Data protection policy

The Management / Governing Body of REACTIVACIÓ BADALONA S.A. (hereinafter, the controller), assumes the maximum responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, ensuring the continuous improvement of the controller in order to achieve 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 individuals with regard to the processing of personal data and on the free movement of such data repealing Directive 95/46 / EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), and the Spanish legislation on the protection of personal data (Organic Law, legislation sector-specific and its development standards).

The Data Protection Policy of REACTIVACIÓ BADALONA S.A. it is based on the principle of proactive responsibility, according to which the controller is responsible for complying with the regulatory and jurisprudential framework that governs this Policy, and is able to demonstrate this to the competent control authorities.

In this sense, the controller will be governed by the following principles that should serve all its staff as a guide and frame of reference in the processing of personal data:

Data protection from the design: the controller shall apply, both at the time of determining the means of treatment and at the time of the processing itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively apply the principles of data protection, such as data minimization, and integrate the necessary safeguards into processing.

Default data protection: the controller will apply the appropriate technical and organizational measures to ensure that, by default, only the personal data that are necessary for each of the specific purposes of the processing are 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 treated in a lawful, fair and transparent manner in relation to the interested party.

Limitation of purpose: personal data will be collected for specific, explicit and legitimate purposes, and will not be further processed in a manner 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: personal data will be accurate and, if necessary, up to date; all reasonable steps shall be taken to delete or rectify without delay personal data which are inaccurate with respect to the purposes for which they are processed.

Limitation of the retention period: personal data will be kept in a way that allows the identification of the interested parties for no longer than necessary for the purposes of processing personal data.

Integrity and confidentiality: personal data will be treated in such a way as to ensure adequate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, through the application of technical measures or appropriate organizational.

Information and training: one of the keys to ensuring the protection of personal data is the training and information provided to staff involved in the processing of the same. During the information life cycle, all staff with access to data will be appropriately trained and informed about their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of REACTIVACIÓ BADALONA S.A. it is communicated to all staff of the controller and made available to all interested parties.

Consequently, this Data Protection Policy involves all the staff 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 rules applicable to their activity. , as well as to identify and contribute the opportunities of improvement that it considers opportune with the aim of reaching the excellence in relation to its fulfillment.

This Policy will be reviewed by the Management / Governing Body of REACTIVACIÓ BADALONA S.A., as many times as deemed necessary, to comply, at all times, with the provisions in force regarding the protection of personal data.