Adelante data protection regulations (GDPR) policy


This Anti-Spam Policy applies to Adelante’s email marketing service Adelante Click – and any other service provided by Adelante to you.

Adelante Click is a permission-based e-mailing service operated by I H M Limited. By using the Adelante Click Service you are agreeing to our standard Terms and Conditions, our Privacy Policy and to this Anti-Spam Policy, which are available online to view at

Please note, Adelante Click is NOT a data controller and does not supply data for use on the Adelante Click service. You are the data controller and supply your own data for use on our system. It is your responsibility to ensure that all personal data that you use is processed in accordance with the relevant data protection law as amended from time to time.


Adelante prohibits the following:

  1. use of the Service in any manner associated with the transmission, distribution or delivery of any unsolicited commercial email or unsolicited bulk email (“Spam”) except where authorised by law. You may not use the Service to send any Spam;
  2. use of the Service to send out communications to anybody who has asked you not to contact them or who has not explicitly signed up to receive such communications by way of an opt-in;
  3. use of the Service to send out communications with an unrelated subject / content to that which the subscriber requested to be informed about;
  4. use of the Service for:
    1. the promotion or sale of email lists;
    2. the sale or advertising or illegal goods or services;
    3. pornography or other sexually explicit emails;
    4. the sale or advertising of pharmaceutical products;
    5. the promotion or offer of internet loans and pay day loans;
    6. Sending adverts for multiple companies to the same list;
    7. get rich quick’, pyramids, work at home schemes;
    8. gambling products and services; or
    9. online trading, day trading and other activities relating to the stock market.

As an Email Service Provider, our service is based around the deliverability of the emails that are sent through our servers. Any email sent through the Service must:

  1. not use or contain invalid, forged or misleading header information;
  2. not use or contain invalid or non-existent domain names;
  3. not use a third party’s internet domain name without permission of the third party;
  4. not misrepresent, hide or obscure in any other way any information identifying the origin or transmission path;
  5. not use or contain false or misleading information in the subject line;
  6. not use or contain any false or misleading content;
  7. provide recipients with an opt-out mechanism able to process opt-out requests;
  8. honour any opt-out request promptly and in any event within 10 working days from receiving the opt-out request;
  9. contain the sender’s full, verifiable, legitimate postal address
  10. if relevant, clearly identify that the commercial email is an advertisement and contain your valid physical postal address;
  11. if relevant, clearly identify the email as a promotional offer and ensure that any conditions which must be met to qualify for it are easily accessible, and presented clearly and unambiguously;
  12. if relevant, clearly identify the email as a promotional competition or game and ensure that any conditions for participation are easily accessible and presented clearly and unambiguously; and
  13. not otherwise violate the applicable terms of the Privacy Policy and our Terms and Conditions (as varied from time to time).

Adelante customers are only allowed to send emails to people who have given prior permission to receive promotional material from them (“Permission Based”).

Data which we consider to be Permission Based:

  • Your data is collected via a subscription form on your website.
  • Your data was collected via an opt-in check box on an online form. This box must not be pre-checked as default as they are then not knowingly opting in.
  • Customers who have purchased from you within the past 12 months.
  • Addresses that were collected via Trade Shows / offline. They must be aware that you will be sending them promotional emails by providing their address.

Data which we consider NOT to be Permission Based (“Non Permission Based”):

  • Any purchased/rented/loaned email list, regardless of whether they have ‘opted in’ or how much the list cost you. You need to obtain the opt in yourself.
  • Any third-party list you have acquired. You need to obtain the opt in yourself.
  • Addresses that you have ‘harvested’ or copied from your target markets websites. You need to obtain the opt in yourself.
  • Addresses of customers that are over 12 months old.
  • Any addresses that you cannot prove how you’ve collected them

Adelante prohibits the use of the Service in any manner associated with the transmission, distribution or delivery of any Non Permission Based email.

Testing of Data or Lists: We are vigilant in our efforts to prevent users using data and lists which are Non Permission Based and have several procedures in place to ensure that our system is kept clean of bad data.

  • Random Email Verifying – We check the content and subject lines of new campaigns to make sure that it is appropriate and not misleading. If we feel it is, the emails will be paused until the content is corrected. We approve all client emails before they are sent with new accounts.
  • List Verification – All large lists will be reviewed by us before you will be allowed to send to them. We have automated systems to allow us to review any uploaded list and if the list is Non Permission Based or does not pass our criteria in any other way, you will not be allowed to send to it.
  • Abuse complaint, Bounce and Unsubscribe Rates – We are constantly receiving information from our partnerships with Internet Service Providers (“ISP’s”) to look for any abnormally high complaint, bounce and unsubscribe rates. If we do see a high rate, we may disable your account and contact you to discuss the issue. We can also terminate accounts based on high complaint, bounce or unsubscribe levels.
  • ISP and Blacklist communication – We continue to communicate with both ISP’s and Blacklists at all times to ensure that our customers aren’t breaking any rules. We have feedback loops set up with the major ISP’s and are always welcoming any blacklist companies or ISP’s to contact us with further suggestions on how to improve.

If we believe that unauthorised or improper use is being made of the Service, we may, without notice, take such action as we, in our sole discretion, deem appropriate, including the suspension or termination of any account. Unauthorised use of the Service may result in civil action against you and anyone assisting you.

Using Adelante Click to send out emails to addresses obtained in any way other than a subscriber opting-in to your list may incur a £250 charge per incident.

Nothing in this policy is intended to grant any right to transmit or send email to, or through, the Service. Failure to enforce this policy does not amount to a waiver of Adelante’s rights.