The Management / Governing Body of MENTALPAGE S.L. (hereinafter, the Data Controller), assumes the maximum responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, guaranteeing the continuous improvement of the Data 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 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 the Spanish legislation on the protection of personal data (Organic Law, sector-specific legislation and its implementing rules).

The Data Protection Policy of MENTALPAGE S.L is based on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework that governs said Policy, and is able to demonstrate this to the competent supervisory authorities.

In this regard, the Data Controller shall be governed by the following principles that must serve as a guide and frame of reference for all its personnel in the processing of personal data:

1. Data protection by design: the controller shall apply, both at the time of determining the means of processing and at the time of the processing itself, appropriate technical and organisational measures, such as pseudonymisation, designed to effectively apply data protection principles, such as data minimisation, and to integrate the necessary safeguards into the processing.

2. Data protection by default: the controller shall implement appropriate technical and organisational measures with a view to ensuring that, by default, only personal data that is necessary for each of the specific purposes of the processing is processed.

3. Data protection in the information lifecycle: measures to ensure the protection of personal data will be applicable throughout the entire information lifecycle.

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 be collected for specific, explicit and legitimate purposes, and will not be further processed in a manner incompatible with those 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 processed.

7. Accuracy: personal data will be accurate and, if necessary, up-to-date; All reasonable measures shall be taken to ensure that personal data that are inaccurate with respect to the purposes for which they are processed are erased or rectified without delay.

8. Limitation of the retention period: personal data will be kept in such a way as to allow the identification of the data subjects for no longer than is necessary for the purposes of the processing of the personal data.

9. Integrity and confidentiality: Personal data will be processed in such a way as to ensure adequate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, through the application of appropriate technical or organisational measures.

Article 10. Information and training: one of the keys to ensuring the protection of personal data is the training and information provided to the personnel involved in the processing of the same. During the information lifecycle, all personnel with access to the data will be properly trained and informed about their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of MENTALPAGE S.L is communicated to all the staff of the data controller and made available to all interested parties.

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

This Policy will be reviewed by the Management / Governing Body of MENTALPAGE S.L. as many times as deemed necessary, in order to adapt, at all times, to the current provisions on the protection of personal data.