Data protection policy

The Management / Governing Body of LUX ISLA SL (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 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 data processing personal and free circulation of these data and repealing Directive 95/46 / EC (General Data Protection Regulation) (DOUE L 119/1, 04-05-2016), and the Spanish protection regulations of personal data (Organic Law, specific sectoral legislation and its implementing regulations).

The Data Protection Policy of LUX ISLA SL rests on the principle of proactive responsibility, according to which the controller is responsible for compliance with the regulatory and jurisprudential framework that governs said Policy, and is able to demonstrate it to 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 staff as a guide and frame of reference in the treatment of personal data:

1. Data protection from design: the controller will apply, both when 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 data minimization, and integrate the necessary guarantees in the treatment.
2. Data protection by default: the controller will apply the appropriate technical and organizational measures with a view to ensuring that, by default, only the personal data that is necessary for each of the specific purposes of the treatment is subject to treatment.
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. Purpose limitation: 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.
7. Accuracy: the personal data will be exact and, if necessary, updated; All reasonable measures will be taken so that personal data that are inaccurate regarding the purposes for which they are processed are deleted or rectified without delay.
8. Limitation of the conservation period: personal data will be kept in such a way that the identification of the interested parties is allowed for no longer than necessary for the purposes of the treatment of personal data.
9. Integrity and confidentiality: personal data will be treated in such a way as to guarantee adequate security of personal data, including protection against unauthorized or unlawful treatment and against its loss, destruction or accidental damage, by applying technical measures or appropriate organizational.
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 the treatment of the same. During the information life cycle, all personnel with access to the data will be suitably trained and informed about their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of LUX ISLA SL is communicated to all the personnel responsible for the treatment and made available to all interested parties.

As a consequence, this Data Protection Policy involves all the personnel responsible for the treatment, who must know 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 the opportunities for improvement that it deems appropriate with the aim of achieving excellence in relation to compliance.

This Policy will be reviewed by the Management / Governing Body of LUX ISLA SL, as many times as deemed necessary, in order to comply, at all times, with the provisions in force regarding the protection of personal data.