Introduction

At MasterBase® we are absolutely against spam, understood as the massive sending of unsolicited, irrelevant or abusive electronic messages.

This definition includes not only communications sent without the recipient's consent, but also those that, even though initially accepted, are excessive, inappropriate, or irrelevant to the user.

In that sense, even a voluntary registration can result in spam if the messages sent do not respect the recipient's reasonable expectation.

MasterBase® is governed by the principles of permission marketing, transparency of the sender and unrestricted respect for the will of the recipient, complying with the applicable regulations on data protection and electronic communications, including the General Data Protection Regulation (GDPR) of the European Union and local laws in each country where it operates.

This statement applies to email and other equivalent electronic messaging channels. GDPR. When messages are sent through our platform, the CLIENT acts as the data controller (as defined by the GDPR), and MasterBase® acts as the data processor (as defined by the GDPR). Where permitted by law, such as in the European Union and the United Kingdom, exceptions based on a prior relationship or “soft opt-in” apply, while the right to object is always maintained in every message.

This statement distinguishes two scenarios:

• MasterBase® as a service platform provider.
• MasterBase® as the sender of its own commercial communications

Roles and Application Scenarios

MasterBase® as Platform Service Provider

When MasterBase® acts as a technology provider for messaging services:

• Data Responsibility: The CLIENT is the data controller (as defined by the GDPR), and MasterBase® acts as the data processor (as defined by the GDPR), in accordance with a Data Processing Agreement.
• Use of databases: MasterBase® does not use, sell, or manage CLIENT databases, nor does it use them for its own purposes; it processes data solely in accordance with the CLIENT’s documented instructions and applicable regulations.
• Minimum Obligations of the CLIENT: The customer agrees to use the platform in a lawful and responsible manner, complying with at least the following:
  • To have a valid and demonstrable legal basis for each shipment.
  • Do not use purchased or leased lists or addresses obtained by automated data extraction (scraping).
  • Clearly identify the sender and include contact information and physical address when required.
  • Use truthful and not misleading matters.
  • Include a visible, free, and functional unsubscribe mechanism that will be honored within a maximum of 48 business hours, without exceeding the maximum legal time limits.
  • Respect and maintain suppression lists.
  • Refrain from phishing, phishing, malware or illicit content.
  • Comply with MasterBase® technical limits and acceptable use policies.
  • Cooperate with abuse investigations and requests from competent authorities.
• Monitoring and Measures: If spam practices are detected, MasterBase® reserves the right to suspend or terminate the service, in accordance with applicable law and the terms of the agreement entered into with the CLIENT, and may cooperate with the relevant authorities when appropriate.

MasterBase® as a Proprietary Communications Sender

When MasterBase® sends its own marketing messages, corporate information, or contractual communications (for example, newsletters, event invitations, promotions, service alerts):

• MasterBase® is directly responsible for the processing of personal data.
• All communications must be based on a valid legal basis, such as prior consent, a contractual relationship, or a legitimate interest in accordance with applicable law.
• The contact information used is based on explicit and documented opt-in consent, obtained through forms, platform registrations, or verifiable business interactions.
• All messages sent by MasterBase® include clear mechanisms for revoking consent or exercising the right to object.
• Requests for cancellation are processed within a maximum period of 48 business hours, without exceeding the maximum applicable legal deadlines.
• MasterBase® retains technical evidence and traceability records of these processes for compliance, audit and continuous improvement purposes only.

Consent, Opposition and Suppression Lists

MASTERBASE® provides and requires clear, visible, accessible, and free mechanisms so that recipients can revoke their consent or opt out of receiving communications, including:

• Visible and functional unsubscription link present in all shipments.
• E-mail address enabled to request cancellation or exercise the right of opposition.
• Processing of requests without requiring additional authentication or generating any cost for the recipient.

Requests for cancellation or revocation will be processed within 48 business hours, and in no case will it exceed the maximum time limits established by applicable law.

MasterBase® maintains traceability mechanisms for these processes for regulatory compliance, internal audit and continuous service improvement purposes.

Contact Channels

To report unsolicited messages or to make inquiries regarding this statement, MasterBase® provides the following channel:

Report spam (https://masterbase.com/es/mb/reporte-abuso/).

Relationship to Privacy Statement

This Anti Spam Statement is supplemented by the MasterBase® Privacy Statement, which governs in detail the collection, use, storage and protection of personal data.

Both documents should be interpreted jointly and coherently, being the Privacy Statement the instrument that regulates the processing of personal data, while this policy establishes the conditions applicable to the responsible sending of electronic communications.

Declaration Update

MasterBase® may update this statement when regulatory, policy, technological or operational changes occur.

Updated versions will be published, indicating the effective date and version number.

MasterBase® Commitment

MasterBase® maintains an ongoing commitment to permission marketing and promotes responsible practices through:

• Mandatory acceptance of Terms and Conditions that expressly prohibit spamming.
• Clear and verifiable identification of the sender.
• Mandatory inclusion of Unsubscription mechanisms.
• Transparency of the issuer and valid mailing address.
• Coordination with Internet Service Providers (ISPs) to prevent abuse.
• Adherence to ESPC's ”Email Marketing Pledge", including:
  • Do not send unsolicited mail (spam)
  • Visible, free and functional unsubscription.
  • Technical authentication (SPF, DKIM, DMARC recommendation).
  • Prohibition of purchased lists or scraping.

Good Practice Guide

The following section is for guidance only and does not replace legal or contractual obligations:

• Do not use databases obtained through purchase, lease, exchange or scraping, ensuring that all contacts have a valid legal basis for sending.
• Maintain updated and purged distribution lists, eliminating inactive contacts, invalid addresses and records that have requested unsubscription or do not maintain a valid relationship.
• Correctly identify the sender in each communication, including truthful and verifiable information about the issuing entity.
• Monitor mailing results (bounces, complaints and deliverability) to ensure that communications are relevant, authorized and well received by recipients.
• Periodically verify the correct functioning of unsubscription links.

MasterBase® is a company focused on permission-based marketing that provides technical control and monitoring tools designed to prevent configuration errors, maintain sender reputation, and avoid practices that could cause messages to be classified as spam.