Commitment to the Protection of Personal Data

The Management of Alberto Alzuria Llamas (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, regarding the protection of natural persons in regarding the processing of personal data and the free circulation of these data and repealing Directive 95/46/EC (General Data Protection Regulation) (DOUE L 119/1, 05-04-2016), and the Spanish regulations on the protection of personal data (Organic Law, specific sectoral legislation and its implementing regulations).

The Data Protection Policy of Alberto Alzuria Llamas rests on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework that governs said Policy, and is capable of prove it to the competent control authorities.

In this sense, the data controller will be governed by the following principles that must serve all its staff as a guide and frame of reference 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 apply the principles of data protection, such as data minimization, and integrate the necessary guarantees in the treatment.
  2. Data protection by default: the data controller will apply the appropriate technical and organizational measures in order to guarantee that, by default, only the personal data that is necessary for each of the purposes are processed. treatment specifics.
  3. Data protection in the information life cycle: the measures that guarantee the protection of personal data will be applicable during the complete life cycle of the information.
  4. Legality, loyalty and transparency: personal data will be processed lawfully, loyally and transparently in relation to the interested party.
  5. Purpose limitation: personal data will be collected for specific, explicit and legitimate purposes, and will not be further processed in a manner incompatible with said purposes.
  6. Minimization of data: personal data will be adequate, pertinent and limited to what is necessary in relation to the purposes for which they are processed.
  7. Accuracy: the personal data will be exact and, if necessary, updated; All reasonable steps will be taken to promptly delete or rectify personal data that is inaccurate with respect to the purposes for which it is processed.
  8. Limitation of the period of conservation: the personal data will be kept in a way that allows the identification of the interested parties for no longer than is necessary for the purposes of the processing of the personal data.
  9. Integrity and confidentiality: personal data will be treated in such a way as to guarantee adequate security of personal data, including protection against unauthorized or unlawful processing and against loss, destruction or accidental damage, through the application of appropriate technical or organizational measures.
  10. Information and training: One of the keys to guaranteeing the protection of personal data is the training and information provided to the personnel involved in their processing. During the life cycle of the information, all personnel with access to the data will be suitably trained and informed about their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of Alberto Alzuria Llamas is communicated to all the personnel of the data controller and made available to all interested parties.

Consequently, this Data Protection Policy involves all the personnel of the person responsible for the treatment, who must know it and assume it, considering it as their own, each member being responsible for applying it and verifying the data protection regulations applicable to their activity. , as well as identify and provide the improvement opportunities it deems appropriate with the aim of achieving excellence in relation to compliance.

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