Privacy Policy

Effective August 18, 2026.

Pombo is a lifecycle marketing platform operated by Pombo LLC. (“Pombo”, “we”, “us”). This policy explains what personal data we handle, why, and what you can do about it.

Two different roles

This distinction matters, so it comes first. We handle personal data in two separate capacities:

• As a controller, for data about the people who use Pombo directly — account holders and visitors to this website. We decide why and how that data is used, and this policy governs it.
• As a processor, for the contact data our customers upload or send to us so they can email their own audiences. That data belongs to the customer. They decide what it is used for; we act on their instructions and do not use it for our own purposes.

If you received an email sent through Pombo and want your data corrected or removed, the organization that emailed you is the right party to contact — they control that list, not us. You can also unsubscribe using the link in any message, which takes effect immediately and permanently across every campaign that organization runs. If you cannot reach them, write to us and we will help.

What we collect as a controller

• Account data: name, email address, organization name, and a hashed password. We never store passwords in readable form.
• Attestation records: confirmation that you have permission to email your recipients, including who accepted it and when.
• Usage data: which features are used and when, plus technical logs such as IP address, browser, and timestamps, used to operate and secure the service.
• Support correspondence you send us.

What we process on behalf of customers

• Contact records a customer imports or sends via our API: email address, name, custom fields, and tags.
• Message and engagement data: what was sent, and whether it was delivered, opened, clicked, bounced, or reported as spam.
• Suppression state: whether an address has unsubscribed, hard bounced, or complained. We retain suppression records even when other data is deleted, because forgetting that someone opted out would let them be emailed again.

Why we are allowed to process it

Where the GDPR or similar laws apply, we rely on: contract, to provide the service you signed up for; legitimate interests, to secure the platform, prevent abuse, and protect deliverability for all customers; and legal obligation, where we must retain or disclose records. For data we process on a customer’s behalf, that customer is responsible for establishing its own lawful basis for contacting its recipients.

Who we share it with

We do not sell personal data, and we do not share it for advertising. We rely on these sub-processors to run the service:

• Amazon Web Services — email delivery (SES) and delivery event processing, United States.
• Hetzner — application and database hosting.
• Cloudflare — DNS, TLS termination, and network protection.
• OpenRouter — routing to AI model providers for generation features.
• Replicate — image generation.

Each processes data only as needed to deliver the service, under its own data-processing terms. We will update this list before adding a sub-processor that handles personal data.

We may also disclose data where legally required, or to protect the rights and safety of our users and the public.

AI processing

Pombo uses AI to draft email content, build audience segments from a description, and generate images. When you use one of those features, the relevant prompt and context are sent to a model provider through OpenRouter or Replicate.

• We do not train models on your data, and we do not permit our providers to train on it.
• We do not feed your contact lists to AI models in order to generate content. Segment building operates on field names and filter structure, not on your recipients’ personal data.
• Prompts you write may be retained briefly by providers for abuse monitoring under their own terms.

How we expect AI to be used, and who is accountable for its output, is set out in our Terms of Use.

International transfers

We operate from the United States and our infrastructure providers may process data there and in the European Union. Where data moves out of the EEA or UK, we rely on Standard Contractual Clauses or another approved transfer mechanism.

How long we keep it

• Account data: for as long as your account is open, then deleted within 90 days of closure.
• Customer contact and campaign data: until the customer deletes it or closes their account. On closure we delete it within 90 days.
• Suppression records: retained indefinitely, so an unsubscribe or complaint can never be undone by a later import.
• Security and delivery logs: typically 12 months.

Security

Data is encrypted in transit with TLS and at rest. Passwords are hashed. Access to production systems is limited to people who need it. Sending is gated: an organization cannot send until it has been reviewed, has confirmed it has permission to email its recipients, and has verified its sending domain with DKIM.

No system is perfectly secure. If a breach affects your personal data, we will notify you and any required regulator without undue delay, and within 72 hours where the law requires it.

Your rights

Depending on where you live, you may have the right to access your data, correct it, delete it, export it, object to or restrict processing, and withdraw consent. Californian residents have the right to know what is collected and to whom it is disclosed, to delete it, and not to be discriminated against for exercising those rights. We do not sell or share personal information as those terms are defined under the CCPA.

To exercise any of these, email [email protected]. We respond within 30 days. You may also complain to your local data protection authority.

Cookies

We use cookies that are necessary for the service to work, principally to keep you signed in. We do not use advertising cookies and we do not track you across other websites.

Children

Pombo is a business tool and is not directed at children. We do not knowingly collect data from anyone under 16. If you believe a child has provided us data, contact us and we will delete it.

Changes

We may update this policy. If a change materially affects how we handle your data, we will tell account holders by email before it takes effect. The effective date at the top always reflects the current version.

Contact

Pombo LLC — questions, requests, or complaints about this policy: [email protected].