Commitment to personal data protection

OUR COMMITMENT TO PERSONAL DATA PROTECTION: “INFORMED INDIVIDUALS AND PROTECTED DATA”

The Management / Governing Body of MICROOMICS SYSTEMS S.L. (hereinafter, the “Data Controller”) assumes full responsibility and commitment regarding the establishment, implementation, and maintenance of this Data Protection Policy. It guarantees 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), as well as Spanish personal data protection regulations (Organic Law, specific sectoral legislation, and implementing regulations).

The Data Protection Policy of MICROOMICS SYSTEMS S.L. is based on the principle of proactive responsibility (accountability), whereby the Data Controller is responsible for compliance with the regulatory and case-law framework governing said Policy and is able to demonstrate such compliance to the competent supervisory authorities.

Accordingly, the Data Controller shall be guided by the following principles, which must serve as a guide and reference framework for all personnel regarding the processing of personal data:

Data protection by design: the Data Controller shall implement—both at the time of determining the means for processing and at the time of the processing itself—appropriate technical and organizational measures (such as pseudonymization) designed to effectively implement data protection principles (such as data minimization) and to integrate the necessary safeguards into the processing. Data protection by design and by default: the data controller shall implement appropriate technical and organizational measures to ensure that, by default, only personal data necessary for each specific purpose of the processing are processed.

Data protection throughout the information lifecycle: measures ensuring the protection of personal data shall apply throughout the entire information lifecycle.

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

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.

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

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.

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.

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.

Information and training: a key factor in 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 shall be suitably trained and informed regarding their obligations concerning compliance with data protection regulations.

The MICROOMICS SYSTEMS S.L. Data Protection Policy …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; they must be familiar with it, adopt it as their own, and take responsibility for its implementation and for verifying the data protection rules applicable to their activities. Furthermore, they are expected to identify and propose opportunities for improvement they deem appropriate in order to achieve excellence in compliance.

This Policy shall be reviewed by the Management / Governing Body of MICROOMICS SYSTEMS S.L. as often as deemed necessary, in order to ensure ongoing compliance with applicable regulations regarding the protection of personal data.