Data Protection Policy

The Management / Governing Body of GINÉS MARTÍNEZ E HIJOS S.L. (hereinafter, the data controller) assumes the highest responsibility and commitment to establishing, implementing and maintaining this Data Protection Policy, ensuring the continuous improvement of the data controller to achieve excellence in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation – GDPR), and the corresponding Spanish data protection legislation (Organic Law, sectoral laws and development regulations).

The Data Protection Policy of GINÉS MARTÍNEZ E HIJOS S.L. is based on the principle of proactive responsibility, by which the data controller is accountable for compliance with the regulatory and case law framework governing this Policy and must be able to demonstrate such compliance before the competent supervisory authorities.

Accordingly, the data controller is guided by the following principles, which all staff members should use as a reference for handling personal data:

Data protection by design: Appropriate technical and organizational measures will be applied from the moment processing means are determined and during processing itself, such as pseudonymization, to effectively implement data protection principles and safeguards, including data minimization.
Data protection by default: Only personal data strictly necessary for each specific purpose will be processed by default.
Data protection throughout the information lifecycle: Measures ensuring data protection will be applied throughout the entire data lifecycle.
Lawfulness, fairness and transparency: Data will be processed lawfully, fairly, and transparently in relation to the data subject.
Purpose limitation: Data will be collected for specific, explicit and legitimate purposes and will not be processed further in a way incompatible with those purposes.
Data minimization: Personal data will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
Accuracy: Data will be accurate and, where necessary, kept up to date; all reasonable steps will be taken to ensure that inaccurate data are rectified or erased without delay.
Storage limitation: Personal data will not be kept for longer than necessary for the purposes for which they are processed.
Integrity and confidentiality: Data will be processed in a manner that ensures adequate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organizational measures.
Information and training: Providing staff with the necessary training and information is key to ensuring data protection. All personnel with access to data will be properly trained and informed throughout the data lifecycle. This Data Protection Policy is communicated to all personnel of the data controller and made available to all interested parties.

This Data Protection Policy is communicated to all personnel of the data controller and made available to all interested parties.

As such, the Policy involves all personnel, who must understand and adopt it as their own. Each member is responsible for applying the Policy, ensuring compliance with applicable data protection laws and proposing improvements where appropriate, with the aim of achieving excellence in compliance.

This Policy will be reviewed by the Management / Governing Body of GINÉS MARTÍNEZ E HIJOS S.L. as often as necessary to remain in line with current personal data protection regulations.