Privacy Policy

The Management / Governing Body of Innovarq Bellaguarda S.L. (hereinafter, the data controller) assumes the highest responsibility and commitment to establish, implement, and maintain this Data Protection Policy, ensuring continuous improvement of the data controller in order to achieve excellence in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJEU L 119/1, 04-05-2016), and the Spanish regulations on personal data protection (Organic Law, specific sectoral legislation, and their implementing regulations).

The Data Protection Policy of Innovarq Bellaguarda S.L. is based on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the legal and jurisprudential framework that governs this policy, and is able to demonstrate it to the competent supervisory authorities.

In this sense, the data controller will be guided by the following principles, which should serve as a guide and reference framework for all its staff in the processing of personal data:

  1. Data protection by design: The data controller will apply, both at the time of determining the means of processing and at the time of 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 will apply appropriate technical and organizational measures to ensure that, by default, only personal data necessary for each specific purpose of processing are processed.
  3. Data protection throughout the information life cycle: Measures to ensure the protection of personal data will be applicable throughout the entire life cycle of the information.
  4. Lawfulness, fairness, and transparency: Personal data will be processed lawfully, fairly, and transparently in relation to the data subject.
  5. Purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes and will not be further processed in a manner that is 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 where necessary, kept up to date; every reasonable step will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
  8. Storage limitation: Personal data will be kept in a form that allows the 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 will be processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, by using appropriate technical or organizational measures.
  10. Information and training: One of the keys to ensuring the protection of personal data is the training and information provided to staff involved in data processing. Throughout the information life cycle, all staff with access to data will be properly trained and informed about their obligations regarding compliance with data protection regulations.

The Data Protection Policy of Innovarq Bellaguarda S.L. is communicated to all personnel of the data controller and made available to all interested parties.

As a result, this Data Protection Policy involves all the personnel of the data controller, who must be aware of it and assume it, considering it as their own, with each member responsible for applying it and verifying the data protection rules applicable to their activity, as well as identifying and contributing opportunities for improvement as they see fit in order to achieve excellence in compliance.

This Policy will be reviewed by the Management / Governing Body of Innovarq Bellaguarda S.L. as often as necessary to ensure compliance with current regulations on the protection of personal data.