESSMENT AND SHARING Profiles are available to authorised Focus Europe staff in a restricted area, according to assigned roles. Searches use criteria declared by the organisation, such as country, themes, skills and availability. Filters and any suggestions support assessment by the responsible staff: no solely automated decisions producing legal or similarly significant effects on individuals are made, and matching does not trigger automatic outreach. Data are not published or automatically made available to members or other partners. Any disclosure of personal data to prospective partners for a specific collaboration will first be agreed with the representative, identifying the recipients, purpose and legal basis. Submitting a PIF does not authorise general sharing of contact details. SERVICE PROVIDERS AND TRANSFERS The portal and its database are hosted by Netsons S.r.l., Via Tirino 99, 65129 Pescara, Italy. For data entrusted to the hosting service, Netsons acts as a processor under the Data Processing Agreement (DPA) accompanying the service contract, pursuant to Article 28 GDPR. The provider may use sub-processors for activities needed to deliver, maintain and secure the service, subject to data protection obligations. According to Netsons’ published documentation, data stored by customers on its systems are kept in Italy and are not transferred outside the European Union. The PIF collection and storage process described here does not involve transfers outside the European Economic Area. If a future service or collaboration requires such transfers, Focus Europe will inform data subjects before proceeding, identifying the recipients, countries and applicable basis, such as adequacy decisions or safeguards under Articles 45 and 46 GDPR. For information about processors and any safeguards, and to obtain a copy where relevant, write to privacy@focuseurope.org. RETENTION The profile and contact details are retained for a maximum of 12 months from submission, unless erasure is requested or consent is withdrawn earlier. At the end of this period Focus Europe reviews the record and deletes data that are no longer necessary; deletion is not automatic. Profiles beyond the retention period are excluded from matching searches. Continuing availability requires a fresh response from the representative and a defined retention period: an internal edit does not renew consent. If an actual collaboration starts, information on the relevant processing and retention periods will be provided. Temporary references to forms and submission receipts in the session expire after one hour. Anti-abuse identifiers are valid for a maximum of 48 hours; expired records are removed during subsequent portal clean-up operations. For infrastructure logs, Netsons states that retention is determined by service delivery purposes and legal obligations: the 12-month PIF retention period does not apply to those logs. According to Netsons’ documentation, ordinary web hosting backups rotate with a maximum retention period of 31 days. Deletion from the active database may therefore precede expiry of backup copies used for technical restoration. If a backup is restored, Focus Europe must reapply subsequent erasures and restrictions. Any exported copies are kept under restricted access and must not be used to extend the profile’s availability beyond its retention period. When the hosting service ends, Netsons provides for a courtesy backup for a maximum of 45 days where contractually applicable. RIGHTS AND UPDATES You may request access, rectification or an update, erasure and restriction of processing and, where applicable, data portability and objection. To withdraw consent, withdraw availability or exercise your rights, write to privacy@focuseurope.org, quoting the PIF reference if available. Information strictly necessary to verify the requester's identity may be requested. Requests are answered within one month, subject to any extensions permitted by the GDPR, of which you will be informed. You may lodge a complaint with the Italian data protection authority (www.garanteprivacy.it) or the competent supervisory authority.