Last updated: 18 September 2026
This Privacy Policy explains how we process personal data when you use F.L.O.W. (Flow Loops Operational Workspace) and when you contact us.
Controller
The controller responsible for the processing of personal data is:
Holon Puzzle
Tomasz Karczewski
Block C-15, Südstraße 31
47475 Kamp-Lintfort
Germany
Privacy contact: kontakt@holonpuzzle.com
Phone: +49 176 79911047
Hosting and technical data
The website is hosted by Hostinger.
When you access the website, the hosting infrastructure processes technical data required to deliver the website and protect its security. Depending on the configuration, this may include in particular:
- IP address,
- date and time of the request,
- requested address or resource,
- request method and server response code,
- technical information transmitted by the browser or device,
- data required for error diagnosis and infrastructure protection.
The legal basis for this processing is Article 6(1)(f) GDPR. Our legitimate interest is to ensure the secure, stable and proper operation of the website, detect errors and prevent misuse.
Hostinger processes data in connection with the provision of hosting and email services. Additional subprocessors may be involved in the provider's infrastructure. Where personal data is transferred outside the European Economic Area in connection with these services, the transfer mechanisms and appropriate safeguards provided by law are used.
Technical data is retained only for as long as necessary for the security, proper operation and diagnosis of the infrastructure, taking into account the retention rules applied by the provider to the relevant service.
Settings stored on your device
The website may remember settings selected by you, in particular the interface language or the state of certain informational notices.
These records are used only to preserve a selected function or preference. We do not use them for advertising, analytics or user profiling.
Where storing information on a user's device or accessing information already stored there is strictly necessary to provide a function expressly requested by the user, Section 25(2) No. 2 TDDDG applies.
You can remove stored settings by clearing the website data in your browser settings. After deletion, the website may ask you to select a setting again or may display a previously dismissed notice again.
Contact by email, phone, SMS and WhatsApp
If you contact us, we process the data you provide in connection with your message or call. This may include, in particular, your email address, phone number, the name used in correspondence, the content of the message and other information required to handle your request.
The legal basis depends on the nature of the contact:
- Article 6(1)(b) GDPR — where the contact concerns a contract or steps taken at your request before entering into a contract,
- Article 6(1)(f) GDPR — for ordinary communication relating to our activities or the website; our legitimate interest is to answer questions and conduct ongoing correspondence,
- Article 6(1)(c) GDPR — where processing or further retention of specific information is required by law.
Email is handled using services provided by Hostinger.
If you choose WhatsApp as a contact channel, WhatsApp Ireland Limited also participates in the processing in accordance with the rules of that service. WhatsApp uses a global infrastructure, so data may also be processed outside the European Economic Area. If you do not wish to use WhatsApp, you can contact us by email instead.
We retain correspondence for as long as necessary to handle the relevant matter. If a message concerns a contract, billing, a legal obligation or possible claims, the relevant information may be retained for a longer period where required by law or for the applicable limitation periods.
Holon Puzzle Newsletter
Shared Holon Puzzle newsletter
We offer the possibility of signing up for the Holon Puzzle email Newsletter via the Holon Puzzle websites and the individual projects operated by the Controller, in particular holonpuzzle.com, element.guru and holonflow.app.
Regardless of the website on which the sign-up form is located, this is one newsletter operated by Tomasz Karczewski – Holon Puzzle.
Public news remains available without signing up for the email version on the newsletter pages of the individual projects and in the combined Holon Puzzle newsletter.
Scope of data processed
In connection with operating the newsletter we may process in particular:
the email address; information about the sign-up source, for example Holon Puzzle, Element Guru or F.L.O.W.; information related to the granting, confirmation and withdrawal of consent; subscription status; the date of sign-up and unsubscribe; information concerning delivery of messages; data concerning message opens and clicks on links contained in them; and information concerning the type of device and operating system used to open the newsletter, to the extent generated by the mailing system used.
The sign-up source may be used to assign the recipient to the appropriate segment, to select newsletter content and to direct messages relating to the given project. In particular, the newsletter may first present information related to the project from which the sign-up took place, and then information from the other projects of the Holon Puzzle ecosystem.
Purpose of processing and measurement of newsletter use
The Holon Puzzle email Newsletter is a voluntary channel for delivering news to people who want to receive it directly at the email address provided.
The email version also includes individual measurement of the use of this channel, in particular measurement of message opens and clicks on links contained in them, and analysis of aggregated statistics concerning types of devices and operating systems used to open messages.
We use this measurement to manage the email news channel, in particular to assess list activity, identify recipients who have stopped using the newsletter, limit or end sending to inactive recipients, make an aggregated assessment of interest in particular topics, and improve the form and presentation of subsequent messages, for example their layout, length, structure or adaptation to the devices most often used by recipients.
We use the sign-up source to assign the recipient to the segment corresponding to the project from which the sign-up took place. Open and click data may be used to assess subscription activity and to manage the recipient list. Aggregated statistics concerning interest in content and the way the newsletter is used are used to improve subsequent messages.
We do not use this data to take decisions that produce legal effects concerning recipients or similarly significantly affect them.
Legal bases
The legal basis for processing personal data for the purpose of operating the Holon Puzzle email Newsletter, including segmentation and the described measurement of newsletter use, is the recipient's consent pursuant to Article 6(1)(a) GDPR.
The sending of advertising or marketing messages by email takes place on the basis of the recipient's prior express consent required by Section 7(2) No. 2 of the German Act Against Unfair Competition (UWG).
Where measurement mechanisms used in messages involve storing information on the recipient's terminal device or accessing information already stored on that device, we use them on the basis of consent pursuant to Section 25(1) TDDDG.
The consent covers the email newsletter together with the described measurement as one voluntarily chosen communication channel. A person who does not want to use the email version that includes such measurement may still use the public news available on the websites of Holon Puzzle and its projects.
Double Opt-In
Sign-up for the newsletter is confirmed in a Double Opt-In procedure.
After the form is submitted, a message used to confirm the sign-up is sent to the email address provided. Until confirmation, the address is not used for regular newsletter sending.
Unconfirmed sign-up requests are deleted after 30 days at the latest if the sign-up is not confirmed within that time.
We do not add or import into the mailing system as active subscribers addresses for which we do not have an appropriate, documented basis for sending the newsletter.
Hostinger Reach
We use the Hostinger Reach service for the technical operation of the Holon Puzzle Newsletter.
Hostinger Reach is used by us in particular to operate the recipient list, carry out the Double Opt-In procedure, segment recipients, send messages, handle unsubscribes, and measure opens, clicks and use of the newsletter on particular types of devices.
Hostinger processes data of Holon Puzzle Newsletter recipients on our behalf as a processor on the basis of a data processing agreement. Further Hostinger processors may participate in providing the service.
If, in connection with providing the service, data is transferred outside the European Economic Area to a country for which there is no European Commission decision finding an adequate level of protection, Hostinger provides for the use of appropriate transfer mechanisms, in particular standard contractual clauses approved by the European Commission.
Retention period
Data used to send the newsletter is processed in principle for the duration of an active subscription — until consent is withdrawn, a valid objection to direct marketing is made, the recipient is removed due to inactivity, or the newsletter is discontinued.
Data concerning interactions with the newsletter is used for as long as it is needed to manage an active subscription, assess use of the channel and apply the adopted rules for managing inactive recipients. Data that is no longer needed in a form that allows it to be linked to a specific recipient is deleted or — where possible — retained only as aggregated or anonymised statistics.
After the subscription ends we stop using the recipient's data to send the newsletter and for its individual analysis.
To a limited extent we may continue to store information necessary to demonstrate prior consent, its scope, confirmation in the Double Opt-In procedure and a later unsubscribe, and to establish, exercise or defend legal claims. We store such data in principle for a period corresponding to the applicable limitation period and then delete it, unless a specific proceeding or legal obligation justifies further storage.
Minimal unsubscribe information may also be stored on a suppression list to the extent necessary to ensure that the address is not used again to send the newsletter without a new legal basis. Data on such a list is not used to conduct marketing.
Withdrawal of consent and objection to direct marketing
You may unsubscribe from the Holon Puzzle Newsletter and withdraw the consent given at any time with effect for the future. The simplest way is to use the unsubscribe link contained in every message. You may also contact us at newsletter@holonpuzzle.com.
Withdrawal of consent ends the email subscription and further individual measurement of newsletter use. It does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.
You also have the right at any time to object to the processing of your personal data for direct marketing purposes. After receiving such an objection we will no longer process your data for that purpose.
Recipients of personal data
Depending on how the website is used, recipients of personal data or parties involved in its processing may include:
- Hostinger — for hosting, infrastructure and email,
- telecommunications providers,
- WhatsApp Ireland Limited — if you choose WhatsApp as a contact channel,
- public authorities or other authorised recipients where disclosure is required by law.
We do not sell personal data or disclose it for behavioural advertising.
Transfers outside the EEA
Locating a server in the European Union does not mean that every processing operation performed by external providers takes place exclusively within the EEA.
When using services provided by Hostinger, transfers outside the EEA may occur in connection with additional infrastructure providers. Where required, transfers are safeguarded in accordance with Chapter V GDPR, in particular through an applicable adequacy decision or appropriate standard contractual clauses.
If you contact us via WhatsApp, data may also be processed outside the EEA in accordance with the transfer mechanisms described by that provider.
Retention period
We retain personal data no longer than necessary for the purpose for which it was collected, unless a longer period is required by law or is necessary for the establishment, exercise or defence of legal claims.
Where a fixed deletion date cannot be specified in advance for a particular category of data, the retention period is determined by the purpose of the processing, security requirements, statutory obligations and applicable limitation periods.
Your rights
Subject to the conditions set out in the GDPR, you have in particular the right to:
- access your personal data,
- rectification,
- erasure,
- restriction of processing,
- data portability where the statutory requirements are met.
You can exercise these rights by contacting us at kontakt@holonpuzzle.com.
Right to object
Where we process personal data on the basis of Article 6(1)(f) GDPR, you may object to the processing at any time on grounds relating to your particular situation.
Following an objection, we will no longer process the data for that purpose unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims.
Withdrawal of consent
Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.
Right to lodge a complaint
You have the right to lodge a complaint with a competent supervisory authority, in particular in the Member State of your habitual residence, place of work or the place of the alleged infringement.
The supervisory authority responsible for the controller's place of establishment is:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW)
Email: poststelle@ldi.nrw.de
Website: www.ldi.nrw.de
Provision of data
Technical connection data is required to deliver the website.
Information you provide when contacting us is provided voluntarily. However, without the information required to identify and handle your request, we may be unable to respond.