Data Protection Policy.

Management / Governing Body of Advanced Research and Strategic Marketing S.L. (henceforth, the Data Controller), takes full responsibility and commitment for the establishment, implementation and maintenance of the Data Protection policy in place, guaranteeing the continued improvement of the Data Controller with the aim of reaching excellence relating to filling the regulation (EU) 2016/679 of the European Union and Council, from 27th April 2016, regarding the protection of people regarding the collection of personal data and the free circulation of this data and subsequently repeals the enforced 95/46/CE (General regulation of Data Protection) (DOUE L 119/1,04-05-2016), and Spanish regulations for the collection of personal data (Ley Orgánica, legislación sectorial específica y sus normas de desarrollo).

The Data Protection Policy of Advanced Research and Strategic Marketing S.L. is underpinned by the principle of proactive responsibility, according to which the data controller charged with meeting normal and legal standards which governs said Policy, and is capable to demonstrate it before the authorities of appropriate authorities.

In this sense, the Data Controller will be governed by the following principles that should be followed as a guide and reference point for all personal when dealing with personal data:

1. Data Protection from the design: the Data controller will apply, equally in the moment of determining the means of data collection as in the moment of the actual treatment, appropriate technical and organisational means, such as encryption, conceived to apply in an effective way the principles of data protection, like the minimisation of data and integrate necessary guarantees in its treatment.

2. Protection of data by defect: the data controller will apply the appropriate technical and organisational means with the aim of guaranteeing that, by defect, only necessary personal data should be collected for each one of the specified aims of collection.

3. Data protection in the information life cycle: steps taken that guarantee the protection of personal data will be applied during the entire information life cycle.

4. Lawfulness, loyalty and transparency: personal data will be treated in a legal, fair and transparent way as far as the involved party is concerned.

5. Purpose limitation: the personal data will be collected with clear, explicit and legitimate objectives, and will not be treated ultimately in way which goes against said aims.

6. Data minimisation: personal data will be adequate, relevant and limited to the required information related to the aims for which they will be treated.

7. Accuracy: personal data will be exact, and if necessary updated: all reasonable steps will be adopted to delete and rectify any personal data without delay which might be incorrect regarding the purpose for which they will be treated.

8. Limitation of the conservation period: personal data will be maintained in way that will not allow the identification of the concerned for more time than is necessary for the purpose of personal data.

9. Integrity and confidentiality: personal data will be treated in such a way that sufficient security of personal data, including the protection against non-authorised treatment or illegal or against its loss, destruction or accidental harm, through the application of appropriate technical and organisational steps.

10. Information and training: one of the keys to guarantee the protection of personal data is training and information that allows any personnel involved in the treatment of the same. During the information life cycle, all personnel with access to data will be sufficiently trained and informed of their obligations regarding the fulfilling of the data protection rules. 

The Data Protection Policy of Advanced Research and Strategic Marketing S.L. is communicated to all the personnel of the Data Collector and made available to all involved parties.

As a result, the current Data Protection Policy involves all personnel of the Data Collector, who must know and follow it, always keeping it in mind, taking responsibility to apply it and check the norms of data protection applicable to its activity, and so identify and bring the opportunities to improve which it considers would help to reach excellence in relation to its fulfilment.

This policy will be revised by Management/Governing Body of Advanced Research and Strategic Marketing S.L., as many times as it considers necessary, to adapt to any moment, the law enforced related to the data protection of personal data.