Privacy Policy
Privacy information — Holdup Agency
22 April 2026
Controller
Controller: Holdup Agency — Shams Business Center, Sharjah Media City Free Zone, Sharjah — United Arab Emirates. Email: info@holdupagency.it.
Scope
This policy describes how we process personal data through holdupagency.it (and subdomains operated by the same controller), including booking forms.
Data we collect
Data you provide: through the booking form we collect name, email, call type, selected date/time slot, and optional message.
Technical data: server/hosting logs, IP address, user agent; and — only with consent — data collected via Google Analytics 4 and Meta Pixel.
Cookie consent records: preference and timestamp stored locally on your device (local storage).
Purposes and legal bases
Call booking handling: performance of a contract / pre-contractual measures (Art. 6(1)(b) GDPR).
Transactional emails (confirmation, internal notification): same basis and/or legitimate interests (Art. 6(1)(f) GDPR), balanced with your rights.
Creating a calendar event in the controller’s Google Calendar: scheduling (Art. 6(1)(b)).
Audience and campaign measurement (GA4, Meta Pixel): consent (Art. 6(1)(a) GDPR).
Security, abuse prevention, and legal compliance: legitimate interests / legal obligations (Art. 6(1)(c)(f)).
Recipients / processors
We use service providers who process data on our behalf under appropriate agreements.
Vercel Inc.
Website hosting and delivery (edge infrastructure).
Google Calendar API for creating booking events; Google Analytics 4 only with consent.
Meta Platforms
Meta Pixel only with marketing consent.
Resend Inc.
Transactional email delivery (booking confirmation and internal notifications). Email content includes the data you submitted.
Retention
Booking data: kept in the controller’s Google Calendar until deleted or superseded, subject to legal obligations.
Email provider logs: per vendor policy (typically limited retention for deliverability and abuse prevention).
Analytics/marketing: per Google/Meta policies; withdrawing consent stops new collection via those tools.
Your rights
You may exercise GDPR rights (access, rectification, erasure, restriction, portability, objection where applicable) and withdraw consent without affecting the lawfulness of processing based on consent before withdrawal.
Requests: info@holdupagency.it. You may lodge a complaint with your supervisory authority (e.g. the Italian Garante for individuals in the EEA context).
International transfers
Some providers are located in the USA; appropriate safeguards (e.g. DPF, SCCs) apply where required. The controller is established in the UAE; data may be accessible from that jurisdiction while EEA rights remain as described.
Security
We implement appropriate technical and organizational measures (HTTPS, credential handling on servers, access minimization). We do not operate a proprietary application database for bookings: appointment data is stored in the controller’s calendar and transactional emails.
Changes
We may update this policy; the date above reflects the last material revision.
Privacy contacts
info@holdupagency.it — Holdup Agency, Sharjah Media City Free Zone, Sharjah, UAE.