6th November 2018

(the "Company") is an Organization in which data processing activities of a personal nature occur, which gives it an important responsibility in the design and organization of procedures so that they are aligned with the legal compliance in this matter. In the exercise of these responsibilities and in order to establish the general principles that should govern the treatment of personal data in the Company, approves this Policy of protection of personal data, which notifies its employees and makes available of all its interested groups.


1. Purpose

The Policy of protection of personal data is a measure of proactive responsibility that has the purpose of ensuring compliance with the applicable legislation in this matter and relation to it, respect for the right to honour and privacy in the treatment of data of a personal nature of all the people who are related to the Company. In accordance with the provisions of this Personal Data Protection Policy, the Principles that govern the processing of the data in the organization and, consequently, the procedures, and the organizational and security measures that the people affected by it, are established. This Policy is committed to implement in their area of responsibility. To this end, the Directorate will assign the responsibilities to the personnel that participate in the data processing operations.


2. Scope of application

This Policy of protection of personal data will apply to the Company, its administrators, managers and employees, as well as to all persons who are related to it, with express inclusion of service providers with access to data (" Managers of the treatment ")


3. Principles of the processing of personal data

As a general principle, The Company will scrupulously comply with the legislation on the protection of personal data and must be able to demonstrate it (Principle of "proactive liability"), paying special attention to those treatments that may pose a greater risk to the rights of those affected (Principle of "risk approach").

In relation to the exposed CARMEN VILLAZAN S.L. will ensure compliance with the following Principles:

  • Legality, loyalty, transparency and limitation of the purpose. The data processing must always be informed to the affected party, through clauses and other procedures; and only if there is consent to the processing of data (with special attention to the one provided by minors), or if it has another valid legitimacy and the purpose thereof is in accordance with the Regulations.
  • Minimization of data. The data processed must be adequate, relevant and limited to what is necessary in relation to the purposes of the treatment. - Accuracy. The data must be accurate and, if necessary, updated. In this respect, the necessary measures will be taken to that personal data that are inaccurate with respect to the purposes of processing are deleted or rectified without delay.
  • Limitation of the conservation period. The data will be maintained in such a way that identification of the interested parties is allowed for no longer than necessary for the purposes of the treatment.
  • Integrity and Confidentiality. The data will be treated in such a way as to ensure adequate security of personal data, including protection against unauthorized or illegal treatment and against loss, destruction or accidental damage, through the application of appropriate technical or organizational measures.
  • Data transfers. It is prohibited to purchase or obtain personal data from illegitimate sources or in those cases in which said data have been collected or transferred in contravention of the law or its legitimate origin is not sufficiently guaranteed.
  • Hiring of suppliers with access to data. Only suppliers that offer sufficient guarantees to apply appropriate technical and security measures in data processing will be selected for hiring. With these third parties will be documented due agreement in this regard.
  • International data transfers. Any processing of personal data subject to European Union regulations that involve a transfer of data outside the European Economic Area must be carried out in strict compliance with the requirements established in the applicable law. - Rights of those affected. The Company will provide those affected with the exercise of rights of access, rectification, deletion, limitation of treatment, opposition and portability, establishing for this purpose the internal procedures, and in particular the models for their exercise that are necessary and timely, which must meet, at least, the legal requirements applicable in each case. The Company will promote that the principles contained in this Policy of protection of personal data are taken into account (i) in the design and implementation of all work procedures, (ii) in the products and services offered (iii) in all the contracts and obligations that they formalize or assume and (iv) in the implementation of any systems and platforms that allow the access of employees or third parties and / or the collection or processing of personal data.


4. Commitment of workers

Workers are informed of this Policy and are aware that personal information is an asset of the Company, and in this respect they adhere to it, committing to the following:

  • Carry out awareness training on Data Protection that the Company puts at your disposal.
  • Apply security measures at user level that apply to your job, without prejudice to the design and implementation responsibilities that could be attributed to you based on your role within CARMEN VILLAZAN S.L.
  • Use the established formats for the exercise of Rights by those affected and inform the Company immediately so that the response can be made effective.
  • Inform the Company, as soon as it becomes aware, of deviations from the established in this Policy, in particular "Violations of security of personal data", using the format established for that purpose.


5. Control and evaluation

An annual verification, evaluation and validation will be carried out, or whenever there are significant changes in data processing, the effectiveness of technical and organizational measures to ensure the safety of the treatment.