OUR COMMITMENT TO PERSONAL DATA PROTECTION: “INFORMED PEOPLE AND PROTECTED DATA”

The Management / Governing Body of SPAINLEX GLOBAL CENTER SL (hereinafter, the data controller), assumes the highest responsibility and commitment to the establishment, implementation, and maintenance of this Data Protection Policy, ensuring the continuous improvement of the data controller with the aim of achieving excellence in relation to compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), and the Spanish personal data protection regulations (Organic Law, specific sectoral legislation, and its development regulations).

The Data Protection Policy of SPAINLEX GLOBAL CENTER SL is based on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework governing this Policy and is able to demonstrate it to the competent supervisory authorities.

In this regard, the data controller will be governed by the following principles that should serve all its staff as a guide and reference framework in the processing of personal data:

  1. Data protection by design: the data controller will apply, both at the time of determining the means of processing and at the time of the processing itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively implement data protection principles, such as data minimization, and integrate the necessary safeguards into the processing.
  2. Data protection by default: the data controller will apply appropriate technical and organizational measures to ensure that, by default, only personal data that are necessary for each specific purpose of the processing are processed.
  3. Data protection in the information lifecycle: measures that ensure the protection of personal data will be applicable throughout the entire lifecycle of the information.
  4. Lawfulness, fairness, and transparency: personal data will be processed lawfully, fairly, and transparently in relation to the data subject.
  5. Purpose limitation: personal data will be collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.
  6. Data minimization: personal data will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
  7. Accuracy: personal data will be accurate and, where necessary, kept up to date; all reasonable steps will be taken to ensure that inaccurate personal data, in relation to the purposes for which they are processed, are erased or rectified without delay.
  8. Storage limitation: personal data will be kept in a form that permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
  9. Integrity and confidentiality: personal data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
  10. Information and training: one of the keys to ensuring the protection of personal data is the training and information provided to the staff involved in processing them. Throughout the information lifecycle, all staff with access to the data will be appropriately trained and informed about their obligations regarding compliance with data protection regulations.

The Data Protection Policy of SPAINLEX GLOBAL CENTER SL is communicated to all staff of the data controller and made available to all interested parties.

As a result, this Data Protection Policy involves all personnel responsible for processing, who must know and adopt it, considering it as their own. Each member is responsible for applying it and verifying the data protection regulations applicable to their activity, as well as identifying and contributing any improvement opportunities they deem appropriate to achieve excellence in compliance.

This Policy will be reviewed by the Management / Governing Body of SPAINLEX GLOBAL CENTER SL as often as deemed necessary to comply at all times with the current provisions on personal data protection.