The Management / Governing Body of Valdinox, S.L. (hereinafter, the Data Controller) assumes the utmost 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 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) (OJ L 119/1, 04-05-2016), as well as Spanish legislation on personal data protection (Organic Law, specific sectoral legislation, and implementing regulations).

Valdinox, S.L.'s Data Protection Policy is based on the principle of accountability, according to which the Data Controller is responsible for compliance with the legal and case-law framework governing this Policy and is able to demonstrate such compliance before the competent supervisory authorities.

Accordingly, the Data Controller shall be governed by the following principles, which shall serve as guidance and a framework of reference for all personnel involved in the processing of personal data:

• Data protection by design: the Data Controller shall implement, both when determining the means of processing and during the processing itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively apply data protection principles, such as data minimization, and to integrate the necessary safeguards into the processing.
• Data protection by default: the Data Controller shall implement appropriate technical and organizational measures to ensure that, by default, only personal data necessary for each specific processing purpose are processed.
• Data protection throughout the information lifecycle: measures ensuring the protection of personal data shall apply throughout the entire lifecycle of the information.
• Lawfulness, fairness, and transparency: personal data shall be processed lawfully, fairly, and transparently in relation to the data subject.
• 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.
• Data minimization: personal data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
• Accuracy: personal data shall be accurate and, where necessary, kept up to date; all reasonable measures shall be taken to ensure that inaccurate personal data are erased or rectified without delay, taking into account the purposes for which they are processed.
• Storage limitation: personal data shall be kept in a form that permits identification of data subjects for no longer than is necessary for the purposes of the processing.
• Integrity and confidentiality: personal data shall be processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, through the implementation of appropriate technical and organizational measures.
• Information and training: one of the key elements in ensuring the protection of personal data is the training and information provided to personnel involved in processing such data. Throughout the information lifecycle, all personnel with access to personal data shall receive appropriate training and information regarding their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of Valdinox, S.L. is communicated to all personnel of the Data Controller and made available to all interested parties.

Consequently, this Data Protection Policy involves all personnel of the Data Controller, who must be familiar with and assume responsibility for it, considering it as their own. Each member is responsible for applying it, verifying the data protection rules applicable to their activities, and identifying and proposing any opportunities for improvement that they deem appropriate in order to achieve excellence in compliance.

This Policy shall be reviewed by the Management / Governing Body of Valdinox, S.L. as often as deemed necessary in order to ensure continuous compliance with the applicable provisions governing personal data protection.