Finanztreuhand Karriere
Anti-Spam Policy
1. Purpose and scope
This policy sets out the requirements for B2B email marketing projects agreed with Positive Group Deutschland GmbH through finanztreuhand-karriere.de. It supplements the individual engagement and the terms and conditions. This presentation website itself has no sending function.
2. Permission to contact recipients
Electronic advertising is generally planned only where the recipient has given prior express consent. This also applies to business recipients. A publicly displayed email address, a relevant industry, a business card or assumed interest does not replace that consent.
The existing-customer exception can be considered only when all conditions of section 7(3) of the German Act Against Unfair Competition are satisfied together: the address was obtained in connection with the sale of goods or services; the advertising concerns the sender’s own similar goods or services; the customer has not objected; and a clear opportunity to object is given when the address is collected and every time it is used, without charges beyond standard transmission costs.
The data protection basis and required information must also be considered. A legitimate interest alone does not replace consent required for email advertising under competition law.
3. Evidence and origin
The origin of recipient data and the permission to contact recipients must be documented in a traceable way. In particular, records should show the consent wording used at collection, the time, source and scope of consent, and any confirmation.
For online signups, an appropriately documented double opt-in process is intended. Double opt-in does not retrospectively justify the use of data previously collected without a valid basis.
4. Unacceptable practices
Purchased, rented or automatically harvested address lists are not accepted as a substitute for documented contact permission. Lists must not be used to bypass an objection or unsubscribe request.
Misleading sender details or subject lines, concealing the commercial purpose, and unlawful content or content that infringes third-party rights are prohibited.
5. Sender identity and unsubscribing
Every advertising email must identify the responsible sender, include required provider information and offer an easy way to unsubscribe. Unsubscribing must not depend on having an account, signing in or providing a reason.
Unsubscribes, withdrawals of consent and objections must be acted on promptly. Any necessary suppression list is used solely to prevent renewed unlawful contact; its content and retention must be limited to what is needed.
6. Approval and technical implementation
Before an agreed send, the recipient permission, content, sender identity, unsubscribe process and technical responsibilities are settled. Required data protection and processing agreements must be concluded.
Sending may begin only after the agreed approval. Deliverability and technical authentication do not replace consent or legal review. No particular delivery, open or conversion rates are guaranteed.
7. Complaints and project measures
If a complaint or justified suspicion of a breach arises, the affected activity is put on hold pending clarification. Origin and consent records may be requested, and disputed contacts may be suppressed. Statutory and contractual rights remain unaffected.
Where possible, a complaint should identify the domain, sender, time of sending and relevant message content. Please avoid providing unnecessary third-party data.
Contact for complaints and objections
Please use the address below. A subject such as “Unsubscribe”, “Objection” or “Spam complaint” will help route your request.