Privacy Policy

Effective Date: December 11, 2025

1. Introduction

This Privacy Policy explains how MAIN INNOVATE LOGISTIC UP d.o.o. ("Company", "we", "us", or "our") collects, uses, stores, and protects personal data when you use our Service.

This Privacy Policy applies to the following domains and services operated by us:

Throughout this document, references to "the Service" include both domains and all associated subdomains.

We are committed to protecting your privacy and ensuring that your personal data is handled in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

By using our Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the Service.

2. Data Controller

The data controller responsible for your personal data is:

MAIN INNOVATE LOGISTIC UP d.o.o.
Ulica 1. svibnja - Via Primo Maggio 4
52470 Umag, Istarska županija, Croatia
VAT Number: HR42367327103
Email: [email protected]

We have not appointed a Data Protection Officer (DPO) as we do not meet the threshold requirements under Article 37 of the GDPR. For any privacy-related inquiries, please contact us at the email address above.

3. Categories of Data Subjects

We process personal data from three distinct categories of individuals:

4. Personal Data We Collect

4.1 Data Collected from Tenants (Registered Users)

When you register for and use a Visiono.io account, we collect:

Data Type Examples Purpose
Account Information Name, email address, password (hashed) Account creation and authentication
Business Information Company name, company logo, VAT number Service customization and invoicing
Billing Information Billing address, payment method (via Stripe) Payment processing
Preferences Timezone, language, notification settings Service personalization
Usage Data Login history, feature usage, API calls Service improvement and support

4.2 Data Collected from Customers (End-Users)

When Customers upload photos through links provided by Tenants (via visio.now or tenant-specific subdomains like [tenant].visio.now), we collect the following data on behalf of the Tenant (as Data Processor):

Data Type Details
Uploaded Photos Image files captured via the interface
Stored encrypted
Geolocation GPS coordinates (if enabled)
Optional; Tenant decides if required
Device Information Device type, operating system, browser
For compatibility and debugging
Technical Data IP address, browser info, user agent
Security and rate limiting
Timestamps Date and time of upload
Audit trail

Important: For Customer data, the Tenant is the Data Controller and determines the purposes and means of processing. We process this data solely on the Tenant's instructions as their Data Processor.

4.3 Data Collected from Demo Users

When you use our Interactive Demo on visiono.io (without registration), we collect:

Data Type Purpose Retention
IP Address Rate limiting, abuse prevention 48 hours
User Agent Statistics, debugging 48 hours
Demo Photo Demo functionality 48 hours
Event Timestamps Analytics 48 hours

We do NOT collect from Demo users: GPS/geolocation data, names, email addresses, or any other personally identifiable information beyond what is listed above.

5. Legal Bases for Processing

Under the GDPR, we process personal data based on the following legal bases:

Legal Basis GDPR Article Processing Activities
Contract Performance Art. 6(1)(b) Account management, service provision, billing, support
Legitimate Interests Art. 6(1)(f) Security, fraud prevention, service improvement, analytics
Legal Obligation Art. 6(1)(c) Tax records, legal compliance, responding to authorities
Consent Art. 6(1)(a) Demo usage (explicit acceptance required), optional features

For Customer data processed on behalf of Tenants: We act as a Data Processor under Article 28 GDPR. The Tenant (Data Controller) is responsible for ensuring an appropriate legal basis exists for collecting their Customers' data.

6. How We Use Your Data

We use personal data for the following purposes:

6.1 Service Provision

6.2 Billing and Payments

6.3 Communication

6.4 Security and Fraud Prevention

6.5 Service Improvement

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected:

Data Category Retention Period Reason
Tenant Account Data Duration of account + 30 days Service provision
Billing/Invoice Records 11 years from transaction Croatian tax law requirements
Customer Photos (via Tenants) As determined by Tenant Tenant is Data Controller
Demo Data (photos, IP, etc.) 48 hours Data minimization
Server Logs 30 days Security and debugging
Analytics Data (Umami) 24 months (aggregated) Service improvement

Upon account deletion or at the end of the retention period, personal data is permanently deleted or anonymized, except where retention is required by law.

7.1 Photo Deletion and External Storage

When you delete a photo or your entire workspace, Visiono applies the following rules to external copies:

You can toggle these options at any time in Storage Settings → Photo Deletion Behavior. To exercise the GDPR right to erasure (Art. 17) across all locations, enable both toggles before deleting the relevant photos, or contact us using the details below.

8. Data Sharing and Sub-Processors

We do not sell your personal data. We share personal data only with the following categories of recipients:

8.1 Sub-Processors

We use the following third-party service providers who may process personal data on our behalf:

Provider Purpose Location Data Processed
Hetzner Online GmbH Cloud hosting infrastructure Germany (EU) All service data
Stripe, Inc. Payment processing USA (EU SCCs) Billing data, payment info
Umami (self-hosted) Privacy-friendly analytics Germany (EU) Aggregated, anonymized
Cloudflare, Inc. CDN, DDoS protection, Turnstile Global (EU SCCs) IP address, request data

8.2 Other Disclosures

We may also disclose personal data:

9. International Data Transfers

Your personal data is primarily stored and processed within the European Union (Germany) on servers operated by Hetzner Online GmbH.

When data is transferred outside the EU/EEA (e.g., to Stripe in the USA), we ensure appropriate safeguards are in place:

You may request information about the specific safeguards applied to transfers of your data by contacting us.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

10.1 Technical Measures

10.2 Organizational Measures

10.3 Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours as required by GDPR Article 33. If the breach is likely to result in a high risk, we will also notify affected individuals directly (Article 34).

11. Your Rights Under GDPR

Under the GDPR, you have the following rights regarding your personal data. To exercise any of these rights, please contact us at [email protected].

Right Description
Right of Access (Art. 15) Request a copy of the personal data we hold about you
Right to Rectification (Art. 16) Request correction of inaccurate or incomplete data
Right to Erasure (Art. 17) Request deletion of your data ("right to be forgotten")
Right to Restriction (Art. 18) Request limitation of processing in certain circumstances
Right to Portability (Art. 20) Receive your data in a structured, machine-readable format
Right to Object (Art. 21) Object to processing based on legitimate interests
Withdraw Consent (Art. 7) Withdraw previously given consent at any time

Response Time: We will respond to your request within one month. This period may be extended by two additional months for complex requests, in which case we will inform you.

Verification: We may need to verify your identity before processing your request to protect your data from unauthorized access.

Right to Complain: You have the right to lodge a complaint with a supervisory authority. For Croatia, this is the Agencija za zaštitu osobnih podataka (AZOP) at azop.hr.

12. Cookies and Tracking Technologies

This section applies to both visiono.io and visio.now (including all subdomains).

12.1 Cookies We Use

We use only strictly necessary (technical) cookies that are essential for the operation of our Service. These cookies:

12.2 Analytics

We use Umami Analytics, a privacy-friendly, cookie-less analytics solution. Umami:

12.3 No Marketing or Third-Party Tracking Cookies

We do NOT use:

13. Children's Privacy

Visiono.io is designed for business use and is not intended for use by individuals under 18 years of age. We do not knowingly collect personal data from minors.

If you believe we have inadvertently collected data from a minor, please contact us immediately at [email protected], and we will take steps to delete such information.

For Tenants: If your use case involves collecting photos from minors, you (as Data Controller) are solely responsible for ensuring compliance with applicable laws regarding children's data, including obtaining verifiable parental consent where required.

14. Data Controller vs. Data Processor Roles

Understanding our respective roles is important for GDPR compliance:

14.1 When We Are the Data Controller

We act as the Data Controller for:

14.2 When We Are the Data Processor

We act as a Data Processor for:

As Data Processor, we process Customer data only according to the Tenant's instructions as documented in our Terms of Service and any Data Processing Agreement (DPA).

14.3 Tenant Responsibilities as Data Controller

Tenants using Visiono.io to collect Customer data are responsible for:

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

When we make changes:

Your continued use of the Service after any changes indicates your acceptance of the updated Privacy Policy.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

MAIN INNOVATE LOGISTIC UP d.o.o.
Ulica 1. svibnja - Via Primo Maggio 4
52470 Umag, Istarska županija, Croatia
VAT Number: HR42367327103
Email: [email protected]
Website: https://visiono.io

Supervisory Authority: Agencija za zaštitu osobnih podataka (AZOP), Selska cesta 136, 10000 Zagreb, Croatia — azop.hr


By using Visiono.io, you acknowledge that you have read and understood this Privacy Policy.

Last updated: December 11, 2025