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Privacy policy

What Scrisly holds about visitors, customers and the business contacts its customers write to, where it comes from, how long it stays and your rights.

Privacy policy

Draft. This text describes how Scrisly works today. A lawyer reviews it before public launch, so it may still change. Highlighted passages are details still to be filled in.

Who is responsible

Scrisly is run by [company name], [postal address]. For anything about your data, use the data request page or write to [privacy contact address]. Data protection officer: [name and contact, if one is appointed].

This policy covers three groups of people: visitors to this website, customers who use the Scrisly app, and the business contacts Scrisly customers write to.

Visitors to this website

The public pages set no tracking cookies. The cookies page lists the few cookies there are. If visit counting is switched on, it runs on Umami, on our own server, without cookies. [Whether the web server keeps access logs (IP address, time, page), and for how long].

Customers

To run your account we keep:

  • your sign-in email address (you sign in with an email and a password, with Google through Continue with Google, or with a link we email you) and your language;
  • your workspace: its name, the postal address you print in every email, your company profile, campaigns, leads, the emails written for you, the emails sent, and the replies you receive with the label and short summary our AI gives them;
  • your mailbox settings, with passwords and keys sealed so that only our background worker can open them;
  • your credits and usage, and a log of important actions in your workspace with the IP address they came from.

The sign-in page checks that you are a person with Cloudflare Turnstile. We process this data to provide the service you signed up for (Art. 6(1)(b) GDPR), and the action log to keep accounts secure (Art. 6(1)(f) GDPR).

[Emails Scrisly sends itself (sign-in and password links, data request confirmations, referral notices) go out through Resend, and "Continue with Google" sign-in is handled by Google, which tells us your email address and name. Both act for us as processors], see the subprocessors page.

When you delete a workspace, its contacts, campaigns, emails, replies and mailboxes are deleted at once, and the lead lists you uploaded are deleted within an hour. Some records stay, because they protect the people you wrote to or keep the service fair:

  • the workspace's suppression list (unsubscribes and addresses added by hand, kept for each product; bounces and complaints, for every product), as one-way fingerprints (hashes) with their reason, tied to your sending domain, so a new workspace sending from that domain still respects them, and the unsubscribe links in emails you already sent keep working;
  • the action log, no longer linked to the workspace, and a record of the deletion with the workspace's id and name, who deleted it and how many records it held.

The action log of a deleted workspace is deleted after [a period set by our team, currently 12 months; records of purchases and credits are kept longer, for accounting].

When your account is deleted, we keep your user id and a hash of your email address, only so that the free starting credits are given once per person.

Feedback you send us. When you rate a draft, send us feedback or answer our occasional question, we keep your rating, the reasons, what you write, the page you were on and the app version, with your workspace and your account. What you write can quote a draft, and so a lead's name or details; only you and our team see it. When a contact is erased, the notes on its drafts are erased too; everything else goes when the workspace or your account is deleted. A screenshot is taken only when you tick the box, is stored privately, seen only by our team, and deleted after 90 days, or within a day after your account is deleted. We use this to improve the service (Art. 6(1)(f) GDPR).

Business contacts our customers write to

This part is for you if a Scrisly customer emailed you or might.

What we hold. Your business email address; your name and role when your company's website shows them; your company's name, website, public description, country, city, industry, size band, the email addresses its website publishes and links to its social profiles; the text of your company's website as we read it, which can mention people; the result of checking whether your address can receive mail. In a customer's campaign we also hold the email written to you and, if you answer, your reply with the label and short summary our AI gives it.

Where it comes from. From your company's own public website; from search result pages (DuckDuckGo and Bing), used to find company websites; from OpenStreetMap, through the Overpass services overpass-api.de and overpass.private.coffee; and from lists that a customer uploads or types in, for which that customer answers.

The shared pool. Company and contact details found on public websites are kept once, with the page they were found on, in a pool shared by all Scrisly workspaces, so the same website is not read twice. For this pool Scrisly is the controller. Each customer who adds you to a campaign has their own copy, for which that customer is the controller and Scrisly processes the data on their behalf.

Contacts our customers share with Scrisly. When a customer uploads a list of business contacts, they choose whether to share it with Scrisly. The box is ticked unless they untick it, and the choice is recorded with who made it and when. If they share, Scrisly keeps its own copy of the business contact details only: the email address, the person's name and language, the company's name and web address, and the country the customer gave. Scrisly never takes the customer's notes, priorities, history with you or your replies. At the time of the upload it leaves out contacts who agreed to hear from that customer, who had unsubscribed, bounced or asked to be deleted, or who use a personal mailbox such as Gmail, and it drops names that contain links, addresses or phone numbers. The copy is reused to find leads for Scrisly's other customers, who may then email you, only after your address checks as valid, and Scrisly stops reusing a customer's contacts when too many of them bounce, complain or unsubscribe. Such an email carries the same line about where the address was found as any other. For this copy Scrisly is the controller. A customer who unticks the box stops sharing their next uploads; contacts already shared stay with Scrisly. If you later unsubscribe from that customer, Scrisly's copy stays; your deletion request on the data request page stops every Scrisly workspace and removes the copy everywhere. [The legal basis for keeping and reusing shared contacts, and how the people concerned are told].

Why, and on what basis. So that our customers can write one relevant business email to the right person. The legal basis is legitimate interest (Art. 6(1)(f) GDPR), in direct marketing between businesses. We limit it to business addresses and public business information, every email carries the sender's name and postal address, a line saying where your address came from with links to this policy and the data request page, and an unsubscribe link, and Scrisly adds no tracking pixels. Contacts in Germany and Austria, where this kind of email needs prior consent, are skipped by default.

How to stop it. The unsubscribe link in any email stops that sender's emails about that product at once. A bounce or a spam complaint stops all of that sender's products. It does not stop other Scrisly customers. On the data request page you can stop all email from every workspace and ask us to delete your details, with no account. When you confirm, your address is suppressed for every workspace at once. At the same moment the shared pool's copies of your details and the results of checks of your address are deleted. Records a customer keeps in their own workspace (their contact entry, the emails they sent you and your replies) stay under that customer's control; they can no longer email you, and you can ask them directly. We keep your request, with your address, until our team closes it, within one month; after that only its kind, its dates and a one-way fingerprint (hash) of the address stay, [for a period set by our team, currently 3 years].

AI. The emails are written by an AI model from your company's public facts, and replies are sorted and summarised by one. The models run at the providers on the subprocessors page. [Whether these providers may use the data to train their models]. No decision with legal or similarly significant effect on you is made automatically.

How long we keep it

  • Shared pool and address check results: [periods set by our team, currently 24 months for a shared pool entry that was not found, checked or shared again in that time, and 180 days for an address check result]. A deletion request removes yours at once.
  • A customer's contacts, emails and replies: while the customer keeps them, and at most until the workspace is deleted.
  • When a customer deletes a contact, the content is erased: the reply's address, subject, text, summary and copies, the message ids, attachment names, suggested answers and the address in the unsubscribe link. What stays are counts and one-way fingerprints: that an email was sent, when, from which mailbox and campaign, the reply's label, and an opt-out by hash.
  • Copies outside a contact: the shared pool and check results (above), technical job records that can contain an address ([a period set by our team, currently 90 days after the job ends]), and email delivery notifications we could not process (90 days).
  • Uploaded lead lists: 30 days, or until the workspace is deleted, whichever comes first.
  • Unconfirmed data requests: deleted when their link expires after 24 hours, or after 24 hours if the email could not be delivered. Confirmed requests keep the address until our team closes them, within one month.

A one-way fingerprint (SHA-256 hash) cannot be turned back into the address, but anyone who already knows an address can check it against the fingerprint.

Who processes data for us

The companies that process personal data for Scrisly, what for and where, are on the subprocessors page. When data leaves the European Economic Area, [the transfer safeguard, for example the EU standard contractual clauses].

Security

Connections are encrypted, mailbox passwords are sealed so only the background worker can open them, and every workspace sees only its own data, which the database itself enforces. Staff tools need a second sign-in factor.

Your rights

You can ask what we hold about you, have it corrected or deleted, have its use restricted, receive it in a common format, and object to its use. An objection to direct marketing always succeeds. Use the data request page, or write to [privacy contact address]. We answer within one month. You can also complain to a data protection authority, for example [the lead supervisory authority].

Changes

When this policy changes, the date at the top changes with it.