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Anti-Spam Policy

DEFINITIONS AND EXPLANATIONS

  1. Last update

September 1, 2023

 

  1. Introduction to the anti-spam policy

ExpertSender S.A. does not collect, buy, share or sell any mailing lists for bulk mailing campaigns. We only provide a platform for electronic communication to those senders who have read all the terms of this anti-spam policy and accepted them in full.

 

  1. Justification of the anti-spam policy

The anti-spam policy introduces uniform rules for all senders using ExpertSender’s infrastructure, which are aimed at protecting the interests of the company, senders, recipients and other entities involved in the legal and ethical functioning of electronic communication.

 

  1. Definition of spam

Spam is unsolicited commercial information. Colloquially, spam is also associated with annoying marketing content (e.g. too frequent advertisements for products and services, promotional materials not adapted to the expectations of recipients), which does not necessarily violate the law. Spam is also considered to be messages that present false information or are used to steal personal data. Spam distribution is prohibited.

 

  1. Scope of the anti-spam policy

ExpertSender bases the content of this anti-spam policy on many years of knowledge and experience, on legal acts (Polish Act on the provision of electronic services, GDPR, CAN-SPAM, CASL, CCPA) and on best sending practices promoted by trusted organizations, inter alia M3AAWG, CSA, Vade, Google, Microsoft and Yahoo.

 

TERMS AND OBLIGATIONS

  1. Verification of senders and their sending plans

Each sender undergoes a mandatory check before signing a cooperation agreement with ExpertSender. Verification consists of a set of questions and analyses that are designed to confirm compliance with the policies in force in our organization. The process is at the same time advisory and helps in preparing for the use of the platform.

 

  1. Email address acquisition rules
  1. It is required to collect the date of subscription, the website address and the IP address for each email address (ExpertSender is entitled to verify this data in the course of cooperation with each sender, and the senders are obliged to provide a complete set of data within 24 hours of receiving a written request);
  2. It is forbidden to buy lists with email addresses;
  3. It is forbidden to use services that allow to add email addresses to subscriber lists based on relationships with other data sources (so-called email appending);
  4. It is recommended to use confirmed subscriptions (so-called double opt-in) and CAPTCHA security for web forms;
  5. It is recommended to exclude the possibility of subscribing to role accounts in the web form (e.g. admin@domain, office@domain, contact@domain).

 

  1. Removal of email addresses from subscriber lists

Each message sent from the ExpertSender platform must have an unsubscribe link that will be active for at least 30 days from the date the message was sent and will remove the email address from the list immediately after clicking on it.

It is allowed for senders to use their own unsubscribe links, provided that they unsubscribe the email address from the list in the ExpertSender platform within 24 hours of receiving the request.

ExpertSender requires that the process of unsubscribing from the list is as simple as the process of signing up to the list and does not force additional login or contact with the sender.

Removing email addresses from the list is mandatory if their owners have filed a complaint or unsubscription request, unless the continued presence on the list results from a different legal basis for data processing than the consent of the person and does not expose ExpertSender to legal, reputational or financial consequences.

The same obligation applies to non-existent email addresses, the status of which has been confirmed by a non-delivery report from the mail server at the first unsuccessful attempt to deliver an electronic message.

ExpertSender maintains an internal list with non-existent email addresses in order to prevent messages from being sent to such addresses and to protect the reputation of senders.

 

  1. Obligation of senders to reply and process notifications

Each sender is required to create mailboxes in the sending domain to receive requests from message recipients and other interested parties.

The minimum is the contact mailboxes used in the “From” and “Reply to” fields, in the footer of the message, as well as dedicated email aliases abuse@sendingdomain and postmaster@sendingdomain. Contact mailboxes must be constantly monitored and requests ought be processed in accordance with ExpertSender policies and legal regulations.

All reports regarding a given sender and delivered directly to ExpertSender will be made available to the given sender for further consideration.

 

  1. Sender authentication

Each business unit in ExpertSender, used for sending electronic messages, has assigned IP addresses and a sending domain. ExpertSender requires each sender to use the Sender Policy Framework (RFC 4408) and DomainKeys Identified Mail (RFC 4871) authentication standards and helps to configure them correctly.

Domain-based Message Authentication, Reporting, and Conformance (DMARC) is not mandatory, but every sender is encouraged to use it.

 

  1. Identification of senders

Each message sent from the ExpertSender platform must contain a footer with:

  1. Name and address details of the sender;
  2. The name of the register and the registration number of the company depending on the country of business;
  3. Contact phone number and email address (instead of an email address, a link to the contact form on the website is allowed).

 

  1. Sending domains

Each sending domain must have:

  1. Website with a working subscription form and an up-to-date privacy policy, containing details of personal data processing and the name and address details of the personal data controller;
  2. Age over 30 days;
  3. Owner’s public WHOIS contact information.

 

  1. Warming up dedicated IP addresses and sending domains

Senders starting cooperation with ExpertSender are required to go through the warm-up period of dedicated IP addresses and sending domains. This period usually ranges from 2 to 4 weeks and depends on additional factors (e.g. age and status of the subscriber list, division of email addresses by mailbox providers, planned volume of mailings).

This process is designed to increase sender trust on the part of mailbox providers to prevent message over-filtering and maximize the chances of getting high deliverability rates for all mailing campaigns.

ExpertSender provides senders with assistance of experienced specialists both during the preparation for the warm-up period and during its implementation.

 

  1. List of prohibited and restricted content
  1. Hatred, violence and discrimination;
  2. Disinformation, deceptive and misleading communication;
  3. Malware and phishing;
  4. Unsolicited commercial messages;
  5. Messages containing domains present on RBL lists – Realtime Blackhole List;
  6. High-interest, payday loans and cash advance;
  7. Multi-level marketing and pyramid schemes;
  8. Cryptocurrencies (related to third parties);
  9. Medicines and supplements (related to third parties);
  10. Gambling and betting (related to third parties);
  11. Pornography, nudity and dating (related to third parties);
  12. Stock exchanges and Forex markets (related to third parties).

 

  1. List of prohibited practices
  1. Sending marketing messages to recipients without obtaining their consent;
  2. Ignoring reports from people, especially complaints and unsubscription requests;
  3. Exceeding 0.2% of complaints for messages delivered within 1 day;
  4. Exceeding 5% of hard bounces for messages sent within 1 day;
  5. Sending messages to spamtrap email addresses;
  6. Use of sender names and subject lines of messages unrelated to the distributed content or misleading;
  7. Using links in messages redirecting to pages unrelated to their content;
  8. No unsubscribe link or hiding it in the content (e.g. small font, color blending with the background);
  9. Putting links in messages with an insecure http protocol;
  10. Using link shorteners (e.g. bit . ly) in the body of the message;
  11. Using domains not owned by the sender in the “From” field;
  12. Sending the same messages to the same recipients from more than 1 domain;
  13. Sending the same messages to the same recipients within 1 day;
  14. Sending messages to millions of recipients without throttling;
  15. Copyright infringement through non-contractual use of someone else’s trademarks.

 

  1. Dealing with IP addresses and domains which are found in RBLs

In the event that the IP addresses or the sending domain of the sender are included in the RBL list, ExpertSender is entitled to block the sending of messages and request explanations from the sender.

In the absence of explanations from the sender within 3 days of the request or if the explanations are not satisfactory, ExpertSender will be entitled to unilaterally disable the service of one or more business units of the sender or to terminate the contract in its entirety, with immediate effect.

In the event that the IP addresses or the sending domain of the sender once again enter the RBL list, ExpertSender will be entitled to unilaterally disable the service of one or more business units of the sender or to terminate the contract in its entirety, with immediate effect, without requesting explanations.

 

  1. Consequences of non-compliance with the anti-spam policy

Violation of any point of this anti-spam policy entitles ExpertSender to draw the sender’s attention and request to cease further violation of the terms.

The sender has 3 days to provide satisfactory clarifications and 14 days to resolve the non-compliance.

Failure to provide satisfactory explanations or further violation of the terms of the anti-spam policy will result in unilateral disabling of one or more business units of the sender or termination of the contract in its entirety, with immediate effect.

Another case of violation entitles ExpertSender to unilaterally disable the service of one or more business units of the sender or to terminate the contract in its entirety, with immediate effect, without requesting explanations.

 

COMPLAINTS AND INQUIRIES

  1. Contact addresses

In case of problems with the use of unsubscribe links or other abuse on the part of the sender who uses the infrastructure of ExpertSender, please send the report along with the original message headers to abuse @ expertsender . com.

We try to process all requests on an ongoing basis, but we reserve the right to respond within 30 days depending on the complexity and number of open requests.

Alternatively, notifications can be sent by post to the address of the registered office of ExpertSender S.A. at Cypriana Kamila Norwida 1, 80-280 in Gdansk (Poland).