I don’t think this is necessarily true, and I would be extremely careful if I was in anyone’s shoes. Losing access to your Proton account means losing accesses to many online accounts if you have aliases linked to them. Not to mention losing all your emails from Proton Mail.
Proton gets to interpret their rules however they want, to the point where they change the meaning of words like “bulk”. They can also reprimand you even if you have not broken any of their rules, which is what I believe happened to me.
A) I got warning despite technically not breaking their rule
Proton’s rule explicitly says the following:
you shouldn’t use email aliases for bulk signups on a third party website.
Even if I agreed with Proton’s nonsensical definition of “bulk”, which I don’t, I did no such thing.
I created 3 aliases for the same website within 2 hours. But I was not signing up to any service, I was simply updating my email address for accounts I’ve had for years. Signing up to a service and updating your email for existing accounts are not the same thing.
But Proton doesn’t care. For them, it might as well be.
B) Sometimes you cannot afford to wait.
If my current email provider is shutting down (e.g.: Skiff), and I have many online accounts linked to addresses from that provider, I cannot afford to wait to update my email for those accounts. This is just one example, and there are plenty of others.
In situations like these, I have to allocate the time to update my email for those accounts, and in that time block of sometime just a couple of hours, I need to create multiple aliases for the same website.
That is the context in which I got a warning.
C) Bulk means I should (technically) be allowed to have 100+ aliases for the same website.
Acquiring something in bulk means acquiring a lot of it in a very short instant.
If I buy 100 pairs of socks from the same shop in a single day, you can argue that I bought them in bulk.
But if I buy 3 pairs of socks in a week, however you slice it, I did NOT buy them in bulk.
Suppose I decide to buy 3 pairs of socks a week, and I buy each pair on different days, Monday, Wednesday, and Friday.
In a single week, I have acquired 3 pairs of socks. In a month, I will have 12 pairs of socks, and after a year, I will have 144 pairs of socks.
I now have 144 pairs of socks in my drawer.
Did I buy them in bulk?
The answer is no.
By that logic, if I create aliases at the same pace, I should be allowed to have 144 aliases for the same website, without breaking Proton’s ToS.
I am doubtful they would allow it, even if it technically didn’t infringe their ToS. This is something that could easily occur with Substack, as subscriptions quickly rack up.
D) PSAs could trigger a warning
Even if you pace when you create your aliases, a public service announcement (PSA) could trigger a warning. Suppose you have 3 Dropbox accounts that you create a month apart with aliases.
If six months after, Dropbox sends an email announcement about a new product they’re launching, you will receive 3 emails at the same time from the same website, to your 3 aliases.
That could trigger a warning from Proton. Companies make announcements all the time, so I personally don’t want to take that risk until Proton changes and/or clarifies their ToS. I already got a warning.