Privacy Policy


In accordance with the provisions of Regulation 679/2016, the General Data Protection Regulation (GDPR), Organic Law 3/2018 of December 5 on Data Protection and Digital Rights Guarantees, as well as the Law on Information Society Services and Electronic Commerce, several matters must be addressed concerning the existing website.

  1. A Privacy Policy must be in place to inform users – especially consumers – about how the processing of their personal data is conducted. This policy should be displayed in the footer of the webpage and also on any forms that enable users to contact the company. If the company intends to utilize additional information (such as profiling, mailing, etc.), further steps would be required. This would involve conducting an Impact Assessment prior to expanding the information.
  2. The existence of an existing Cookie Policy should be mentioned. In this context, user preferences, as typically managed during navigation, should be prioritized. Thus, the Cookie Policy should not only be found in the footer, but should also be a requirement to proceed with browsing, unless exclusively technical and session cookies are used, in which case it would not be necessary. To be fully compliant, users should be allowed to deactivate all non-technical cookies, although this may be technically intricate; however, it is strongly recommended. In the specific case presented, it is indeed necessary, as Google Analytics cookies will be utilized. The provided model should be completed with the precise cookies being used.
  3. Email footer: We have attached a proposed content for the email footer, which you may consider using.
  4. In a separate document, we have attached the purchasing policy. It is necessary to complete certain aspects that should have been decided beforehand.

If it is deemed entirely necessary to emphasize, for effective compliance with consumer and user protection regulations, LSSI, and data protection, we would require more comprehensive data than what we currently possess. We are able to provide a no-obligation quote that encompasses the full implementation of these regulations. We are at your complete disposal for this purpose.



Ly Company Trade Holding S.L., with its address at C/ San Lorenzo 12 3A Postal Code: 29001,– Málaga, and CIF G72768104, is the DATA CONTROLLER. The entity’s main business is the marketing of bottled water for consumption. You can contact us via email at:


At Ly Holding Capital, we process the information you provide us for the purpose of carrying out the intermediary activity of the Entity’s professional activity.

Additionally, the processing purposes are as follows:

  1. Management of users of the websites and management of services offered through the website.
  2. Management of inquiries received through the websites.
  3. Sending information about products marketed by the entity.
  4. In the case of explicit authorization, conducting advertising and commercial information mailings.
  5. Management of purchases.


The personal data provided will be retained for as long as the commercial relationship is maintained, and for a period of 1 year from the execution of the contract. However, information related to contracts will be retained in our databases for the duration of the statute of limitations for civil actions.


The legal basis for processing your data is grounded in:

  1. Express consent manifested through the acceptance for the processing of your data.
  2. Execution of the contract and pre-contractual relationship, according to the terms and conditions set forth therein.
  3. Legitimate interest of the Entity in the processing of your data.


Data will only be disclosed to public bodies and entities in accordance with applicable material legislation.


  • You have the right to obtain confirmation from the entity as to whether we process your personal data and to know which data are subject to processing.
  • You have the right to request the correction of inaccurate data, or, where appropriate, to request their deletion when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
  • You can revoke your consent for the processing of your data for commercial purposes at any time, without this affecting you in any way.
  • You can object to the processing of your data, which will limit the processing of your data solely for legitimate reasons related to the contract, or for the exercise or defense of potential claims.
You can exercise your rights in person at the office indicated below, or by sending an email to, including a photocopy of your ID to verify your identity. In the subject of the email, you should specify the right you wish to exercise, namely: ACCESS, DELETION, CORRECTION, OBJECTION, or LIMITATION.
We inform you that if you do not agree with the processing of your data by the Controller, you can direct your complaint to the Spanish Data Protection Agency, at Calle Jorge Juan 6, 28001 Madrid.


The personal data we process are freely provided by you and do not involve specially protected data. Personal data is provided through web forms and paper forms provided by you.
We process your identification data, contact information, commercial information, as well as data related to your purchasing preferences.


What is a cookie?

A file that is downloaded to your computer or another device when you access certain web pages that collect information about your browsing. In some cases, cookies are necessary to facilitate navigation and allow the storage and retrieval of information about a user’s or their device’s browsing habits, among other things. Depending on the information they contain and how you use your device, cookies can be used to recognize the user.

Identification of cookies used
Following the guidelines established by the Spanish Data Protection Agency, the cookies used on this website are classified as follows:

Own cookies: Those sent to the user’s terminal equipment from a computer or domain managed by the publisher and from which the requested service is provided.

Third-party cookies: Those sent to the user’s terminal equipment from a computer or domain that is not managed by the publisher, but by another entity that processes data obtained through cookies.

Session cookies: Collect and store data while the user accesses a web page.

Persistent cookies: Store data on the terminal so that they can be accessed and processed for a period defined by the responsible for the cookie – from a few minutes to several years.

Technical cookies: Allow the user to navigate through a web page, platform, or application and use the different options or services available on it.

Personalization cookies: Allow the user to access the service with some predefined general characteristics based on a series of criteria on the user’s terminal, such as language, type of browser used to access the service, regional configuration from which the user accesses the service, etc.

Analytical cookies: Allow the data controller to track and analyze the behavior of users of the linked websites. The information collected through this type of cookie is used to measure the activity of websites, applications, or platforms and to create navigation profiles of the users of these sites, applications, and platforms, in order to introduce improvements based on the analysis of the usage data provided by users of the service.

Advertising cookies: Allow the most effective management possible of the advertising spaces that, if applicable, the publisher has included on a web page, application, or platform from which the requested service is provided, based on criteria such as the content edited or the frequency with which the ads are displayed.

Behavioral advertising cookies: Allow the most effective management possible of the advertising spaces that, if applicable, the publisher has included on a web page, application, or platform from which the requested service is provided. These cookies store information on user behavior obtained through continuous observation of their browsing habits, which allows the development of a specific profile to display ads based on it.

Disabling cookies
You can allow, block, or delete cookies installed on your computer by configuring the options of the browser installed on your computer. Please read the help section of your browser carefully to learn more about how to activate “private mode” or unblock certain cookies.

Internet Explorer: Tools -> Internet Options -> Privacy -> Settings.
For more information, you can consult Microsoft’s support or the browser’s help.
Firefox: Tools -> Options -> Privacy -> History -> Custom Settings.
For more information, you can consult Mozilla’s support or the browser’s help.
Chrome: Settings -> Show advanced settings -> Privacy -> Content settings.
For more information, you can consult Google’s support or the browser’s help.
Safari: Preferences -> Security.
For more information, you can consult Apple’s support or the browser’s help.
Disabling or Deleting Google Analytics Cookies
If you accept the use of cookies belonging to Google Analytics, you can uninstall them later by configuring your browser, as indicated, or by installing the Google Analytics Opt-out Add-on:

We remind you that if you delete personalization cookies, you will need to update your preferences every time you log in with us or if you use a different device, computer profile, or browser, you will need to provide us with your preferences again. Likewise, this deletion may prevent the correct functioning of some features.

Updates and Changes to the Cookie Policy
THE ENTITY may modify this Cookie Policy in accordance with legislative and regulatory requirements, or in order to adapt this policy to the instructions and recommendations issued by the Spanish Data Protection Agency. Users are advised to review the Cookie Policy periodically.

THE ENTITY wishes to point out that the variation of cookies that appear on this website may not be related to its management and maintenance, so periodic reviews are carried out to adapt its cookie policy.

THE ENTITY assumes no responsibility for legal or technical problems caused by the USER’s failure to comply with the included recommendations. This communication is for the knowledge and use of the users and should not be used for any other purpose.

THE ENTITY is not responsible for the content and accuracy of the privacy policies of third parties included in this cookie policy.

If you have any doubts about this cookie policy, you can contact us at