Data protection policy

The Management / Governing Body of INés Rosales S.A.U., hereinafter referred to as the ENTITY (hereinafter, the data controller), assumes the highest level of 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 compliance with Regulation (EU) 2016/679 of the European Parliament and Council, dated April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), as well as Spanish personal data protection legislation (Organic Law, specific sectoral legislation, and its implementing regulations).

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

In this regard, the data controller shall be governed by the following principles, which must serve as a guide and framework for all its staff in the processing of personal data:

1. Data protection by design: The data controller shall apply, both when determining the means of processing and during 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 shall apply appropriate technical and organizational measures to ensure that, by default, only personal data that is necessary for each specific purpose of the processing is processed.

3. Data protection throughout the information lifecycle: Measures ensuring the protection of personal data shall be applicable throughout the entire lifecycle of the information.

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

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

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

7. Accuracy: Personal data shall be accurate and, where necessary, kept up to date; all reasonable measures shall be taken to ensure that inaccurate personal data is erased or rectified without delay, in relation to the purposes for which it is processed.

8. Storage limitation: Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes of the processing of personal data.

9. Integrity and confidentiality: Personal data shall 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

10. Information and training: One of the key elements to ensure the protection of personal data is the training and information provided to the staff involved in its processing. Throughout the information lifecycle, all staff with access to the data will be properly trained and informed about their obligations regarding compliance with data protection regulations.

The Data Protection Policy of the ENTITY is communicated to all staff of the data controller and made available to all interested parties.

Consequently, this Data Protection Policy involves all staff of the data controller, who must be familiar with it and embrace it as their own. Each member is responsible for applying it and ensuring compliance with the data protection regulations relevant to their activities, as well as identifying and suggesting improvements deemed appropriate with the aim of achieving excellence in its compliance.

This Policy will be reviewed by the Management / Governing Body of the ENTITY as often as necessary to ensure it is always in compliance with the current provisions regarding the protection of personal data.