Introduction

LAZARO GROUP has zero tolerance for anyone using its products and services or marketing them to use Unsolicited Broadcast Email and Unsolicited Commercial Email ("UBE/UCE"), commonly known as "spam"). All spam complaints are taken seriously. Spam is an unethical form of Internet advertising and is illegal. LAZARO GROUP is committed to protecting valid email senders using our products and services and also marketing them by using all measures possible to eliminate spammers for the ultimate benefit of all.

Definition

LAZARO GROUP defines spam as unsolicited email that is sent to addresses that do not affirmatively and verifiably request such material from that specific sender, including but not limited to, advertising, surveys, Contact Information pieces, third party spamming, website addresses, sales, and auctions.

Many email lists obtained from third parties are culled from Internet web sites, domain registrations, and other non opt-in sources. The use of such lists is considered spam.

Posting messages to Usenet or News Group groups that explicitly forbid the posting of commercial solicitations or solicitations not pertaining to their content is spam.

Buying a list of emails from a third party and, individually or in bulk, emailing them is considered spam.

Sending to a list of email addresses that comes to you via a chain letter or advertising is spam.

Sending to recipients who have opted out in order to prevent solicitation is spam.

Hiring a company to email to a list of people that did not specifically request to receive your Contact Information beforehand is considered spam.

Advertising on Free For All (FFA) sites is not permitted for promoting or using any LAZARO GROUP products or services. Any complaints generated from advertising with FFA programs will be treated as spam.

All emails regarding LAZARO GROUP must have an opt out feature. LAZARO GROUP's products contain this feature including physical address, which is required by the current spam law, but this opt out feature must also be on marketing emails, including physical address, and if a recipient opts out, they must be removed immediately.

Emailing through double opt-in list providers is NOT considered spam. Double opt-in means that not only did the potential recipients request to be emailed, they verified it by approving the request a second time. Furthermore, if you use a double opt-in list, you must also obtain from the provider the IP address of the requester, the date and time they requested the first and second opt in, and the specific website address or email from which the opt in was generated.

If you use a double opt-in provider, the following rules must be followed:

1. The email addresses obtained by the third party must be strictly opt-in and follow all LAZARO GROUP policies regarding opt-in email list collection.
2. The third party assembling the email list must make a clear disclosure stating that recipients' emailaddresses are provided to others.
3. The third party must be able to provide documentation regarding the validity of the addresses in case of an unsolicited email complaint.
4. Any messages sent to addresses obtained from a third party must contain an opt-out link and also a physical address, per the current spam law.
5. The content of messages sent to addresses from a third party list must be consistent with the disclosure made to the recipients upon initial provision of the email address.
6. You are fully responsible for any third party's adherence to LAZARO GROUP policies for lists that you obtain and use with our products and services or marketing. Any violation of LAZARO GROUP policies by third parties will be perceived as violations by you, and you will be subject to your account being suspended, termination, and penalty fees assessed accordingly.

The Policy

1. LAZARO GROUP's Associates and customers are prohibited from sending spam. LAZARO GROUP does not allow their products and services to be used for sending spam or marketed through spam. Email senders are required to maintain records that verify, on a case-by-case basis, that explicit affirmative permission was obtained from recipients before mailing. Records should include the date of opt in, full names, and any other data, such as phone numbers and addresses that will further validate the request for emailing is legitimate. Lack of such records can be considered, at LAZARO GROUP's sole discretion, proof that permission was not obtained.
2. LAZARO GROUP's Associates and customers are responsible for ensuring that they abide by this policy. LAZARO GROUP's Associates and customers will be held responsible for all traffic sent via their LAZARO GROUP products or services. Associates and customers are also responsible for ensuring that they do not advertise or promote LAZARO GROUP through spam.
3. LAZARO GROUP may charge a monetary fine of $10,000 or more per valid spam complaint of which LAZARO GROUP is notified. The account may also be terminated and the Associate or customer may lose access to all products and services without refund.
4. If LAZARO GROUP receives a complaint, it will be forwarded to the Associate or customer for a response and complete resolution. If within twenty-four (24) hours, there is no response indicating complete resolution, LAZARO GROUP may suspend the product or service until LAZARO GROUP is convinced that the problem is resolved and preventative measures have been implemented to prevent the violation from recurring. If LAZARO GROUP receives repeated complaints indicating that a problem has not been resolved, LAZARO GROUP may terminate the product or service, in its sole discretion, to the Associate or customer involved in the spam complaint.
5. LAZARO GROUP products and services may be used only for lawful purposes. Associates and customers may not use LAZARO GROUP products and services to transmit, distribute or store material (a) in violation of any applicable law, (b) in a manner that will infringe upon the copyright, trademark, trade secret or other intellectual property rights of others or the privacy, publicity or other personal rights of others, or (c) that is obscene, discriminatory, threatening, abusive, hateful or controversial.
6. LAZARO GROUP performs random audits by sending emails to recipients in various lists at random times. If an audit reveals recipients with no prior knowledge of opting in, LAZARO GROUP will suspend the user's account until the issue is resolved and, if it is determined that the user has violated LAZARO GROUP's spam policy, then the user will be subject to account termination without refund.
7. When a user learns of invalid email addresses on their lists, the email addresses must be removed immediately from the lists. ISPs monitor emails to invalid email addresses and will suspect spam if numerous emails are sent to invalid email addresses.

What does this mean?

1. You must provide us with current Contact Information for us to notify you regarding compliance with these provisions.
2. You must educate your Associates and customers about spam to ensure compliance with these provisions.
3. You must promptly investigate and satisfactorily deal with any spam complaints forwarded to you.
4. When using a mailing list, you must confirm that the recipients on the mailing lists have requested or otherwise affirmatively accepted receipt of any materials to be sent by you.

Tips on handling mailing lists

1. Only add people to your contact manager,newsletter, or autoresponder lists who have specifically requested to be added.
2. Include a removal link in all emails and your physical address, which is now required by the current spam law.
3. Promptly delete people from any and all email lists when asked.
4. Do not buy lists from email spam ads you receive from services that do not have a real working return email address in the sender's field.
5. Before purchasing a list, make sure you can call the list provider and talk to a real person. Do NOT buy lists from providers who cannot adhere to LAZARO GROUP's policies.