The Directorate / Governing Body of Atramentum S.L. (hereinafter, the data controller), assumes the maximum responsibility and commitment to the establishment, implementation, and maintenance of this Data Protection Policy, guaranteeing the continuous improvement of the data controller to achieve excellence 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of these data and by which Directive 95/46 / EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016) is repealed, and of the Spanish regulations for the protection of personal data (Organic Law, specific sectoral legislation and its implementing regulations).
The Atramentum S.L. Data Protection Policy 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:
Data protection by design:
the data controller 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, designed to effectively apply the principles of data protection, such as data minimization, and integrate the necessary guarantees in the treatment.
Data protection by default:
the data controller will apply the appropriate technical and organizational measures to guarantee that, by default, only the personal data that are necessary for each of the specific purposes of the treatment will be processed.
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.
Legality, loyalty and transparency:
personal data will be processed in a lawful, loyal and transparent manner with the interested party.
personal data will be adequate, relevant and limited to what is necessary to the purposes for which they are processed.
the personal data will be exact and, if necessary, updated; All reasonable measures will be taken so that personal data that are inaccurate to the purposes for which they are processed are deleted or rectified without delay.
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 processing of personal data.
Integrity and confidentiality:
personal data will be treated in such a way as to guarantee adequate security of personal data, including protection unauthorized or illegal processing and against accidental loss, destruction or damage, through the application of appropriate technical or organizational measures.
Information and training:
one of the keys to guaranteeing the protection of personal data is the training and information that is provided to the personnel involved in their treatment. During the life cycle of the information, all personnel with access to the data will be properly trained and informed about their obligations to compliance with data protection regulations.
The Atramentum S.L. Data Protection Policy 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 opportunities for improvement that it deems appropriate to achieve excellence to compliance.
This Policy will be reviewed by the Directorate / Governing Body of Atramentum S.L. , as many times as deemed necessary, to adapt, at all times, to the current provisions on the protection of personal data.