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Anti-Spam Policy

Anti-Spam Policy

Our anti-spam and communications policy.

Anti-Spam & Communications Policy

Effective Date: December 17, 2025
Last Updated: December 17, 2025

1. Introduction

This Anti-Spam & Communications Policy ("Policy") governs how Gestlat ThinkLab ("we," "us," or "Company") communicates with customers, users, and subscribers, and defines our commitment to responsible email practices and compliance with anti-spam regulations.

This Policy covers:

  • Email communications from Gestlat ThinkLab
  • SMS/text message communications
  • Push notifications and in-app messages
  • Phone calls and voicemail
  • WhatsApp and other messaging platforms
  • Newsletter and marketing communications

Our Commitment: We are committed to respecting your inbox and communication preferences. We comply with anti-spam laws in Uganda, East Africa, and internationally, including:

  • Uganda Communications Act
  • Kenya Information and Communications Act
  • CAN-SPAM Act (USA)
  • GDPR (EU)
  • CASL (Canada)

2. Types of Communications

2.1 Transactional Communications (Non-Marketing)

These communications are necessary for service delivery and cannot be opted out of (except by closing your account):

Account and Service Management

  • Account Creation: Welcome emails, account setup instructions
  • Password Resets: Security-related communications
  • Account Changes: Confirmation of profile updates, security alerts
  • Subscription Changes: Confirmations of plan changes, renewals, cancellations

Billing and Payment

  • Invoices and Receipts: Payment confirmations, billing statements
  • Payment Issues: Failed payment notifications, payment reminders
  • Subscription Renewals: Upcoming renewal notices, auto-renewal confirmations
  • Refunds: Refund processing notifications

Product and Service Delivery

  • Order Confirmations: Hardware purchases, software licenses
  • Shipping Updates: Delivery status, tracking information
  • License Delivery: Software activation keys, download links
  • Access Credentials: Login information, temporary passwords

Support and Technical

  • Support Tickets: Ticket updates, resolution notifications
  • System Notifications: Service outages, maintenance windows, security alerts
  • Product Updates: Critical security patches, mandatory updates
  • Data Exports: Requested data download links

Legal and Compliance

  • Policy Updates: Changes to Terms of Service, Privacy Policy, etc.
  • Legal Notices: Compliance requirements, regulatory communications
  • Security Alerts: Data breach notifications, security incidents

Frequency: As needed based on account activity
Opt-Out: Not available (essential for service)

2.2 Marketing Communications (Promotional)

These communications promote our products and services and can be opted out of at any time:

Promotional Emails

  • Product Announcements: New product launches, feature releases
  • Special Offers: Discounts, promotions, seasonal sales
  • Newsletters: Company updates, industry insights, blog posts
  • Event Invitations: Webinars, workshops, conferences
  • Product Recommendations: Personalized suggestions based on your usage

Educational Content

  • Tips and Tutorials: How-to guides, best practices
  • Case Studies: Customer success stories
  • Webinars and Training: Educational opportunities
  • Industry Reports: Market research, whitepapers

Surveys and Feedback

  • Customer Satisfaction Surveys: Product feedback, NPS surveys
  • Product Research: Feature requests, user experience research
  • Beta Testing Invitations: New feature preview opportunities

Frequency:

  • Newsletters: 2-4 times per month
  • Promotional Emails: 1-2 times per week (maximum)
  • Surveys: Quarterly or as needed

Opt-Out: Available at any time (see Section 6)

2.3 Service and Engagement Communications

These are optional communications that enhance your experience:

Product Usage

  • Usage Tips: Feature highlights, productivity tips
  • Milestone Celebrations: Account anniversaries, usage milestones
  • Onboarding Guidance: Getting started tips, setup assistance
  • Inactivity Reminders: Re-engagement emails for inactive users

Community and Social

  • User Community Invitations: Forum participation, user groups
  • Social Media Updates: Important announcements via social channels
  • Partner Communications: Co-marketing messages from partners (with permission)

Frequency: 1-2 times per month
Opt-Out: Available in preferences

3. Consent and Permission

3.1 How We Obtain Consent

Explicit Consent (Opt-In)

We obtain your explicit consent when you:

  • ✅ Check a box during account registration (unchecked by default)
  • ✅ Subscribe to our newsletter via website form
  • ✅ Request information or download resources
  • ✅ Register for events or webinars
  • ✅ Participate in promotions or contests
  • ✅ Update communication preferences to opt-in

Implied Consent (Soft Opt-In)

We may send marketing communications based on implied consent when:

  • ✅ You purchased or trialed our products/services
  • ✅ You inquired about our services within last 6 months
  • ✅ You have existing business relationship with us

Requirements for Implied Consent:

  • Must be relevant to products/services you've shown interest in
  • Must provide easy opt-out in every message
  • Ceases if you opt-out or show no engagement

3.2 What Constitutes Consent

Valid consent requires:

  • Freely Given: No coercion or bundling with services
  • Specific: Clear what you're consenting to
  • Informed: Know what communications you'll receive
  • Unambiguous: Clear affirmative action required

NOT Valid Consent:

  • Pre-checked boxes
  • Inactivity or silence
  • Purchased email lists
  • Third-party provided lists (without verification)

3.3 Consent Management

We record:

  • When consent was given
  • How consent was obtained
  • What you consented to
  • IP address and timestamp (for verification)

You can:

  • Review your consent at any time
  • Modify communication preferences
  • Withdraw consent instantly

4. Email Best Practices

4.1 Identification and Transparency

All our emails include:

  • ✅ Clear "From" Name: "Gestlat ThinkLab" or specific product name
  • ✅ Valid "From" Address: @gestlatthinklab.com domain
  • ✅ Accurate Subject Lines: No deceptive or misleading subjects
  • ✅ Physical Address: Our business address in Uganda
  • ✅ Clear Identification: Who we are and why we're emailing

We NEVER:

  • ❌ Use misleading subject lines
  • ❌ Hide or disguise our identity
  • ❌ Use deceptive headers or routing information
  • ❌ Imply false affiliations

4.2 Content Standards

Our emails:

  • ✅ Are relevant to your interests or account activity
  • ✅ Provide value (information, offers, updates)
  • ✅ Are professional and respectful in tone
  • ✅ Have clear calls-to-action
  • ✅ Are mobile-responsive and accessible

We avoid:

  • ❌ Excessive frequency (email fatigue)
  • ❌ Irrelevant content
  • ❌ Aggressive or pushy language
  • ❌ ALL CAPS or excessive punctuation!!!
  • ❌ Misleading or false claims

4.3 Deliverability and Technical Standards

We implement:

  • SPF (Sender Policy Framework): Validates sending servers
  • DKIM (DomainKeys Identified Mail): Email authentication
  • DMARC (Domain-based Message Authentication): Email security
  • List Hygiene: Regular removal of bounced/invalid addresses
  • Engagement Tracking: Monitor and respect engagement levels
  • Complaint Monitoring: Track and respond to spam complaints

5. Communication Frequency

5.1 Expected Frequency by Type

Communication Type Typical Frequency Maximum Frequency
Transactional As needed Unlimited (necessary)
Marketing Newsletters 2-4 per month 1 per week
Promotional Offers 1-2 per month 2 per week
Product Updates 1-2 per month 1 per week
Educational Content 2-4 per month 2 per week
Surveys Quarterly 1 per month
Re-engagement As needed 1 per quarter

Overall Marketing Limit: Maximum 2-3 marketing emails per week during peak periods (promotions, launches).

5.2 Frequency Management

We manage frequency by:

  • Preference Center: Granular control over email types
  • Engagement Monitoring: Reduce frequency for inactive users
  • Smart Sending: Avoid multiple emails on same day
  • Suppression Lists: Honor do-not-contact requests immediately

5.3 Reducing Email Volume

If receiving too many emails:

  1. Update Preferences: Choose specific email types
  2. Digest Options: Receive weekly digest instead of individual emails
  3. Pause Communications: Temporarily stop marketing emails (3-6 months)
  4. Unsubscribe: Completely opt-out of marketing

6. Opt-Out and Unsubscribe

6.1 Easy Unsubscribe Mechanism

Every marketing email includes:

  • Unsubscribe Link: One-click unsubscribe in footer
  • Preference Center Link: Manage specific email types
  • Clear Instructions: How to opt-out

Location: Bottom of every marketing email

Process:

  1. Click "Unsubscribe" link
  2. Confirm on unsubscribe page (or instant one-click)
  3. Receive confirmation email
  4. Removal processed immediately (up to 48 hours)

6.2 Unsubscribe Timeframe

Processing Time:

  • Immediate: Most unsubscribes processed instantly
  • Maximum: 48 hours (2 business days)
  • Already Scheduled: Emails scheduled before unsubscribe may still send

6.3 Alternative Opt-Out Methods

You can also unsubscribe via:

  • Email: [email protected] with "Unsubscribe" in subject
  • Account Settings: Update preferences in your account portal
  • Reply: Reply to any marketing email with "UNSUBSCRIBE"
  • Phone: Call support and request removal
  • Written Request: Mail to our physical address

6.4 Partial Opt-Out (Preferences)

Instead of complete unsubscribe, you can:

  • Opt-out of specific email types (newsletters only, promotions only)
  • Reduce frequency (weekly digest instead of daily)
  • Choose topics of interest
  • Pause temporarily

Access Preference Center: Link in every email or via account settings

6.5 What Happens After Unsubscribe

You will NO LONGER receive:

  • ❌ Marketing emails
  • ❌ Newsletters
  • ❌ Promotional offers
  • ❌ Product announcements
  • ❌ Event invitations

You WILL STILL receive:

  • ✅ Transactional emails (invoices, receipts)
  • ✅ Service notifications (outages, security)
  • ✅ Support communications (ticket updates)
  • ✅ Legal notices (policy changes)
  • ✅ Account security alerts

Re-Subscription:

  • You can re-subscribe anytime via website or email preferences
  • Requires new opt-in action

7. SMS/Text Messaging

7.1 SMS Communications We Send

Transactional SMS

  • Account verification codes (2FA, OTP)
  • Password reset codes
  • Critical security alerts
  • Payment confirmations
  • Delivery notifications (hardware orders)

Marketing SMS (Opt-In Required)

  • Special promotions and offers
  • Event reminders
  • Product launch alerts
  • Flash sales

7.2 SMS Consent

Explicit Opt-In Required:

  • Cannot send marketing SMS without your express consent
  • Consent obtained via website form, SMS keyword, or account settings
  • Must provide clear terms at opt-in (frequency, message rates)

Standard Terms:

  • Message frequency varies by campaign
  • Message and data rates may apply
  • Carriers not liable for delayed or undelivered messages

7.3 SMS Opt-Out

To Stop SMS:

  • Reply STOP, UNSUBSCRIBE, or QUIT to any marketing SMS
  • Processed immediately
  • Receive confirmation SMS

Help:

  • Reply HELP for assistance
  • Receive information on how to contact support

7.4 SMS Best Practices

We:

  • ✅ Send during reasonable hours (8 AM - 8 PM recipient's timezone)
  • ✅ Limit frequency (max 4 marketing SMS per month)
  • ✅ Keep messages concise and valuable
  • ✅ Include sender identification
  • ✅ Provide opt-out in every message

8. Push Notifications and In-App Messages

8.1 Mobile and Web Push Notifications

Types:

  • Transactional: Order updates, sync status, security alerts
  • Engagement: Usage tips, new features, reminders
  • Marketing: Special offers, product announcements (opt-in)

Permission:

  • Requested at app install or first use
  • Can be managed in device settings
  • Can be customized in app settings

8.2 In-App Messages

Types:

  • Onboarding: Getting started tips, feature tours
  • Contextual Help: Tips based on current activity
  • Announcements: New features, updates
  • Feedback: Surveys, ratings prompts

Management:

  • Can be dismissed
  • Frequency controlled to avoid annoyance
  • Relevant to your usage

8.3 Controlling Push Notifications

Device Level:

  • iOS: Settings → Notifications → Gestlat App
  • Android: Settings → Apps → Gestlat App → Notifications

App Level:

  • In-app Settings → Notifications
  • Choose notification types
  • Set quiet hours

9. Phone and WhatsApp Communications

9.1 Phone Calls

When We Call:

  • You requested a consultation or callback
  • Follow-up on support tickets (with permission)
  • Account verification (suspected fraud)
  • Enterprise customer check-ins (account managers)

We Do NOT:

  • Make unsolicited cold calls for sales
  • Call outside business hours (8 AM - 8 PM EAT)
  • Call repeatedly if you don't answer
  • Use automated robocalls (except appointment reminders with consent)

Your Opt-Out:

  • Request no-call status in account preferences
  • Tell representative during call
  • Email: [email protected]

9.2 WhatsApp and Messaging Apps

Uses:

  • Customer support (if you initiate)
  • Order and delivery updates (with consent)
  • Appointment reminders (with consent)
  • Event confirmations (with consent)

Consent Required:

  • We ask permission before sending WhatsApp messages
  • Opt-in via website, account settings, or reply to initial message
  • Opt-out: Reply "STOP" or update preferences

10. Third-Party Communications

10.1 Partner Marketing

When We Share Your Information:

  • NEVER without your explicit consent
  • Only with trusted partners offering relevant services
  • Always provide opt-out option

When Partners May Contact You:

  • You attended co-hosted webinar or event
  • You opted-in to partner offers
  • You purchased partner-integrated product

Your Control:

  • Separate consent for each partner
  • Opt-out affects only that partner
  • Does not affect Gestlat communications

10.2 Third-Party Services We Use

Email Service Providers:

  • We use reputable email platforms for delivery
  • They process data under strict agreements
  • They do not use your data for their purposes

Analytics and Tracking:

  • Email open and click tracking (anonymized where possible)
  • Can opt-out via email preferences
  • Used to improve content and relevance

11. Data and Privacy

11.1 Information We Collect

For Communications:

  • Email address, phone number (if provided)
  • Name and company information
  • Communication preferences
  • Engagement data (opens, clicks)
  • Device and browser information

Usage:

  • Deliver communications you've requested
  • Personalize content
  • Measure effectiveness
  • Improve services
  • Comply with legal requirements

See our Privacy Policy for full details.

11.2 Data Security

We protect your information with:

  • Encryption in transit and at rest
  • Access controls (need-to-know basis)
  • Regular security audits
  • Secure email transmission (TLS)
  • Data minimization practices

11.3 Data Retention

Contact Information:

  • Active subscribers: Retained indefinitely
  • Unsubscribed: Retained in suppression list (to honor opt-out)
  • Inactive (3 years): May be deleted

Engagement Data:

  • Retained for 2 years for analytics
  • Aggregated data retained longer

12. Compliance and Enforcement

12.1 Anti-Spam Laws We Comply With

Uganda:

  • Uganda Communications Act
  • Data Protection and Privacy Act, 2019

Regional:

  • Kenya Information and Communications Act
  • Tanzania Electronic and Postal Communications Act
  • EAC data protection frameworks

International:

  • CAN-SPAM Act (USA)
  • GDPR (European Union)
  • CASL (Canada)
  • PECR (UK)

12.2 Consequences of Non-Compliance

If we violate anti-spam laws:

  • Regulatory fines and penalties
  • Legal action from affected parties
  • Damage to reputation and trust
  • Service provider blacklisting

We take compliance seriously.

12.3 Using Our Services for Spam

Prohibited: You may NOT use our Services to:

  • ❌ Send unsolicited bulk email (spam)
  • ❌ Harvest email addresses
  • ❌ Purchase or rent email lists
  • ❌ Violate anti-spam laws
  • ❌ Send emails without proper consent

Consequences:

  • Immediate account suspension
  • Account termination
  • Reporting to authorities
  • Legal action

See our Acceptable Use Policy for details.

13. Best Practices for Users

13.1 Using Our Email Features Responsibly

If you use our software to send emails (e.g., from POS, school systems):

Do:

  • ✅ Obtain proper consent from recipients
  • ✅ Provide clear opt-out mechanism
  • ✅ Honor unsubscribe requests promptly
  • ✅ Send relevant, valuable content
  • ✅ Comply with applicable laws

Don't:

  • ❌ Send unsolicited bulk emails
  • ❌ Use purchased email lists
  • ❌ Make false or misleading claims
  • ❌ Hide your identity
  • ❌ Ignore unsubscribe requests

13.2 Managing Your Own Mailing Lists

Best Practices:

  • Build organic lists (earned permission)
  • Use double opt-in when possible
  • Regularly clean lists (remove bounces, inactive)
  • Segment lists for relevance
  • Monitor engagement and adjust
  • Test emails before sending

14. Reporting and Complaints

14.1 Report Spam or Abuse

If you receive spam from Gestlat ThinkLab:

  1. Verify: Ensure it's actually from us (@gestlatthinklab.com domain)
  2. Report: [email protected] with email headers
  3. Unsubscribe: Use unsubscribe link if legitimate but unwanted

If you receive spam from our customer:

  1. Contact them directly to unsubscribe
  2. Report to: [email protected] (we'll investigate)

14.2 Our Response to Reports

We will:

  • Investigate within 48 hours
  • Take corrective action if confirmed
  • Notify you of outcome
  • Update systems to prevent recurrence

If Our Customer Violates:

  • Warning and required corrective action
  • Service suspension for repeat violations
  • Account termination for serious violations

14.3 Filing a Complaint with Authorities

If unsatisfied with our response:

  • Uganda: Uganda Communications Commission (UCC)
  • Regional Authorities: Respective national regulators
  • International: Relevant authority in your jurisdiction

15. Modifications to This Policy

15.1 Updates and Changes

We may update this Policy to:

  • Reflect new communication channels
  • Comply with legal changes
  • Improve clarity
  • Add new services

15.2 Notice of Changes

Material Changes:

  • 30 days advance notice via email
  • Posted on website with updated date
  • Prominent notice in communications

Non-Material Changes:

  • Posted on website
  • Effective upon posting

15.3 Your Options

If you disagree with changes:

  • Update communication preferences
  • Unsubscribe from marketing
  • Close account (if changes fundamentally alter agreement)

16. Contact Us

16.1 Communications Team

General Inquiries:

Unsubscribe Requests:

Preference Management:

Spam Reports:

Opt-Out Requests (All Channels):

16.2 Mailing Address

Gestlat ThinkLab
Kampala
Kampala, Uganda

17. Summary of Your Rights

You Have the Right To:

  • ✅ Know what communications you'll receive before opting in
  • ✅ Opt-out of marketing communications at any time
  • ✅ Update your communication preferences
  • ✅ Choose which types of emails you receive
  • ✅ Expect reasonable communication frequency
  • ✅ Receive only relevant, valuable content
  • ✅ Have your opt-out honored within 48 hours
  • ✅ Not receive deceptive or misleading communications
  • ✅ Access and correct your contact information
  • ✅ File complaints with regulatory authorities

We Commit To:

  • ✅ Respecting your communication preferences
  • ✅ Making opt-out easy and effective
  • ✅ Sending only relevant, valuable content
  • ✅ Being transparent about who we are
  • ✅ Complying with all anti-spam regulations
  • ✅ Protecting your personal information
  • ✅ Responding promptly to your requests

18. Acknowledgment

By providing your contact information to Gestlat ThinkLab, you acknowledge that:

  1. You have read and understood this Policy
  2. You consent to receive communications as described
  3. You understand how to opt-out or manage preferences
  4. You agree to our data practices as outlined

Last Updated: December 17, 2025
Effective Date: December 17, 2025
Version: 1.0

Quick Links:

This Anti-Spam & Communications Policy is available in English, French (Français), and Arabic (العربية). The English version is authoritative in case of discrepancies.

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