Data Protection Policy - esennia

DATA PROTECTION POLICY

Commitment to the privacy and security of your personal data

The Management / Governing Body of KHATNANI, S.L. (hereinafter, the data controller), assumes the utmost responsibility and commitment to 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 relation to 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) (OJEU L 119/1, 04-05-2016), and with Spanish personal data protection legislation (Organic Law, specific sectoral legislation, and its implementing regulations).

The Data Protection Policy of KHATNANI, S.L. is based on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework governing said Policy, and is able to demonstrate it to the competent supervisory authorities.

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

  1. Data protection by design: the data controller shall apply, both at the time of determining the means of processing and at the time of the processing itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively implement data protection principles, such as data minimization, and to integrate the necessary safeguards into the processing.
  2. Data protection by default: the data controller shall 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 shall be applicable throughout the complete information lifecycle.
  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 minimization: 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 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 shall be kept in a form which 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 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 staff involved in their processing. During the information lifecycle, all personnel with access to data shall be appropriately trained and informed about their obligations regarding compliance with data protection regulations.

The Data Protection Policy of KHATNANI, S.L. is communicated to all staff of the data controller and made available to all interested parties.

Consequently, this Data Protection Policy involves all staff of the data controller, who must know and assume it, considering it as their own, with each member being responsible for applying it and verifying the data protection rules applicable to their activity, as well as identifying and providing improvement opportunities they consider appropriate with the aim of achieving excellence in relation to compliance.

This Policy shall be reviewed by the Management / Governing Body of KHATNANI, S.L., as many times as considered necessary, to adapt, at all times, to the current provisions on personal data protection.

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