COMPLIANCE WITH REGULATION (EU) 2016/679 AND THE SPANISH DATA PROTECTION REGULATIONS

IDENTIFICATION OF THE RESPONSIBLE FOR THE TREATMENT

a) Name and contact details of the person responsible for the treatment:
– Corporate name / Name and surname: Tour Autocaravanas SL
– CIF / NIF: B13631494
– Activity: Motorhome rental
– Contact phone: 662 601 030
– Registered office: C / calle throw 3, 2C (Miguelturra)
– Address for notification purposes: C / calle throws 3, 2C (Miguelturra)
– Electronic contact address: info@tourautocaravanas.com
– Website (URL): www.tourautocaravanas.com

b) Name and contact details of the person in charge of the treatment:
– There is no person responsible for the treatment

c) Name and contact details of the representative of the person in charge:
– The treatment representative is established in the territory of the European Union

d) Name and contact details of the data protection delegate:
– The entity responsible for the processing has not designated a data protection delegate

I. OBJECT OF THE DOCUMENT.

The Spanish Agency for Data Protection expressed, in its Strategic Plan 2015-2019, its willingness for those responsible for the treatment to achieve high compliance with the obligations that data protection regulations impose on them, fostering a culture of data protection that supposes a clear improvement of the competitiveness, compatible with the economic development.

Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, concerning the protection of natural persons with regard to the processing of personal data and the free movement of these data and by which Directive 95/46 / EC (General Data Protection Regulation) is repealed (DOUE L 119/1, 04-05-2016) (hereinafter, GDPR), provides a modernized framework based on accountability for Data protection in Europe.

In this regard, Article 5 (2) of Regulation (EU) 2016/679 expressly establishes the principle of “proactive responsibility”, according to which the person responsible for the treatment will be responsible for compliance (and able to prove it) of the following principles related to treatment:

– Personal data will be treated in a lawful, loyal and transparent manner in relation to the interested party (“legality, loyalty and transparency”);

– Personal data will be collected for specific, explicit and legitimate purposes, and will not be further processed in a manner incompatible with those purposes; in accordance with article 89, paragraph 1, the further processing of personal data for the purpose of archiving in the public interest, scientific and historical research purposes or statistical purposes shall not be considered incompatible with the initial purposes (“limitation of purpose”) ;

– Personal data will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimization”);

– Personal data will be accurate and, if necessary, updated; all reasonable measures will be taken so that personal data that are inaccurate with respect to the purposes for which they are processed (“accuracy”) are deleted or rectified without delay;

– Personal data will be maintained in a way that allows the identification of the interested parties for no longer than necessary for the purposes of the processing of personal data; personal data may be kept for longer periods provided that they are processed exclusively for archival purposes in the public interest, scientific or historical research purposes or statistical purposes, in accordance with article 89, paragraph 1, without prejudice to the application of the measures appropriate technical and organizational measures imposed by this Regulation in order to protect the rights and freedoms of the interested party (“limitation of the conservation period”);

– Personal data will be treated in such a way that adequate security of personal data is guaranteed, including protection against unauthorized or unlawful treatment and against its loss, destruction or accidental damage, through the application of appropriate technical or organizational measures ( «Integrity and confidentiality»).
In summary, the principle of «proactive responsibility» requires a conscious, diligent and proactive attitude on the part of organizations in relation to all personal data processing
Let them carry out.

In this regard, the Directorate / Governing Body of Tour Autocaravanas SL advocates a proactive compliance policy, in order to ensure that the fundamental right to data protection is actively respected in the development of its purposes.

Consequently, this document is prepared in order to establish the Tour Autocaravanas SL Policy 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 in the Spanish regulations for the protection of personal data (Organic Law, its development rules and specific sector legislation).

II. COMMITMENT OF THE MANAGEMENT / GOVERNMENT BODY WITH DATA PROTECTION.

The Directorate / Governing Body of Tour Autocaravanas SL (hereinafter, the person responsible for the treatment), assumes 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 relation to compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, concerning the protection of natural persons with regard to data processing personal data and the free circulation of these data and repealing Directive 95/46 / EC (General Data Protection Regulation) (DOUE L 119/1, 04-05-2016), and Spanish protection regulations of personal data (Organic Law, specific sector legislation and its development standards).

The Data Protection Policy of Tour Autocaravanas SL 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 said Policy, and is able to demonstrate it before the competent control authorities .

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

1. Protection of data from the design: the person responsible for the treatment will apply, both at the time of determining the means of treatment and at the time of the treatment itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively apply the principles of data protection, such as data minimization, and integrating the necessary guarantees in the treatment.

2. Default data protection: the data controller will apply the appropriate technical and organizational measures with a view to ensuring that, by default, only the personal data that is necessary for each of the specific purposes of the treatment are processed.

3. Data protection in the information life cycle: the measures that guarantee the protection of personal data will be applicable during the entire life cycle of the information.

Data protection policy. Compliance with Regulation (EU) 2016/679 and Spanish data protection regulations

4. Legality, loyalty and transparency: personal data will be treated in a lawful, loyal and transparent manner in relation to the interested party.

5. Limitation of purpose: personal data will be collected for specific, explicit and legitimate purposes, and will not be 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, if necessary, updated; All reasonable measures will be taken so that personal data that are inaccurate with respect to the purposes for which they are processed are deleted or rectified without delay.

8. Limitation of the term of conservation: the personal data will be maintained in a way that allows the identification of the interested parties for no longer than necessary for the purposes of the processing of personal data.

9. Integrity and confidentiality: personal data will be treated in such a way as to ensure adequate security of personal data, including protection against unauthorized or unlawful treatment and against loss, destruction or accidental damage, through the application of measures appropriate technical or organizational.

10. Information and training: one of the keys to guarantee the protection of personal data is the training and information that is provided to the personnel involved in the processing of them. During the information life cycle, all personnel with access to the data will be conveniently trained and informed about their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of Tour Autocaravanas SL is communicated to all personnel responsible for the treatment and made available to all interested parties.

Consequently, this Data Protection Policy involves all personnel responsible for the treatment, who must know and assume it, considering it as their own, each member being responsible for applying it and verifying the data protection rules applicable to their activity. , as well as identify and provide opportunities for improvement that it deems appropriate in order to achieve excellence in relation to compliance.

This Policy will be reviewed by the Directorate / Governing Body of Tour Autocaravanas SL, as many times as deemed necessary, to adapt, at all times, to the provisions in force regarding the protection of personal data.

In Miguelturra, on November 5, 2019.

Address / Governing Body of Tour Autocaravanas SL