The Management/Governing Body of SAFAME COMECIAL S.L. (hereinafter referred to as the data controller) assumes the maximum 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 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, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), as well as Spanish legislation on the protection of personal data (Organic Law, specific sectoral legislation, and its implementing regulations).

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

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

1. Data protection by design: The data controller will apply appropriate technical and organizational measures, such as pseudonymization, both at the time of determining the means of processing and at the time of processing itself, 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 will apply appropriate technical and organizational measures to ensure that, by default, only personal data necessary for each specific purpose of the processing is processed.
3. Data protection throughout the information lifecycle: Measures ensuring the protection of personal data will be applicable throughout the entire lifecycle of the information.
4. Lawfulness, fairness, and transparency: Personal data will be processed in a lawful, fair, and transparent manner 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 identification of the data subject for no longer than is necessary for the purposes of processing personal data.
9. Integrity and confidentiality: Personal data will be processed in a manner that ensures appropriate security, 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 key factors in ensuring the protection of personal data is the training and information provided to the staff involved in the processing of such data. Throughout the information lifecycle, all personnel with access to the data will be duly trained and informed of their obligations regarding compliance with data protection regulations.

The Data Protection Policy of SAFAME COMERCIAL S.L. is communicated to all personnel of the data controller and made available to all interested parties.

As a result, this Data Protection Policy involves all personnel of the data controller, who must be aware of it, assume it, and consider it their own. Each member is responsible for implementing and verifying the data protection rules applicable to their activities, as well as identifying and contributing any opportunities for improvement they may consider necessary in order to achieve excellence in compliance.

This Policy will be reviewed by the Management/Governing Body of SAFAME COMERCIAL S.L. as many times as deemed necessary to ensure compliance with current regulations on the protection of personal data.