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Privacy Policy

Last updated: 1 June 2026

Holtzapffel sp. z o.o. ("we", "us", "our"), with registered address at Prosta 7/9, 10-028 Olsztyn, Poland, is the controller of personal data collected through this website. This policy explains what data we collect, why, and your rights under Regulation (EU) 2016/679 (the General Data Protection Regulation, GDPR).

1. What data we collect and why

We collect personal data in the following circumstances:

  • Contact form submissions. When you use the form on the Get in Touch page, we collect your name, email address and the content of your message. The legal basis is our legitimate interest in responding to enquiries (Article 6(1)(f) GDPR), or, where you are booking a service, the performance of a contract (Article 6(1)(b) GDPR).
  • Email correspondence. If you contact us directly by email, we retain that correspondence. Legal basis: legitimate interest.
  • Workshop bookings and commission agreements. We collect the name, contact details and, where relevant, payment information necessary to fulfil a booked service. Legal basis: performance of a contract (Article 6(1)(b) GDPR).
  • Analytics cookies. If you accept non-essential cookies, we may collect anonymised data about how you navigate the site. See our Cookie Policy for details. Legal basis: consent (Article 6(1)(a) GDPR).

2. How we use your data

  • To respond to your enquiry or manage your booking
  • To fulfil a commission or service agreement
  • To send information you have specifically requested
  • To understand how our website is used (analytics, if consented)

We do not use your data for automated decision-making or profiling. We do not sell personal data to third parties. We do not send unsolicited marketing communications.

3. Data retention

Enquiry and correspondence data is retained for up to three years from the date of last contact. Booking and contract data is retained for six years in accordance with Polish accounting law requirements. Analytics data (if applicable) is retained in anonymised form and subject to the retention policy of the analytics provider.

4. Data sharing

We share data only where necessary to deliver a service: with courier or shipping providers for commission deliveries, and with payment processors for fee collection. All third-party processors with whom we share data are bound by data processing agreements and comply with GDPR where applicable.

We do not transfer personal data outside the European Economic Area unless the recipient is located in a country with an adequacy decision or adequate safeguards are in place.

5. Your rights under GDPR

You have the right to:

  • Access the personal data we hold about you
  • Request correction of inaccurate data
  • Request erasure of your data where there is no overriding legal basis for retention
  • Object to processing based on legitimate interest
  • Withdraw consent at any time (where processing is based on consent)
  • Request restriction of processing in certain circumstances
  • Lodge a complaint with the Polish Personal Data Protection Office (UODO) at uodo.gov.pl

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

6. Security

We take reasonable technical and organisational measures to protect personal data against unauthorised access, loss or disclosure. Our website uses HTTPS. Access to stored personal data is restricted to studio staff with a need to process it.

7. Cookies

We use essential cookies that are necessary for the site to function. We use non-essential analytics cookies only with your consent. See our Cookie Policy for full details.

8. Changes to this policy

We may update this policy from time to time. The current version will always be available at this URL. Significant changes will be noted on the site.

9. Contact

For any privacy-related questions or to exercise your rights, contact us at [email protected] or by post to Holtzapffel sp. z o.o., Prosta 7/9, 10-028 Olsztyn, Poland.