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MANUFACTURAS HEPYC, S.A. (the “Company”) is an Organization in which personal data processing activities 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, it approves this Policy for the protection of personal data, which notifies its Employees and makes available of all your interest groups.

1. Purpose

The Personal Data Protection Policy is a measure of proactive Responsibility that aims to ensure compliance with the applicable legislation on this matter and in relation to it, respect for the right to honor and privacy in the processing of data. of a personal nature of all the people who are related to The Company.

In development of the provisions of this Personal Data Protection Policy, the Principles that govern the processing of data in the organization are established and, consequently, the procedures, and the organizational and security measures that the people affected by They undertake to implement this Policy in their area of responsibility.

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

2. Scope of application

This Personal Data Protection Policy will be applicable to the Company, its administrators, managers and employees, as well as all the people who are related to it, expressly including the service providers with access to data (“Responsible for the treatment”)

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 demonstrate it (Principle of "Proactive responsibility"), paying special attention to those treatments that may pose a greater risk to the rights of those affected (Principle of "risk approach").

In relation to the above, MANUFACTURAS HEPYC, S.A. will ensure compliance with the following Principles:

The Company will promote that the principles contained in this Policy for the 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 they formalize or assume and (ii) in the implementation of any systems and platforms that allow the access of employees or third parties and / or the collection or processing of personal data.

4. Commitment of workers

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

5. Control and evaluation

An annual verification, evaluation and assessment will be carried out, or each time there are significant changes in the data processing, of the effectiveness of the technical and organizational measures to guarantee the security of the processing.


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