Personal data protection policy

15-05-2019

WATA FACTORY S.L. (the "Company") is an Organization in which personal data processing activities take place, which gives it an important responsibility in the design and organization of procedures so that they are aligned with the legal compliance in this matter.

In the exercise of these responsibilities and in order to establish the general principles that should govern the processing of personal data in the Company, approves this Policy for the protection of personal data, which notifies its employees and makes available to all its stakeholders.

1. Purpose

The Personal Data Protection Policy is a proactive Responsibility measure that aims to ensure compliance with applicable legislation in this area and related to it, respect for the right to honor and privacy in the processing of personal data of all persons who relate to The Company.

In accordance with the provisions of this Personal Data Protection Policy, the Principles governing the processing of data in the organisation are established and, consequently, the procedures and organisational and security measures that the persons affected by this Policy undertake to implement in their area of responsibility.

To this end, TOTALDAT, S.L.U. with address at C/ JOAQUIN SANCHEZ VALVERDE; 3 BADAJOZ, BADAJOZ and e-mail ----, together with the Management will assign the responsibilities to the personnel participating in the data processing operations.

2. Scope of application

This Personal Data Protection Policy shall apply to the Company, its directors, officers and employees, as well as to all persons related to the Company, expressly including service providers with access to data ("Data Processors").

3. Principles for the processing of personal data

As a general principle, The Company will scrupulously comply with the legislation on the protection of personal data and must be able to demonstrate this (Principle of "proactive responsibility"), paying special attention to those treatments that may pose a greater risk to the rights of those affected (Principle of "risk approach").

In relation to the foregoing, WATA FACTORY S.L. will ensure compliance with the following Principles:

Lawfulness, loyalty, transparency and limitation of the purpose. The treatment of data must always be informed to the affected, by means of clauses and other procedures; and it will only be considered legitimate if there is consent for the treatment of data (with special attention to the one given by the minors), or it has another valid legitimation and the purpose of the same one is according to Regulation.

Minimisation of data. The data processed must be adequate, relevant and limited to what is necessary in relation to the purposes of the processing.

Accuracy. The data must be accurate and, if necessary, up to date. In this respect, the necessary measures shall be taken to delete or rectify without delay personal data that are inaccurate with respect to the purposes of the processing.

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

Integrity and Confidentiality. 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 accidental loss, destruction or damage, through the application of appropriate technical or organisational measures.

Transfers of data. It is forbidden to purchase or obtain personal data from illegitimate sources or in those cases in which such data have been collected or transferred in contravention of the law or their legitimate origin is not sufficiently guaranteed.

Contracting suppliers with access to data. Only suppliers that offer sufficient guarantees to apply appropriate technical and security measures in the processing of data will be chosen for contracting. The appropriate agreement in this respect will be documented with these third parties.

International data transfers. Any processing of personal data subject to European Union regulations that involves a transfer of data outside the European Economic Area must be carried out in strict compliance with the requirements established in the applicable law.

Rights of those affected. The Company will facilitate the exercise of the rights of access, rectification, suppression, limitation of processing, opposition and portability, establishing for this purpose the internal procedures, and in particular the models for their exercise that are necessary and appropriate, which must satisfy, at least, the legal requirements applicable in each case.

The Company will encourage the principles contained in this Personal Data Protection Policy to be taken into account (i) in the design and implementation of all work procedures, (ii) in the products and services offered, (iii) in all contracts and obligations that they formalize or assume and (iv) in the implementation of any systems and platforms that allow access by employees or third parties and/or the collection or processing of personal data.

4. Commitment of workers

Employees are informed of this Policy and declare that they are aware that personal information is an asset of the Company, and in this respect adhere to it, committing to the following:

Carry out the awareness training in Data Protection that the Company makes available to you.

Apply the security measures at user level that apply to their workplace, without prejudice to the responsibilities in its design and implementation that may be attributed to them according to their role within WATA FACTORY S.L..

Use the formats established for the exercise of rights by those affected and inform the Company immediately so that the response can be effective.

Inform the Company, as soon as it becomes aware, of deviations from the provisions of this Policy, in particular "Violations of security of personal data", using the format established for this purpose.

5. Crontrol and evaluation

There shall be an annual verification, evaluation and assessment, or whenever there are significant changes in data processing, of the effectiveness of the technical and organisational measures to ensure the security of the processing.