Data Protection Policy

WARNING: THE ENGLISH VERSION OF THE DATA PROTECTION POLICY IS FOR PURELY INFORMATIONAL PURPOSES. IN THE EVENT OF ANY CONTRADICTION BETWEEN THE ENGLISH VERSION AND THE SPANISH VERSION, THE LATTER SHALL ALWAYS PREVAIL.

The Management / Governing Body of VISTA POINT SC (hereinafter, the person responsible for the treatment), assumes the maximum responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, guaranteeing the continuous improvement of the person responsible for the treatment with the objective 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 data personal data and the free movement of such data and repealing Directive 95/46 / EC (General Data Protection Regulation) (OJEU L 119/1, 04-05-2016), and Spanish protection legislation of personal data (Organic Law, specific sector legislation and its development regulations).

VISTA POINT SC´s Data Protection Policy rests on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework that governs such Policy, and is able to demonstrate it to the competent control authorities.

In this sense, the person responsible for the data treatment will be governed by the following principles that should serve all its personnel as a guide and frame of reference in the processing of personal data:

  1. Data protection by design: the controller will implement, both at the time of the determination of the means for 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 integrate the necessary safeguards into the processing.
  2. Data protection by default: the data controller will apply the appropriate technical and organizational measures in order to guarantee that, by default, only the personal data necessary for each specific purposes of the processing will be processed.
  3. Data protection throughout the information lifecycle: the person responsible for the data treatment will take the necessary measures that guarantee that the protection of personal data will be applicable during the entire lifecycle of the information.
  4. Fair, lawful and transparent processing: Personal data must be processed lawfully, fairly and in a transparent manner in relation to the data subject.
  5. Purpose limitation principle: Personal data may only be collected for specified, explicit and legitimate purposes and must not be further processed in a manner that is incompatible with those purposes.
  6. Data minimization: Personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which those data are processed.
  7. Accuracy: Personal data must be accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that are inaccurate are either erased or rectified without delay.
  8. Data retention periods: Personal data must be kept in a form that 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 must be processed in a manner that ensures appropriate security of those data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
  10. Information and training: one of the keys to guarantee the protection of personal data is the training and information provided to the personnel involved in their treatment. During the information life cycle, all personnel 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 VISTA POINT S.C is communicated to all personnel subject to be responsible for the treatment and made available to all interested parties.

As a consequence, this Data Protection Policy involves all the personnel subject to be responsible for the treatment, who must know and assume it, considering it as their own, with each member being responsible for applying it and verifying which data protection rules are applicable to their activity, as well as identifying and contributing for any improvement that it considers appropriate with the aim of achieving excellence in relation to compliance.

This Policy will be reviewed by the Directorate / Governing Body of VISTA POINT S.C, as many times as deemed necessary, to adapt, at all times, to the current provisions on the protection of personal data.