Commitment to Personal Data Protection

OUR COMMITMENT TO PERSONAL DATA PROTECTION: “INFORMED PEOPLE AND PROTECTED DATA”

The Management / Governing Body of MASKELINE S.L. (hereinafter, the data controller) assumes the highest 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 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, repealing Directive 95/46/EC (General Data Protection Regulation) (OJEU L 119/1, 04-05-2016), and with Spanish personal data protection legislation (Organic Law, specific sector legislation and its implementing rules).

The Data Protection Policy of MASKELINE S.L. rests on the principle of proactive accountability, whereby the data controller is responsible for compliance with the regulatory and case-law framework governing that Policy, and is able to demonstrate it before the competent supervisory authorities.

Accordingly, the data controller shall be governed by the following principles, which 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 shall apply, both when determining the means of processing and at the time of the processing itself, appropriate technical and organisational measures, such as pseudonymisation, designed to implement data protection principles effectively, such as data minimisation, and to integrate the necessary safeguards into the processing.

2. Data protection by default: the data controller shall apply appropriate technical and organisational measures to ensure that, by default, only personal data which are necessary for each specific purpose of the processing are processed.

3. Data protection throughout the information life cycle: the measures guaranteeing the protection of personal data shall apply throughout the full life cycle 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, 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 they are 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 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 the 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 unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

10. Information and training: one of the keys to guaranteeing the protection of personal data is the training and information provided to the staff involved in processing it. Throughout the information life cycle, all staff with access to the data shall be duly trained and informed about their obligations regarding compliance with data protection regulations.

The Data Protection Policy of MASKELINE S.L. 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 know it and adopt it as their own, each member being responsible for applying it and for verifying the data protection rules applicable to their activity, as well as for identifying and contributing any improvement opportunities they consider appropriate with the aim of achieving excellence in its fulfilment.

This Policy shall be reviewed by the Management / Governing Body of MASKELINE S.L. as many times as deemed necessary, so that it is adapted at all times to the provisions in force on the protection of personal data.