1. Purpose
This policy explains Impero IT Services Private Limited’s (the “Company”, “we”, “us”, “our”) commitment to preventing unsolicited advertising and protecting visitors’ contact information from being used for unwanted communications by us, our affiliates, partners, vendors, or third parties.
2. Scope
This policy applies to all communications channels (including email, SMS/MMS, telephone calls, fax, messaging apps such as WhatsApp, social media direct messages, and other electronic or physical messaging) and to all categories of recipients (prospective customers, registered users, customers, and site visitors). It applies to the Company and to any third party who receives personal data from us.
3. Definitions
- Unsolicited Advertising (Spam): Any promotional or marketing communication sent without the recipient’s prior affirmative consent or without a lawful basis under applicable law. Bulk promotional messages sent without individual consent are considered unsolicited advertising.
- Transactional/Service Messages: Communications strictly necessary to fulfill a contract or provide a service the user requested (e.g., order confirmations, account notices, security alerts). These are not considered unsolicited advertising if they do not contain promotional content.
4. Policy Statement — Prohibition of Unsolicited Advertising
- We do not sell, rent, lease, or otherwise disclose personal contact information to third parties for the purpose of sending unsolicited advertising.
- The Company and its affiliates, agents, or partners must not send promotional or marketing messages to any person unless that person has explicitly opted in or otherwise consented as required by applicable law.
- Third parties (including affiliates, marketing vendors, resellers and partners) who receive personal data from the Company are prohibited from using that data to send unsolicited advertising and must agree in writing to this prohibition.
5. Consent and Opt-in
- Where required by law or by our practices, we will obtain clear, affirmative consent before sending marketing communications. Consent must be specific, informed, freely given and recorded.
- For promotional communications delivered by email, we will use a double-opt-in process or equivalent where required by local law or good practice.
6. Opt-out / Unsubscribe
- Every promotional message the Company sends will include an easy, free and clearly visible method to opt out of future messages (e.g., an unsubscribe link in emails, or instructions for SMS/WhatsApp).
- Opt-out requests will be processed promptly and within any timeframes required by applicable law. Once an individual opts out, we will not send further promotional messages except those necessary to confirm the opt-out or to send transactional communications.
7. Third Parties, Affiliates and Processors
- We may share data with service providers for performance of services, but we will require those providers by contract to comply with this policy and not to use the data for unsolicited advertising.
- Affiliates and partners may be permitted to contact users only where the user has provided explicit consent to receive messages from those specific parties; otherwise such contact is prohibited.
8. Exceptions
- Transactional or service messages necessary to perform a service requested by the user are permitted and do not require marketing consent, provided they do not contain promotional marketing content.
- Communications required by law or to respond to a legal request are not covered by the opt-out requirement.
9. Enforcement and Remedies
- Violations of this policy by Company employees, affiliates, vendors, or partners will result in disciplinary action up to termination of contract and other legal remedies as appropriate.
- Individuals who receive unsolicited advertising in violation of this policy may report it to our Data Protection Officer at [dpo@imperoit.com] (or alternate contact). We will investigate and take corrective action.
10. Contact & Complaints
- For questions, opt-out requests, or complaints about unsolicited messaging, contact: [dpo@imperoit.com] or postal address: [insert address]. We aim to acknowledge complaints within [5] business days.
11. Changes to this Policy
We may update this policy from time to time. When we make material changes we will post a prominent notice on our website and update the effective date.
