Commitment to personal data protection

Texts translated into English from the Spanish version. For legal purposes the valid texts are those of the Spanish version.

COMMITMENT TO PERSONAL DATA PROTECTION

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

The Management / Governing Body of Airpull Aviation S.L. (hereinafter, the Data Controller), assumes the maximum responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, ensuring the continuous improvement of the Data Controller with the aim of achieving excellence in relation to 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 Spanish personal data protection regulations (Organic Law, specific sectoral legislation and its implementing rules).

The Data Protection Policy of Airpull Aviation S.L. rests on the principle of proactive responsibility, according to which the controller is responsible for compliance with the regulatory and jurisprudential framework governing such Policy, and is able to demonstrate it to the competent control authorities.

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

1. Data protection by design: the controller shall implement, both at the time of determining the means of 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.

2. Data protection by default: the controller shall implement appropriate technical and organizational measures with a view to ensuring that, by default, only personal data that are necessary for each of the specific purposes of the processing are processed.

3. Data protection in the life cycle of the information: the measures ensuring the protection of personal data shall be applicable throughout the entire life cycle of the information.

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

5. Purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes and shall not be further processed in a way 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; all reasonable steps shall be taken to ensure that personal data which are inaccurate in relation to the purposes for which they are processed are promptly deleted or rectified.

8. Limitation of the storage period: personal data shall be kept in a form that allows the identification of 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 such a way as to ensure appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, through the implementation of 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 personnel involved in the processing of personal data. During the life cycle of the information, all personnel with access to the data will be properly trained and informed about their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of Airpull Aviation S.L. is communicated to all staff of the data controller and made available to all interested parties.

Consequently, this Data Protection Policy involves all the staff of the data controller, who must know it and assume it, considering it as their own, each member being responsible for applying it and verifying the data protection rules applicable to their activity, as well as identifying and providing the opportunities for improvement that they consider appropriate with the aim of achieving excellence in relation to their compliance.

This Policy will be reviewed by the Management / Governing Body of Airpull Aviation S.L., as many times as deemed necessary, to adapt, at all times, to the provisions in force regarding the protection of personal data.