SMS and Email Marketing Policy

This Policy applies to PlayerReach.io and all associated brands, websites, services and business units operated by Numima FZC LLC (Formation Number 4429474.01). It establishes standards governing email marketing, SMS marketing, customer acquisition activities and related communications.

The purpose of this Policy is to promote responsible marketing practices, support compliance obligations, protect business relationships and provide operational guidance for personnel, contractors, suppliers and commercial partners.

This Policy applies to all marketing campaigns conducted by Numima FZC LLC, whether undertaken directly, through technology providers, affiliate partners, data providers, media buyers, technical delivery arrangements or third-party service providers.

Marketing activities may include email campaigns, SMS campaigns, newsletters, promotional communications, lead generation activities, customer acquisition campaigns, affiliate marketing, audience development and related communications.

The Company may utilise first-party data, licensed data, partner data, customer data and other lawful data sources. Prior to use, data sources should be reviewed to confirm ownership, authority and lawful use rights.

Where data is supplied by a third party, the Company shall seek to obtain appropriate contractual documentation including Data Ownership Declarations, Data Usage Agreements and other supporting evidence reasonably required to assess legitimacy and compliance.

The Company expects appropriate permissions, consents or lawful bases to exist for intended marketing activities. Where required by applicable law, evidence of consent should be capable of being demonstrated by the originating data owner.

SMS campaigns should clearly identify the sender, contain appropriate unsubscribe instructions where required, avoid misleading content and comply with applicable laws, carrier requirements and platform rules.

Marketing emails should identify the sender, contain appropriate unsubscribe functionality, provide accurate information and avoid deceptive subject lines, misleading content or prohibited practices.

The Company may maintain suppression lists to prevent communications being sent to recipients who have opted out, unsubscribed, objected to processing or otherwise requested that communications cease.

Complaints relating to marketing activities shall be reviewed promptly and investigated where appropriate. Corrective measures may be implemented to address recurring issues or identified compliance concerns.

The Company may conduct reasonable due diligence on data suppliers, marketing partners, affiliate partners, service providers and other counterparties involved in marketing activities.

Records relating to campaigns, consent evidence, complaints, opt-outs, data sources, commercial relationships and compliance reviews may be maintained for operational, legal and audit purposes.

Where affiliate marketing activities are undertaken, the Company expects relationships with operators, networks, merchants or commercial partners to be governed by appropriate agreements and programme terms.

Where the Company acts as a technical delivery partner, responsibility for ownership, consent and commercial authority may remain with the client or originating data owner, subject to contractual arrangements.

Marketing activities, data sources and commercial relationships may be reviewed periodically to assess compliance, performance, operational effectiveness and risk exposure.

Appropriate technical and organisational measures should be implemented to protect marketing data from unauthorised access, misuse, disclosure, alteration or loss.

Personnel involved in marketing activities should be familiar with applicable policies, operational standards and compliance expectations relevant to their responsibilities.

Actual or suspected breaches of this Policy may result in investigation, corrective action, suspension of activities or termination of relationships where appropriate.

This Policy may apply to future websites, affiliate brands, comparison services, media properties, customer acquisition platforms and other business units operated by Numima FZC LLC.

This Policy may be updated periodically to reflect changes in law, technology, industry standards, commercial activities and operational requirements.