Email marketing services

Clever Elements

German newsletter service with subscriptions and prepaid sending

GermanyEU Ownership reviewed, controller unresolved

Scope verdict

Ownership reviewed, controller unresolved

The pricing FAQ expressly says the business is 100% self-financed and belongs exclusively to its two managing directors, named in the imprint as Manuel Kistner and Matthias Meinecke. This is a direct ownership statement, stronger than merely listing founders. A current shareholder list, voting/veto arrangements and independent evidence establishing European ultimate control were not obtained, so the directory retains unresolved status while recording that claim.

How we classify services

Clever Elements GmbH offers hosted email campaigns, recipient lists, an editor and campaign statistics. The operator is in Berlin, HRB 125967 B at Amtsgericht Charlottenburg, VAT DE813700499, with Manuel Kistner and Matthias Meinecke named as managing directors.

Its terms use German law and, where legally permitted, the provider's seat as forum. The company claims German servers and processing and offers a data-processing agreement. A complete public application, sending and backup vendor annex was not obtained; the marketing website's privacy policy does not establish that full service chain.

Pricing

The full September 2026 table lists €5/month for 100 recipients, €20 for 1,000, €90 for 10,000 and €360 for 50,000, with unlimited sends in those paid tiers, plus VAT. Prepaid examples are €10/1,000 credits and €240/50,000; each send consumes one credit per recipient plus 250 credits. The detailed table advertises 1,000 recipients/4,000 emails free, while the FAQ describes a 30-day trial and the terms describe 250 recipients/1,000 emails over 31 days. Confirm the applicable free offer and billing period before relying on them.

Data and operations

Infrastructure and email path

Verified operational dependencies, shown separately from ownership and from the service's core data hosting.

Core service hosting

Clever Elements; full application subprocessor chain not retrieved

Provider control not verified
Observed
Pricing FAQ claims all servers and data processing are in Germany and offers an AVV. The reviewed public pages did not provide the executed agreement, technical measures or complete application/delivery/backup subprocessor annex. Terms promise backups every 24 hours, not a backup deletion deadline.

Public website

NETWAYS GmbH

Provider control not verified
Observed
Website privacy policy explicitly names NETWAYS GmbH, Nuremberg, and a visitor-data processing agreement. Actual 17 September 2026 A record is 193.142.157.15. This is evidence for the marketing site, not the whole mailing platform or supplier ultimate control.

Incoming business email

Google Workspace

Non-European provider
Observed
MX 1 aspmx.l.google.com · 5 alt1.aspmx.l.google.com · 5 alt2.aspmx.l.google.com · 10 alt3.aspmx.l.google.com · 10 alt4.aspmx.l.google.com

Why this matters

Published MX records route incoming business email through Google Workspace. Correspondent details and message content can therefore enter this non-European provider's systems; MX does not reveal the configured storage region.

Authorised outbound email

Google, Intercom and cemsc.net authorised senders

Provider control not verified
Observed
17 September 2026: SPF includes _spf.google.com, spf.mail.intercom.io and cemsc.net. The complete newsletter sending pool and its processing locations were not established from this apex authorisation record.
Evidence

Supporting services

Google YouTube/Maps and Fonticons Font Awesome

Non-European provider
Observed
The website policy names YouTube in extended privacy mode, Google Maps and Font Awesome, including US transfer considerations. This concerns website visitor features and is not a list of newsletter-recipient subprocessors.

Why this matters

The published disclosure lists Google YouTube/Maps and Fonticons Font Awesome for supporting services. Depending on the function, account or customer data may reach this non-European provider. See the source for the documented scope.

Public DNS records identify visible providers and routes, not every backend location or private data-region setting.

Infrastructure checked:

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