The Management / Governing Body of XUBATACOS (hereinafter, the Data Controller) assumes maximum responsibility and commitment to the establishment, implementation, and maintenance of this Data Protection Policy, guaranteeing 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) (OJEU L 119/1, 04-05-2016), and the Spanish regulations on the protection of personal data (Organic Law, specific sectoral legislation, and its implementing regulations).

The Data Protection Policy of XUBATACOS is based on the principle of proactive responsibility (accountability), according to which the Data Controller is responsible for compliance with the regulatory and jurisprudential framework governing said 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, which must serve all its personnel as a guide and frame of reference in the processing of personal data:

• 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.

• Data protection by default: The Data Controller will apply appropriate technical and organizational measures 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 cycle: The measures ensuring the protection of personal data will be applicable during the entire life cycle of the information.

   

• Lawfulness, fairness, and transparency: Personal data will be processed lawfully, fairly, and in a transparent manner in relation to the data subject.

   

• Purpose limitation: Personal data will be collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

   

• Data minimization: Personal data will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.

   

• Accuracy: Personal data will be accurate and, where necessary, kept up to date; every reasonable step will 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 limitation: Personal data will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.

• 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.

• Information and training: One of the keys to ensuring the protection of personal data is the training and information provided to the personnel involved in its processing. During the information life cycle, all personnel with access to data will be properly trained and informed about their obligations regarding compliance with data protection regulations.

The Data Protection Policy of XUBATACOS is communicated to all personnel of the Data Controller and made available to all interested parties.

Consequently, this Data Protection Policy involves all personnel of the Data Controller, who must know and assume it, considering it as their own, with each member being responsible for applying it and verifying the data protection rules applicable to their activity, as well as identifying and providing any improvement opportunities they consider appropriate with the aim of achieving excellence in relation to its compliance.

This Policy will be reviewed by the Management / Governing Body of XUBATACOS as often as deemed necessary, to adapt, at all times, to current provisions regarding the protection of personal data.