COMMITMENT TO PERSONAL DATA PROTECTION

Our commitment to personal data protection: “informed individuals and protected data”

 

The Board of Directors / Governing Body of FRUTAS Y TURRONES S.A. (hereinafter the data controller) assumes the highest responsibility and commitment for the establishment, implementation, and maintenance of this Data Protection Policy, ensuring 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, repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), and the Spanish regulations on personal data protection (Organic Law, specific sectoral legislation, and its implementing regulations).

The Data Protection Policy of FRUTAS Y TURRONES S.A. rests on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework that governs this Policy and is able to demonstrate it before the competent supervisory authorities.

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

  1. Data protection by design: The data controller will apply, both at the time of determining the means of processing and at the time of the actual processing, appropriate technical and organizational measures, such as pseudonymization, designed to apply data protection principles effectively, such as data minimization, and to integrate the necessary safeguards into the processing.
  2. Data protection by default: The data controller will apply appropriate technical and organizational measures to ensure that, by default, only personal data necessary for each specific purpose of the processing are processed.
  3. Data protection throughout the information lifecycle: Measures ensuring the protection of personal data will be applicable throughout the entire information lifecycle.
  4. Lawfulness, fairness, and transparency: Personal data will be processed lawfully, fairly, and transparently in relation to the data subject.
  5. Purpose limitation: Personal data will be collected for specified, explicit, and legitimate purposes and not 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: Personal data will be accurate and, where necessary, kept up to date; every reasonable step will 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.
  8. Storage limitation: Personal data will be kept in a form that permits the 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 will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
  10. Information and training: One of the keys to ensuring the protection of personal data is the training and information provided to personnel involved in the processing. Throughout the information lifecycle, all personnel with access to the data will be appropriately trained and informed about their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of FRUTAS Y TURRONES S.A. is communicated to all the data controller’s personnel and made available to all interested parties.

Consequently, this Data Protection Policy involves all the data controller’s personnel, who must know and assume it, considering it their own. Each member is responsible for applying it and verifying the data protection rules applicable to their activity, as well as identifying and contributing improvement opportunities they deem appropriate, aiming to achieve excellence in compliance.

This Policy will be reviewed by the Board of Directors / Governing Body of FRUTAS Y TURRONES S.A. as many times as deemed necessary to comply at all times with the provisions in force regarding personal data protection.