PRIVACY POLICY
The Management / Governing Body of Cultural Travel Spain (hereinafter, the "Data Controller") assumes full responsibility for and commitment to the establishment, implementation, and maintenance of this Data Protection Policy, guaranteeing the Data Controller's continuous improvement with the aim of achieving excellence in 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 with Spanish personal data protection regulations (Organic Law, specific sectoral legislation, and their implementing regulations).
The Cultural Travel Spain Data Protection Policy is based on the principle of proactive responsibility, under which the data controller is responsible for compliance with the regulatory and jurisprudential framework governing said Policy and is able to demonstrate such compliance to the competent supervisory authorities.
In this regard, the data controller shall be governed by the following principles, which must serve as a guide and frame of reference for all its personnel regarding the processing of personal data.:
1. Data protection by design: the controller shall implement appropriate technical and organisational measures—such as pseudonymisation—both at the time of determining the means for processing and at the time of the processing itself, 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: the controller shall implement appropriate technical and organisational measures to ensure that, by default, only personal data which are necessary for each specific purpose of the processing are processed.
3. Data protection throughout the information lifecycle: measures guaranteeing the protection of personal data shall apply throughout the entire information lifecycle.
4. Lawfulness, fairness, and transparency: personal data shall be processed lawfully, fairly, and in a transparent manner in relation to the data subject.
5. Purpose limitation: personal data shall be collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.
6. Data minimization: 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, where necessary, kept up to date; every reasonable step shall 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. Limitation of the storage period: personal data shall be kept in a form which permits identification of the 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 unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
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 their processing. Throughout the information lifecycle, all personnel with access to the data will receive appropriate training and information regarding their obligations concerning compliance with data protection regulations.
The Data Protection Policy of Cultural Travel Spain is communicated to all personnel of the data controller and made available to all interested parties.
Consequently, this Data Protection Policy applies to all personnel of the data controller, who must be familiar with and embrace it as their own; each member is responsible for implementing it and verifying the data protection rules applicable to their activities, as well as identifying and proposing opportunities for improvement deemed appropriate to achieve excellence in compliance.
This Policy shall be reviewed by the Management / Governing Body of Cultural Travel Spain as often as deemed necessary, in order to ensure ongoing compliance with applicable regulations regarding the protection of personal data.
