The Data Protection Policy of Baldomero Confección (hereinafter, the data controller) assumes maximum responsibility and commitment to the establishment, implementation, and maintenance of this Data Protection Policy, ensuring the continuous improvement of the data controller with the aim of achieving 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 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) (EU Official Journal L 119/1, 04-05-2016), and Spanish legislation on the protection of personal data (Organic Law, specific sectoral legislation, and its development regulations).

The Data Protection Policy of Baldomero Confección 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 regard, the data controller shall abide by the following principles that should serve as a guide and reference framework for all its staff in the processing of personal data:

Data Protection by Design: The data controller shall apply, both at the time of determining the means of processing and at the time of the processing itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively apply data protection principles, such as data minimization, and to integrate necessary safeguards into the processing. Data Protection by Default: The data controller shall apply appropriate technical and organizational measures with the aim of ensuring that, by default, only personal data necessary for each specific purpose of the processing is processed. Data Protection throughout the Information Lifecycle: Measures ensuring the protection of personal data shall be applicable throughout the complete lifecycle of the information. Lawfulness, Fairness, and Transparency: Personal data shall be processed lawfully, fairly, and transparently in relation to the data subject. Purpose Limitation: Personal data shall be collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes. Data Minimization: Personal data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed. Accuracy: Personal data shall be accurate and, where necessary, kept up to date; reasonable steps shall be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay. 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 is processed. Integrity and Confidentiality: Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures. Information and Training: One of the keys to ensuring the protection of personal data is the training and information provided to personnel involved in its processing. Throughout the information lifecycle, all personnel with access to the data shall be appropriately trained and informed about their obligations regarding compliance with data protection regulations. The Data Protection Policy of Baldomero Confección is communicated to all staff of the data controller and made available to all interested parties.

Therefore, this Data Protection Policy involves all staff of the data controller, who must be aware of and adhere to it, considering it as their own, with each member responsible for its implementation and verification of the data protection rules applicable to their activities, as well as identifying and contributing to opportunities for improvement to achieve excellence in compliance.

This Policy will be reviewed by the Management of Baldomero Confección as many times as deemed necessary to ensure compliance with current regulations on the protection of personal data.