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CLOSELY ANTI-SPAM POLICY

Effective Date: July 1, 2021

"Closely has a zero-tolerance policy towards Spam. At Closely, we believe that any electronic communication and other solicitation must be legitimate and expected by their recipients. That’s why, Closely expects the Client to follow a few basic but mandatory rules when using the Platform and Services. In this regard, the Client shall be sure to read this Anti-Spam Policy (the “Policy”) before creating the account and starting using the Services. This Policy is an integral part of the Closely Terms of Use (the “Terms”) and Privacy Policy and incorporated thereto by reference. In the event of non-compliance with the Policy, we may immediately suspend or restrict the Client’s account to prevent any damage to third-parties, the Closely’s reputation, or to the global efficiency of the Services, in accordance with the suspension process described in the Terms."

1. LEGAL COMPLIANCE

Notwithstanding this Policy, the Client shall fulfill its obligations under generally applicable laws, such as:

  1. The CAN SPAM Act of 2003 (Controlling the Assault of Non-Solicited Pornography and Marketing Act);
  2. Regulation (EU) 2016/689 of the European Parliament and of the Council of 27 April 2016;
  3. The Directive on Electronic Commerce (2000/31/EC) of the European Parliament and Council of 8 June 2000;
  4. The Directive on Privacy and Electronic Communications (2002/58/EC) of the European Parliament and Council of 12 July 2002.

The communication and the Content shall be clear, acceptable and disclose:

  1. Who the Client is;
  2. The reason (real intention) of the communication event;
  3. The reason of bothering the exact recipient; and
  4. That it is okay not to communicate back if the recipient is not interested in the communication/the Client’s business.

If the recipient ignores the act of the communication, notifies that they are not interested in the communication, or demands that the Client shall not communicate with the recipient anymore, the Client is prohibited from ordering, initiating, or conducting the contact with that recipient again.

2. CLIENT’S CONTENT; DEFINITION OF SPAM

The Client’s Content shall not include any prohibited information, be used against the rules outlined herein, and be ordered to distribute (and be distributed) as the Spam by the Client.

Spam is any kind of unwanted, unrequested, and unsolicited digital communication that gets sent out in bulk without recipients’ permission. The communication may be also identified as spam if:

  1. The recipient’s personal identity, scope of communication, or context are irrelevant because the communication is equally applicable to many other potential recipients;
  2. The communication is being sent to recipients against their will;
  3. The communication includes the Content with prohibited materials; or
  4. The transmission and reception of the communication sent to the recipient to give a disproportionate benefit to the Client who is the sender.

3. PROHIBITED CONTENT

Neither the Client’s Content, nor the communication shall include, without limitation:

  1. Anything that interferes with or disrupts the Website/Platform or their operation owing to its uploading or transmitting;
  2. Anything that states any type of connection with Closely;
  3. Statements or material that defames, harasses, abuses, stalks, threatens, intimidates, or in any way violates the rights of others;
  4. Unauthorized copyrighted materials or any other material that infringes on the intellectual property rights, trade secrets, or privacy of others;
  5. Statements or material that violates other contractual or fiduciary rights, duties, or agreements;
  6. Statements or material that is bigoted, hateful, or racially offensive;
  7. Statements or material that encourages criminal conduct or that would give rise to civil liability or otherwise violates any law or regulation in any jurisdiction;
  8. Statements or material that constitutes anti-competitive collaboration and/or antitrust violations;
  9. Statements or material that contains vulgar, obscene, profane, or otherwise objectionable language or images that typically would not be considered socially or professionally responsible or appropriate in person;
  10. Obscenity, pornography, sexually explicit, political statements or material, statements or material relating to gambling, betting, etc.;
  11. Statements or material that harms minors,
  12. Statements or material that impersonates any other person or entity, whether actual or fictitious, including employees and representatives of Closely or its affiliates;
  13. Statements or material that misrepresents the Client’s affiliation with any entity or Closely or its affiliates,
  14. Anything that violates the privacy or publicity rights of any other person, including, without limitation, posting any personal information;
  15. Chain letters or pyramid schemes;
  16. Statements or materials that are deceptive or misleading;
  17. Statements or material that constitutes junk mail, spam, or unauthorized advertising or promotional materials;
  18. Files that contain malicious code, viruses, corrupted files, or any other similar software or programs that may damage the operation of another’s computer, network, or the Website/Platform;
  19. Any external links;
  20. Any fraudulent information, fake news, phishing simulations, etc.;
  21. Statements or material that do not comply with laws applicable to the Client, Closely or the recipients, international laws; and
  22. Statements or material that do not comply with ad policies or other legal documents of the social media platforms where the communication is initiated.

Nonetheless, the following industries, including without limitation, are strictly prohibited to be related to the communication:

  1. Exchange of currencies and any financial services;
  2. Pornography or e-commerce related to adult goods/services for adults only;
  3. Any Political activity;
  4. Initial Coin Offering (ICO);
  5. Forex trading and related activity;
  6. Debt collection;
  7. Any religion and related activity;
  8. Healthcare and Nutrition;
  9. Drugs, alcohol and tobacco;
  10. Cryptocurrencies;
  11. Dating services;
  12. Gambling, casino and other money games;
  13. Clairvoyance, fortune telling and astrology.

4. REPORTING SPAM

Should you suspect that you may have received an unsolicited electronic communication from the Clients, please let us know and send an email to [email protected] that contains the following information:

  1. Full details on the sender name displayed in the electronic communication;
  2. Links to the sender’s social media accounts (if applicable);
  3. The exact date and time of the unsolicited communication, a number of the Spam events (received unsolicited communication);
  4. The text or description of the unsolicited communication.

If the provided data is enough to trace the offender among the Clients, we will immediately investigate the issue, take relevant steps on preventing the Spam distribution, or even suspend the offender’s account on the Platform, so they will have no opportunity to breach the Policy and your privacy once more.