Privacy Policy
Plimsoll
1. Who we are and what this policy covers
Plimsoll (“we”, “us”) enforces a published daily send ceiling on each sending domain and uses an AI reply classifier to decide whether a domain's ramp continues. It provisions the domains and mailboxes that ceiling applies to.
Registered at 1204 E 6th St, Unit 3, Austin, TX 78702.
We handle personal data in two different situations, and different rules apply to each:
| Whose data | Our role | What applies | |
|---|---|---|---|
| Part A | People who visit this website, ask about the service or write to us | Controller: we decide why and how the data is used | This policy |
| Part B | Recipient data in the customer's outbound campaigns | Set out in B.1, because it depends on the data | This policy and the data processing agreement we sign with each customer |
If the data processing agreement (“DPA”) and this policy ever disagree about Part B, the DPA wins.
2. Part A: this website and our contact with you
This part covers the personal data we collect for our own purposes: running this website, answering requests, and staying in touch with people who are or might become customers.
A.1 What we collect
What you give us. When you send the form on this site, we collect what you type into it, such as your name, email address, phone number or company, and the fact that you agreed to be contacted. If you email or talk to us, we keep that correspondence and any contact details in it.
What is collected automatically. Our web server records the IP address a request came from, the browser used, the pages requested, the page you came from and the time. These logs exist to keep the site running and secure.
We don’t ask for sensitive data (the “special categories” in Article 9 GDPR) through this website, so please don’t send any through the form.
A.2 Why we use it, and what allows us to
| Why | What | Legal basis (GDPR Art. 6) |
|---|---|---|
| Answering your request and working out whether the service fits | What you sent in the form, our correspondence | Art. 6(1)(b): steps you asked for before a contract |
| Looking after customers, billing and support | Contact details, correspondence | Art. 6(1)(b): carrying out a contract |
| Keeping the site running, secure and free of abuse | Server logs | Art. 6(1)(f): our legitimate interest in running a secure service |
| Contacting you about the service | Email address, company | Art. 6(1)(f): our legitimate interest in business-to-business marketing. You can object at any time |
| Meeting tax, accounting and legal duties | Billing and contract records | Art. 6(1)(c): a legal obligation |
Where we rely on legitimate interest, we have weighed that interest against your rights, and you can ask to see the assessment.
A.3 How long we keep it
- Requests from people who don’t become customers: 12 months from our last contact, then deleted.
- Customer contact and contract records: for the length of the agreement plus 6 years, to cover legal claims and accounting rules.
- Server logs: 30 days.
- A record that you objected or opted out: kept indefinitely, so we can keep respecting it.
A.4 Your rights
If you are in the EEA or the UK, you can ask to see your data, correct it, have it deleted, limit or object to how we use it, get a copy you can take elsewhere, and withdraw consent where we rely on it. Write to [email protected] and we will answer within one month.
You can also complain to a data protection authority. If you are in the EEA, that can be the authority where you live or work.
3. Part B: data inside the service
The customer is the controller of every recipient record. Plimsoll processes recipient addresses and reply content on the customer's instructions and does not use either for its own outbound.
B.1 What we handle, and in what role
What Plimsoll handles on a customer's behalf.
- Outbound message metadata. Recipient address, sending domain, mailbox, timestamp and delivery result for every message sent through a Plimsoll domain. Read in order to enforce the ceiling and to attribute a reply.
- Reply content. The body and headers of replies delivered to a Plimsoll mailbox, read in order to classify the reply and to decide whether a domain's ramp continues.
Plimsoll never uploads, stores or enriches a prospect list. Addresses are seen at send time and retained only as the metadata described above.
B.2 What we do with it
Region. Sending, the mailboxes, the reply store and the review queue run on cloud infrastructure in Oregon. Until Q1 2027 reply classification runs on Microsoft Azure in West US 3; from then Plimsoll's own classifier does it, in Oregon. Fine-tuning of the classifier runs on Azure in West US 3. Reply bodies stay in the United States.
Model provider. Free-text replies are classified by Azure OpenAI in West US 3 under zero data retention: Microsoft does not store reply content or use it to train any model. Header-matched replies are classified by rule without a model call. Classification decides every domain's ramp and runs for every customer. From Q1 2027 Plimsoll's own classifier, served on GPU instances in Oregon, classifies free-text replies instead.
Human review. Replies below the confidence floor are read by a named Plimsoll reviewer. Each read is logged and appears in the customer's audit export.
Suppression. Any reply classified as a removal request suppresses that address across every domain the customer operates, immediately and permanently, and the suppression cannot be lifted from the interface.
B.3 AI models: where they run and what they learn from
Where models run. Header-matched replies are classified by rule without a model call. Free-text replies are classified on Microsoft Azure in West US 3 by Azure OpenAI, under zero data retention; classification decides each domain's ramp and runs for every customer. The embedding pass, the classification queue and the reply store run on cloud infrastructure in Oregon. From Q1 2027 free-text replies are classified instead by Plimsoll's own model, fine-tuned on Azure Machine Learning and served on GPU instances there. Both regions are in the United States.
Training. No customer's replies train a general model, and reply content sent to Azure OpenAI is neither stored nor used for training. The quoted sentence and the reviewer's decision for each reviewed reply are retained as a labeled corpus, detached from customer and recipient identifiers, and used only to fine-tune Plimsoll's own classifier on Azure Machine Learning in West US 3 through 2026 and 2027. A customer may opt out in domain settings.
Where a person decides. The model classifies and never raises a ceiling. Below the confidence floor the reply holds that domain's ramp and a named reviewer reads it before anything moves.
B.4 Where the data is kept
Our cloud infrastructure provider, named on our subprocessor list, in Oregon: sending infrastructure and mailboxes, compute for the embedding pass, the classification and review queues and, from Q1 2027, Plimsoll's own classifier on GPU instances, and object storage for the reply store, the published ramp schedules and the labeled corpus.
Microsoft Azure, West US 3: Azure OpenAI for classifying free-text replies under zero data retention until Q1 2027, and Azure Machine Learning for fine-tuning Plimsoll's classifier on the labeled corpus.
The customer's own sending tool, wherever they run it, which connects over SMTP or IMAP to mailboxes we operate.
The suppliers that handle data in the service are named on our subprocessor list, which comes with the data processing agreement and which we send to anyone who asks: write to [email protected].
B.5 How long we keep it, and what deleting can’t remove
Reply bodies are held for 180 days and then deleted; the classification and its confidence score are kept, and for a reviewed reply the sentence the classifier quoted is kept with the reviewer's decision, detached from customer and recipient identifiers.
Send metadata is kept for two years so a deliverability question can be answered after the fact.
Suppressions are permanent and survive cancellation, because an address that asked to be removed does not become sendable when a contract ends.
B.6 Requests from people whose data is in the service
A recipient may write to us directly. We will suppress the address across every customer domain within one business day and pass the request to the customer that sent to them.
For everyone
4. Moving data between countries
Plimsoll is a company in the United States. When personal data from the EEA or the UK reaches us, for example because someone there writes to us or a customer there uses the service, it is protected by the European Commission’s Standard Contractual Clauses, a transfer impact assessment and the extra technical measures described in our security documentation. You can ask us for a copy of the clauses.
EU representative (Article 27 GDPR). Write to [email protected] with “EU representative” in the subject line and we will send you our representative’s details.
5. Security
We protect data in line with the risk. That includes encryption in transit and at rest, access limited to the people and systems that need it, each customer’s data kept separate from every other’s, and a log of every access to production systems.
If a personal data breach affects you, we tell you without undue delay, and at the latest within 36 hours of finding out, with the information you need to meet your own reporting duties.
6. Children
The service is sold to businesses and is not meant for children. We don’t knowingly collect personal data from anyone under 16.
7. Changes to this policy
We may update this policy. If a change matters, we email customers at least 30 days before it takes effect. The version number and date at the top of this page change every time.
8. Contact
Privacy questions and anything else: [email protected]
By post: Plimsoll, 1204 E 6th St, Unit 3, Austin, TX 78702