The Management / Governing Body of FERNANDO GARCIA CANO (hereinafter, the data controller) assumes the highest 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 compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, concerning the protection of individuals in relation to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (DOUE L 119/1,04-05-2016), and Spanish legislation on personal data protection (Organic Law, specific sectoral legislation, and its implementing regulations).

The Data Protection Policy of FERNANDO GARCIA CANO is based on the principle of proactive responsibility, whereby the data controller is responsible for complying with the regulatory and jurisprudential framework governing this Policy and is able to demonstrate this to the competent supervisory authorities.

In this regard, the data controller will be guided by the following principles that should 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 will apply, both at the time of determining the means of processing and during the actual processing, appropriate technical and organizational measures, such as pseudonymization, designed to effectively implement the principles of data protection, such as data minimization, and integrate the necessary safeguards in 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 processing purpose will be processed.

3. Data protection throughout the lifecycle of information: measures ensuring the protection of personal data will apply throughout the entire lifecycle of the information.

4. Legality, 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, legitimate, and explicit purposes, and will not be processed further in a manner incompatible with those purposes.

6. Data minimization: personal data will be adequate, relevant, and limited to what is necessary concerning the purposes for which they are processed.

7. Accuracy: personal data will be accurate and, where necessary, kept up to date; all reasonable measures will be taken to rectify or delete without delay inaccurate personal data concerning the purposes for which they are processed.

8. Storage limitation: personal data will be kept in a form which permits identification of data subjects for no longer than necessary for the purposes of processing personal data.

9. Integrity and confidentiality: personal data will be processed in a manner that ensures an adequate level of security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, by applying 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 the processing. Throughout the lifecycle of the information, all staff with access to the data will be adequately trained and informed about their obligations concerning compliance with data protection regulations.

The Data Protection Policy of FERNANDO GARCIA CANO 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 adopt it, considering it as their own, with each member being responsible for applying it and verifying the applicable data protection rules related to their activity, as well as identifying and proposing any improvement opportunities they deem appropriate to achieve excellence in compliance.

This Policy will be reviewed by the Management / Governing Body of FERNANDO GARCIA CANO as often as deemed necessary to adapt it at all times to the current regulations on personal data protection.