The Management / Governing Body of SELLBOOST SOLUTIONS, S.L. (hereinafter, the data controller) assumes full responsibility and commitment for the establishment, implementation, and maintenance of this Data Protection Policy, ensuring the continuous improvement of the data controller with the aim of achieving excellence regarding compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), as well as Spanish personal data protection legislation (Organic Law, specific sectoral legislation, and its implementing regulations).
The Data Protection Policy of SELLBOOST SOLUTIONS, S.L. is based on the principle of proactive responsibility, according to which the data controller is accountable for compliance with the regulatory and case law framework governing this Policy and is able to demonstrate such compliance to the competent supervisory authorities.
Accordingly, the data controller shall be guided by the following principles, which serve as a guide and reference framework for all its personnel in the processing of personal data:
1. Data Protection by Design
The data controller shall apply, both at the time of determining the means of processing and during the processing itself, 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 into the processing.
2. Data Protection by Default
The data controller shall apply appropriate technical and organizational measures to ensure that, by default, only personal data necessary for each specific purpose of the processing are processed.
3. Data Protection Throughout the Information Lifecycle
Measures ensuring the protection of personal data shall be applied throughout the entire information lifecycle.
4. Lawfulness, Fairness, and Transparency
Personal data shall be processed lawfully, fairly, and in a transparent manner in relation to the data subject.
5. Purpose Limitation
Personal data shall be collected for specified, explicit, and legitimate purposes and shall not be further processed in a manner incompatible with those purposes.
6. Data Minimization
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, where necessary, kept up to date; all reasonable measures shall be taken to ensure that inaccurate personal data are erased or rectified without delay in relation to the purposes for which they are processed.
8. Storage Limitation
Personal data shall 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 shall be processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
10. Information and Training
One of the key elements to ensuring personal data protection is the training and information provided to personnel involved in processing. Throughout the information lifecycle, all personnel with access to personal data shall be adequately trained and informed about their obligations regarding compliance with data protection regulations.
The Data Protection Policy of SELLBOOST SOLUTIONS, S.L. is communicated to all personnel of the data controller and made available to all interested parties.
Consequently, this Data Protection Policy involves all personnel of the data controller, who must know and assume it as their own, with each member being responsible for applying it, verifying applicable data protection rules in their activity, and identifying and proposing improvements as necessary to achieve excellence in compliance.
This Policy shall be reviewed by the Management / Governing Body of SELLBOOST SOLUTIONS, S.L. as many times as deemed necessary to ensure compliance with current personal data protection regulations at all times.