Commitment to Personal Data Protection

The Management/ Governing Body of ENERGY ENERAGUA S.L.L. (hereinafter, the data controller) assumes the maximum responsibility and commitment to establishing, implementing, and maintaining this Data Protection Policy, ensuring the continuous improvement of the data controller with the aim of achieving excellence in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons concerning the processing of personal data and the free movement of these data, repealing Directive 95/46/EC (General Data Protection Regulation) (OJEU L 119/1, 04-05-2016), and Spanish regulations on the protection of personal data (Organic Law, specific sector legislation, and its development regulations).

The Data Protection Policy of ENERGY ENERAGUA S.L.L. is based on the principle of proactive responsibility, whereby the data controller is responsible for complying with the regulatory and jurisprudential framework governing this Policy and is capable of demonstrating it to the competent supervisory authorities.

In this regard, the data controller will be governed by the following principles that should serve as a guide and reference framework for all its staff in the processing of personal data:

1. Data Protection by Design: The data controller will apply, both when determining the means of processing and during the processing itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively implement data protection principles, such as data minimization, and integrate the necessary guarantees into the processing.
2. Data Protection by Default: The data controller will apply appropriate technical and organizational measures to ensure that, by default, only personal data necessary for each specific purpose of processing are processed.
3. Data Protection throughout the Information Lifecycle: Measures ensuring the protection of personal data will be applicable throughout the entire life cycle of the information.
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 specified, 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, updated; all reasonable measures will be taken to promptly delete or correct inaccurate personal data concerning the purposes for which they are processed.
8. Limited Storage Period: Personal data will be kept in a form that permits the identification of data subjects for no longer than necessary for the purposes of processing 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 unauthorized or unlawful processing and against accidental loss, destruction, or damage, by applying appropriate technical or organizational measures.
10. Information and Training: Key to ensuring the protection of personal data is the training and information provided to personnel involved in their processing. Throughout the information lifecycle, all personnel with access to the data will be appropriately trained and informed about their obligations regarding compliance with data protection regulations.

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

Consequently, this Data Protection Policy involves all personnel of the data controller, who must be aware of it, assume it, consider it as their own, with each member being responsible for applying and verifying the data protection rules applicable to their activity, as well as identifying and contributing any improvement opportunities they consider appropriate to achieve excellence in compliance.

This Policy will be reviewed by the Management/ Governing Body of ENERGY ENERAGUA S.L.L. as often as necessary to adapt, at all times, to the current provisions on the protection of personal data.