DATA PROTECTION POLICY

The Management / Governing Board of Legal Partners & Partners, SL (hereinafter, the data controller), assumes the maximum responsibility and commitment with 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 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 Legal Partners & Partners, SL 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 bound by the following principles that must serve all his staff as a guide and frame of reference in the processing of personal data:

1. Data protection by design: the data controller shall apply appropriate technical and organizational measures, such as pseudonymization, designed to effectively implement data protection principles, such as data minimization, and to integrate the necessary safeguards in the processing, both at the time of determining the means of processing and at the time of processing itself.

2. Data protection by default: the controller shall implement appropriate technical and organizational 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.

3. Data protection in the information lifecycle: measures ensuring the protection of personal data shall apply throughout the entire lifecycle of the information.

4. Lawfulness, fairness and transparency: personal data shall be lawfully, fairly and transparently processed in relation to the data subject.

5. 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.

6. Minimization of data: personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

7. 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.

8. Limitation of the storage period: personal data shall be kept in such a way that identification of data subjects is not permitted for longer than is necessary for the purposes of processing personal data.

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

10. 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 staff with access to the data will be properly trained and informed about their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of Legal Partners & Partners, SL is communicated to all staff of the person responsible for processing and making it available to all interested parties.

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

This Policy will be reviewed by the Management / Governing Body of Legal Partners & Partners, SL, as many times as deemed necessary, in order to adapt, at all times, to the provisions in force regarding protection.