Privacy Policy

Effective date: November 08, 2025

This Privacy Policy explains how PLOOQ (plooq.com, "we", "us", "our")—currently operated by Petru Dimulescu as an individual data controller—collects, uses, stores, and protects your personal data. PLOOQ is based in the United Kingdom and complies with the UK General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications Regulations (PECR), and other applicable laws. This policy will be updated if the business structure changes in the future.

1. Data We Collect

• User-Provided Content: Typed text, voice/audio recordings, video files, images, and scanned documents you upload.
• Identifiers: Name, email address, phone number, WhatsApp contact, and other information you provide.
• Recipient Data: Contact details of recipients you provide for messaging, subject to their consent.
• Usage Data: Log data, device information, IP address, browser type, and behavioral metadata.
• Preferences & History: Communication preferences, message history, and personalization data.

2. Lawful Basis for Processing

• Consent: For processing recipient data and sending communications, we require explicit consent from both you and your recipients.
• Contract: To provide and improve the PLOOQ service as agreed with you.
• Legitimate Interests: For service maintenance, security, and analytics, provided these do not override your rights.
• Legal Obligation: To comply with applicable laws and regulations.

3. How We Use Your Data

• To provide, personalize, and improve the PLOOQ service
• To process your content using AI for extracting meaning, intent, and generating follow-up actions
• To send emails, texts, or WhatsApp messages on your behalf, only with proper consent
• To maintain security, prevent abuse, and comply with legal obligations

4. Automated Processing, AI, and Provider Choice

PLOOQ uses AI to process your submitted content and automate certain actions (e.g., message generation). We employ an AI router provided by Requesty to route requests to various AI providers. You may choose your preferred AI provider, or use our default selection based on your task. No fully automated decisions with legal or similarly significant effects are made without human review.

5. Data Storage & Retention

• All uploaded content is stored securely in a dedicated Amazon S3 bucket, segregated per user, and physically located in the EU for compliance.
• Our application workloads are hosted in the EU, primarily on Heroku and AWS infrastructure. All user data, including files and database records, are stored in the EU.
• Our database is hosted on AWS in the EU region.
• Data is retained as long as necessary to provide the service or as required by law.
• You may request deletion of your data at any time (see "Your Rights" below).

6. International Data Transfers

While your data is stored and processed in the EU (including all application workloads and databases), it may be processed by subprocessors (including AI providers) outside the EU. We ensure appropriate safeguards are in place for international transfers, in line with UK GDPR requirements.

7. PII Obfuscation & Tokenization

We aim to obfuscate and tokenize all content containing personally identifiable information (PII) such as emails and phone numbers before AI processing. However, due to the unstructured nature of user input, we cannot guarantee that all PII will be correctly identified and obfuscated. By using PLOOQ, you acknowledge and accept this limitation.

8. Sharing & Subprocessors

We use trusted subprocessors to provide our service. See our Subprocessors List for details. We do not sell your data.

9. Your Rights

• Access your data
• Rectify inaccurate data
• Request erasure ("right to be forgotten")
• Restrict or object to processing
• Data portability
• Withdraw consent at any time (where processing is based on consent)
• Lodge a complaint with the UK Information Commissioner's Office (ICO)

10. Consent

We obtain your consent when you sign up and for any processing of recipient data. You are responsible for ensuring you have a lawful basis to provide recipient data and for obtaining their consent.

11. Contact

For questions or to exercise your rights, contact:
Petru Dimulescu
Email: [email protected]

12. Changes to This Policy

We may update this policy from time to time. Significant changes will be notified via the platform.

13. Cookies & Session Management

We use cookies to operate and secure the PLOOQ service. Currently, the only cookie we set is called session, which is essential for identifying you and maintaining your login session. This cookie is set for strictly functional purposes only and is required for the service to function. We do not use cookies to track you, build profiles, or target you with marketing or advertising. If we introduce additional cookies in the future, we will update this policy and provide appropriate notice.

14. Data Subprocessors