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The Management / Governing Body of TOPTRAX S.L. (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 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 and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), and Spanish regulations on the protection of personal data (Organic Law, specific sectoral legislation and its implementing rules).
The Data Protection Policy of TOPTRAX S.L. is based on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework governing said Policy, and is able to demonstrate it before the competent supervisory authorities.
In this regard, the data controller shall be governed by the following principles, which must serve all its personnel as a guide and reference framework in the processing of personal data:
The data controller shall 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 data protection principles, such as data minimization, and to integrate the necessary safeguards into the processing.
The data controller shall apply appropriate technical and organizational measures in order to ensure that, by default, only personal data which are necessary for each of the specific purposes of the processing are processed.
Data protection throughout the information lifecycle: the measures that ensure the protection of personal data shall be applicable throughout the entire lifecycle of the information.
Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject.
Personal data shall be collected for specified, explicit and legitimate purposes and shall not be further processed in a manner incompatible with those purposes.
Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
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, having regard to the purposes for which they are processed, are erased or rectified without delay.
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.
Personal data shall be processed in such a manner as to ensure appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, through the application of appropriate technical or organizational measures.
One of the keys to ensuring the protection of personal data is the training and information provided to personnel involved in their processing. Throughout the lifecycle of the information, all personnel with access to the data shall be duly trained and informed about their obligations in relation to compliance with data protection regulations.
The Data Protection Policy of TOPTRAX S.L. is communicated to all personnel of the data controller and made available to all interested parties.
Consequently, this Data Protection Policy involves all personnel of the data controller, who must be aware of it and assume it, considering it as their own, each member being responsible for applying it and verifying the data protection rules applicable to their activity, as well as identifying and providing improvement opportunities that they consider appropriate with the aim of achieving excellence in relation to its compliance.
This Policy shall be reviewed by the Management / Governing Body of TOPTRAX S.L., as many times as deemed necessary, in order to adapt, at all times, to the current provisions regarding personal data protection.
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