Data Protection Policy

The Management / Governing Body of IBORRA E HIJOS SL (hereinafter, the data controller), assumes the highest responsibility and commitment to the establishment, implementation, and maintenance of this Data Protection Policy, ensuring continuous improvement of the data controller with the aim of achieving excellence in 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 Spanish data protection regulations (Organic Law, specific sectoral legislation, and its implementing rules).

The Data Protection Policy of IBORRA E HIJOS SL is based on the principle of proactive responsibility, according to which the data controller is responsible for complying with the normative and jurisprudential framework that governs this Policy, and is capable of demonstrating this to the competent control authorities.

In this regard, the data controller shall be governed by the following principles which should serve as a guide and reference framework for all its personnel 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 processing itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively implement data protection principles such as data minimization, and to 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 which are necessary for each specific purpose of the processing are processed.
3. Data protection in the lifecycle of information: measures ensuring 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 that is 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; every reasonable step must be taken to ensure that personal data that are inaccurate, with regard to the purposes for which they are processed, are erased or rectified without delay.
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 way 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 personnel involved in the processing of the data. Throughout the information lifecycle, all personnel with access to the data will be properly trained and informed about their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of IBORRA E HIJOS SL is communicated to all personnel of the data controller and made available to all interested parties.

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