Last updated: 18 September 2026
This page provides a short overview of the processing of personal data in connection with Element Guru. Full details are available in the website's Privacy Policy.
Controller
Holon Puzzle
Tomasz Karczewski
Block C-15, Südstraße 31
47475 Kamp-Lintfort
Germany
Privacy email: kontakt@holonpuzzle.com
Phone: +49 176 79911047
Purposes and legal bases
Depending on how the website is used, personal data may be processed for the following purposes:
- technical delivery of the website, security and error diagnosis — Article 6(1)(f) GDPR,
- handling correspondence concerning a contract or steps taken at your request before entering into a contract — Article 6(1)(b) GDPR,
- ordinary communication relating to our activities or the website — Article 6(1)(f) GDPR,
- compliance with legal obligations — Article 6(1)(c) GDPR,
- establishment, exercise or defence of legal claims — Article 6(1)(f) GDPR.
If you deliberately load external YouTube content, Article 6(1)(a) GDPR is the legal basis for the processing associated with that activation. Where information is stored on the user's device or information already stored there is accessed, Section 25(1) TDDDG may also apply.
Recipients of personal data
Depending on how the website is used, personal data may be processed by:
- Hostinger — for hosting, infrastructure and email,
- Google or YouTube — after the external player is loaded,
- authorised public authorities where disclosure is required by law.
Transfers outside the EEA
External providers may in certain circumstances process personal data outside the European Economic Area. Where required, transfers are carried out using the mechanisms provided for in Chapter V GDPR.
Retention period
Personal data is retained for as long as necessary to achieve the relevant purpose of processing.
Where a fixed deletion date cannot be specified in advance, the retention period is determined by the purpose of processing, security requirements, statutory obligations and applicable limitation periods.
Your rights
Subject to the GDPR, you have the right to:
- access,
- rectification,
- erasure,
- restriction of processing,
- data portability where the statutory requirements are met.
Where processing is based on Article 6(1)(f) GDPR, you may object to the processing on grounds relating to your particular situation.
Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out before the withdrawal.
Requests concerning your rights can be sent to kontakt@holonpuzzle.com.
Right to lodge a complaint
You have the right to lodge a complaint with a competent supervisory authority.
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, but without the information needed to handle the matter we may be unable to respond.
Full details are available in the Privacy Policy.
Newsletter
If you sign up for the Holon Puzzle email Newsletter, we process your email address, the sign-up source and data related to the subscription and use of the newsletter.
The newsletter is shared by Holon Puzzle and its projects. We use the sign-up source, for example Holon Puzzle, Element Guru or F.L.O.W., for segmentation and content selection.
The email version of the newsletter includes individual measurement of message opens and clicks on links and analysis of aggregated statistics concerning types of devices and operating systems. We use the measurement to manage list activity, assess use of the email news channel and improve the form and presentation of subsequent messages.
The legal basis for processing is consent pursuant to Article 6(1)(a) GDPR. For marketing email communication we also apply Section 7(2) No. 2 UWG, and for mechanisms that access information on the terminal device — Section 25(1) TDDDG.
We use Hostinger Reach as a processor to operate the newsletter. Sign-up is confirmed in a Double Opt-In procedure.
You may withdraw your consent at any time using the unsubscribe link contained in every message or by contacting us.
Full information concerning recipients of data, transfers, retention periods, segmentation, how activity data is used and your rights is available in the Privacy Policy.