Data Protection Policy

The Management / Governing Body of Ballena Alegre Management SL (hereinafter, the Data Controller) assumes the highest level of 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 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), as well as Spanish legislation on the protection of personal data (Organic Law, specific sectoral legislation, and implementing regulations).

The Data Protection Policy of the Data Controller is based on the principle of accountability, according to which the Data Controller is responsible for compliance with the legal and case-law framework governing this Policy and is able to demonstrate such compliance to the competent supervisory authorities.

In this regard, the Data Controller shall be governed by the following principles, which must serve as a guide and framework of reference for all personnel involved in the processing of personal data:

  1. Data protection by design: the Data Controller shall implement appropriate technical and organisational measures, such as pseudonymisation, both when determining the means of processing and at the time of processing itself, designed to effectively apply data protection principles, such as data minimisation, and to integrate the necessary safeguards into processing activities.
  2. Data protection by default: the Data Controller shall implement appropriate technical and organisational measures to ensure that, by default, only personal data that are necessary for each specific processing purpose are processed.
  3. Data protection throughout the information lifecycle: measures ensuring the protection of personal data shall apply throughout the entire lifecycle of the information.
  4. Lawfulness, fairness and transparency: personal data shall be processed lawfully, fairly and transparently in relation to the data subject.
  5. Purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes and shall not be further processed in a manner incompatible with those purposes.
  6. Data minimisation: personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  7. Accuracy: personal data shall be accurate and, where necessary, kept up to date. Every reasonable step shall be taken to ensure that inaccurate personal data are erased or rectified without delay, having regard to the purposes for which they are processed.
  8. Storage limitation: personal data shall be kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
  9. Integrity and confidentiality: personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, through the application of appropriate technical or organisational measures.
  10. Information and training: one of the key elements in ensuring the protection of personal data is the training and information provided to personnel involved in processing activities. Throughout the information lifecycle, all personnel with access to personal data shall receive appropriate training and information regarding their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of the Data Controller is communicated to all personnel of the Data Controller and made available to all interested parties.

Consequently, this Data Protection Policy applies to all personnel of the Data Controller, who must be familiar with it and assume it as their own, with each member being responsible for applying it, verifying the data protection regulations applicable to their activities, and identifying and proposing any improvement opportunities deemed appropriate in order to achieve excellence in compliance.

This Policy shall be reviewed by the Management / Governing Body of the Data Controller as often as deemed necessary to ensure its ongoing adaptation to current personal data protection regulations.