Personal data protection commitment

Our commitment to personal data protection: “Informed people, protected data”

The Management / Governing Body of Auto Comercial Monedero, S.A.U (hereinafter referred to as the Data Controller), assumes the maximum responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, ensuring the continuous improvement of the Data Controller with a view to 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 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) (OJEU L 119/1, 04-05-2016), and Spanish personal data protection legislation (National laws, sector-specific legislation and the implementing regulations thereof).

The Data Protection Policy of Auto Comercial Monedero, S.A.U. is based on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the regulatory and judicial framework governing the Policy, and is capable of demonstrating this to the pertinent supervisory authorities.

In this regard, the controller shall be governed by the following principles which should serve as a guide and frame of reference for all its staff when processing personal data:

1. Data protection by design: the controller shall implement, when establishing the processing medium and in the course of the processing itself, appropriate technical and organisational measures, such as pseudonymisation, designed to effectively implement data protection principles, such as data minimisation, and to integrate the necessary safeguards into the processing.
2. Data protection by default: controller shall implement appropriate technical and organisational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed.
3. Data protection in the information life cycle: measures ensuring the protection of personal data shall 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 only be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
6. Data minimisation: 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 must 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 shall be kept in a form which 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 of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
10. Information and training: one of the keys to ensuring the protection of personal data entails the training and information provided to the personnel involved in their processing. During the information life cycle, all personnel with access to data will be properly trained and informed about their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of Auto Comercial Monedero, S.A.U. is communicated to all personnel of the data controller and made available to all data subjects.

Consequently, this Data Protection Policy involves all of the data controller’s personnel, who must be aware of and follow it, considering it as their own, with each member of personnel being responsible for applying the Policy, verifying the data protection regulations applicable to their activity, and identifying and contributing the improvement opportunities they consider appropriate with the aim of achieving excellence in relation to compliance.

This Policy will be revised by the Management/Governing Body of Auto Comercial Monedero, S.A.U. as often as necessary to ensure that it conforms at all times to the pertinent personal data protection provisions in force.