Terms of Service

Effective date: 3 August 2026 · Version 1.3 · Previous version 1.2 of 3 August 2026
These Terms are a binding agreement between you and JC Establishment LLC, trading as CopperMailer. Please read them before buying.

1. Who we are

The CopperMailer service is provided by:

JC Establishment LLC, a limited liability company organised under the laws of the State of Wyoming, United States, trading as CopperMailer.
30 N Gould St, Ste N, Sheridan, WY 82801, United States
Email: support@coppermailer.com

In these Terms, “CopperMailer”, “we”, “us” and “our” mean the company above. “You”, “your” and “Customer” mean the person or organisation that opens an account or buys from us.

2. Acceptance of these Terms

1. By creating an account, using free credits, making a purchase or otherwise using the Service, you confirm that you have read, understood and agree to be bound by these Terms, the Privacy Policy, the Acceptable Use Policy and the Refund Policy, all of which form part of this agreement.
2. Before any payment is taken you must tick a checkbox at checkout confirming acceptance of these documents. We record the date, time and version accepted. Because every purchase is a one-time payment, no recurring-payment authorisation is requested and none is given.
3. If you agree on behalf of a company or other organisation, you warrant that you are authorised to bind that organisation, and “you” means that organisation.
4. If you do not agree with these Terms, do not use the Service.

3. The Service

1. CopperMailer is a cloud-hosted software-as-a-service application that connects to mailboxes you control, analyses incoming email and generates draft or automatically sent replies using artificial intelligence, together with related routing, analytics, integration and administration features.
2. The Service is delivered digitally over the internet. No physical goods are sold, produced or shipped. There is nothing to deliver and no delivery times apply.
3. CopperMailer is sold on a one-time-payment basis. There are no subscriptions, no billing cycles and no automatically renewing charges of any kind. You buy a licence once, and you buy credits when you choose to.
4. A licence grants a perpetual, non-exclusive, non-transferable, revocable right to use the Service for your own internal business purposes, subject to these Terms. “Perpetual” means for as long as we operate the Service; clause 14.5 governs what happens if we stop.
5. What each licence, unlock, reply pack, service and credit purchase includes is described on the Pricing section and the Credits section, both of which form part of this agreement.
6. CopperMailer is a tool for replying to email that others have sent to you. It is not a bulk-email, cold-outreach or marketing-campaign platform, and must not be used as one.

4. Eligibility and accounts

1. You must be at least 18 years old and legally capable of entering into a binding contract.
2. Accounts are opened by request, not by self-service. You apply through the account request form or by writing to us, and we open the workspace manually after checking that the mailbox you want to connect is yours and that you intend to answer incoming mail rather than send campaigns. We may ask for proof of control of the domain, and we may decline a request, in which case nothing is charged and no account exists. Approval is normally given within one business day.
3. You must provide accurate, current and complete registration and billing information and keep it up to date. Providing false information is a material breach of these Terms.
4. You are responsible for all activity under your account and for keeping credentials confidential. Enable multi-factor authentication where offered. Tell us immediately at security@coppermailer.com if you suspect unauthorised access.
5. You are responsible for the acts and omissions of every user you invite into your workspace.

5. Free credits and account creation

1. Opening an account is free and requires no payment method, at the request stage or afterwards. Approved accounts receive 50 free credits so you can evaluate the Service on your own mail.
2. Because no payment method is collected, nothing can be charged to you at any point unless you deliberately make a purchase. There is no trial that converts, no countdown and no subscription to forget about.
3. When free credits are used up, reply generation pauses and the account remains open and read-write. You may buy credits, or not, as you prefer.
4. Free credits are limited to one grant per organisation, carry no cash value and are not refundable. We may withdraw or reduce them if they are abused.
5. An account with no purchase and no activity for 24 months may be closed on 30 days’ email notice.

6. What you can buy

1. Licences (Wire, Coil, Alloy, Foundry) are one-time purchases that set how many mailboxes you may connect and how many people may use the workspace. They do not expire and do not renew.
2. Feature unlocks are one-time purchases that permanently enable a named feature on your account.
3. Credits are prepaid units of use, bought in any whole quantity from 10 to 20,000 in a single purchase (a minimum ticket of $0.99), at the rate published in the Pricing section, currently 10 credits per US dollar less a flat 1¢ discount on every purchase, with the marginal bonus tiers set out in the Credits section. The amount charged is calculated exactly and always falls on a whole cent. Credits are not money, not electronic money, not a stored-value or gift instrument and not a security. They have no cash value, are non-transferable between accounts, and are redeemable only against use of the Service or as a refund under clause 8.
4. One credit is consumed per generated reply, with the complete cost table in the Credits section. A draft you reject still consumes its credit, because the work of generating it was done. Purchased credits do not expire while your account is open.
5. Reply packs are one-time purchases of downloadable template and knowledge content, licensed to you for internal use and editing, but not for resale or redistribution.
6. Services are one-time engagements delivered by our staff within the working days stated in the Pricing section, counted from the date we agree a start with you.
7. If your credit balance reaches zero, the Service stops generating replies and notifies you. It never charges you automatically to continue, and there is no overage, usage bill or stored card charged in the background.
8. Upgrading a licence costs the difference between the two prices at the time of upgrade. You are never asked to pay again for what you already own.

7. Prices, payment and taxes

1. One-time payments only. Every purchase is charged once, at the moment you confirm it. We do not operate subscriptions, do not create recurring payment mandates, and do not retain your card credentials for future charges unless you explicitly ask us to save a payment method for convenience, which you may remove at any time.
2. Currency. All prices are quoted, charged and refunded in United States dollars (USD). Your bank may apply its own conversion rate and foreign-transaction fee if your card is denominated in another currency; that charge is between you and your bank, and we never receive any part of it.
3. The total is shown before you confirm. The checkout page displays the full amount, including any tax we are required to collect, before you authorise payment. We add no handling charge, processing fee, service charge, account fee or minimum spend, and there are no hidden costs of any kind. What is displayed is what is charged, once.
4. Authorisation. A charge is only ever created by you clicking to confirm a purchase you have configured yourself. We do not create payment mandates, standing orders or recurring authorisations, and we cannot initiate a payment on your behalf.
5. Fraud screening. Payments are screened for fraud by Stripe. We may decline, or refund and reverse, a purchase we reasonably believe to be fraudulent or made with a payment method used without its owner’s authority. Where we do, you are told why and nothing is retained.
6. Taxes. Prices exclude VAT, GST and sales tax. Where we must collect such tax, it is calculated and displayed at checkout before you confirm payment and is shown on your invoice. Where a destination country requires us to collect VAT or GST on sales to consumers, we register and account for it in that country and show it separately on your invoice.
7. Delivery. Licences, unlocks and credits are applied to your account on successful payment, normally within seconds and always within one hour. Reply packs are downloadable immediately. Nothing is physically shipped.
8. Price changes. We may change published prices at any time. A change never affects a purchase you have already made, and because nothing renews, no price change can ever result in a charge you did not choose. Credits already in your balance keep their full value regardless of later pricing.
9. Payment processing. Payments are processed by Stripe, Inc. and its affiliates. Card details are captured directly by Stripe; CopperMailer never receives or stores full card numbers. We store only the card brand, last four digits, expiry date and a Stripe customer token.
10. Descriptor. Charges appear on your statement as JC Establishment, once per purchase. That is the legal name of the company behind the CopperMailer trading name, so the two do not read identically; it is stated here, in the Pricing section and in the Refund Policy so that the entry is never a surprise.
11. Invoices. An invoice is emailed for every purchase and is always available in Settings → Billing → Invoices.
12. Failed payments. If a payment fails, the purchase simply does not complete and nothing is applied to your account. There is nothing to retry, no dunning process and no suspension for non-payment, because you never owe us anything you have not already paid.
13. Disputes with your card issuer. If you believe a charge is wrong, we would appreciate the chance to fix it: write to billing@coppermailer.com and we resolve billing errors quickly and refund genuine mistakes without argument. Contacting us first is a request, not a condition. Your right to dispute a charge with your card issuer or bank is yours alone, and we will never suspend, restrict or penalise an account for exercising it.

8. Refunds

1. You may request a refund of any purchase within 14 days, to the extent it has not been used.
2. Unused credits are refundable for 24 months from the date of purchase, not only within 14 days, pro rata at the effective price you actually paid per credit, for as long as your account is open. This is not discretionary. Beyond 24 months, unused credits remain in your balance and never expire for use, but are no longer eligible for a cash refund.
3. Consumers in the EU and UK additionally have a statutory right of withdrawal.
4. Because nothing recurs, there is no subscription to cancel. Stopping simply means not buying again: no notice, no cancellation form and no retention process.
5. The complete rules, exceptions, timelines and process are set out in the Refund Policy, which forms part of this agreement.

9. Closing your account

1. You may close your account at any time in Settings → Account, or by emailing support@coppermailer.com. There is no fee and no notice period.
2. Before closing, you may request a refund of your unused paid credit balance under the Refund Policy. Credits are not refunded automatically on closure, so ask first.
3. Licences and unlocks are tied to the account. Closing it ends the right to use them, and they are not restored if you open a new account later. If you might return, leave the account open; an idle account costs nothing.
4. Data is handled on closure as set out in clause 12.5.

10. Your responsibilities and acceptable use

1. You must only connect mailboxes that you own or are authorised to administer, and you must have the right to allow us to process the email in them.
2. You must comply with the Acceptable Use Policy at all times. In particular you must not use the Service to send unsolicited bulk or commercial email, to impersonate another person or organisation, or for any unlawful, fraudulent or deceptive purpose.
3. You are responsible for complying with the laws that apply to your own communications, including e-privacy, consumer protection, financial-promotion, medical and advertising rules in the markets you serve.
4. You must not attempt to reverse engineer, decompile, resell, sublicense, or use the Service to build a competing product, nor circumvent usage limits or security controls, nor probe our systems except under the disclosure process on our Security section.

11. AI output and human oversight

1. The Service uses large language models to generate text. AI-generated output can be inaccurate, incomplete or inappropriate. We do not warrant that any generated reply is correct, suitable or fit for a particular purpose.
2. Auto-send is disabled by default for every new topic. Approval mode, escalation rules and topic restrictions are provided so that a human can review output before it is sent.
3. You decide which categories of message may be answered automatically, and you remain solely responsible for every message sent from your mailbox, whether drafted by a human or by the Service.
4. You must not use the Service to generate replies that give regulated legal, medical or financial advice without qualified human review, nor to make automated decisions producing legal or similarly significant effects on an individual within the meaning of Article 22 GDPR.
5. Where required by law, you are responsible for telling your correspondents that AI assistance is used in handling their messages. The Service can add a configurable disclosure line to outgoing mail.

12. Your data and privacy

1. As between you and us, you own all content you submit and all email content processed through the Service (“Customer Data”). We claim no ownership of it.
2. We process Customer Data only to provide, secure, support and improve the Service in accordance with the Privacy Policy and, where the GDPR applies, the Data Processing Addendum, under which you are the controller and we are the processor.
3. We do not sell Customer Data, and we do not use the content of your customers’ emails to train shared or third-party AI models. Model providers we use are contractually bound not to train on data submitted through our API accounts.
4. You may export your data at any time in CSV and JSON format from the admin console.
5. On termination we retain Customer Data for 30 days so you can export it, then delete it from production systems and, within a further 60 days, from backups, unless a longer period is required by law.

13. Intellectual property

1. We and our licensors own all rights in the Service, including software, models, interfaces, documentation, the CopperMailer name, logo and branding. Nothing in these Terms transfers those rights to you.
2. You keep all rights in Customer Data. You grant us a limited, worldwide, non-exclusive, royalty-free licence to host, copy, transmit, display and process Customer Data solely as needed to operate the Service for you and as instructed by you.
3. As between the parties and to the extent permitted by law, output generated for you by the Service is yours to use; you are responsible for checking that its use does not infringe the rights of others.
4. If you send us feedback or suggestions, we may use them without obligation or compensation.

14. Availability, support and changes

1. We aim for 99.9% monthly availability. Commitments, exclusions and the credit compensation available on the Alloy and Foundry licences are set out in the Service Level Agreement.
2. Support channels, target response times and hours are published in the Contact section.
3. Planned maintenance is announced at least 48 hours in advance and normally takes place between 22:00 and 04:00 UTC on Saturdays and Sundays.
4. We continuously improve the Service and may add, modify or remove features. If we permanently remove or materially degrade a feature you bought as an unlock, or that was a stated part of your licence, we will give at least 30 days’ notice and refund what you paid for it, reduced pro rata over 36 months from the date of your purchase.
5. We may discontinue the Service entirely on 90 days’ notice. In that case we refund your unused credit balance in full, and refund licences and unlocks reduced pro rata over 36 months from purchase. This is the trade-off for a perpetual licence sold at a one-time price, and we state it here rather than bury it.

15. Third-party services

1. The Service integrates with third-party platforms (for example Google Workspace, Microsoft 365, Slack, HubSpot, Shopify, Zapier) and relies on third-party infrastructure and model providers listed in Annex B of the Data Processing Addendum.
2. Your use of a third-party platform is governed by that provider’s own terms. We are not responsible for third-party services, their availability, or changes they make to their APIs.
3. You are responsible for maintaining any licences and permissions needed for the third-party platforms you connect.

16. Sanctions and export control

1. You represent that you are not located in, ordinarily resident in, or organised under the laws of a country or territory subject to comprehensive EU, UK, UN or US sanctions, and that you are not listed on any applicable restricted-party or sanctions list, nor owned or controlled by such a party.
2. You must not use the Service in breach of applicable export-control or sanctions laws, or on behalf of any person prohibited by them.
3. We do not rely on your representation alone: every account request is screened against applicable sanctions and watchlists as part of the approval process described on the account request page, before a workspace is opened, and periodically thereafter.
4. We may refuse, suspend or terminate service to comply with sanctions and export-control obligations.

17. Warranties and disclaimers

1. We warrant that we will provide the Service with reasonable skill and care and in a manner materially conforming to the documentation.
2. Except as expressly stated in these Terms and save for rights that cannot be excluded by law, the Service is provided “as is” and “as available”, and we disclaim all other warranties, express or implied, including implied warranties of merchantability, fitness for a particular purpose and non-infringement.
3. We do not warrant that the Service will be uninterrupted or error-free, that AI output will be accurate, or that the Service will achieve any particular commercial result. We make no representation or guarantee about revenue, savings, response quality metrics, conversion rates or headcount reduction.
4. Nothing in this clause limits the statutory rights of consumers described in clause 23.

18. Limitation of liability

1. Nothing in these Terms excludes or limits liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, for wilful misconduct, or for anything else that cannot lawfully be excluded or limited, including, for consumers, liability under mandatory consumer-protection law.
2. Subject to clause 18.1, neither party is liable for indirect or consequential loss, loss of profit, loss of revenue, loss of anticipated savings, loss of goodwill or loss of business opportunity, however arising.
3. Subject to clause 18.1, our total aggregate liability arising out of or in connection with this agreement in any 12-month period is limited to the total fees you actually paid to us for the Service in the 12 months immediately preceding the event giving rise to the claim.
4. Subject to clause 18.1, we are not liable for loss or damage caused by content sent from your mailbox, by your configuration choices (including enabling auto-send), or by your failure to review AI-generated output before it is sent.
5. You must notify us of any claim within 12 months of becoming aware of the circumstances giving rise to it.

19. Indemnity

If you use the Service as a business, you agree to indemnify and hold us harmless against claims, damages, losses and reasonable costs arising from (a) your breach of these Terms or the Acceptable Use Policy, (b) content sent from mailboxes you connect, (c) your infringement of a third party’s rights, or (d) your breach of laws applicable to your communications. This clause does not apply to consumers.

20. Term and termination

1. This agreement starts when you first accept these Terms and continues until your account is closed under clause 9 or terminated under this clause.
2. You may terminate at any time by closing your account under clause 9. Because nothing recurs, you can also simply stop using the Service and owe nothing.
3. We may suspend or terminate immediately if you materially breach these Terms or the Acceptable Use Policy, if we are required to do so by law or valid legal process, or if your use creates a genuine and immediate security or legal risk to us or to other customers. Where the breach is capable of remedy and does not create an immediate risk, we will give you 14 days’ notice to fix it. We will not terminate you merely because a supplier of ours asks us to, and commercial inconvenience to us is not a ground for termination.
4. If we terminate for a reason other than your breach, we refund your unused credit balance in full, together with licences and unlocks on the pro-rata basis in clause 14.5.
5. If we terminate for your material breach, your unused paid credit balance is still refunded to you. We take away your access, not your money: credits you paid for and never spent are returned to your original payment method. Licences and unlocks are not refunded in that case, and credits granted free of charge are not refundable because nothing was paid for them.
6. Clauses 12.5, 13, 17, 18, 19, 22 and 24 survive termination.

21. Changes to these Terms

1. We may update these Terms to reflect changes in the Service, in our business, or in the law.
2. We will give at least 30 days’ notice of material changes by email and in the application. Non-material changes (typography, clarifications, contact details) take effect on publication.
3. If you do not accept a material change, you may close your account before it takes effect and receive a refund of your unused credit balance in full. Continuing to use the Service after the effective date means you accept the change. A change to these Terms can never trigger a charge, because nothing renews.
4. This is version 1.3. It restates the minimum credit purchase at $0.99 for 10 credits, with every purchase priced a flat 1¢ under the round number; bounds the cash-refund window on unused credits to 24 months of purchase (credits still never expire for use); and adds sanctions and watchlist screening to account approval. None of this takes anything away that a purchase already made relied on. Version 1.2 of 3 August 2026, version 1.1 of 3 August 2026, version 1.0 of 29 July 2026 and every later version are archived and available on request from legal@coppermailer.com.

22. Governing law and disputes

1. These Terms are governed by the laws of the State of Wyoming, United States, excluding its conflict-of-law rules and the UN Convention on Contracts for the International Sale of Goods.
2. For business customers, the state and federal courts located in Sheridan County, Wyoming have exclusive jurisdiction.
3. For consumers, this choice of law does not deprive you of the protection of the mandatory law of your country of habitual residence, and you may bring proceedings in the courts of that country.
4. We would always rather fix a problem than argue about it. Please write to legal@coppermailer.com first; we respond to every complaint within 14 days.
5. There is no mandatory arbitration clause in this agreement, no class-action waiver and no jury-trial waiver. We have not required you to give up any of those, and we do not intend to.
6. If you are a consumer, you may also use any alternative dispute resolution or consumer-mediation body available to you under the law of your country of residence. We will engage with such a body in good faith and bear our own costs of doing so.
7. Nothing in this clause prevents either party from seeking urgent injunctive relief, or from bringing a claim in a small-claims court where one is available.

23. Consumer rights

1. If you use the Service as a consumer (outside your trade, business or profession), you have statutory rights that these Terms do not affect, including any right of withdrawal available to you under the law of your own country. These are described in the Refund Policy.
2. Because the Service is digital content supplied immediately, some jurisdictions allow us to ask you to consent to immediate performance and to acknowledge that the statutory withdrawal right then falls away. We do not ask for that waiver, and we do not rely on it. Our own 14-day refund in clause 8 applies to everything you have not used, for consumers and businesses alike, and it is the only rule you need to remember.
3. We apply the same 14-day refund in clause 8 to sole traders and very small businesses as we do to consumers, without asking which category you fall into.

24. General

1. Entire agreement. These Terms, together with the documents they incorporate, form the entire agreement between us and supersede all prior discussions.
2. Severability. If any provision is held invalid, the rest remains in force.
3. No waiver. Failure to enforce a provision is not a waiver of it.
4. Assignment. You may not assign this agreement without our written consent. We may assign it to an affiliate or in connection with a merger or sale of assets, on notice to you.
5. Force majeure. Neither party is liable for delay or failure caused by events beyond its reasonable control.
6. Notices. We send notices to the email address on your account; you send notices to legal@coppermailer.com or to the postal address in clause 1.
7. Language. These Terms are concluded in English. Translations are provided for convenience; in case of conflict, the English version prevails, except where mandatory consumer law provides otherwise.

25. How to contact us

We do not publish a telephone support line, because a number nobody answers is worse than none at all. Ask at support@coppermailer.com for a call and we will book one, usually the same day.

26. Acceptable Use Policy

This clause governs what the Service may be used for. Breaching it is grounds for immediate suspension or termination; your unused paid credits are refunded even then, under clause 20.5.

26.1 What the Service is for

• Replying to inbound customer support, sales, billing and general enquiries sent to mailboxes you control.
• Drafting responses for a human to review, approve or edit.
• Routing, tagging, escalating and analysing inbound email.
• Answering transactional questions grounded in knowledge sources you supply.

26.2 Prohibited sending practices

You must not use CopperMailer to:

• send unsolicited bulk email, spam, cold outreach or marketing campaigns of any kind;
• email addresses obtained by scraping, purchase, rental or exchange, or any address that has not contacted you first or given you a valid, documented consent;
• continue emailing anyone who has unsubscribed, objected or asked you to stop;
• forge, spoof or obscure headers, sender identity, reply-to addresses or message origin;
• evade spam filters, rate limits, blocklists or authentication (SPF, DKIM, DMARC) checks;
• relay mail for a third party, resell sending capacity, or operate the Service on behalf of an undisclosed principal;
• generate volume intended to test, degrade or attack another mail system.

26.3 Prohibited content and conduct

You must not use the Service to create, send, store or process content that:

• is unlawful, defamatory, harassing, threatening, hateful or discriminatory;
• sexually exploits or endangers minors, in any form, ever;
• promotes or facilitates violence, terrorism, self-harm or the trade in weapons;
• is deceptive or fraudulent, including phishing, credential harvesting, invoice fraud, business email compromise, fake support, romance or investment scams, and pretending to be a person or organisation you are not;
• infringes copyright, trade marks, trade secrets, privacy or publicity rights;
• contains malware, ransomware, exploit code or malicious links;
• makes unsubstantiated claims about earnings, health outcomes, guaranteed returns or miracle cures;
• gives regulated legal, medical, tax or financial advice automatically without qualified human review;
• is generated to impersonate a real individual’s voice or identity without their permission.

26.4 Restricted and prohibited uses

We do not permit the Service to be used to support the following activities, whether lawful in your jurisdiction or not:

• sale or promotion of illegal drugs, controlled substances, unlicensed pharmaceuticals or drug paraphernalia;
• weapons, ammunition, explosives and their components;
• counterfeit goods, pirated media and stolen data;
• unlicensed gambling, lotteries, pyramid or Ponzi schemes, multi-level marketing recruitment and “get rich quick” programmes;
• unlicensed financial services, unregistered securities offerings, binary options, high-yield investment programmes and unlicensed crypto-asset exchange services;
• debt collection using intimidation, misrepresentation of legal status, or contact with third parties about a debtor;
• essay mills, exam impersonation and academic-fraud services;
• adult content services where CopperMailer would handle explicit material;
• surveillance, stalkerware, doxxing, or building profiles on people without their knowledge;
• political campaigning, canvassing or electioneering mail;
• any business that the payment networks or our payment processor classify as prohibited.

Certain regulated sectors (healthcare, insurance, credit and legal services) may use the Service, but only with human approval enabled for all substantive replies, and only where you can demonstrate the necessary licences and a lawful basis for processing. Contact sales@coppermailer.com before onboarding in these sectors.

26.5 Technical restrictions

• Do not attempt to gain unauthorised access to the Service, other tenants’ data, or our infrastructure.
• Do not probe, scan or load-test our systems except under the responsible disclosure process on our Security section.
• Do not reverse engineer, decompile or attempt to extract model weights, prompts or training data.
• Do not use the Service to build a competing product or to benchmark it for publication without our written consent.
• Do not exceed documented API rate limits, share API keys outside your organisation, or automate the interface in a way that degrades service for others.
• Do not attempt to make the model produce content prohibited by clause 26.3 through prompt injection or jailbreaking.

26.6 Your duties when using AI output

• Keep human approval enabled for anything involving money, legal consequences, health, complaints or personal data disclosure.
• Do not present AI-generated statements as verified fact when they concern price, availability, warranty or legal rights, unless the underlying source is authoritative and current.
• Disclose the use of automated assistance where the law of your market requires it. The Service can append a configurable disclosure line.
• Keep your knowledge sources accurate. Most bad answers are stale documentation, not model failure.
• Do not use the Service to make automated decisions with legal or similarly significant effects on individuals (Art. 22 GDPR).

26.7 How we enforce this policy

1. We monitor for abuse signals (bounce and complaint rates, sending patterns, blocklist hits, third-party reports) using automated systems and, where a report needs judgement, human review.
2. Depending on severity we may: contact you and ask for an explanation; require corrective action within a stated time; throttle or restrict features; suspend the account; or terminate it.
3. For serious harm (child sexual abuse material, fraud in progress, phishing, malware, credible threats of violence) we act immediately without prior notice and may report to law enforcement.
4. Where a breach is capable of remedy and creates no immediate risk, we give 14 days’ notice to fix it before terminating.
5. Termination for breach of this policy does not entitle you to a refund of the licence or unlocks you bought. Your unused paid credits are still refunded, as set out in clause 20.4: we take away access, not money you paid for work we never did.
6. You may appeal any enforcement decision by writing to legal@coppermailer.com. An independent reviewer responds within 14 days.

26.8 Reporting abuse

If you have received unwanted, deceptive or abusive email that you believe was generated through CopperMailer, tell us at abuse@coppermailer.com. Please include the full message headers if you can. We acknowledge every report within one business day and investigate every one. You do not need to be a customer to report abuse.

26.9 Changes

We may update this policy as abuse patterns and law evolve. Material changes are notified by email at least 30 days in advance. Changes required to stop active harm take effect immediately.

26.10 Contact

Abuse: abuse@coppermailer.com · Legal: legal@coppermailer.com
JC Establishment LLC, 30 N Gould St, Ste N, Sheridan, WY 82801, United States

27. Service Level Agreement

Credit compensation applies to the Alloy and Foundry licences; the uptime target is the same for everyone.

27.1 Uptime commitment

We commit to a Monthly Uptime Percentage of at least 99.9% for the CopperMailer application, API and reply-generation pipeline. That allows roughly 43 minutes of downtime in a 30-day month.

Foundry customers with a signed order form may contract for 99.95% (about 22 minutes per month) with the credit schedule in clause 27.5 doubled.

27.2 How availability is measured

1. Monthly Uptime Percentage = (total minutes in the calendar month – Unavailable Minutes) ÷ total minutes in the month, expressed as a percentage.
2. A minute is Unavailable if all requests to the application or API during that minute return a 5xx error, time out, or if no reply is generated for queued messages while the queue is non-empty.
3. Measurement is taken from our external monitoring nodes in Frankfurt, Dublin and Virginia, polling every 30 seconds. Two of three nodes must agree before a minute is counted as unavailable.
4. We do not operate a public status page. Availability figures for a disputed month are produced from our monitoring records and sent to you on request, and clause 27.6 does not require you to cite a status page to make a claim.

27.3 Exclusions

Unavailable Minutes do not include downtime caused by:

• announced planned maintenance (at least 48 hours’ notice, normally Saturday or Sunday 22:00 to 04:00 UTC, capped at 4 hours per month);
• emergency security maintenance, announced as early as circumstances allow;
• failure of a third-party platform you connect (Gmail, Microsoft 365, your IMAP host, HubSpot, Shopify), or of your own network or DNS;
• your configuration errors, an exhausted credit balance, revoked OAuth tokens, suspended mailboxes, or exceeding documented rate limits;
• suspension for breach of the Acceptable Use Policy;
• beta, preview or clearly labelled experimental features;
• force majeure: natural disaster, war, civil unrest, government action, internet backbone or upstream provider failure beyond our reasonable control.

27.4 Support response targets

These are targets for a first substantive human response, not resolution times. Business hours are Monday to Friday, 09:00 to 17:00 Mountain Time, excluding US federal holidays.

We do not offer a 24×7 response target on any licence, and we are not going to pretend otherwise. A total outage pages us automatically whenever it happens, and in practice we start work long before the target above expires, but the number we commit to contractually is the one we can hold every single time, including at three in the morning on a public holiday. If genuine round-the-clock cover is a requirement for you, we are the wrong vendor today and would rather you knew that before you paid us.

27.5 Compensation in credits

Because CopperMailer is sold as one-time purchases rather than a subscription, there is no monthly fee to discount. We compensate downtime in the currency that actually matters here: CopperMailer credits, added to your balance free of charge. The amount is a percentage of the credits you consumed in the affected calendar month.

1. The minimum award applies even if you used few or no credits that month; downtime you could not use is still downtime you paid a licence for.
2. Awarded credits behave like purchased ones in every respect except that, having cost you nothing, they are not refundable for cash.
3. Awards in any month cannot exceed 100% of the credits you consumed that month, or the minimum award, whichever is greater.
4. Credit compensation is your sole and exclusive remedy for failure to meet the uptime commitment. Statutory rights, and the right to a refund under clause 27.6, are unaffected.

27.6 Claiming a credit

1. Email support@coppermailer.com with the subject “SLA credit request” within 30 days of the end of the affected month.
2. Include the dates and times of the incident and, if you have them, request logs or error identifiers. If we already announced the incident by email, quoting that announcement is sufficient evidence on its own and you do not need to prove anything further.
3. We respond within 10 business days. If we agree, the credits appear in your balance immediately and you are told how the figure was calculated.
4. If Monthly Uptime falls below 95% in any two months within a rolling six-month period, you may close your account and receive a refund of your entire unused paid credit balance, plus your licence and unlocks reduced pro rata over 36 months from purchase, in addition to any credits already awarded.

27.7 Incident communication

• Incidents affecting your workspace are emailed to your account notification address within 60 minutes of confirmation, and updated as the picture changes until they are resolved.
• You do not need to subscribe to anything: if it affects you, you get the email.
• For P1 incidents lasting more than one hour, we publish a post-incident review within 5 business days, describing what happened, why, and what we changed.

27.8 Changes

We may update this SLA on 30 days’ notice. Changes that reduce the commitment do not apply to a Foundry order form during its current term.

Privacy Policy

Effective date: 3 August 2026 · Version 1.1 · Previous version 1.0 of 29 July 2026
This policy explains how JC Establishment LLC handles personal data. It covers our website, our marketing and the CopperMailer application.

1. Who is responsible

JC Establishment LLC (trading as CopperMailer): data controller
30 N Gould St, Ste N, Sheridan, WY 82801, United States
Privacy contact: privacy@coppermailer.com

We are a US company. Where we offer the Service to customers in the European Economic Area or the United Kingdom, we apply Regulation (EU) 2016/679 (GDPR) and the UK GDPR to that processing, and we act as a processor for mailbox content under the Data Processing Addendum. We also comply with applicable US federal and state privacy law, including the California Consumer Privacy Act where it applies to a resident of that state.

2. Controller and processor roles

We wear two hats, and it matters which one applies:

If you emailed a company that uses CopperMailer and you want your data corrected or erased, please contact that company; they control the data. If you contact us instead, we will forward your request to them and tell you we have done so.

3. Data we collect

3.1 Account and billing data

Name, business name, work email address, telephone number (optional), postal or billing address, VAT number, country, job title (optional), workspace name, licence and unlocks owned, credit balance and ledger, invoices and purchase history, and the card brand, last four digits and expiry date returned to us by Stripe.

3.2 Customer Data (mailbox content)

When you connect a mailbox we process the email messages in it: sender and recipient addresses, subject lines, message bodies, attachments, headers, timestamps and thread structure, plus anything those messages happen to contain. We also store the knowledge sources you upload and the replies generated. We are a processor for all of this.

3.3 Usage and technical data

IP address, browser type and version, operating system, device type, pages viewed, referring URL, timestamps, feature usage counters, API call metadata, error traces, and audit-log entries (who did what, when, from where) in the application.

3.4 Support and communications

Messages you send us, support ticket history, call notes and, where you have opted in, newsletter subscription status and engagement.

3.5 Data we do not collect

We do not knowingly collect special-category data (health, biometrics, religion, political opinions, trade-union membership, sexual orientation) about you as a customer, and we do not buy personal data from data brokers. Please do not send special-category data in support tickets. Mailbox content is a different matter: your customers may write anything to you, which is why the DPA and our security controls apply to it.

4. Why we use it and on what legal basis

Where we rely on legitimate interests, we have carried out a balancing assessment and you may object at any time under clause 11.

5. AI processing and model training

1. To generate a reply, the relevant message and the knowledge sources you supplied are sent to a large language model operated by us or by a contracted model provider listed in Annex B of the Data Processing Addendum.
2. We do not use the content of your mailboxes to train shared, public or third-party models. We use commercial API terms with our model provider that prohibit training on data we submit. Retention at the provider is governed by that provider’s published API policy, which we link from Annex B of the Data Processing Addendum rather than restate in our own words.
3. Tone matching (“Patina Engine”) produces a style profile that is confined to your workspace and never applied to another customer.
4. We may use aggregated, de-identified statistics (reply volumes, latency, acceptance rates) which cannot be linked to an individual, to improve the Service.
5. You can enable PII redaction so that detected phone numbers, card-like numbers and national identifiers are masked before content reaches a model provider.
6. Storage and application processing can be pinned to our EU region on request before onboarding. Model inference currently runs against our provider’s endpoints and we cannot guarantee it stays inside the EEA; if EU-only inference is a hard requirement for you, tell us before you buy, because today we cannot offer it.

6. Payment data

Card payments are processed by Stripe, Inc., 354 Oyster Point Boulevard, South San Francisco, CA 94080, USA, and its EU affiliate Stripe Payments Europe Ltd, Dublin, Ireland. Card details are entered directly into Stripe-hosted fields and are never transmitted to or stored on CopperMailer systems. Stripe acts as an independent controller for payment and fraud-prevention purposes; see the Stripe Privacy Policy. We receive from Stripe only a customer token, the card brand, the last four digits, the expiry date, the country and the outcome of each charge. We are PCI DSS compliant by using Stripe’s hosted payment fields (SAQ A scope).

7. Who we share data with

• Sub-processors: hosting, email infrastructure, model providers, support tooling, analytics. The current list, with locations and purposes, is in Annex B of the Data Processing Addendum. Each is bound by a written data-processing agreement.
• Payment and tax providers: Stripe for payments; our accountants for statutory bookkeeping.
• Professional advisers: lawyers, auditors and insurers, under confidentiality.
• Authorities: where required by a valid legal obligation. We assess every request, refuse overbroad ones, and notify you unless legally prohibited.
• A successor: in a merger, acquisition or asset sale, subject to this policy continuing to apply and notice to you.

We never sell personal data and we never share it with advertising networks or data brokers. That is meant in the legal sense as well as the ordinary one: we do not “sell” or “share” personal information as those terms are defined by the California Consumer Privacy Act as amended, and we have not done so in the preceding 12 months. Every disclosure listed above is a service-provider or business-purpose disclosure under a written contract that forbids the recipient using the data for anything else.

8. International transfers

1. Our default hosting region is the United States. Customers who need Customer Data stored at rest in the European Union can have their workspace provisioned in our EU region (Frankfurt, Germany) at no extra cost, but must ask before a mailbox is connected: a workspace cannot be moved between regions afterwards. This matches what the Security section says, and neither statement is marketing.
2. Some sub-processors are established in the United States. Where personal data is transferred outside the European Economic Area we rely on the European Commission’s Standard Contractual Clauses (2021/914), supplemented by transfer impact assessments, encryption in transit and at rest, and, where applicable, the EU-US Data Privacy Framework certification of the recipient.
3. You can request a copy of the safeguards in place by emailing privacy@coppermailer.com.
4. Foundry customers can contractually restrict all processing, including model inference, to the EU.

9. How long we keep data

10. Security

TLS 1.2+ in transit, AES-256 at rest, encrypted backups, role-based access control, mandatory MFA on administrative accounts, least-privilege access, isolated per-tenant data, centralised audit logging and a documented incident-response plan. We have not yet commissioned an external penetration test and hold no third-party security certification; the Security section sets out exactly what is and is not in place, including the gaps.

10.1 If something goes wrong

If a personal data breach occurs, we notify affected customers without undue delay and within 72 hours of becoming aware of it, whether or not the law requires it in a particular case. Where we act as processor for mailbox content, that notice goes to you as controller so you can meet your own Article 33 deadline, and it includes what happened, which data and how many records are involved, what we have done and what we suggest you do. Where we are the controller, we notify the competent supervisory authority under Article 33 and, where the risk to individuals is high, the individuals themselves under Article 34. We do not wait for a full investigation before telling you that one is happening.

Card data is out of scope for any breach of ours by design: it never reaches our systems, because it is captured directly by Stripe.

11. Your rights

Where we are the controller you have the right to:

• Access the personal data we hold about you and receive a copy;
• Rectify data that is inaccurate or incomplete;
• Erase data where the conditions of Article 17 are met;
• Restrict processing in the circumstances of Article 18;
• Data portability: receive data you gave us in a structured, machine-readable format;
• Object to processing based on legitimate interests, and to direct marketing at any time, absolutely;
• Withdraw consent at any time, without affecting processing already carried out;
• Complain to a supervisory authority.

Write to privacy@coppermailer.com. We reply within one month, extendable by two further months for complex requests, and we will tell you if we need the extension. We may ask for proof of identity. Exercising these rights is free; we charge only for manifestly unfounded or excessive repeat requests.

If you are in the EEA or the UK, you may lodge a complaint with the supervisory authority where you live or work. Nothing here requires you to contact us first, though we would rather you did, because we can usually fix it faster.

11.1 California and other US state privacy rights

If you are a resident of California, and in substance also of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana and the other states with comprehensive privacy statutes, you have the rights below in respect of data for which we are the business or controller. They sit alongside the rights above rather than replacing them, and we apply them to every US resident who asks, without checking which state you are in.

• Know and access. What categories of personal information we collected about you in the past 12 months, the sources, the purposes, the categories of recipient, and a copy of the specific pieces.
• Delete personal information we hold about you, subject to the exceptions in the statute, chiefly our legal duty to keep invoices and tax records for seven years.
• Correct inaccurate personal information.
• Opt out of sale, sharing and targeted advertising. There is nothing to opt out of: we do not sell personal information and we do not share it for cross-context behavioural advertising, as those terms are defined by the CCPA as amended by the CPRA. We have not done so in the preceding 12 months and we have no plans to start. We run no advertising pixels, no ad networks and no cross-site tracking.
• Limit the use of sensitive personal information. We do not collect sensitive personal information about our customers for any purpose that would trigger this right.
• Non-discrimination. Exercising any of these rights costs nothing, and never changes the price you pay, the credits you get or the service you receive. We operate no financial-incentive programme.
• Appeal. If we refuse a request, you may appeal by replying to our decision. A different person reviews it and answers within 45 days, with reasons. Where your state provides one, you may then complain to your Attorney General.

The categories of personal information in the tables in clause 3, collected for the purposes in clause 4 and disclosed for a business purpose only to the recipients in clause 7, are the complete picture; we do not maintain a separate, longer list somewhere else.

Requests go to privacy@coppermailer.com. We confirm receipt within 10 business days and answer within 45 days, extendable once by a further 45 where the request is complex, in which case we tell you before the first period runs out. An authorised agent may act for you if you give them written permission and we can verify it with you directly.

Global Privacy Control. We honour GPC and similar browser opt-out signals. In practice they change nothing here, because we set no advertising or tracking cookies to begin with; if that ever changes, the signal will be respected automatically and clause 12.5 will say so before the first such cookie is set.

12. Cookies

This marketing website sets no cookies at all, which is why you have not seen a banner on it. The application sets strictly necessary cookies only: session, CSRF, load balancing, and two interface preferences you set yourself. We run no analytics, advertising or cross-site tracking cookies anywhere. The rest of this clause sets out every cookie, its purpose and its duration.

12.1 What cookies are

Cookies are small text files placed on your device by a website. Similar technologies (local storage, session storage and pixels) do comparable jobs, and this clause covers them too. We use them to keep you signed in, to keep the site secure, and (only if you agree) to understand how the site is used.

12.2 Your choices

1. On this website: nothing is set, so there is nothing to choose. We do not run analytics here, and we do not load any third-party script.
2. In the application: strictly necessary cookies are set without consent, because you cannot stay signed in without them. That is permitted by Article 5(3) of the ePrivacy Directive and equivalent rules.
3. The application sets no analytics, advertising, retargeting or cross-site tracking cookies. If we ever add a non-essential cookie, we will ask for consent before setting it and update this clause first.
4. You can delete any of these at any time in your browser. Deleting the session cookie signs you out; nothing else breaks.

12.3 Cookies we use

All of the following are set by the application at app.coppermailer.com after you sign in. None of them is set by the pages on this marketing site.

Strictly necessary: always active

Preferences: strictly necessary, first party, no tracking

Analytics and advertising

We set none. There is no analytics cookie, no advertising cookie, no retargeting pixel and no cross-site tracker anywhere on this website or in the application. This is not a promise about the future dressed up as a fact: it is what is deployed today, and clause 12.5 says what happens if it changes.

12.4 Controlling cookies in your browser

Every major browser lets you block or delete cookies: Chrome (Settings → Privacy and security → Third-party cookies), Firefox (Settings → Privacy & Security), Safari (Preferences → Privacy), Edge (Settings → Cookies and site permissions). Blocking strictly necessary cookies will stop you from signing in.

12.5 Changes to this clause

If we add a cookie we update this clause first. If the new cookie is anything other than strictly necessary, we will ask for your consent before setting it, and rejecting will be exactly as easy as accepting. The version and date at the top of this policy show the current version.

12.6 Cookie questions

Questions: privacy@coppermailer.com
JC Establishment LLC, 30 N Gould St, Ste N, Sheridan, WY 82801, United States

13. Children

The Service is intended for business use by adults. We do not knowingly collect personal data from children under 16. If you believe a child has provided us with data, contact privacy@coppermailer.com and we will delete it.

14. Automated decision-making

We do not make decisions producing legal or similarly significant effects about you based solely on automated processing. The Service generates text automatically, but it does not decide anything about your rights, and you configure whether a human reviews output before it is sent.

15. Changes

We will update this policy when our practices change. Material changes are announced by email and in the application at least 30 days before they take effect. The version and date at the top always tell you what you are reading. This is version 1.1: it adds US state privacy rights, a 72-hour breach-notification commitment and a correction to how hosting regions are described. It gives you more than version 1.0 did and takes nothing away. Earlier versions are archived and available on request from privacy@coppermailer.com.

16. Contact and complaints

Privacy team: privacy@coppermailer.com · answered Monday to Friday, 09:00 to 17:00 Mountain Time
Post: JC Establishment LLC, 30 N Gould St, Ste N, Sheridan, WY 82801, United States

Two things we would rather state than let you discover. We have not appointed a Data Protection Officer, because our processing does not meet the Article 37 thresholds that would require one; the address above reaches the person who actually handles these requests, not a queue. We have not yet appointed an Article 27 representative in the European Union or the United Kingdom. We will appoint one before we market actively into the EEA, and until then EEA and UK data subjects can write to the address above, or to their own supervisory authority, and lose nothing by doing so: we answer within the statutory deadline either way.

If you are unhappy with how we have handled a request, say so in the same thread and ask for escalation. Someone who was not involved in the original decision reviews it and replies within 14 days. That is in addition to, and never a precondition of, your right to complain to a supervisory authority.

Refund Policy

Effective date: 3 August 2026 · Version 1.2 · Previous version 1.1 of 3 August 2026
This policy forms part of the Terms of Service of JC Establishment LLC. Version 1.2 bounds the open-ended cash-refund right on unused credits to 24 months of purchase (credits still never expire for use) and clarifies that a purchase may be paused, not the account, while a chargeback is open; version 1.1 of 3 August 2026 is archived on request.

At a glance

1. There is nothing to cancel

1. CopperMailer does not operate subscriptions. Licences, feature unlocks, credits, reply packs and services are each charged once, at the moment you buy them.
2. There is therefore no renewal date, no cancellation form, no notice period, no retention call and no cancellation fee. If you no longer want the Service, you simply stop buying credits. Nothing further is charged, ever.
3. We do not keep your card on file for future charges unless you explicitly ask us to save a payment method for convenience. You can remove a saved method at any time in Settings → Billing, and removing it cannot break anything, because nothing is scheduled to charge it.
4. Your account can stay open indefinitely at no cost, with your licence and any remaining credits intact.

2. 14-day refund on anything unused

1. Within 14 days of a purchase, you may ask us to refund it to the extent you have not used it. No justification is required. One line to billing@coppermailer.com is enough.
2. How “unused” is measured for each thing we sell:

3. This applies to consumers and business customers alike.
4. It applies to every purchase, not just your first one.

3. Unused credits

1. Unused credits are refundable pro rata within 14 days of purchase, at the effective per-credit price you paid. If you bought 1,000 credits for $99.99 and received 1,025 with the bonus, the effective rate is $0.09755, so 400 unused credits refund $39.02.
2. After 14 days, unused paid credits remain refundable on request for 24 months from the date of that purchase, for as long as your account is open. This is a rule, not a favour, and it is not subject to our discretion. The rate is the effective per-credit price you actually paid in the purchase being refunded. Beyond 24 months, unused credits stay in your balance and never expire for use, but are no longer eligible for a cash refund – only for use against replies, which is what keeps a credit a usage right rather than an indefinitely cashable balance. Ask before closing the account, because closure is not reversible and does not trigger a refund automatically.
3. Credits consumed are not refundable, because the replies were generated. Credits deducted through a fault of ours are returned to your balance in full as soon as we confirm it, which is a correction rather than a refund and is not limited by any time period.
4. Credits granted free of charge (the 50 starter credits, promotional grants and goodwill top-ups) have no cash value and are never refundable, because nothing was paid for them.
5. Where a refund is made partly in money and partly in credits, we always tell you which is which before processing it, and you can decline.

4. Statutory right of withdrawal (EU / UK consumers)

1. If you are a consumer resident in the European Union, the United Kingdom, Norway, Iceland or Liechtenstein, you have a statutory right to withdraw from a distance contract within 14 days of concluding it, without giving a reason.
2. To exercise it, send an unambiguous statement to billing@coppermailer.com or to JC Establishment LLC, 30 N Gould St, Ste N, Sheridan, WY 82801, United States. You may use the model form in clause 9, but you do not have to.
3. Article 16(m) of Directive 2011/83/EU would let us ask you to waive that right in exchange for immediate access to digital content. We do not ask for the waiver and we do not rely on it. You get immediate access and you keep the right.
4. Our own 14-day refund in clause 2 runs alongside it and applies to anything you have not used, so whichever route you take, the unused part comes back to you.
5. If you withdraw within the period, we refund all payments received from you without undue delay and within 14 days at the latest, using the same means of payment you used.

5. Refunds outside the 14 days

1. Billing errors. Duplicate charges, incorrect amounts, wrongly applied tax, charges for something you did not buy and anything else caused by our error are refunded in full, always, as soon as we confirm them. There is no time limit on correcting our own mistakes.
2. Unauthorised charges. If you believe your payment method was used without your authorisation, contact billing@coppermailer.com immediately. We investigate within 5 business days and refund confirmed unauthorised charges in full.
3. Service defects. If a feature you paid to unlock does not work as described and we cannot fix it within a reasonable time, we refund what you paid for it in full.
4. We withdraw a feature or close the Service. Clauses 14.4 and 14.5 of the Terms apply: unused credits are refunded in full, and licences and unlocks pro rata over 36 months from purchase.
5. We terminate your account without your being in breach. Same treatment as clause 5.4 above.

6. What is not refundable

• Credits that have been consumed.
• Free credits, promotional grants and goodwill top-ups, which were never paid for.
• Reply packs that have been downloaded.
• Services already performed. Work not yet done is refunded.
• Purchases made more than 14 days ago that have been used, except in the situations listed in clause 5.
• Nothing on account of termination. If we close your account for breaching the Terms or the Acceptable Use Policy, your unused paid credits are still refunded to you. We will stop you using the Service, but we will not keep money you paid for replies we never generated. Credits granted free of charge are the exception, because nothing was paid for them.
• Third-party costs you incur separately, such as your email provider or CRM. We never charge those, so we cannot refund them.

7. How to request a refund

1. Email billing@coppermailer.com from the address on the account.
2. Include your workspace name and the invoice number or purchase date if you have it. That is all. You do not need to give a reason.
3. We acknowledge within 1 business day and decide within 5 business days, in writing, with reasons if we decline.
4. Approved refunds go to the original payment method through Stripe, in United States dollars, the currency you were charged in. Funds normally appear within 5 to 10 business days depending on your bank or card issuer. We cannot refund to a different card or account, and we cannot refund in cash, in credits you did not ask for, or in vouchers.
5. If the original card has expired or been closed, tell us: Stripe can usually still route the refund to the account behind it, and where it cannot we will arrange another lawful route with you rather than keep the money.
6. We charge no processing fee and do not deduct payment-processing costs from the amount refunded.
7. Refunded credits are removed from your balance at the moment the refund is issued.

8. Complaints and chargebacks

1. If you disagree with our decision, reply in the same thread and ask for escalation, or write to legal@coppermailer.com. A second reviewer who was not involved in the first decision responds within 14 days.
2. Please contact us before opening a chargeback. Almost every dispute we see is a misunderstanding we can settle the same day, and a chargeback only makes it slower for both of us.
3. If you do not recognise a charge, it will read JC Establishment on your statement, which is the legal name of the company trading as CopperMailer, and it will correspond to a single purchase made from your account. Ask us and we will send you the invoice, the date, the amount and what was applied to the account, within one business day.
4. If you open a chargeback anyway, we respond to your card issuer with the invoice, the acceptance record for these Terms and the delivery log showing what was applied to the account and when. If the issuer decides in your favour, that is the end of it: we do not re-bill, we do not pursue you for the amount and we do not add fees.
5. We do not close, penalise or hold your data hostage because you disputed a charge with your bank. That right is yours and it is not ours to discourage with consequences. While a chargeback is open and unresolved, we may pause new purchases on the account until it is settled, purely to avoid the same payment method being disputed and reused before the first case is closed; this never affects the data, licence or credits already on the account, is never treated as a breach, and is lifted the moment the dispute is resolved either way.
6. Where a chargeback duplicates a refund we have already issued, we will show both records to the issuer so that you are not refunded twice by accident, which would only be reversed later.

9. What happens to your data if you close the account

1. Day 0: account closed. The workspace becomes read-only and export remains available.
2. Day 30: Customer Data is deleted from production systems.
3. Day 90: Customer Data has rotated out of encrypted backups.
4. We retain invoices and transaction records for the period required by US federal and Wyoming tax law (currently seven years from the end of the relevant tax year). This is a legal obligation and is not affected by deletion requests.
5. You can request immediate deletion instead of waiting for day 30 by writing to privacy@coppermailer.com.
6. Leaving the account open costs nothing and preserves your licence and credit balance, so there is rarely a reason to close it in a hurry.

10. Model withdrawal form

You may use this form if you wish to withdraw from the contract, but you are not required to.

11. Contact

Billing and refunds: billing@coppermailer.com · Monday to Friday, 09:00 to 17:00 Mountain Time
Post: JC Establishment LLC, 30 N Gould St, Ste N, Sheridan, WY 82801, United States

Data Processing Addendum

Effective date: 29 July 2026 · Last updated: 29 July 2026 · Version 1.0
This Addendum forms part of the Terms of Service and applies automatically whenever we process personal data on your behalf. A counter-signed PDF is available on request from legal@coppermailer.com.

1. Parties and scope

1. This Addendum is between the customer identified in the account (“Controller”) and JC Establishment LLC, 30 N Gould St, Ste N, Sheridan, WY 82801, United States (“Processor”).
2. It applies to processing of personal data contained in Customer Data by the Processor in the course of providing the Service.
3. Terms defined in the Terms of Service have the same meaning here. “GDPR” means Regulation (EU) 2016/679 and, where relevant, the UK GDPR as incorporated by the European Union (Withdrawal) Act 2018.
4. In case of conflict between this Addendum and the Terms of Service on data protection matters, this Addendum prevails.

2. Details of processing (Art. 28(3))

3. Processor obligations

The Processor shall:

1. process personal data only on documented instructions from the Controller, including as to international transfers, unless required otherwise by EU or Member State law, in which case it will inform the Controller before processing, unless that law prohibits it on important grounds of public interest. Use of the Service in accordance with the documentation constitutes documented instruction;
2. immediately inform the Controller if, in its opinion, an instruction infringes the GDPR or other data protection law;
3. ensure that persons authorised to process the data are bound by confidentiality obligations that survive the end of their engagement, and are trained on data protection before access is granted;
4. implement the technical and organisational measures in Annex A (clause 11) in accordance with Article 32;
5. respect the conditions on sub-processing in clause 4;
6. assist the Controller, by appropriate technical and organisational measures and insofar as possible, in fulfilling requests from data subjects exercising their rights under Chapter III;
7. assist the Controller in complying with Articles 32 to 36 (security, breach notification, data protection impact assessment and prior consultation), taking into account the nature of processing and the information available;
8. at the Controller’s choice, delete or return all personal data at the end of the provision of services, and delete existing copies unless retention is required by law;
9. make available to the Controller all information necessary to demonstrate compliance with Article 28 and allow for and contribute to audits under clause 8.

4. Sub-processors

1. The Controller grants a general written authorisation for the Processor to engage sub-processors.
2. The current list is published in Annex B, below, and forms part of this Addendum.
3. The Processor will notify the Controller of any intended addition or replacement of a sub-processor at least 30 days in advance, by email to the account’s notification address and by updating that page. Customers may subscribe to change notifications at privacy@coppermailer.com.
4. The Controller may object on reasonable data-protection grounds within 30 days of notice. The parties will discuss in good faith; if no resolution is found, the Controller may terminate the affected part of the Service without penalty and receive a prorated refund of the unused prepaid fees.
5. The Processor imposes on every sub-processor, by written contract, data protection obligations no less protective than those in this Addendum, and remains fully liable to the Controller for the sub-processor’s performance.

5. International transfers

1. The Processor’s default hosting region is the United States. On request before onboarding, a workspace can be provisioned in the EU region (Germany) so that Customer Data is stored at rest within the European Economic Area.
2. Where personal data is transferred outside the EEA, the Processor relies on Commission Implementing Decision (EU) 2021/914 Standard Contractual Clauses, which are incorporated into this Addendum by reference: Module Two (controller to processor) between the Controller and the Processor, and Module Three (processor to processor) between the Processor and its sub-processors.
3. For the purposes of the SCCs: the docking clause applies; clause 9 option 2 (general written authorisation, 30 days) applies; clause 11 optional independent dispute resolution does not apply; clause 17 selects the law of Ireland; clause 18(b) selects the courts of Ireland. Annexes I, II and III are populated by clauses 2, 11 and Annex B respectively.
4. The Processor is established in the United States and is the data importer under the SCCs. We have not appointed an Article 27 representative in the European Union, because we do not currently target the Service at consumers in the EEA; if that changes we will appoint one and name it here before doing so. EEA and UK customers can reach our privacy team directly at privacy@coppermailer.com.
5. Transfer impact assessments are maintained and available on request. Supplementary measures include encryption in transit and at rest, pseudonymisation where feasible, and a policy of challenging overbroad government access requests and notifying the Controller unless legally prohibited.
6. UK transfers use the UK International Data Transfer Addendum to the SCCs; Swiss transfers use the SCCs with the adaptations required by the FDPIC.

6. Data subject requests

1. The Service provides self-service tools to search, export, correct and delete individual records, so the Controller can normally answer requests without our help.
2. If a data subject contacts the Processor directly, the Processor will not respond substantively but will refer the request to the Controller without undue delay, and in any case within 5 business days.
3. Additional assistance beyond the self-service tools is provided free of charge for reasonable volumes.

7. Personal data breach

1. The Processor will notify the Controller without undue delay, and in any event within 72 hours of becoming aware of a personal data breach affecting Customer Data.
2. The notification will describe the nature of the breach, the categories and approximate number of data subjects and records concerned, the likely consequences, the measures taken or proposed, and a contact point, to the extent known, with updates as the investigation progresses.
3. The Processor will not notify a supervisory authority or data subjects on the Controller’s behalf unless instructed to do so in writing.
4. Notification is not an admission of fault or liability.

8. Audit rights

1. The Processor makes available its security documentation and completes customer security questionnaires free of charge. It holds no third-party audit report and no penetration test summary today; both will be offered here once they exist.
2. The Controller may request an audit no more than once in any 12-month period, on 30 days’ written notice, during business hours, without unreasonably disrupting the Processor’s operations, and subject to confidentiality. Where a recognised third-party report addresses the scope, that report satisfies the request.
3. Additional audits, or audits following a confirmed material breach, may be conducted more frequently; the Controller bears reasonable costs of audits it initiates beyond the annual allowance.

9. Confidentiality and staff

Access to Customer Data by Processor personnel is limited to what is necessary to operate and support the Service, granted on a least-privilege basis, logged, and reviewed whenever a role changes. Support staff access production Customer Data only against a documented support request from the Controller. All personnel are bound by written confidentiality undertakings before access is granted.

10. Return and deletion

1. The Controller may export Customer Data at any time in CSV and JSON.
2. On termination, Customer Data remains available for export for 30 days, is then deleted from production systems, and rotates out of encrypted backups within a further 60 days.
3. Earlier deletion is available on written request to privacy@coppermailer.com.
4. The Processor may retain data where required by EU or Member State law, in which case it continues to protect it and processes it only for the purpose requiring retention.
5. A certificate of deletion is issued on request.

11. Annex A: technical and organisational measures

• Encryption. TLS 1.2+ in transit; AES-256 at rest for databases, object storage and backups; keys managed in a hosted KMS with rotation.
• Access control. Mandatory MFA on all administrative accounts; role-based permissions; least privilege; access reviewed whenever a role changes and revoked immediately on departure.
• Tenant isolation. Logical separation of Customer Data with tenant identifiers enforced at the data-access layer and tested automatically.
• Network. Private subnets, security groups, WAF, DDoS protection, no public database endpoints, bastion-free administrative access via short-lived credentials.
• Application security. Peer-reviewed code, dependency scanning, static analysis and secret scanning in CI, prompt-injection defences and output filtering. External penetration testing is planned but has not yet been commissioned.
• Logging and monitoring. Centralised, append-only audit logs held in managed storage; alerting on anomalous access; 12-month retention.
• Resilience. Automated encrypted daily backups, retained 30 days; multi-availability-zone deployment. Restores are tested before being relied on. We do not publish an RPO or RTO figure, because we have not yet run the failure drills that would let us stand behind one.
• Incident response. Documented plan with defined severities; automated alerting; written post-incident reviews sent to affected customers. There is no 24×7 on-call rotation.
• Vendor management. Security review before onboarding a sub-processor and annually thereafter.
• People. Written confidentiality undertakings for everyone with production access, documented onboarding and offboarding, and security training before access is granted.
• Data minimisation. Optional PII redaction before model inference; customer-configurable retention within a 12-month ceiling; no use of Customer Data for training shared or third-party models.

12. Liability and general

1. Each party’s liability under this Addendum is subject to the limitations in clause 18 of the Terms of Service, except where the GDPR provides otherwise.
2. This Addendum is governed by the laws of the State of Wyoming, United States, without prejudice to clause 5.3.
3. If any provision is invalid, the remainder continues in force.
4. Signature: this Addendum is incorporated by reference into the Terms of Service and requires no separate signature. A signed copy can be issued on request to legal@coppermailer.com.

13. Annex B: current sub-processors

Every party listed here is bound by a written data-processing agreement with obligations no less protective than those in this Addendum.

Infrastructure and platform

AI model providers

Business operations

Affiliates

JC Establishment LLC has no parent, no subsidiaries and no affiliated companies. Nothing is processed by a related entity, because there is no related entity. If that ever changes, this Annex is updated with 30 days’ notice.

Optional integrations you control

If you connect Google Workspace, Microsoft 365, HubSpot, Shopify, Zapier or your own IMAP server, those platforms process your data under your own agreement with them. They are not our sub-processors; you are their customer and we act on your instruction to exchange data with them.

Change history

This is the first published version of this Annex, so there is nothing to report yet. Every future addition, replacement or removal will be recorded here with its date, and we will not backfill entries for periods before this Annex existed.