Privacy Policy and Terms of Use

## Privacy Policy

1. Who we are and our roles

Pigeonscale is operated by Botanica Studios Limited. Botanica Studios Limited acts as controller for personal data relating to account registration, billing, service administration, support, website operation, security monitoring, abuse prevention, and legal compliance. When customers use Pigeonscale to process emails, attachments, websites, uploads, or other customer content on their behalf, Botanica Studios Limited generally acts as processor or service provider for that customer.

2. Data sources and when data is required

We collect personal data directly from you, automatically from your use of Pigeonscale, from our customers and their authorised users, from people who send communications to or interact with content processed through Pigeonscale, and from service providers acting on our instructions.

If you do not provide personal data that we need to create or administer an account, process payments, communicate with you, or provide the service, we may be unable to provide some or all of Pigeonscale.

3. Information we collect

We may collect and process the following categories of information:

• account and contact details, such as names, email addresses, company details, and billing contacts;
• service configuration data, such as mailbox handles, domains, approval settings, scan rules, and publish settings;
• content and metadata relating to emails, websites, uploads, attachments, and support requests processed through the service;
• technical and usage data, such as IP addresses, device and browser information, logs, diagnostics, request metadata, and security events; and
• communications you send to us, including support and administrative correspondence.

4. How we use personal data

We use personal data to provide, operate, secure, support, and administer Pigeonscale, including to create and manage accounts, route and deliver messages, host published content, review abuse, detect malware and spam, detect prompt injection and secrets leakage, provide support, enforce these terms, and comply with legal obligations.

We do not use customer data to train general-purpose or customer-facing machine learning models.

5. Legal bases

Where the GDPR applies, we generally process personal data because it is necessary to perform a contract with you, because it is necessary for our legitimate interests in operating, securing, and supporting the service, or because we must comply with a legal obligation. If we rely on consent for a specific activity, you may withdraw that consent at any time.

6. Service providers and recipients

We may disclose personal data to hosting and infrastructure providers, email delivery and routing providers, AI and scanning providers, professional advisers, auditors, corporate transaction counterparties, and competent authorities where required. Current core service providers for Pigeonscale include Amazon AWS for email sending, Fly.io for inbound email handling, OpenAI for message and content scanning, and Cloudflare for hosting and edge delivery. These providers may process personal data on our behalf subject to contractual and technical safeguards.

We do not sell customer data. We transfer and disclose personal data only as needed to deliver the services you request, maintain and secure those services, comply with law, or enforce these terms.

The current subprocessor list for Pigeonscale is:

• Amazon AWS, used for email sending and related infrastructure;
• Fly.io, used for inbound email handling;
• OpenAI, used for message and content scanning; and
• Cloudflare, used for hosting and edge delivery.

We may update this subprocessor list from time to time by updating this page.

7. International transfers

Your information may be processed outside your jurisdiction. Any international transfer of personal data is made solely as necessary to deliver the services you request, operate and secure the service, or comply with legal obligations. Where required, we use appropriate safeguards for cross-border transfers, such as contractual protections and similar transfer mechanisms recognised under applicable law. You may request details of the relevant safeguards by contacting coo@pigeonscale.com.

8. Law enforcement and lawful requests

We may be required to respond to requests from law enforcement agencies, regulators, courts, or other public authorities where they present a valid warrant, court order, or other lawful authority requiring disclosure. Where we are legally permitted to do so, we will notify you if we provide your data in response to such a request.

9. Retention

We retain personal data for as long as reasonably necessary to provide the service, maintain security, resolve disputes, enforce agreements, and meet legal requirements. Retention periods may vary depending on the product settings you choose, the type of data involved, and whether we need the data for abuse prevention or compliance records. When customer data is no longer required for service delivery, security, or compliance, we will delete it at the earliest reasonable opportunity.

10. Cookies and similar technologies

Pigeonscale uses cookies and similar technologies only where necessary to deliver, secure, and operate its services, unless we separately ask for consent for non-essential technologies. We do not use cookies for third-party advertising, cross-site profiling, or unrelated tracking.

11. Automated review and scanning

We use automated systems to scan and classify content and events for security, abuse prevention, policy enforcement, spam, malware, secrets leakage, and prompt injection. These systems may flag, quarantine, rate-limit, or block content or actions, or trigger account review. They are intended to support service security and, where applicable, human review. We do not intentionally make solely automated decisions about individuals that produce legal or similarly significant effects unless permitted by law and accompanied by the safeguards required by law.

12. Security

We use reasonable technical and organisational measures designed to protect personal data. No service is completely secure, and you are responsible for maintaining the confidentiality of your account credentials and any systems you connect to Pigeonscale.

13. Your rights

Subject to applicable law, you may have the right to request access to, correction of, deletion of, restriction of, or portability of your personal data, and the right to object to certain processing. You may exercise these rights by contacting coo@pigeonscale.com. Where we process personal data on behalf of a customer, we may direct the request to the relevant customer or ask them to handle it. You may also lodge a complaint with the Irish Data Protection Commission or another competent supervisory authority.

14. Marketing and service messages

We may send service, billing, administrative, and security communications. Where we send marketing communications, we will do so in accordance with applicable law and provide a clear way to unsubscribe.

15. Children

Pigeonscale is not directed to children, and you may not use the service if you are not legally able to enter into a binding agreement.

16. Security reporting

If you discover a vulnerability, security issue, or suspected compromise affecting Pigeonscale, please report it promptly to coo@pigeonscale.com. Please include enough detail for us to investigate and remediate the issue.

17. Abuse reporting

If you believe Pigeonscale is being used for spam, malware, phishing, fraud, or other abusive or unlawful activity, please report it to coo@pigeonscale.com with any relevant evidence or message identifiers.

18. Updates to this policy

We may update this Privacy Policy from time to time. If we make a material change, we may provide notice by updating this page or through the service.

## Terms of Use

1. Scope

These Terms of Use apply to your access to and use of Pigeonscale, including related software, websites, APIs, command-line tools, hosted mailboxes, publishing features, and support services.

Pigeonscale enforces eventual human approval as a condition of using its services. You must ensure that a natural person with appropriate authority reviews and approves any use that requires human approval under your internal controls and applicable law.

2. Accounts

You must provide accurate information, keep your credentials secure, and remain responsible for activity that occurs under your account. If you use Pigeonscale on behalf of an organisation, you represent that you have authority to bind that organisation to these terms.

3. Acceptable use

You may use Pigeonscale only for lawful purposes and in compliance with these terms. You must not, and must not permit others to:

• send unsolicited or unauthorised bulk email, spam, mass marketing campaigns, or other high-volume messaging that is not expressly authorised by us;
• distribute malware, spyware, ransomware, malicious code, phishing content, or any material intended to harm systems, users, or networks;
• use the service for fraud, harassment, infringement, unlawful surveillance, or any other unlawful or abusive activity;
• attempt to bypass service limits, security controls, approval workflows, or abuse protections;
• use the service to gain unauthorised access to systems, accounts, or data; or
• interfere with the normal operation, integrity, or security of Pigeonscale or any third-party service.

4. Compliance with communications, privacy, and publishing laws

You are solely responsible for the legality of your content and of any message, website, or other material sent, routed, hosted, or published using Pigeonscale, including recipient selection, consent, unsubscribe handling, suppression lists, sender identification, sender authentication, and any notices required by law. You must comply with all applicable laws and industry standards relating to privacy, direct marketing, electronic communications, consumer protection, intellectual property, sanctions, and export controls. You must not use purchased, scraped, or unlawfully obtained contact lists.

5. Public content reporting

If Pigeonscale is used to host or publish public content, reports of allegedly illegal content may be sent to coo@pigeonscale.com. We also use proactive scanning and related safeguards designed to detect and reduce unlawful, abusive, or policy-violating content before or during publication. We may remove or disable access to content we reasonably believe is unlawful or violates these terms. Where required by law, we will provide affected users with a statement of reasons or other information about available review or redress.

6. Customer content

You retain ownership of the content you submit to Pigeonscale. You grant us a non-exclusive, worldwide, limited licence to host, store, copy, transmit, display, scan, transform, and otherwise process that content only as necessary to provide, secure, maintain, and support the service, comply with law, and enforce these terms. We do not acquire ownership of your content. This licence is revocable by deleting your Pigeonscale account, except to the extent we must retain or continue processing certain data for security, compliance, dispute resolution, or other purposes described in these terms and the Privacy Policy.

7. Automated review and scanning

You acknowledge that Pigeonscale will automatically scan emails, attachments, websites, and related data for security, abuse prevention, prompt injection, malware, spam, secrets leakage, and policy enforcement. These checks may flag, quarantine, rate-limit, or block content or actions, or trigger account review, and they are a core part of the service.

8. Suspension and termination

We may suspend or terminate access immediately if we reasonably believe your use creates security risk, violates these terms, exposes us or others to liability, or is otherwise abusive or unlawful. We may also, at our sole discretion, decline to open an account, refuse to reactivate an account, or block the creation of new accounts where we reasonably believe doing so is necessary to prevent fraud, abuse, repeated violations, chargeback misuse, or other harm to Pigeonscale or others. You may stop using the service at any time. Sections that by their nature should survive termination will survive termination.

9. Fees

Paid features, if any, are billed on the pricing and payment terms presented at the time of purchase. Unless otherwise stated, fees are non-refundable except where required by law. We may change pricing prospectively by posting updated pricing or otherwise notifying you.

If you delete your Pigeonscale account, you may request a refund, without giving any reason, of any amounts you paid to us during the 30 days immediately before that deletion. Domain name registration fees are non-refundable in all situations.

10. Availability and disclaimers

Pigeonscale is provided on an "as is" and "as available" basis to the maximum extent permitted by law. We do not guarantee uninterrupted availability, delivery, or error-free operation, and we disclaim implied warranties of merchantability, fitness for a particular purpose, and non-infringement to the extent permitted by law.

11. Service ownership and feedback

We and our licensors retain all right, title, and interest in and to Pigeonscale, including the service, software, APIs, documentation, branding, and related intellectual property. Except for the limited rights expressly granted in these terms, no rights are granted to you. If you provide feedback or suggestions, you grant us a worldwide, perpetual, irrevocable, royalty-free licence to use them without restriction or obligation.

12. Limitation of liability

To the maximum extent permitted by law, Botanica Studios Limited and its directors, employees, contractors, and suppliers will not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, revenues, goodwill, data, or business opportunities.

To the maximum extent permitted by law, our aggregate liability arising out of or relating to Pigeonscale will not exceed the fees you paid to us for the service during the 30 days immediately preceding the event giving rise to the claim. If you did not pay any fees during that period, our aggregate liability will be zero.

13. Indemnity

You will indemnify and hold harmless Botanica Studios Limited from claims, damages, losses, and expenses arising out of your content, your use of the service, or your breach of these terms, except to the extent caused by our gross negligence or wilful misconduct where such limitation is not permitted by law.

14. Changes to the service or terms

We may modify the service or these terms from time to time. Changes become effective when posted unless a later date is stated. Your continued use of Pigeonscale after the effective date of an update means you accept the updated terms.

15. Governing law and venue

These terms and any non-contractual disputes arising out of or in connection with them are governed by the laws of the Republic of Ireland, without regard to conflict of law principles. The courts of Ireland will have exclusive jurisdiction over disputes relating to these terms or the service.

## Contact

Questions about these terms or privacy practices can be sent to coo@pigeonscale.com or by mail to Botanica Studios Limited, 9-11 Fenian Street, Dublin, D02 RX24, Ireland.