ANTI-SPAM POLICY OF TECHCUBE SOLUÇÕES EM TECNOLOGIA LTDA
This translation is provided for convenience only. The official, legally binding version of this document is the Portuguese (pt-BR) version, which prevails in case of any discrepancy.
Read the official version in Portuguese1. PURPOSE AND SCOPE
This Anti-Spam Policy aims to establish the guidelines, rules, and responsibilities applicable to the use of the Mailerweb platform, particularly regarding mass electronic messaging, with the purpose of:
(i) preventing spam and abusive communications;
(ii) ensuring Mailerweb's compliance with applicable legislation, including the Brazilian Internet Civil Framework (Law 12.965/2014) and General Data Protection Law (LGPD - Law 13.709/2018);
(iii) safeguarding Mailerweb's technical, legal, and reputational integrity before authorities, business partners, digital platforms, and application providers; and
(iv) establishing clear accountability parameters for clients regarding the origin, legality, and use of databases submitted to the platform.
This Policy applies to all clients, users, partners, and third parties who directly or indirectly use the dispatch services provided by Mailerweb.
2. LEGAL AND REGULATORY COMPLIANCE
Mailerweb develops its activities in strict observance of applicable legislation and industry standards:
i. Brazilian Internet Civil Framework (Law 12.965/2014), regarding freedom of communication, privacy protection, and network functionality;
ii. General Data Protection Law (LGPD - Law 13.709/2018), observing the principles of purpose, adequacy, necessity, transparency, security, and accountability;
iii. Standards and recommendations of the Brazilian Internet Steering Committee (CGI.br) and Self-Regulation Code for Email Marketing (CAPEM);
iv. Recognized technical best practices against spam and digital abuse.
Mailerweb maintains specialized legal counsel to act preventively and handle compliance breaches, ensuring effective and serious Anti-Spam operations.
3. INSTITUTIONAL STANCE ON SPAM
Mailerweb does not practice, encourage, or tolerate unsolicited electronic messages (spam). The platform acts as a technology dispatch infrastructure provider, and is not the owner, controller, or manager of databases or message content used by its clients.
4. DATABASE AND CONTENT LIABILITY
Clients using Mailerweb expressly warrant and declare that:
(i) personal data entered into the platform was collected in a lawful, transparent, and legitimate manner in compliance with LGPD;
(ii) they hold a valid legal basis for processing and sending communications, including consent when applicable;
(iii) they provide recipients with clear and functional opt-out mechanisms; and
(iv) they maintain documentation verifying the origin and legality of databases whenever requested.
Mailerweb does not perform prior individualized validation of client databases, providing only the technological infrastructure.
5. LIMITATION OF LIABILITY FOR DELIVERY
Mailerweb's liability is strictly limited to technical dispatch, not guaranteeing final delivery to the inbox, which depends on external factors including:
i. database reputation submitted by the client;
ii. sender reputation and history of complaints;
iii. filtering, moderation, and Anti-Spam policies of third-party receiving providers;
iv. recipient interaction behavior regarding past messages.
6. SPECIFICALLY REGARDING META PLATFORMS
For messages sent via channels or integrations linked to Meta platforms (Facebook, Instagram, WhatsApp):
(i) Meta maintains its own independent privacy, Anti-Spam, integrity, and acceptable use policies;
(ii) message delivery, rate limits, blocks, and suspensions are subject exclusively to Meta's algorithms and rules;
(iii) any sanctions or account restrictions imposed by Meta stem from client database quality, message content, and platform behavior.
Consequently, Mailerweb bears no liability for delivery failures or account bans applied by Meta related to client data or breaches of Meta policies.
7. PREVENTION AND CONTROL MECHANISMS
To mitigate risks and prevent abuse, Mailerweb implements:
i. mandatory unsubscribe / opt-out mechanisms in all dispatches;
ii. technical volume, anomaly, and complaint monitoring;
iii. audit logging for regulatory compliance;
iv. dedicated abuse reporting channel: https://www.mailerweb.com.br/reportar-abuso
8. ENFORCEMENT MEASURES
Evidence of spam or breach of this Policy may result, at Mailerweb's sole discretion, in:
(i) formal warning to client;
(ii) temporary dispatch suspension;
(iii) permanent account block;
(iv) contract termination with cause;
(v) notification to competent authorities when applicable.
9. FINAL PROVISIONS
This Policy is part of Mailerweb's compliance governance and may be updated at any time. Use of the platform constitutes full and unrestricted acceptance of this Anti-Spam Policy.
Final Considerations
This Anti-Spam Policy may be updated periodically to reflect legal, regulatory, or technical changes.
Last updated: January 26, 2026.