Our Commitment to Personal Data Protection: “Informed Individuals and Protected Data”
David Martín Moncunill, as the data controller, assumes the utmost responsibility and commitment to the establishment, implementation, and maintenance of this Data Protection Policy. He guarantees the continuous improvement of his processes with the objective of achieving excellence in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, as well as applicable Spanish regulations regarding personal data protection.
This Data Protection Policy rests on the principle of proactive accountability, according to which the data controller not only complies with the applicable regulatory and jurisprudential framework but is also capable of demonstrating it before the competent supervisory authorities.
Core Data Protection Principles
In this regard, the processing of personal data will be governed by the following principles:
- Data protection by designAppropriate technical and organizational measures will be applied, both at the time of determining the means for processing and at the time of the processing itself, designed to effectively implement data-protection principles, such as data minimization, and to integrate the necessary safeguards into the processing.
- Data protection by defaultAppropriate technical and organizational measures will be adopted to ensure that, by default, only personal data which are necessary for each specific purpose of the processing are processed.
- Data protection in the information life cycleMeasures ensuring the protection of personal data will be applicable throughout the entire life cycle of the information.
- Lawfulness, fairness, and transparencyPersonal data will be processed lawfully, fairly, and in a transparent manner in relation to the data subject.
- Purpose limitationPersonal data will be collected for specified, explicit, and legitimate purposes and will not be further processed in a manner that is incompatible with those purposes.
- Data minimizationPersonal data will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
- AccuracyPersonal data will be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
- Storage limitationPersonal data will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes of the processing.
- Integrity and confidentialityPersonal data will be processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
- Information and trainingOne of the keys to guaranteeing the protection of personal data is to stay informed about legal obligations in this matter. In this regard, the data controller commits to undergoing periodic training and updates to ensure compliance with current regulations.
Policy Availability and Review
- Public AvailabilityThis Data Protection Policy will be available to all interested parties.
- Individual CommitmentConsequently, this Policy must be understood as an individual commitment of the data controller, who assumes the responsibility of applying it, verifying its compliance, and detecting opportunities for improvement with the aim of achieving maximum quality in personal data management.
- Continuous UpdatesThis Policy will be reviewed by David Martín Moncunill as often as deemed necessary, in order to adapt, at all times, to current provisions regarding the protection of personal data.