Data Protection

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OUR COMMITMENT TO THE PROTECTION OF PERSONAL DATA: “INFORMED INDIVIDUALS AND PROTECTED DATA”

The Management / Governance Body of MARK MENZHAUSEN (hereinafter, the data controller), assumes the highest 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 the processing of personal data and the free movement of these data and repealing Directive 95/46/EC (General Data Protection Regulation) (DOUE L 119/1, 04-05-2016), and Spanish personal data protection regulations (Organic Law, specific sectoral legislation, and its implementing rules).

The Data Protection Policy of MARK MENZHAUSEN 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 this Policy and is able to demonstrate this to the competent control authorities.

In this regard, the data controller will be guided by the following principles that should serve all its staff as a guide and framework 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 processing itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively apply the principles of data protection, such as data minimization and to integrate the necessary guarantees in the processing.
  2. Data protection by default: the data controller will apply appropriate technical and organizational measures to ensure that by default only the personal data necessary for each of the specific purposes of the processing is processed.
  3. Data protection in the information lifecycle: measures that ensure the protection of personal data will be applicable during the complete life cycle of the information.
  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 shall be collected for specific, explicit and legitimate purposes and shall not be further processed in a manner that is 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; all reasonable measures shall be taken to ensure that personal data that are inaccurate with 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 such a manner as to ensure adequate 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 the processing of such data. During the information lifecycle, all staff with access to data will be properly trained and informed about their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of MARK MENZHAUSEN is communicated to all staff of the data controller and made available to all interested parties.

Accordingly, this Data Protection Policy involves all the 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 checking the data protection rules applicable to their activity, as well as identifying and providing the improvement opportunities they consider appropriate in order to achieve excellence in relation to compliance.

This Policy will be reviewed by the Management / Governance Body of MARK MENZHAUSEN as often as necessary, to adapt at all times to the current provisions on the protection of personal data.