Data protection Policy

OUR COMMITMENT TO THE PROTECTION OF PERSONAL DATA: “INFORMED INDIVIDUALS AND PROTECTED DATA”

The Management / Governing Body of Aturnos Solutions S.L (hereinafter, the data controller) assumes full responsibility and is fully committed to the establishment, implementation and maintenance of this Data Protection Policy, ensuring the data controller’s continuous improvement with the aim 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, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJEU L 119/1, 04-05-2016), and Spanish legislation on the protection of personal data (Organic Law, specific sectoral legislation and its implementing regulations).

The data protection policy of Aturnos Solutions S.L is based on the principle of proactive accountability, according to which the data controller is required to comply with the regulatory and case-law framework governing this policy, and is able to demonstrate this to the relevant supervisory authorities.

In this regard, the data controller shall adhere to the following principles, which should serve as a guide and framework for all staff when processing personal data:

1. Data protection by design: the data controller shall implement, both when determining the means of processing and at the time of processing itself, appropriate technical and organisational measures, such as pseudonymisation, designed to effectively apply data protection principles, such as data minimisation, and to incorporate the necessary safeguards into the processing.
2. Data protection by default: the data controller shall implement appropriate technical and organisational measures to ensure that, by default, only personal data that is necessary for each of the specific purposes of the processing is processed.
3. Data protection throughout the information lifecycle: measures to ensure the protection of personal data shall apply throughout the entire information lifecycle.
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, explicit and legitimate purposes, and shall not be further processed in a manner incompatible with those purposes.
6. Data minimisation: personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
7. Accuracy: personal data shall be accurate and, where necessary, kept up to date; every reasonable step shall be taken to ensure that personal data which are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
8. Limitation of storage period: personal data will be retained in a form that allows for the 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 will be processed in such a way as to ensure appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by implementing appropriate technical or organisational measures.
10. Information and training: one of the key factors in ensuring the protection of personal data is the training and information provided to staff involved in processing such data. 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 Aturnos Solutions S.L is communicated to all staff of the data controller and made available to all interested parties.

Consequently, this Data Protection Policy applies to all staff of the data controller, who must familiarise themselves with it and embrace it as their own; each member is responsible for implementing it and verifying the data protection regulations applicable to their work, as well as identifying and proposing any improvements they deem appropriate with the aim of achieving excellence in compliance.

This Policy will be reviewed by the Management / Governing Body of Aturnos Solutions S.L as often as deemed necessary, to ensure that it complies at all times with the current provisions on the protection of personal data.