Personal data protection policy

SOLE S.A. (the "Company") is an organizaton in which data processing activities of a personal nature take place, 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.


The Policy of protecton of personal data is a measure of proactie responsibility that has the purpose of ensuring compliance with the applicable legislation in this matter and relation to it, respect for the right to honor and privacy in the treatment of data of a personal nature of all the people who are related to The Company.

In accordance with the provisions of this Personal Data Protection Policy, the Principles that govern the data processing in the organization and, consequently, the procedures, and the organizational and security measures that the people affected by it, are established. This Policy is committed to implement in their area of responsibility.

To this end, the Directorate will assign the responsibilities to the personnel that participate in the data processing operations.

Area of application

This Policy of protecton of personal data will apply to the Company, its administrators, managers and employees, as well as to all persons who are related to it, with the express inclusion of service providers with access to data (" Managers of the treatment ")

Principles of the processing of personal data

As a general principle, The Company will scrupulously comply with the legislaton on the protection of personal data and must be able to demonstrate it (Principle of "proactive liability"), paying special atention to those treatments that may pose a greater risk to the rights of those afected (Principle of "risk approach").

In relation to the exposed SOLE S.A. will ensure compliance with the following Principles:


  • Legality, loyalty, transparency and limitation of the purpose. The data processing should always be informed to the afected party, through clauses and other procedures; and it will only be considered legitimate if there is consent to the processing of data (with special atention to the one provided by minors), or has another valid legitimation and the purpose thereof is in accordance with the Regulatons.

  • Data minimizaton. 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. In this regard, the necessary measures will be taken so that personal data that are inaccurate with respect to the purposes of the processing are deleted or rectified without delay.

  • Limitaton of the conservaton period. The data will be maintained in such a way as to allow the identificaton of the interested parties for no longer than necessary for the purposes of the treatment.

  • Integrity and Conidentality. The data will be treated in such a way as to guarantee an adequate security of the personal data, including the protection against the unauthorized or illicit treatment and against its loss, destruction or accidental damage, through the application of the appropriate technical or organizatonal measures.

  • Data transfers. It is forbidden to purchase or obtain personal data from illegitmate sources or in those cases in which said data has been collected or transferred in contravention of the law or its legitmate origin is not sufficiently guaranteed.

  • Hiring of suppliers with access to data. Only suppliers that offer suficient guarantees to apply appropriate technical and security measures in data processing will be selected for hiring. With these third parties will be documented due agreement in this regard.

  • International data transfers. Any processing of personal data subject to European Union regulations that involve a transfer of data outside the European Economic Area must be carried out in strict compliance with the requirements established in the applicable law

  • Rights of those affected. The Company will provide those afected with the exercise of the rights of access, rectificaton, deletion, limitation of treatment, opposition and portability, establishing for this purpose the internal procedures, and in particular the models for their exercise that are necessary and timely, which must meet, 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 implementaton of all work procedures, (ii) in the products and services ofered (iii) in all the contracts and obligations that they formalize or assume and (iv) in the implementation of any systems and platorms that allow the access of employees or third parties and / or the collection or processing of personal data.

Commitment of workers

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

  • Carry out awareness training on data protection that the Company puts at your disposal.
  • Apply security measures at the user level that apply to their job, without prejudice to the design and implementation responsibilites that could be attributed to them based on their role within SOLE S.A..
  • Use the established formats for the exercise of Rights by those afected and inform the Company immediately so that the response can be made effective.
  • Inform the Company, as soon as it becomes aware, of deviations from the provisions of this Policy, in partcular of "Personal data security breaches", using the format established for this purpose.

Control and evaluation

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