Your data in one click: Every e-mail from us contains the link “Meine Daten ansehen oder ändern” (view or change my data) at the bottom. There you can view and change your details, download them or delete everything yourself with one click.
View my data
1Introduction and Scope
This Privacy Policy explains how Visions Umsetzung S.L. (“Visions Umsetzung”, “we”, “us”) processes personal data in its e-mail system (the “System”). The System was developed by Visions Umsetzung, is operated exclusively by us and is used only for our own communication. No other company sends e-mails through it.
We use the System to send:
- newsletters to people who have subscribed and confirmed their subscription (double opt-in),
- customer e-mails to people who have bought one of our products (for example via Digistore24), containing information about the purchased product, customer support and – within the limits permitted by law – similar products of our own,
- partner e-mails to affiliate partners who promote our products,
- invitations to webinars and events, where consent or another legal basis exists.
We are the controller within the meaning of Article 4(7) GDPR for the data processed in the System. The System is hosted by All-Inkl.com; e-mails are sent through Mailgun’s EU region. Data processing agreements under Article 28 GDPR are in place with both providers.
This Policy does not apply to our websites, shops or other services where separate privacy notices exist.
2Controller and Contact Details
| Legal name | Visions Umsetzung S.L. |
| Registered address | Calle Lisboa 3, Bloque 1, Planta 1, Puerta 4, Urb. La Marina, 03177 San Fulgencio, Alicante, Spain |
| General contact | support@visions-umsetzung.com |
| Privacy contact | privacy@visions-umsetzung.com |
Visions Umsetzung is established in Spain and thus within the European Union. The appointment of a representative under Article 27 GDPR is therefore not required.
3What Personal Data We Process
3.1 Newsletter subscribers
| Category | Data elements | Purpose |
|---|---|---|
| Contact details | E-mail address, optionally first name | Sending and personal salutation |
| Proof of subscription (double opt-in) | Time of subscription and confirmation, IP addresses at subscription and confirmation, sign-up form or source, wording of the consent given | Proving that you consented to receive e-mails |
| Interests and assignment | Tags and interests derived from your sign-up or your clicks | Sending content that matches your interests |
3.2 Customers
| Category | Data elements | Purpose |
|---|---|---|
| Contact details | First and last name, e-mail address | Customer communication |
| Purchase data | Product purchased, order number, purchase date, amount, payment, refund or cancellation status | Delivering access and product information, customer support, offers for similar products |
Purchase data is usually transmitted to us automatically by our reseller Digistore24 (see Section 11). We do not receive or store payment details such as card or bank account numbers.
3.3 Affiliate partners
| Category | Data elements | Purpose |
|---|---|---|
| Contact details | Name, e-mail address, partner ID (e.g. Digistore24 ID) | Information about partner programmes, campaigns and promotional material |
3.4 Delivery and usage data (all recipients)
| Category | Data elements | Purpose |
|---|---|---|
| Delivery data | Time of sending, delivery status, bounces, spam complaints | Ensuring deliverability, removing invalid addresses |
| Opens | Whether and when an e-mail was opened | Measuring and improving our e-mails (see Section 4) |
| Clicks | Which link was clicked and when | Measuring performance, assigning interests (see Section 4) |
| Unsubscriptions | Time of unsubscription or objection, e-mail series concerned | Honouring your withdrawal or objection |
4Open and Click Tracking
We measure whether our e-mails are opened and which links in them are clicked. This measurement is personal, i.e. linked to your e-mail address. The measurement is performed by our own System; our delivery provider Mailgun does not track opens or clicks. We do not store your IP address or device when measuring.
How it works:
- Open tracking: our e-mails contain a very small, invisible image (a tracking pixel). When your e-mail client loads this image, the open is recorded.
- Click tracking: links in our e-mails first pass through a redirect address. When you click, we record which link was used; you are then forwarded immediately to the actual destination.
What we use the data for: to understand which topics interest you, to send you more relevant content, to improve timing and content, and to identify inactive recipients so that we do not keep writing to them indefinitely.
Legal basis: for newsletter subscribers, tracking is based on the consent you give when subscribing (Article 6(1)(a) GDPR). For customer and partner e-mails, we rely on our legitimate interest in verifying the delivery and effectiveness of our communication (Article 6(1)(f) GDPR); you may object at any time.
How to prevent tracking: you can withdraw your consent or object at any time, for example by e-mail to privacy@visions-umsetzung.com. As it is not technically possible to opt out of tracking separately, withdrawing consent for newsletters results in unsubscribing from the newsletter. You can also disable automatic image loading in your e-mail client; opens will then not be recorded. Clicks are still recorded when you click a link.
5Purposes and Legal Bases
| Purpose | Processing activity | Legal basis |
|---|---|---|
| Newsletters and webinar invitations to subscribers | Sending newsletters, offers and invitations to confirmed subscribers | Art. 6(1)(a) GDPR – consent |
| Proof of consent | Storing the double opt-in record | Art. 6(1)(c) in conjunction with Art. 7(1) GDPR – duty to demonstrate consent; Art. 6(1)(f) GDPR – defence against claims |
| Customer communication about the purchase | Access details, product updates, usage information, customer support | Art. 6(1)(b) GDPR – performance of a contract |
| Marketing similar products to existing customers | Information about our own products and webinars similar to the product already purchased | Art. 6(1)(f) GDPR – legitimate interest in direct marketing (Recital 47), within the limits of Art. 21(2) LSSI (Spanish Information Society Services Act) and § 7(3) UWG (German Act against Unfair Competition) |
| Partner communication | Information about partner programmes, campaigns and commissions | Art. 6(1)(b) GDPR – partner agreement; additionally Art. 6(1)(f) GDPR |
| Open and click tracking | See Section 4 | Newsletters: Art. 6(1)(a) GDPR; customers and partners: Art. 6(1)(f) GDPR |
| Segmentation | Assigning tags based on sign-up, purchases and clicks | Art. 6(1)(a) GDPR (newsletters) or Art. 6(1)(f) GDPR (customers, partners) |
| Deliverability | Processing bounces and spam complaints, blocking invalid addresses | Art. 6(1)(f) GDPR – legitimate interest in reliable delivery |
| Suppression list | Storing unsubscribed addresses so they are not contacted again | Art. 6(1)(c) and (f) GDPR |
| Security and logging | Access and security logs of the System | Art. 6(1)(f) GDPR; Art. 5(2) and Art. 32 GDPR |
| Legal obligations | Retention to defend legal claims, responses to authorities | Art. 6(1)(c) GDPR |
Where we rely on legitimate interests, that interest lies in operating functioning, secure and effective e-mail communication with subscribers, customers and partners. We have concluded that your interests and fundamental rights do not override it, as we process only the necessary data and you can object at any time.
Note on marketing to existing customers: if you have bought a product from us, we may send you information about similar products of our own even if you have not subscribed to the newsletter. You can object to this at any time without incurring any costs other than transmission costs at basic rates. Every such e-mail contains an unsubscribe link. You will only receive newsletter content on other topics if you have subscribed via double opt-in.
We do not collect special categories of personal data (Article 9 GDPR) through the System.
6Recipients of Personal Data
- All-Inkl.com – Neue Medien Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany. Hosting of the System and its database on servers in Germany, acting as processor under Article 28 GDPR. Our data processing agreement with All-Inkl.com can be viewed here.
- Mailgun – Mailgun Technologies, Inc. (a Sinch company). Technical delivery of e-mails and reporting of delivery problems, spam complaints and unsubscriptions back to our System. We use Mailgun’s EU region; delivery data is processed in data centres within the EU. Mailgun acts as processor under Article 28 GDPR. The current Data Processing Agreement of Sinch (Mailgun) forms part of our contract.
- Staff and contractors of Visions Umsetzung, to the extent they need access for their tasks. Permissions are graded by role; staff cannot, for example, download or permanently delete data.
- Public authorities and courts, where we are legally required to disclose data.
We do not sell or rent your data. Affiliate partners have no access to the addresses of our subscribers or customers.
7International Data Transfers
The System is hosted in Germany. For sending we use Mailgun’s EU region, so delivery data is processed within the EU. However, Mailgun belongs to a group of companies that also operates in the United States, so access from the US, for example for support or maintenance, cannot be fully excluded. Mailgun Technologies, Inc. is certified under the EU-US Data Privacy Framework; to that extent an adequacy decision of the European Commission under Article 45 GDPR applies. In addition, the European Commission’s Standard Contractual Clauses under Article 46(2)(c) GDPR have been agreed.
7aReminders via WhatsApp
On some confirmation pages you can additionally order reminders via WhatsApp. This only happens if you send us a message containing your personal code yourself. Your consent covers only the offer that code belongs to (for example “Dinner Talk”); we do not use it to send you marketing for other offers.
| What | Details |
|---|---|
| Data stored | Phone number, the name from your profile, the offer you ordered reminders for, the wording of your order message as proof, a log of sent and received messages with delivery status |
| Legal basis | Your consent, Article 6(1)(a) GDPR |
| Withdrawal | At any time: send “STOP” to the same number. Your e-mails are not affected. |
| Recipient WhatsApp | WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland (WhatsApp Business Platform). Meta may also process data in the United States; Meta Platforms, Inc. is certified under the EU-US Data Privacy Framework (Article 45 GDPR). |
| Retention | As long as you receive the reminders. After “STOP”, number, name and order are deleted after 30 days; unused codes also after 30 days; the message log after 90 days. |
Information and webinar registration via WhatsApp
If you scan one of our QR codes or tap a WhatsApp link and send us the prepared message, we reply there automatically with information, images or videos and ask what we may call you and whether you would like to give us your e-mail address (optional). If you choose a webinar date, we register you in our webinar system (operated by us, servers at ALL-INKL) and send you your personal access link there, plus reminders the day before and shortly before the start.
| What | Details |
|---|---|
| Data stored | Phone number, profile name, the name you give us, your e-mail address (if provided), your replies and button taps, the chosen date, whether you attended the webinar and clicked the offer |
| Legal basis | Your consent by sending the message, Article 6(1)(a) GDPR; for the webinar registration Article 6(1)(b) GDPR |
| E-mail address | If you provide your address, we also send your webinar access by e-mail. You only receive our newsletter after confirming it via the link in our confirmation e-mail (double opt-in). |
| Withdrawal | At any time: send “STOP” to the same number. |
| Retention | 30 days after “STOP”, otherwise 12 months after your last message. In the webinar system its own deletion periods apply (registrations are deleted shortly after the webinar). |
8Retention Periods
We follow the subscription principle: you decide when it starts, and you decide when it ends. Your data is stored as long as you receive our e-mails or are a customer. If you unsubscribe or delete your data yourself, that is the end of it. So that we can defend ourselves against unjustified accusations, we afterwards keep only the proof that you consented and unsubscribed — or that we deleted your data.
| Data | How long | What remains afterwards |
|---|---|---|
| Newsletter | Until you unsubscribe | Within 30 days thereafter everything is deleted except the proof (see below). Unconfirmed sign-ups are deleted after 30 days. |
| Purchases | As long as you are a customer | An active subscription always counts. If for 3 years there has been no purchase, no payment and no response to our e-mails, we delete the data. |
| Partners | As long as the partnership exists | Then we delete the data. |
| Opens and clicks | 24 months | Then only the anonymous total remains. |
| Your proof: consent and unsubscription | 3 years after the end of the year of unsubscription or deletion | Time, IP address and wording of your consent, the time of your unsubscription and how many e-mails you had received — also after a deletion, proving that every e-mail was lawful (Article 17(3)(e) GDPR). |
| Suppression list and proof of deletion | As long as we send e-mails | Only an irreversible hash of the e-mail address, the time and the occasion. This way we never e-mail unsubscribed addresses by mistake and can prove when data was deleted. If you sign up again later, it is a new sign-up. |
| Mailgun delivery logs | A few days up to 30 days | As set by Mailgun. |
| Security logs | Up to 12 months | To investigate misuse. |
Our System applies these periods automatically once a day. Automatic backups are overwritten after 14 days; until then they may still contain data already deleted from the live System. Where data is needed longer in an individual case, for example due to a legal dispute or an official request, we keep it in restricted form until that reason ceases to apply.
9Segmentation and Profiling
We assign recipients to tags and interests based on their sign-up, purchases and click behaviour in order to send relevant content. This is a form of profiling. It serves only to select e-mail content. No automated individual decision-making producing legal effects concerning you or similarly significantly affecting you (Article 22 GDPR) takes place.
10Unsubscribing
Every newsletter and marketing e-mail contains an unsubscribe link. E-mails supporting a purchased product contain a link to cancel only that e-mail series. Our e-mails also support one-click unsubscription directly in your e-mail client where your provider offers it. You can also unsubscribe at any time by e-mail to privacy@visions-umsetzung.com. Unsubscriptions are processed without delay.
11Source of Personal Data
Newsletter data is provided directly by you through our sign-up forms. Purchase data is provided by Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany, through which you buy our products. Digistore24 is an independent controller for processing the purchase; please refer to Digistore24’s privacy policy. Partner data is provided by you or by the Digistore24 partner programme. Delivery, open and click data arises when you use our e-mails.
12Your Rights
| Right | What it means |
|---|---|
| Access (Art. 15 GDPR) | You can find out whether and what data we hold about you and receive a copy. |
| Rectification (Art. 16 GDPR) | Inaccurate data is corrected. |
| Erasure (Art. 17 GDPR) | Your data is deleted unless a retention obligation applies. |
| Restriction (Art. 18 GDPR) | Your data is blocked rather than deleted. |
| Data portability (Art. 20 GDPR) | You receive your data in a structured, machine-readable format. |
| Objection (Art. 21 GDPR) | You can object to processing based on legitimate interests. You can object to direct marketing, including related profiling, at any time without giving reasons; we will then no longer use your data for that purpose. |
| Withdrawal of consent (Art. 7(3) GDPR) | You can withdraw consent at any time with effect for the future, e.g. via the unsubscribe link. |
| Complaint (Art. 77 GDPR) | You can lodge a complaint with a supervisory authority (see Section 15). |
The quickest way is self-service: via the link “Meine Daten ansehen oder ändern” in every e-mail from us, or at https://post.advertise-smart.com/meine-daten.php, you can view and change your details, download them as a file or delete everything yourself with one click — you will receive a confirmation by e-mail right away. Access is sent only to your own e-mail address — this ensures nobody else can see your data.
You can also exercise your rights by e-mail to privacy@visions-umsetzung.com. We will take reasonable steps to verify your identity before providing information or deleting data.
13Security Measures
- Encrypted transmission (TLS) when accessing the System and when sending to Mailgun.
- Access to the System only for authorised persons, with a role and permission concept.
- Passwords are stored only as a cryptographic hash.
- Credentials for external services (e.g. Mailgun keys) are stored encrypted.
- Protection of sign-up forms against automated bulk submissions.
- Rate limiting of login attempts and signed links, so nobody can trigger clicks or unsubscriptions on behalf of others.
- Regular backups.
- Hosting exclusively in data centres in Germany or the EU.
14Obligation to Provide Data
To receive the newsletter we need your e-mail address; all other information is voluntary. Without an e-mail address we cannot send you e-mails. For customers, the e-mail address is required to deliver access and information about your purchase.
15Right to Lodge a Complaint
If you consider that the processing of your personal data infringes the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or the place of the alleged infringement. The authority competent for Visions Umsetzung is:
| Authority | Agencia Española de Protección de Datos (AEPD) |
| Address | C/ Jorge Juan, 6, 28001 Madrid, Spain |
| Website | www.aepd.es |
16Changes to this Policy
We update this Policy when the System, our service providers or the law change. The version in force is the one bearing the “Last reviewed” date above. We will inform you of material changes by e-mail.
17Contact
| General contact | support@visions-umsetzung.com |
| Privacy contact | privacy@visions-umsetzung.com |
| Postal address | Visions Umsetzung S.L., Calle Lisboa 3, Bloque 1, Planta 1, Puerta 4, Urb. La Marina, 03177 San Fulgencio, Alicante, Spain |
Last reviewed: 24 September 2026 · Visions Umsetzung S.L.