The Management / Governing Body of TOPTRAX S.L. (hereinafter, the data controller), assumes maximum responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, ensuring 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 27 April 2016, on the protection of individuals with regard to the processing of personal data and the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulations) (OJEU L 119/1, 04-05-2016), and the Spanish regulations on the protection of personal data (Organic Law, specific sectoral legislation and its implementing regulations).

The Data Protection Policy of TOPTRAX S.L. is based on the principle of proactive responsibility, according to which the data controller is responsible for complying with the regulatory and jurisprudential framework that governs said Policy, and is capable of demonstrating this before the competent control authorities.

In this sense, the data controller will be governed by the following principles that must serve all his staff as a guide and frame of reference in the processing of personal data:

Data protection by design: the data controller shall apply appropriate technical and organisational measures, such as pseudonymisation, designed to effectively apply data protection principles, such as data minimisation, and to integrate the necessary guarantees in the processing, both at the time of determining the means of processing and at the time of the processing itself.

Data protection by default: the controller shall implement appropriate technical and organisational measures with a view to ensuring that, by default, only personal data which are necessary for each of the specific purposes of processing are processed.
Data protection in the information lifecycle: the measures ensuring the protection of personal data will be applicable during 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 will be collected for specified, explicit and legitimate purposes and will not be further processed in a manner incompatible with those purposes.

Minimisation of data: personal data will 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, if necessary, kept up to date; all reasonable steps shall be taken to ensure that personal data which are inaccurate in relation to the purposes for which they are processed are deleted or rectified without delay.

Limitation of the storage period: personal data will be kept in such a way as to allow identification of data subjects for no longer than is necessary for the purposes of processing personal data.

Integrity and confidentiality: personal data shall be processed in such a way as to ensure adequate security of personal data, including protection against unauthorised or unlawful processing and against their accidental loss, destruction or damage, through the application of appropriate technical or organisational measures.

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

The Data Protection Policy of TOPTRAX S.L. is communicated to all staff of the person responsible for processing and making it available to all interested parties.

Consequently, this Data Protection Policy involves all the personnel of the data controller, who must know it 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 identifying and providing opportunities for improvement that it deems appropriate with the aim of achieving excellence in relation to compliance.

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