PRIVACY POLICY

PRIVACY POLICY & DATA PROTECTION POLICY

Cole, Simon Anthony (the “Company”) is an Organization in which personal data processing activities occur, which gives it an important responsibility in the design and organization of procedures so that they are aligned with legal compliance in this matter. In the exercise of these responsibilities and in order to establish the general principles that should govern the processing of personal data in the Company, approves this Policy of protection of personal data, which notifies its Employees and makes available of all its Interest groups.

1. Purpose

The Policy of protection of personal data is a measure of proactive Responsibility that has the purpose of ensuring compliance with applicable legislation in this area and in relation to it, respect for the right to honour and privacy in the processing of data of a personal nature of all the people that relate to the Company. In development of the provisions of this Personal Data Protection Policy, the Principles governing the processing of data in the organization and, consequently, the procedures, and the organizational and security measures that people affected by This Policy undertakes to implement in its area of responsibility. To this end, the Directorate will assign the responsibilities to the personnel that participate in the data processing operations.

2. Scope of application

This Policy for the protection of personal data will be applicable to the Company, its administrators, managers and employees, as well as to all persons related to it, with the express inclusion of service providers with access to data (“ Treatment Managers ”)

3. Principles of the processing of personal data

As a general principle, the Company will scrupulously comply with the legislation on the protection of personal data and must be able to prove it (Principle of "proactive responsibility"), paying special attention to those treatments that may pose a greater risk to rights of those affected (Principle of "risk approach"). Regarding the above, Simon Anthony will ensure compliance with the following Principles:

• Legality, loyalty, transparency and limitation of purpose. Data processing. The affected party must always be informed through clauses and other procedures; and will only be considered legitimate if there is consent to the processing of data (with special attention given to minors), or has another legitimation valid and the purpose of it is in accordance with regulations.
• Data minimization. The data processed must be adequate, relevant and limited to what is necessary in relation to the purposes of the treatment.
• Accuracy. The data must be accurate and, if necessary, updated. To this In this regard, the necessary measures will be taken to eliminate or rectify them without procrastination of personal data that is inaccurate with respect to the purposes of treatment.
• Limitation of the term of conservation. The data will be maintained so that allow the identification of the interested parties for no more time than necessary to the purposes of the treatment.
• Integrity and Confidentiality. The data will be treated in such a way that adequate security of personal data is guaranteed, including protection against unauthorized or unlawful treatment and against its loss, destruction or accidental damage, through the application of appropriate technical or organizational measures.
• Transfer of data. The purchase or obtaining of character data is prohibited staff from illegitimate sources or in those cases where such data have been collected or transferred in contravention of the law or its legitimate origin is not sufficiently guaranteed.
• Hiring suppliers with access to data. Only suppliers that offer sufficient guarantees to apply appropriate technical and security measures in the processing of data will be chosen for contracting. Due agreement will be documented with these third parties in this regard.
• International data transfers. All processing of personal data subject to European Union regulations that imply a transfer of data outside the European Economic Area must be carried out with strict compliance with the requirements established in the applicable law.
• Rights of those affected. The Company will facilitate the exercise of rights of access, rectification, deletion, limitation of treatment, opposition and portability, establishing internal procedures for this purpose, and in particular models for their exercise that are necessary and timely, which should satisfy, at least, the legal requirements applicable in each case.

The Company will promote that the principles contained in this Policy of protection of personal data are taken into account (i) in the design and implementation of all work procedures, (ii) in the products and services offered (iii) in all the contracts and obligations that formalize or assume and (ii) in the implementation of how many systems and platforms allow access by employees or third parties and / or the collection or processing of personal data.

4. Commitment of workers

The workers are informed of this Policy and declare themselves aware that personal information is an act of the Company, and in this respect they adhere to it, committing to the following:

• Perform awareness training on Data Protection that the Company makes available to you.
• Apply security measures at the user level that apply to your job, without prejudice to the responsibilities in its design and implementation that may or may be attributed to it depending on your role within Cole, Simon Anthony.
• Use the formats established for the exercise of Rights by the affected and inform the Company immediately so that it can be done Effective response.
• Inform the Company, as soon as it becomes aware, of deviations from the provisions of this Policy, in particular of “Violations of security of personal data”, using the format established for this purpose.

5. Control and evaluation

An annual verification, evaluation and evaluation will be carried out, or whenever there are significant changes in the data processing, of the effectiveness of the technical and organizational measures to ensure the safety of the treatment. Cole, Simon Anthony