No-Spam / Anti-Spam Policy

Last Modified: June 22,2016

1. Purpose

1.1 SVAAPTA does not permit its Services to be used for spam, abusive bulk messaging or unlawful direct marketing. This Part B applies to email and, where relevant to the Service, other stored electronic messages such as SMS, messaging-platform messages or similar communications.

1.2 The Client is responsible for messaging carried out by its employees, contractors, marketing agencies, resellers, customers or other persons using the Services on its behalf.

2. Prohibited messaging practices

2.1 The Client must not use or promote the Services through:

• Unsolicited bulk email or mass messaging sent in breach of applicable law or without a reasonable, documented basis for contacting recipients.

• Messages using forged, concealed or materially misleading sender identities, domains, routing information or subject lines.

• Email harvesting, dictionary attacks, purchased or scraped lists where the sender cannot demonstrate a lawful basis and appropriate permission or entitlement to contact recipients.

• Messages sent after a valid unsubscribe, objection or suppression request should reasonably have been implemented.

• Operating an open relay, compromised mail system or other configuration that materially facilitates spam.

• Using another provider to send spam advertising a website, domain, product or service hosted or operated through SVAAPTA Services (sometimes called “spamvertising”).

• Repeated sending to invalid addresses, spam traps or recipients generating material complaint rates after SVAAPTA has required corrective action.

• Any attempt to evade technical anti-spam controls, blocklists, rate limits or abuse detection.

3. Permitted direct marketing and consent standards

3.1 This policy is stricter than merely asking whether a message is technically capable of being sent. Clients must comply with applicable direct-marketing and data-protection law, including the Privacy and Electronic Communications Regulations 2003 (PECR) and UK data-protection law where applicable.

3.2 Where consent is required for electronic marketing, the Client must be able to demonstrate valid consent appropriate to the communication channel and sender.

3.3 Where a lawful “soft opt-in” or business-to-business marketing rule is relied upon, the Client must satisfy all applicable conditions and maintain sufficient records to support that reliance.

3.4 Every marketing message must accurately identify the sender and provide a valid, reasonably accessible method to opt out or unsubscribe where required by law.

3.5 The Client must maintain suppression records so that people who have opted out, objected or withdrawn consent are not inadvertently re-added to marketing campaigns, except where a limited record must be retained solely to respect the suppression.

3.6 Publicly available contact details do not by themselves prove consent. Bought-in or third-party lists must not be used unless the Client has carried out appropriate compliance checks and has a lawful basis to use the data for the intended messaging.

4. Operational email standards

4.1 Website forms, applications and automated systems should use authenticated sender domains and addresses controlled or authorised by the Client or relevant service owner.

4.2 The Client shall maintain appropriate SPF, DKIM, DMARC or equivalent controls where reasonably required for the relevant email service and within the Client's control.

4.3 The Client shall use reasonable list hygiene, bounce handling and complaint monitoring appropriate to the scale of messaging.

4.4 Transactional or service messages must not be disguised as purely operational communications where their primary purpose is direct marketing.

5. Spam complaints and enforcement

5.1 On receipt of a credible spam complaint, SVAAPTA may request campaign details, message samples, sender information, consent or lawful-basis records, source of recipient data, unsubscribe records and relevant SMTP or application logs.

5.2 SVAAPTA may immediately restrict outbound messaging where there is a material risk of ongoing spam, blocklisting, security compromise or harm to shared infrastructure or sender reputation.

5.3 For a first or low-severity incident, SVAAPTA may permit remediation rather than terminate the account where the Client acts promptly and the risk can reasonably be controlled.

5.4 Repeated, deliberate, fraudulent or high-volume spam may result in immediate suspension or termination in accordance with the governing agreement.

5.5 SVAAPTA may require a Client to remove compromised accounts, suspend a marketing campaign, clean a recipient list, implement authentication or suppression controls, or move messaging to an appropriate specialist provider before service is restored.

6. Responsibility for third parties

6.1 The Client remains responsible for compliance where messaging is carried out for its benefit by an advertising agency, contractor, affiliate, sub-user or other third party using or promoting the Services.

6.2 The Client shall ensure such third parties are contractually required to follow equivalent anti-spam and data-protection requirements.

7. Relationship with the Services Agreement

7.1 This Policy is incorporated only where the applicable SOW, Order Form, MSA or Support Agreement states that it applies.

7.2 If there is a conflict between this Policy and the applicable Services Agreement, the Services Agreement prevails unless it expressly states otherwise.

7.3 Suspension, termination, liability, indemnities, payment and dispute-resolution rights are governed by the applicable Services Agreement except where this Policy expressly grants operational protective measures necessary to address abuse.

7.4 This Policy does not create a general obligation on SVAAPTA to monitor Client Content, communications or user activity.