The Governing Body/Management of INSYTE ELECTRONICS, S.A. (hereinafter, the controller), assumes the utmost responsibility and commitment in establishing, implementing and maintaining this Data Protection Policy, assuring continued improvement on the part of the controller with the purpose of attaining excellence in relation with its 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 (Organic Law, sector-specific legislation and its implementing regulations).


The Data Protection Policy of INSYTE ELECTRONICS, S.A. rests on the principle of proactive responsibility, according to which the controller is responsible for compliance with the regulatory framework and case law that governs said Policy, and is capable of proving this to the competent supervisory authorities.


To this end, the controller shall be governed by the following principles that should serve as a guide and reference framework to all its’ staff in the processing of personal data:


  1. Data protection by design: the controller shall, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are designed to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing.


  1. Data protection by default: the 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.


  1. Data protection during the life cycle of the information: the measures that guarantee the protection of personal data shall be applicable during the entire life cycle of the information.


  1. Lawfulness, loyalty and transparency: personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject.


  1. Purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes, and not further processed in a manner that is incompatible with those purposes.


  1. Data Minimisation: personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.


  1. Accuracy: personal data shall 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.


  1. 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.


  1. 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.


  1. Information and training: one of the keys to assuring the protection of personal data is the training and information that is provided to the staff involved in its processing. During the life cycle of the information, all staff with access to the data shall be conveniently trained and informed concerning their obligations in relation with the compliance of data protection legislation.


The Data Protection Policy of INSYTE ELECTRONICS, S.A. is communicated to all the staff of the controller and made available to all the interested parties.


Consequently, this Data Protection Policy involves all the controller’s staff, who must be aware of its contents and accept it, considering it its own, with each member being responsible for its implementation and for verifying the data protection rules applicable to their activity, as well as for identifying and contributing any potential improvements deemed appropriate for the purposes of attaining excellence in relation with its compliance.


This Policy shall be reviewed by the Governing Body/Management of INSYTE ELECTRONICS, S.A. as many times as it is deemed necessary, to comply, at all times, with the prevailing personal data protection legislation.