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Plimsoll SI Privacy Notice
Last updated: not yet in force. Effective: not yet in force.
1. Who we are
Plimsoll SI is run by its operator ("Plimsoll", "we", "us"). Plimsoll tests AI assistants and agents for customers who state that they own them or hold permission to test them, and issues a signed record of each test (a "passport"). A passport records what was tested, how, and the statistical bound that applies. It is not a statement that an AI system is safe or fit for any purpose, and Plimsoll does not vouch for the system tested.
Privacy contact: privacy@plimsollsi.com. Person in charge of the protection of personal information (Quebec): privacy@plimsollsi.com.
2. Our two roles
Where we decide why and how information is used (we act as controller). Your account, sign in and security information, billing records, support and sales messages, our audit records, the details of anyone a customer names as having given permission to test, sanctions and risk checks, abuse reports, and opt out requests from people who operate systems that our customers test.
Where we act on our customer's instructions (we act as processor or service provider). When a customer runs a test, the questions we send, the replies their AI system returns, their connection details and their access policy are handled for that customer under our Data Processing Addendum. If you work for, or use the services of, one of our customers and your information appears in a reply from their AI system, that customer is responsible for it and you should contact them first. We will help them answer you.
When a test may not have been authorised. If we have reason to believe a test was not authorised, we decide for ourselves how to stop it, what to keep and whom to tell, and we are responsible for that handling as a controller.
3. Information we collect and why
- What
- Account information
- Examples
- Email address, name if you give it, organisation, role, team membership
- Why
- To run your account and let your team work together
- Legal basis (EU and UK)
- Contract
- What
- Sign in and security information
- Examples
- Sign in link records (kept only as digests), two factor settings, single sign on identifiers, session records, IP address and request origin, API key records
- Why
- To keep accounts secure and investigate incidents
- Legal basis (EU and UK)
- Legitimate interests; contract
- What
- Billing information
- Examples
- Plan, usage, invoices, billing contact, tax details
- Why
- To charge for the service and meet tax and accounting duties
- Legal basis (EU and UK)
- Contract; legal obligation
- What
- Audit records
- Examples
- Ownership statements with text version, time, IP address and browser details; verification results; runs started and stopped; question identifiers; request counts, status codes, response sizes and timings
- Why
- To show each test was authorised, answer abuse reports, protect people whose systems could be tested without permission, and handle legal claims
- Legal basis (EU and UK)
- Legitimate interests; legal claims
- What
- Permission giver details
- Examples
- Name, role, organisation and business email of the person a customer says gave written permission; date and scope of that permission
- Why
- To check that testing is authorised and, where we choose, to confirm it with that person
- Legal basis (EU and UK)
- Legitimate interests
- What
- Sanctions and risk checks
- Examples
- Account and billing country, organisation name, comparison of your email domain with the systems you register
- Why
- To meet sanctions law and prevent misuse
- Legal basis (EU and UK)
- Legal obligation; legitimate interests
- What
- Opt out and abuse records
- Examples
- Host or domain, method used, confirming email, time, source IP, message content, our actions
- Why
- To stop testing operators do not want, handle complaints, and make sure an opt out is lifted only by whoever placed it
- Legal basis (EU and UK)
- Legitimate interests; your request
- What
- Records of suspected unauthorised testing
- Examples
- The audit records, outcomes and reply digests of the runs concerned, and our correspondence
- Why
- To stop the testing, protect the system's operator, help authorities and defend claims
- Legal basis (EU and UK)
- Legitimate interests; legal claims
- What
- Support and sales messages
- Examples
- What you send us and our replies
- Why
- To answer you
- Legal basis (EU and UK)
- Legitimate interests; contract
- What
- Customer test content (as processor)
- Examples
- Test questions, connection details, access policy, reply outcomes and reply digests, failing examples if the customer opts in
- Why
- To run the tests the customer asks for
- Legal basis (EU and UK)
- The customer's instructions; the customer chooses its own basis
| What | Examples | Why | Legal basis (EU and UK) |
|---|---|---|---|
| Account information | Email address, name if you give it, organisation, role, team membership | To run your account and let your team work together | Contract |
| Sign in and security information | Sign in link records (kept only as digests), two factor settings, single sign on identifiers, session records, IP address and request origin, API key records | To keep accounts secure and investigate incidents | Legitimate interests; contract |
| Billing information | Plan, usage, invoices, billing contact, tax details | To charge for the service and meet tax and accounting duties | Contract; legal obligation |
| Audit records | Ownership statements with text version, time, IP address and browser details; verification results; runs started and stopped; question identifiers; request counts, status codes, response sizes and timings | To show each test was authorised, answer abuse reports, protect people whose systems could be tested without permission, and handle legal claims | Legitimate interests; legal claims |
| Permission giver details | Name, role, organisation and business email of the person a customer says gave written permission; date and scope of that permission | To check that testing is authorised and, where we choose, to confirm it with that person | Legitimate interests |
| Sanctions and risk checks | Account and billing country, organisation name, comparison of your email domain with the systems you register | To meet sanctions law and prevent misuse | Legal obligation; legitimate interests |
| Opt out and abuse records | Host or domain, method used, confirming email, time, source IP, message content, our actions | To stop testing operators do not want, handle complaints, and make sure an opt out is lifted only by whoever placed it | Legitimate interests; your request |
| Records of suspected unauthorised testing | The audit records, outcomes and reply digests of the runs concerned, and our correspondence | To stop the testing, protect the system's operator, help authorities and defend claims | Legitimate interests; legal claims |
| Support and sales messages | What you send us and our replies | To answer you | Legitimate interests; contract |
| Customer test content (as processor) | Test questions, connection details, access policy, reply outcomes and reply digests, failing examples if the customer opts in | To run the tests the customer asks for | The customer's instructions; the customer chooses its own basis |
We do not sell personal information. We do not share it for cross context behavioural advertising. We do not use customer test content to train any AI model. We do not use advertising or analytics cookies.
4. How tests handle replies
Our system sends ordinary questions to a customer's AI system and reads the replies. The full text of a reply is held in memory only while it is graded and is then discarded; we never write it to storage. We keep the grading outcome and a keyed digest of the reply, so the signed record can be checked against the reply by someone who holds it, without the digest revealing the reply. A customer may choose to keep the smallest failing example of a finding with us; otherwise the example stays on the customer's side. Paused tests keep their working state for 30 days and are then deleted.
Every request we send identifies itself (see plimsollsi.com/probe). Our service refuses to test public AI model provider interfaces, private network addresses on hosted runs, and government, military and international domains unless we hold written permission from the system's owner.
5. Our legitimate interests
We rely on legitimate interests to: keep our service and our customers' accounts secure; keep audit records showing that each test was confirmed by someone who said they owned the system or held written permission; answer abuse reports and enforce opt outs; screen for sanctions and misuse; and establish, exercise or defend legal claims. We have weighed these interests against your rights. Audit records hold who did what and when, never the content of replies, and are used for no other purpose. You may object to this use (section 9).
When a system you register belongs to a different domain from your verified email, or other risk signals appear, we may ask for a stronger check before testing. This asks for more proof; it is not a refusal. Some signals pause an account automatically. A person on our staff reviews every pause, and you may ask for that review and give your view.
If a customer names a person who gave permission to test, we may contact that person to confirm it. We use their details only for that purpose, and our confirmation email tells them how we got their details and links to this notice.
6. Who we share information with
- Service providers acting for us: our hosting provider, our transactional email provider, our payment processor, our email forwarding provider and, if you choose to sign in that way, the code hosting service you sign in with (we read only your verified primary email address and do not keep its access token). The current list, with locations, is at plimsollsi.com/subprocessors.
- People a customer chooses: a customer may share a passport by link or give named validators access. A passport shows the organisation and system tested, the ownership level, the commitments and the results. It does not contain reply text, and shared views do not show customer staff names by default.
- Cloud services under the customer's own permissions, where a customer connects an AI system hosted there.
- System operators and authorities, to stop unauthorised testing. If an operator reports testing of a system they control, and we confirm they control it, we may tell them that testing took place, when, at what volume and at what ownership level, and what we have done about it. We tell them who ran it only with the customer's consent, under legal process, once we find the customer lacked permission, or where the operator intends to bring a legal claim and we judge it reasonable. We disclose to authorities where the law requires it, on a request with lawful authority, or where we have reasonable grounds to believe an offence has been committed; information about people in the EU or UK goes to authorities elsewhere only on a recognised legal basis. We record every such disclosure and tell the customer concerned unless the law forbids it or that would put someone at risk. We never pass on the content of tests run by customers whose authority is not in question.
- Others where the law requires, to protect people from harm, or in a sale or reorganisation of our business (with notice to you).
7. How long we keep information
- Information
- Account information
- How long
- While the account is open, then deleted within 60 days of closure
- Information
- Free accounts with no sign in and no test for 12 months
- How long
- Deleted after 30 days notice
- Information
- Session and sign in records
- How long
- Session life plus 30 days; unused sign in links expire after 15 minutes
- Information
- Security logs with IP addresses
- How long
- 90 days, longer only for a specific incident
- Information
- Records about a registered system (ownership statements with their IP and browser details, verification results, permission giver details, run records)
- How long
- While the system stays registered, plus 24 months
- Information
- Short run summary (account, attesting user, statement version, system, level, start and end, totals, slow down and stop events)
- How long
- 6 years from the run, to answer late claims
- Information
- Other audit events (sign ins, key and role changes, settings)
- How long
- 24 months from the event, then reduced to counts that identify no one
- Information
- Billing records
- How long
- As tax and accounting law requires, currently up to 10 years
- Information
- Abuse case files
- How long
- Life of the case plus 24 months
- Information
- Records of disclosures to operators and authorities
- How long
- 6 years from the disclosure
- Information
- Records under a legal hold
- How long
- Until the matter closes; reviewed every 6 months; released within 30 days of closure
- Information
- Opt out entries, including who placed them
- How long
- While the opt out is in force, plus 12 months after it is withdrawn
- Information
- Unconfirmed opt out requests
- How long
- 7 days
- Information
- Sanctions screening results
- How long
- Account life plus 24 months
- Information
- Passport status records (identifier, digest, signature, status)
- How long
- 5 years from issue, so shared passports can still be checked
- Information
- Customer test content
- How long
- As our Data Processing Addendum sets out; reply text is never kept after grading
| Information | How long |
|---|---|
| Account information | While the account is open, then deleted within 60 days of closure |
| Free accounts with no sign in and no test for 12 months | Deleted after 30 days notice |
| Session and sign in records | Session life plus 30 days; unused sign in links expire after 15 minutes |
| Security logs with IP addresses | 90 days, longer only for a specific incident |
| Records about a registered system (ownership statements with their IP and browser details, verification results, permission giver details, run records) | While the system stays registered, plus 24 months |
| Short run summary (account, attesting user, statement version, system, level, start and end, totals, slow down and stop events) | 6 years from the run, to answer late claims |
| Other audit events (sign ins, key and role changes, settings) | 24 months from the event, then reduced to counts that identify no one |
| Billing records | As tax and accounting law requires, currently up to 10 years |
| Abuse case files | Life of the case plus 24 months |
| Records of disclosures to operators and authorities | 6 years from the disclosure |
| Records under a legal hold | Until the matter closes; reviewed every 6 months; released within 30 days of closure |
| Opt out entries, including who placed them | While the opt out is in force, plus 12 months after it is withdrawn |
| Unconfirmed opt out requests | 7 days |
| Sanctions screening results | Account life plus 24 months |
| Passport status records (identifier, digest, signature, status) | 5 years from issue, so shared passports can still be checked |
| Customer test content | As our Data Processing Addendum sets out; reply text is never kept after grading |
Backups roll off within 35 days of deletion from live systems.
8. Where information is processed
We host our service in the European Union (Finland). Some of our service providers process information in other countries, including the United States. Where information leaves the European Economic Area, the United Kingdom or Switzerland, we rely on an adequacy decision (for example the one covering Canada's commercial privacy law) or on the European Commission's standard contractual clauses, the UK International Data Transfer Addendum and the Swiss addendum. For personal information about people in Quebec, we assess each transfer outside Quebec before it happens. You may ask us for a copy of the relevant safeguards.
9. Your rights
Depending on where you live, you may have the right to know whether we hold your information and get a copy, correct it, delete it, restrict or object to our use of it (including use based on legitimate interests), receive it in a portable format, withdraw consent where we rely on it, and complain to a supervisory authority. In Canada you may complain to the Office of the Privacy Commissioner of Canada, and in Quebec to the Commission d'accès à l'information. In California and other US states with privacy laws, you have rights to know, delete and correct, and we will not treat you differently for using them. We do not sell or share personal information as those laws define it, so there is nothing to opt out of.
To use a right, email privacy@plimsollsi.com. We answer within one month (30 days in Canada, 45 days where US state law allows) and tell you if we need longer and why. We may ask you to confirm who you are. You may act through an authorised agent. If your request concerns information we hold for one of our customers, we pass it to that customer and help them answer.
Operators of systems tested. If you run a system and do not want it tested through Plimsoll, see plimsollsi.com/probe: use the opt out form, serve /.well-known/plimsoll-optout with HTTP status 200, or write to abuse@plimsollsi.com. An opt out applies to every customer at once.
10. How we protect information
Encryption in transit for every connection; customer secrets encrypted at rest; sign in links kept only as digests, single use and short lived; two factor sign in for account owners and administrators; single sign on for enterprise customers; audit records kept apart from test content; production access limited to named staff and logged; encrypted backups; reply text never written to storage. No method is free of risk; we will tell you and the relevant authorities of a breach as the law requires.
11. Cookies
We set one cookie: a session cookie that keeps you signed in. It is strictly necessary, cannot be read by scripts on the page, and is not used to track you elsewhere. We do not use analytics or advertising cookies. If that changes, we will ask for your consent first.
12. Children
Plimsoll is a service for businesses. It is not meant for anyone under 18 and we do not knowingly collect information about children. Customers must not point tests at systems built for children without telling us and holding written permission.
13. Changes
We will post changes here and, for material changes, tell account owners by email at least 30 days before they take effect.
14. Contact
privacy@plimsollsi.com.