The Management / Governing Body of WINCHE REDES COMERCIALES S.L. (hereinafter, the person responsible for the treatment), assumes the maximum responsibility and commitment with the establishment, implementation and maintenance of this Data Protection Policy, guaranteeing the continuous improvement of the person responsible for the treatment 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 with regard to the processing of personal data and the free circulation of these data and by which repeals Directive 95/46 / CE (General Data Protection Regulation) (DOUE L 119/1, 04-05-2016), and the Spanish regulations for the protection of personal data (Organic Law, legislation specific sector and its implementing regulations).
The Data Protection Policy of WINCHE REDES COMERCIALES S.L. rests on the principle of proactive responsibility, according to which the person responsible for the treatment is responsible for compliance with the regulatory and jurisprudential framework that governs said Policy, and is capable of demonstrating it before the competent control authorities.
In this sense, the person responsible for the treatment will be governed by the following principles that should serve all its personnel as a guide and frame of reference in the processing of personal data:
1. Data protection from design:
The person in charge of the treatment will apply, both at the time of determining the means of treatment and at the time of the treatment itself, appropriate technical and organizational measures, such as pseudonymisation, designed to effectively apply the principles of data protection, such as minimization data, and integrate the necessary guarantees in the treatment.
2. Data protection by default:
The person in charge of the treatment will apply the appropriate technical and organizational measures in order to guarantee that, by default, only the personal data that are necessary for each of the specific purposes of the treatment will be processed.
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 in a lawful, loyal and transparent manner in relation to the interested party.
5. Limitation of purpose
Personal data will be collected for specific, explicit and legitimate purposes, and will not be further processed in a manner incompatible with those purposes.
6. Data minimization
Personal data will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
Personal data will be accurate and, if necessary, updated; All reasonable measures will be taken so that personal data that are inaccurate with respect to the purposes for which they are processed are deleted or rectified without delay.
8. Limitation of the conservation period:
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 personal data.
9. Integrity and confidentiality:
Personal data will be treated in such a way that adequate security of personal data is guaranteed, including protection against unauthorized or illegal processing and against accidental loss, destruction or 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 treatment. During the information life cycle, 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 WINCHE REDES COMERCIALES S.L. It 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 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 regulations applicable to their activity. , as well as identifying and providing the improvement opportunities that it deems appropriate in order to achieve excellence in relation to its compliance.
This Policy will be reviewed by the Management / Governing Body of WINCHE REDES COMERCIALES S.L., as many times as deemed necessary, to adapt, at all times, to the current provisions on the protection of personal data.