OUR COMMITMENT TO THE PROTECTION OF PERSONAL DATA: ‘INFORMED PEOPLE AND PROTECTED DATA’.

The Management / Governing Body of VILLA GRAN CANARIA INVESTMENTS, S.L. 
(hereinafter, the data controller), assumes the maximum responsibility and commitment to the
establishment, implementation and maintenance of this Data Protection Policy, guaranteeing the continuous improvement of the
the Data Protection Policy, guaranteeing the continuous improvement of the data controller with the objective of
achieving excellence in relation to compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 June 2016.
European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data.
natural persons with regard to the processing of personal data and on the free movement of such data and
of personal data and repealing Directive 95/46/EC (the General Data Protection Regulation) (OJEU L 119, 27.4.2016, p. 1).
(OJEU L 119/1, 04-05-2016), and Spanish legislation on the protection of personal data (Ley Orgánica, Ley Orgánica de Protección de Datos de
personal data (Organic Law, specific sectorial legislation and its implementing regulations).

The Data Protection Policy of VILLA GRAN CANARIA INVESTMENTS, S.L. is based on the principle of proactive responsibility.
principle of proactive responsibility, according to which the data controller is responsible for the
responsible for complying with the regulatory and jurisprudential framework that governs said
Policy, and is capable of demonstrating this to the competent control authorities.
In this respect, the controller shall be guided by the following principles, which should
serve as a guide and frame of reference for all its staff in the processing of personal data.
personal data:

1. Data protection by design: the data controller shall apply, both at the time of determining the means of
at the time of the determination of the means of processing and at the time of the processing itself, appropriate
processing itself, appropriate technical and organisational measures, such as pseudonymisation,
designed to implement effectively the data protection principles, such as data minimisation, and to integrate data
data minimisation, and integrating the necessary safeguards into the processing.

2. Data protection by default: the controller shall implement appropriate technical and organisational measures with a view to ensuring that, by default, data are only processed in a way that is
appropriate technical and organisational measures with a view to ensuring that, by default, only personal data which are necessary for each of the purposes for which they are processed shall be processed.
processing only those personal data which are necessary for each of the specific purposes of the processing.
specific purposes of the processing.

3. Data protection in the information lifecycle: measures ensuring the protection of personal data shall apply throughout the information lifecycle.
protection of personal data shall apply throughout the entire lifecycle of the information.
the information.

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

5. Purpose limitation: personal data will be collected for specified, explicit and legitimate purposes,
explicit and legitimate purposes and shall not be further processed in a way incompatible with those purposes.
those purposes.

6. Data minimisation: personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are collected.
necessary in relation to the purposes for which they are processed.

7. Accuracy: personal data shall be accurate and, if necessary, kept up to date; all reasonable steps shall be taken to ensure that they are deleted or
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 deleted or rectified without delay.
personal data which are inaccurate in relation to the purposes for which they are processed.

8. Limitation of the retention period: personal data shall be kept in a form that
allow the identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
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 adequate security of personal data, including protection against unauthorised access.
adequate security of personal data is ensured, including protection against unauthorised or unlawful processing and against accidental loss, destruction or
unauthorised or unlawful processing and against accidental loss, destruction or damage,
through the implementation of appropriate technical or organisational measures.

10. Information and training: one of the keys to ensuring the protection of personal data is the training and information that is
personal data is the training and information provided to staff involved in the processing of personal data.
processing of personal data. During the life cycle of the information, all staff with access to the data shall be adequately trained in the use of the data.
access to the data shall be adequately trained and informed about their obligations in relation to the
obligations in relation to compliance with data protection regulations.

The Data Protection Policy of VILLA GRAN CANARIA INVESTMENTS, S.L. is
communicated to all staff of the data controller and made available to all interested parties.
interested parties.

Consequently, the present Data Protection Policy involves all the staff of the data controller, who must be aware of
of the data controller, who must be aware of it and accept it, considering it as their own,
each member of staff being responsible for applying it and for verifying the data protection rules applicable to his or her activity, as well as for applicable to their activity, as well as identifying and contributing the opportunities for improvement that they
Each member is responsible for applying it and verifying the data protection rules applicable to his or her activity, as well as identifying and providing the opportunities for improvement that he or she considers appropriate with the aim of achieving excellence in relation to compliance.

This Policy will be revised by the Management / Governing Body of VILLA GRAN CANARIA
INVESTMENTS, S.L., as many times as it is considered necessary, in order to adapt, at all times, to the current
the provisions in force regarding the protection of personal data.