The Management of SURFING ETXEA SL (hereinafter the controller), assumes the maximum responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, ensuring the continuous improvement of the controller with the aim of 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 the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (DOUE L 119/1, 04-05-2016), and the Spanish legislation on the protection of personal data (Organic Law, sector specific legislation and its implementing rules).

In compliance with the regulations established in the Protection of Personal Data, and in particular Organic Law 3/2018, of December 5, on the protection of personal data and guarantee of digital rights, you are informed that the data collected will be processed for administrative and police purposes within the framework of Organic Law 4/2015, of March 30, on the Protection of Citizen Security, as well as, where appropriate, for the processing of the corresponding sanctioning file; all this, in the exercise of public powers conferred by law and based on the public interest. The data may be communicated to competent bodies in the matter and to judicial bodies, as well as to Security Forces and Bodies; also contemplating the framework of international Schengen action or any other by virtue of the agreements, treaties and conventions in force. The information will be kept as long as its maintenance is of police, procedural or judicial interest, the provisions of the archives and documentation regulations also being applicable. You can exercise your rights (access, rectification, cancellation, limitation of treatment, etc.), before the Vice-Ministry of Security -Directorate of Security Coordination / Data Processing Center of the Euskadi Police-, in Larrauri Mendotxe bidea 18, 48950-Erandio, Bizkaia Contact - dgvs@seg.euskadi.eus -. Affected persons may file complaints with the Basque Data Protection Agency (Beato Tomás de Zumárraga, 71 3ª planta, 01008 Vitoria-Gasteiz, Araba), when their rights regarding the processing of personal data are violated.

The Data Protection Policy of SURFING ETXEA SL is based on the principle of proactive liability, according to which the controller is responsible for compliance with the regulatory and case-law framework governing the Policy and is able to demonstrate this to the competent supervisory authorities.

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

1. Data protection by design: the controller shall apply appropriate technical and organisational measures both when determining the means of processing and at the time of processing, such as pseudonymisation, designed to effectively apply data protection principles, such as data minimisation, and to integrate the necessary safeguards into the processing.
2. Default data protection: the controller shall apply appropriate technical and organisational measures to ensure that, by default, only personal data necessary for each specific purpose of processing are processed.
3. Data protection in the information life cycle: measures to ensure the protection of personal data shall apply throughout the entire information life cycle.
4. Lawfulness, fairness and transparency: personal data shall be processed in a lawful, fair and transparent manner in relation to the data subject.
5. Purpose limitation: personal data shall be collected for specific, explicit and legitimate purposes and shall not be further processed in a manner incompatible with those purposes.
6. Data minimisation: 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, if necessary, updated; all reasonable steps shall be taken to delete or rectify without delay personal data which are inaccurate with respect to the purposes for which they are processed.
8. Limitation of the retention period: personal data shall be maintained in such a way as to allow the identification of data subjects for no longer than is necessary for the purposes of processing personal data.
9. Integrity and confidentiality: personal data shall be processed in such a way as to ensure adequate security of personal data, including protection against unauthorised or unlawful processing and against its loss, destruction or accidental damage, through the application of appropriate technical or organisational measures.
10. Information and training: one of the keys to ensuring the protection of personal data is the training and information provided to personnel involved in the processing of personal data. During the life cycle of the information, all staff with access to the data shall be appropriately trained and informed about their obligations in relation to compliance with data protection rules.

The Data Protection Policy of SURFING ETXEA SL is communicated to all the personnel of the controller and made available to all interested parties. As a consequence, this Data Protection Policy involves all the personnel of the controller, who must know and assume it, considering it as their own, each member being responsible for applying it and for verifying the data protection rules applicable to its activity, identify and provide such improvement opportunities as it deems appropriate with a view to achieving excellence in relation to compliance.

This Policy will be reviewed by the Management of SURFING ETXEA SL, as many times as is deemed necessary, in order to adapt, at all times, the provisions in force on the protection of personal data.