II. Data protection policy

The Corporate Directorate and the Administration Body of Pacha Merchandise, S.L. (From now on, the “Responsible for the Treatment”), assume the maximum responsibility and commitment to the establishment, implementation and maintenance of this data protection policy, guaranteeing the continuous improvement of the person responsible for the treatment with the objective of achieving excellence in relation to compliance with the Regulation (EU) 2016/679 of the European Parliament and the Council, of April 27, 2016, related to the protection of natural persons in terms of processing personal data circulation of these data and by which the Directive 95/46/EC (the General Regulation of Data Protection "or the" RGPD ") (DOUE L 119/1, 04-05-2016), and of the Spanish Regulations for the Protection of Personal Data (Organic Law on Data Protection, Specific Sector Legislation and its Development Standards).

The data protection policy of Pacha Merchandise, S.L. It rests in the principle of proactive responsibility, according to which the person responsible for the treatment is responsible for the fulfillment of the regulatory and jurisprudential framework that governs said policy, and is able to demonstrate it before the competent control authorities.

In this sense, the person in charge of the treatment will be governed by the following principles that must serve all their staff as a guide and frame of reference in the processing of personal data:

1. Data protection from the design: the person in charge of the treatment will apply, both at the time of determining the means of treatment and at the time of the treatment, appropriate technical and organizational measures, such as pseudonymization, conceived to effectively apply the principles of data protection, such as data minimization, and integrate the necessary guarantees in the treatment.
2. Default data protection: The person in charge of the treatment will apply the appropriate technical and organizational measures with a view to guaranteeing that, by default, the personal data that is necessary for each of the specific purposes of the treatment are subject to treatment.
3. Data protection in the information life cycle: Measures that guarantee the protection of personal data will be applicable during the complete cycle of information life.
4. Lealt, loyalty and transparency: Personal data will be discussed lawful, loyal and transparent in relation to the interested party.
5. Limitation of the purpose: Personal data will be collected for determined, explicit and legitimate purposes, and will not be treated further in an incompatible way with such purposes.
6. Data minimization: Personal data will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are treated.
7. Accuracy: Personal data will be exact and, if necessary, updated; All reasonable measures will be adopted so that the personal data that is inaccurate with respect to the purposes for which they are treated are suppressed or rectified without delay.
8. Limitation of the conservation period: Personal data will be maintained so that the identification of those interested are allowed for no more time than necessary for the purposes of the process of personal data.
9. Integrity and confidentiality: Personal data will be treated in such a way that adequate security of personal data is guaranteed, including protection against unauthorized or illicit treatment and against their loss, destruction or accidental damage, by applying appropriate technical or organizational measures.
10. Information and training: One of the keys to guarantee the protection of personal data is the training and information that is provided to the personnel involved in their treatment. During the information life cycle, all personnel with access to the data will be conveniently formed and informed about their obligations in relation to compliance with data protection regulations.

The data protection policy of Pacha Merchandise, S.L. It is communicated to all personnel of the person responsible for the treatment and made available to all interested parties.

Consequently, this data protection policy involves all personnel of the person responsible for the treatment, who must know and assume it, considering it as their own, being each member responsible for applying it and verifying the data protection standards applicable to their activity, as well as identifying and providing the improvement opportunities that it deems appropriate with the objective of achieving excellence in relation to compliance.

This policy will be reviewed by the legal advice of Pacha Merchandise, S.L., under the supervision of the corporate management and the administration body of the company, as many times as it is considered necessary, to adapt, at all times, to the provisions in force in the field of personal data protection.