Protection of personal data in accordance with the RGPD


This Application collects some Personal Data from its Users.


Owner of Data Processing
Person in charge: Elise Le Thinh.
Commercial name: Combina con Vino
CIF: Y4732893J
Address: Calle Florista, 153, puerta. 9, 46035-Valencia.
Contact: Tel.- +34 651701379
Activity: Sale of tourist programs focused on discovering the wine world of the Utiel-Requena appellation of origin; as well as, sale of original packages combined with extra activities.


Responsible: Elise Le Thinh
Commercial name: Combina con Vino
CIF: Y4732893J
Address: Calle Florista, 153, puerta. 9, 46035-Valencia.
Contact: Tel.- +34 651701379
Activity: Sale of tourist programs focused on discovering the wine world of the Utiel-Requena appellation of origin; as well as, sale of original packages combined with extra activities. Contact email of the Owner:

Elise Le Thinh , in application of current legislation on the protection of personal data, informs you
that the personal data collected through the forms on the website:, are
included in the specific automated files of users of Elise Le Thinh services.
The purpose of the collection and automated processing of personal data is the maintenance of
the commercial relationship and the performance of information, training, advice and other
activities of Elise Le Thinh.

This data will only be passed on to those entities that are necessary for the sole purpose of
fulfilling the aforementioned purpose.
Elise Le Thinh takes the necessary measures to ensure the security, integrity and confidentiality
of the data in accordance with the provisions of 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 the old
LOPD, the new Organic Law 3/2018 of 5 December on Data Protection and Guarantee of Digital
Rights (LOPDGDDD).

The user may at any time exercise the rights of access, opposition, rectification, cancellation,
limitation and portability recognised in the aforementioned Regulation (EU). These rights may be
exercised by the user by sending an email to: or to the following
address: C/ Florista, 153, Planta 3, Puerta 9, C.P. 46035 – Valencia (Valencia).

The user declares that all the data provided by him/her are true and correct, and undertakes to
keep them updated, communicating any changes to Elise Le Thinh.

Purpose of the processing of personal data:

For what purpose will we process your personal data?
Elise Le Thinh will process your personal data collected through the website:, for the following purposes:
• To comply with the company’s commercial, labour, corporate and accounting obligations.
• To provide its services in accordance with the particular needs of the clients, in order to
comply with the contracts signed by the company.
• Sending commercial information and newsletters about new services offered on the
website and the sector.
• Execute a contract signed remotely with the user.
• To provide the services contracted by the user.
• To send promotional information electronically.
• To provide the information requested by the user through the contact form.

We remind you that you may oppose the sending of commercial communications by any means
and at any time by sending an e-mail to the address indicated above.

The fields in these registers must be filled in, and it will be impossible to carry out the purposes
expressed if these data are not provided.

How long will the personal data collected be kept?

The personal data provided will be kept for as long as the commercial relationship is maintained
or you do not request its deletion and for the period of time for which legal responsibilities may
arise from the services provided.

The processing of your data is carried out on the following legal bases that legitimise the same:
• The request for information and/or the contracting of the services of Elise Le Thinh, the
terms and conditions of which will be made available to you in any case, prior to any
eventual contracting.
• Free, specific, informed and unequivocal consent, insofar as we inform you by making
this privacy policy available to you, which after reading it, if you agree, you can accept by
means of a declaration or a clear affirmative action, such as ticking a box provided for
this purpose.
If you do not provide us with your details or if you do so incorrectly or incompletely, we will not be
able to deal with your request, making it completely impossible to provide you with the information
requested or to carry out the contracting of services.


The data will not be communicated to any third party outside Elise Le Thinh , unless legally
obliged to do so.
Data collected by users of the services
In cases where the user includes files with personal data on the shared hosting servers, Elise Le
Thinh shall not be held responsible for the users failure to comply with the RGPD.
Intellectual property rights

Elise Le Thinh is the owner of all copyrights, intellectual and industrial property rights, know-how
and any other rights relating to the contents of the website and the
services offered therein, as well as the programmes necessary for their implementation and
related information.

The reproduction, publication and/or use of the contents, in whole or in part, of the website, other than for strictly private use, is not permitted without
prior written consent.

Intellectual property of the software

The user must respect third party software made available by Elise Le Thinh, even if it is free
and/or publicly available.

Elise Le Thinh has the necessary exploitation and intellectual property rights to the software.
The user does not acquire any rights or licenses for the contracted service, on the software
necessary for the provision of the service, nor on the technical information for monitoring the
service, with the exception of the rights and licenses necessary for the fulfilment of the contracted
services and only for the duration of the same.

For any action that exceeds the fulfilment of the contract, the user will need written authorisation
from Elise Le Thinh, the user being prohibited from accessing, modifying, visualising the
configuration, structure and files of the servers owned by Elise Le Thinh, assuming the civil and
criminal responsibility derived from any incident that may occur in the servers and security
systems as a direct consequence of negligent or malicious action on their part.

Intellectual property of hosted content

Any use contrary to the legislation on intellectual property of the services provided by Elise Le
Thinh is prohibited, and in particular:
• Use that is contrary to Spanish law or that infringes the rights of third parties.
• The publication or transmission of any content which, in the opinion of Elise Le Thinh , is
violent, obscene, abusive, illegal, racial, xenophobic or defamatory.
• Cracks, software serial numbers or any other content that infringes the intellectual
property rights of third parties.
• The collection and/or use of personal data of other users without their express consent or
in contravention of the provisions of 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.

• The use of the domains mail server and email addresses for sending unsolicited bulk

The user bears full responsibility for the content of his website, transmitted and stored
information, hypertext links, third party claims and legal actions with reference to intellectual
property, third party rights and the protection of minors.

The user is responsible with regard to the laws and regulations in force and the rules concerning
the operation of the online service, e-commerce, copyright, maintenance of public order, as well
as universal principles of Internet use.

The user shall indemnify Elise Le Thinh for the costs incurred by Elise Le Thinh in any case for
which the user is responsible, including legal fees and expenses, even in the event of a non-final
court decision.

Protection of hosted information

Elise Le Thinh makes backup copies of the content hosted on its servers, but cannot be held
responsible for the loss or accidental deletion of data by users. Likewise, it does not guarantee
the total replacement of data deleted by users, as the said data may have been deleted and/or
modified during the period of time elapsed since the last backup.
The services offered, except for specific backup services, do not include the replacement of the
contents kept in the backup copies made by Elise Le Thinh, when this loss is attributable to the
user; in this case, a fee will be determined according to the complexity and volume of the
recovery, always with the prior acceptance of the user.

The replacement of deleted data is only included in the price of the service when the loss of
content is due to causes attributable to Elise Le Thinh .

Commercial communications

In application of the LSSI. Elise Le Thinh will not send advertising or promotional communications
by e-mail or any other equivalent means of electronic communication that have not been
previously requested or expressly authorised by the recipients of the same.
In the case of users with whom there is a prior contractual relationship, Elise Le Thinh is
authorised to send commercial communications concerning Elise Le Thinh products or services
that are similar to those that were initially contracted with the client.
In any case, the user, after proving his/her identity, may request that no further commercial
information be sent to him/her through the Customer Service channels.

Kind of Data collected

Among the kinds of Personal Data collected by this Application, either directly or through third parties are: Cookies; Usage data; first name; surnames; phone number; Email address; Data communicated during the use of the service.
The complete information regarding each category of Personal Data that is collected is provided by specific explanatory texts that are displayed before the collection of said Data.

The Personal Data may be provided freely by the User or, in the case of the Data of Use, will be automatically collected when this Application is used.

All the Data requested by this Application are mandatory and the refusal to provide them may make it impossible for this Application to proceed with the provision of the Service. In cases in which this Application specifically indicates that certain Data are not mandatory, Users will be free not to communicate such Data without this having any consequence on the availability or operation of the Service. Users who have doubts about what Data are required can contact the Owner.

The use of Cookies – or other monitoring tools – by this Application or by the holders of third party services used by this Application is for the purpose of providing the Service requested by the User, in addition to any other purposes described in this document and the Cookies Policy, if available.
The User assumes responsibility for the Personal Data of third parties that are obtained, published or shared through this Application and hereby declares that he has the consent of said third parties to provide said Data to the Holder.


Modality and place of the treatment of the collected data

Treatment Modalities

The Holder will treat the Data of the Users in an appropriate manner and will adopt the appropriate security measures to prevent the unauthorized access, disclosure, alteration or destruction of the Data.

Data processing will be carried out by computers and / or computer tools, following procedures and organizational modalities strictly related to the aforementioned purposes. In addition to the Holder, in certain cases the Data may access certain categories of authorized persons, related to the operation of this Application (administration, sales, marketing, legal department and systems administration) or external contractors that provide services to the Holder (such as external providers of technical services, courier companies, hosting companies, computer companies, communication agencies) that will be appointed by the Holder as Treatment Managers, if necessary.

The Holder may be requested at any time for an updated list of said persons.


Legal Basis of Treatment

The Holder may treat the User’s Personal Data, if one of the following conditions is met:


  • When Users have given their consent for one or more specific purposes. Warning: Under the protection of several different legislations, the Holder may be authorized to process the Personal Data until the User opposes it (“reject”), without the need of consent or any other legal basis. It will not be applicable when the processing of Personal Data is subject to European regulations on the protection of Personal Data;
  • When the obtaining of Data is necessary for the fulfillment of a contract between the User and / or any other pre-contractual obligation of the same;
  • When the treatment is necessary for compliance with a mandatory legal obligation by the User;
  • When the treatment is related to a task performed in the public interest or in the exercise of official competences granted to the Holder;
  • When the treatment is necessary for the purpose of a legitimate interest pursued by the Holder or a third party.


In any case, the Holder will be willing to clarify the specific legal bases that apply to the treatment and in particular, if the obtaining of the Personal Data is a contractual or statutory requirement or a necessary requirement to formalize a contract.



The Data is processed in the offices of the Holder, as well as in any other place in which the parties involved in said treatment process are located. Depending on the location of the Users, data transfers may involve the transfer of User Data to a country other than their own. Users will also have the right to know the legal basis of data transfers to another country outside the European Union or to any international body governed by International Public Law or consisting of two or more countries, such as the UN, and also know the security measures taken by the Holder to safeguard their Data.

In case that said data transfer takes place, Users may obtain more information by consulting the relevant sections of this document or by requesting it from the Owner, through the contact information that appears in the contact section.


Conservation period

The Personal Data will be treated and conserved during the necessary time and for the purpose for which they were collected.



  • The Personal Data collected for the formalization of a contract between the Owner and the User must be kept as such until such time as said contract has been fully formalized.
  • The Personal Data collected in the legitimate interest of the Owner must be kept for the time necessary to fulfill that purpose. Users can find specific information related to the legitimate interest of the Owner by consulting the relevant sections of this document or by contacting the Owner.


The Owner may keep the Personal Data for an additional period when the User consents to such treatment, provided that such consent remains in force. In addition, the Owner will be obliged to keep Personal Data for an additional period whenever it is required for the fulfillment of a legal obligation or by order that comes from the authority.

Once the conservation period has ended, the Personal Data must be deleted. Therefore, the rights of access, modification, rectification and portability of data may not be exercised once that period has expired.


Purpose of the Treatment of the Data collected

The Data relating to the User is collected to allow the owner to provide their Services, as well as for the following purposes: Statistics, Contacting the User, Management of the Users database and Label Management.

Users can find detailed information about such treatment purposes and about the specific Personal Data used for each purpose in the respective sections of this document. Detailed information on the Treatment of Personal Data The Personal Data is collected for the following purposes and using the following services:


  • Contact the UserContact form (this Application)
    By filling out the contact form with your Data, the User authorizes this Application to use said data to respond to requests for information, budgets, reservations or any other type that is indicated in the heading of the form.
    Personal data collected: surname (s); Email address; first name; phone number, bank details.
  • StatisticsThe services contained in this section allow the Owner to monitor and analyze web traffic and can be used to track the User’s behaviour.

    Google Analytics (Google Inc.)
    Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the Collected Data to track and examine the use of this Application, to prepare reports of its activities and to share them with other Google services. Google may use the Collected Data to contextualize and customize the ads of its own advertising network.

    Personal Data collected: Cookies; Usage data.

  • Label ManagementThis type of service helps the owner to manage the labels or scripts that are needed in this Application in a centralized way.

    This implies that the User Data pass through these services, which may result in the retention of said Data.

  • Management of the Users databaseThis type of services allows the owner to create user profiles from an email address, a personal name or any other information that the User provides to this Application, as well as to track the activities of the users. These Personal Data may also be crossed with publicly available User information (such as social network profiles) and be used to create private profiles that the owner can view and use to improve this Application.


Some of these services may also allow the sending of scheduled messages to the User of this Application, such as emails based on specific actions performed in this Application.


The rights of Users

The Users may exercise certain rights with respect to the processing of Data by the Owner.

Especially, Users have the right to do the following:


  • Withdraw your consent at any time. Users have the right to withdraw their consent when they have previously granted it for the processing of their Personal Data.
  • Objection to the processing of your Data. Users have the right to object to the processing of their Data, if such treatment is carried out according to a legal basis other than consent. For more information, go to the corresponding section, below.
  • Access to your Data. The Users have the right to know if their Data will be treated by the Owner, to obtain information about certain aspects of the treatment, in addition to obtaining a copy of the Data object of the treatment.
  • Verify and request the modification. Users have the right to verify the accuracy of their Data and request that they be updated or corrected.
  • Restrict the processing of your Data. Users have the right, in certain cases, to restrict the processing of their Data. In this case, the Owner will process your Data for the sole purpose of storing them.
  • Delete or delete Personal Data. The Users have the right, in certain cases, to obtain the elimination of their Data by the Holder.
  • Receive your Data and transfer it to another person in charge. Users have the right to receive their Data in a standard format, structured, mechanically readable and, if technically possible, to be transferred to another responsible without any impediment. This provision will be applicable provided that the Data have been processed through automated means and that the treatment is based on the consent of the User, in a contract that the User is part of or that appears in the pre-contractual obligations of the same.
  • Make a complaint. Users have the right to file a complaint with the competent authority on the protection of personal data.


Details on the right of opposition to treatment

When the treatment of Personal Data is of public interest, in the exercise of official powers granted to the Holder or due to a legitimate interest of the Holder, the Users may object to the said treatment explaining a reason in relation to their particular situation to justify their objection.

The Users must know that, however, in case their Personal Data are treated for comercial purposes, they can object at any time to such treatment without need of justification.


How to exercise these rights

Any request to exercise the rights of the User can be directed to the Owner through the contact information provided in this document. Said requests will be processed by the Holder without any cost as soon as possible and always within a period of one month.



In case that the Contracting Party acts as the third-party responsible for processing the data, it must guarantee before contracting any service that involves the processing of such data, which has the express authorization of the latter to proceed with the subcontracting of the data the services and uses that have been entrusted to it and that coincide with the purpose of the Main Contract, also ensures that the relationship with the third entity responsible for the data is legally regulated in accordance with the requirements of current legislation on data protection with prior to contracting services through Otherwise, you must abstain from subcontracting with Elise Le Thinh and if you breach this prohibition, you will be responsible and will assume any sanction imposed on it as a consequence of this lack of legitimacy.



Elise Le Thinh has adopted the necessary technical and organizational measures to guarantee the security of personal data and to prevent their alteration, loss, treatment or unauthorized access, in accordance with current regulations on the protection of personal data. Specifically, the measures associated with the average level of security for files and / or automated processing, in accordance with Title VIII of Royal Decree 1720/2007, of December 21, approving the Regulation for the Development of Organic Law 15 / 1999, of December 13, Protection of Personal Data. Elise Le Thinh only provides the technical infrastructure, and in the event that the service is contracted, the administration of the same, circumscribing its responsibility to the security measures provided in relation to these functions. Therefore, its responsibility will be limited to those tasks that, by the very nature of the Main Contract, must be carried out by Elise Le Thinh directly in the addresses of its clients. The Contracting Party recognizes that these measures are adjusted to the level of security applicable to the type of information processed as a consequence of the provision of the services that Elise Le Thinh carries out on behalf of the Contracting Party, in accordance with the provisions of current legislation on data protection. It is the exclusive responsibility of the Contracting Party to assess whether the conditions of the Main Contract are adequate to their needs and comply with the legal requirements to which they are bound as the File / Treatment Manager. In case the treatment to be performed requires any additional measure to those indicated in the Main Contract, the Contracting Party must inform Elise Le Thinh so that it can offer the possibility of contracting additional services necessary to implement said security measure. The hiring of the additional measure will be done through the formalization of a specific document that will be annexed to the Main Contract. If Elise Le Thinh cannot provide the additional measure required by the Contracting Party, she will notify the latter as soon as possible. In the event that for the provision of the contracted services an additional measure not communicated to Elise Le Thinh or not contracted after offering said option to the Contracting Person, Elise Le Thinh will not be responsible for the lack of implementation of the security measures required by current regulations on data protection. Similarly, in case the qualification of the level of the file treated by Elise Le Thinh for the provision of the contracted service was erroneous, Elise Le Thinh will not be responsible for the lack of adequacy of the security measures to the provisions of the regulations.

The Contracting Party must notify the identification of the files or treatments over which Elise Le Thinh is responsible for the treatment, indicating the name of the file, its level or security measures and the data of the File / Treatment Manager, as well as notifying any change in the previous data. In the event that the contracting party fails to fulfill this obligation, it will be liable for the sanctions that were imposed on Elise Le Thinh for that reason.