Distant Measures Anti-Spam Policy

Consent

1. has provided Affirmative Consent to receive email from the Client or
2. has an existing business relationship with the Client.

1. Affirmative Consent. "Affirmative Consent" is a mechanism through which the Recipient expressly consented to receive the message, either in response to a clear and conspicuous request for such consent or at the Recipient's own initiative.
   Clients may obtain Affirmative Consent as follows:
   
   1. Confirmed (closed loop) Opt-in. Following an opt-in request, a confirmation email is subsequently sent to the person notifying him that some action is necessary before his email address will be added to the list. The person must respond or take other equivalent action to be considered "confirmed."
   2. Notified Opt-in (welcome message). At the point of email address collection, a person has affirmatively requested to be included on an email list to receive email. An email is subsequently sent to the person, notifying the person that his or her email address has been added to the email list. The person is not required to take further action to be included on the email list.
   3. Opt-in. At the point of email address collection, a person has affirmatively requested to be included on an email list to receive email. No confirmation email is sent and the person is not required to take further action to be included on the email list.
   In jurisdictions where email communications are subject to a more restrictive definition of consent (e.g., the European Commission Privacy and Electronic Communications Directive), Clients shall adhere to the applicable local standards.
   
2. Existing Business Relationship. A business relationship between a Client and a Recipient may be created through the facilitation or completion of a transaction. A business relationship may also be created through prior correspondence initiated by an individual, including, without limitation, requests for information.
3. Co-Registration. Email addresses collected through co-registration will be acceptable for use with the Distant Measures Service if the following conditions are met:
   1. The Client who acquires the email address was clearly and conspicuously disclosed at the point of email address collection.
   2. Consent was obtained through one of the methods described in Section 1a.
   3. Each act of consent (e.g., a check box) resulted in the addition of an email address to only one list.
   4. Proof of consent, including the date, time, originating IP address, and location (e.g., URL) where the address collection occurred can be produced by the Client upon request.
4. Prohibited Practices.
   
   1. List Sharing. The Distant Measures Service may not be used for list rental, list exchange, partner mailings or similar types of email campaigns.
   2. Email Prospecting. Any form of email prospecting (i.e., where there is no consent or existing business relationship between the Client and the Recipient) using the Distant Measures Service is prohibited.
   3. Other Prohibited Practices. Email addresses to be used for the Distant Measures Service must not be gathered through surreptitious methods (e.g., scraping, harvesting, or dictionarystyle attacks).

Content

1. Message headers, subject lines and content shall not be misleading, misrepresentative or falsified in any way.
2. Messages shall not transmit viruses or other programs which may destroy or limit the functionality of a computer.
3. Messages shall not contain content which is unlawful or harassing.

Unsubscribe

1. Inclusion in Email. Clients shall include an unsubscribe function within each Distant Measures email. All other classes of email must contain an unsubscribe function if required by applicable law. The unsubscribe function must be easy to use and must be clearly and conspicuously located in the email. In addition, the unsubscribe function:
   
   1. must remain active and functional for at least 30 days after the message is sent,
   2. must be processed within 10 business days of receipt (or such shorter period of time if required by applicable law), and
   3. must not require a Recipient to provide any information other than the Recipient's email address (unless the Recipient has been clearly and conspicuously notified at the point of collection that receiving such Email Messages is a requirement to receive a service).
2. Permanence of Unsubscribe. Once an unsubscribe request is received, it shall be considered permanent and no Distant Measures Messages of the same Token class may be sent to that Recipient unless Affirmative Consent is obtained again. Re-establishment of a business relationship is not sufficient to override a prior unsubscribe request.
3. Complaint as Unsubscribe. Unless the level of granularity of a complaint indicates otherwise, Distant Measures will interpret a complaint as a request to unsubscribe and expects Clients to unsubscribe a complaining Recipient. Distant Measures will identify complaining Recipients to Client for this purpose.