The Management/Governing Body of EDUCATION FOR LIFE GROUP, S.L. (hereinafter, the data controller) assumes full responsibility and commitment to the establishment, implementation, and maintenance of this Data Protection Policy, ensuring continuous improvement by the data controller with the goal 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), and with Spanish personal data protection regulations (Organic Law, specific sectoral legislation, and its implementing regulations).

The Data Protection Policy of EDUCATION FOR LIFE GROUP, S.L. It is based on the principle of proactive accountability, according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework governing this Policy and is able to demonstrate this to the competent supervisory authorities.

In this regard, the data controller shall be governed by the following principles, which should serve as a guide and frame of reference for all its personnel in the processing of personal data:

1. Data protection by design: the data controller shall implement, both when determining the means of processing and at the time of 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 safeguards into the processing.

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

3. Data protection throughout the information lifecycle: Measures ensuring the protection of personal data will apply throughout the entire information lifecycle.

4. Lawfulness, fairness, and transparency: Personal data will be processed lawfully, fairly, and transparently with respect 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, where necessary, updated; all reasonable measures will be taken to ensure that personal data that are inaccurate with respect to the purposes for which they are processed are erased or rectified without delay.

8. Retention Limitation: Personal data will be maintained in a manner that allows the identification of data subjects for no longer than necessary for the purposes of the personal data processing.

9. Integrity and Confidentiality: Personal data will be processed in a manner that ensures adequate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, through the application 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 the personnel involved in its 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 EDUCATION FOR LIFE GROUP, S.L. is communicated to all personnel of the data controller and made available to all interested parties.

Consequently, this Data Protection Policy applies to all of the data controller’s staff, who must be familiar with it and adhere to it, considering it as their own. Each member is responsible for applying it and verifying the data protection regulations applicable to their activity, as well as identifying and providing any opportunities for improvement they deem appropriate in order to achieve excellence in compliance.

This Policy will be reviewed by the Management/Governing Body of EDUCATION FOR LIFE GROUP, S.L., as many times as deemed necessary, to comply, at all times, with the current provisions regarding the protection of personal data.