Code of Conduct & Acceptable Use

1. Purpose & Scope

This Code of Conduct and Acceptable Use Policy ("Policy") defines the rules, standards, and expectations for all users of the Sendar messaging platform ("Platform") operated by Sendar Technologies Ltd. ("Sendar", "we", "our"), registered at No 14, Ben Okagbue, Mba Street, Lekki Phase 1, Lagos, Nigeria.

This Policy applies to all messages sent through Sendar, regardless of channel (SMS, WhatsApp, Email, Voice), and to all use of the Sendar dashboard, API, webhooks, and any related tools or services. By using the Platform, you ("User", "you", "your") agree to comply with this Policy in its entirety.

You are solely and fully responsible for the content, timing, and legality of all messages you send through the Platform. Sendar provides the infrastructure for message delivery but does not author, endorse, or approve your message content. You agree that Sendar bears no liability for any claims, damages, fines, or penalties arising from your message content or your failure to comply with this Policy or applicable law.

2. Prohibited Content

You must not use the Platform to create, send, store, or distribute any content that:

• Spam: Unsolicited bulk messages sent to recipients who have not provided verifiable opt-in consent. This includes unsolicited promotional messages, chain messages, and pyramid schemes.
• Phishing & Social Engineering: Messages designed to fraudulently obtain personal information, login credentials, financial details, OTPs, or other sensitive data from recipients.
• Fraud & Scams: Messages that promote fraudulent schemes, advance-fee fraud (419), lottery scams, fake investment opportunities, Ponzi schemes, or any deceptive practice intended to defraud recipients.
• Malware & Harmful Links: Messages containing links to malware, viruses, spyware, ransomware, or any software designed to damage, disable, or gain unauthorised access to devices or systems.
• Hate Speech & Discrimination: Messages that promote hatred, violence, or discrimination based on race, ethnicity, religion, gender, sexual orientation, disability, nationality, or any other protected characteristic under Nigerian law.
• Threats & Harassment: Messages that threaten, intimidate, bully, stalk, or harass any individual or group.
• Illegal Content: Messages that promote, facilitate, or relate to any activity that is illegal under the laws of the Federal Republic of Nigeria, including drug trafficking, human trafficking, terrorism, money laundering, and child exploitation.
• Impersonation: Messages that falsely represent the sender as another person, business, government agency, or entity, including the use of misleading sender IDs.
• Adult & Obscene Content: Sexually explicit content, pornography, or obscene material, unless you have obtained explicit prior written approval from Sendar and all recipients are verified adults who have opted in.
• Defamatory Content: Messages containing false statements of fact that damage the reputation of any individual or entity.
• Intellectual Property Infringement: Messages that infringe the copyrights, trademarks, patents, or other intellectual property rights of any third party.
• Misleading Content: Messages containing false or misleading health claims, fake news designed to cause public harm, or deceptive commercial practices in violation of FCCPC consumer protection regulations.

3. Consent & Opt-In Requirements

You must obtain and maintain verifiable opt-in consent from all message recipients before sending any promotional or marketing messages through the Platform. Consent requirements include:

• Express Opt-In: For promotional messages, you must obtain express, affirmative opt-in consent from each recipient. Pre-checked boxes, implied consent from unrelated transactions, or purchased contact lists do not constitute valid consent.
• Transactional Messages: For transactional messages (order confirmations, shipping notifications, OTPs, account alerts, appointment reminders), consent is implied by the existing business relationship or the recipient's direct request. However, you must not include promotional content in transactional messages.
• Consent Records: You must maintain auditable records of consent for each recipient, including the date, time, method of consent, and the specific messaging types consented to. Sendar may request proof of consent at any time.
• Consent Withdrawal: Recipients must be able to withdraw consent at any time. Withdrawal must be processed within 24 hours.
• NDPA 2023 Compliance: All consent mechanisms must comply with the requirements of Section 25(1)(a) of the Nigeria Data Protection Act 2023, including informed, specific, unambiguous, and freely given consent.

4. Opt-Out & Unsubscribe Requirements

Every promotional or marketing message sent through the Platform must include a clear, functional opt-out mechanism:

• SMS: Include a clear instruction such as "Reply STOP to unsubscribe" or "Text STOP to [shortcode] to opt out." The opt-out mechanism must be free for the recipient.
• WhatsApp: Provide a clear opt-out option within the message, such as "Reply STOP to stop receiving messages." Respect WhatsApp's built-in block functionality.
• Email: Include a visible, functional unsubscribe link in every marketing email. The unsubscribe process must be completed in no more than two clicks and must not require login.
• Voice: For automated voice calls, provide a keypress option (e.g., "Press 9 to be removed from this list") or a callback number for opt-out requests.

Opt-out requests must be honoured within 24 hours. Failure to provide or honour opt-out mechanisms is a serious violation of this Policy and Nigerian communications law.

5. Do-Not-Disturb (DND) Compliance

You must comply with the Nigerian Communications Commission (NCC) Do-Not-Disturb (DND) regulations at all times:

• Sendar automatically filters all promotional messages against the NCC DND registry before delivery. Messages to DND-registered numbers are blocked.
• You must not attempt to circumvent DND filtering by misclassifying promotional messages as transactional.
• You must not send promotional messages to numbers you know or reasonably should know are registered on the DND list, through any alternative channel or method.
• DND status applies to the number, not the subscriber. If a number changes hands, DND status remains until the new subscriber modifies it.
• Credits are not deducted for messages blocked by DND filtering, as these messages are never dispatched.

Repeated attempts to circumvent DND filtering will result in immediate account suspension and potential reporting to the NCC.

6. Sender ID Rules

All messages sent through the Platform must use a verified sender ID. Sender ID rules include:

• Registration: All sender IDs must be registered and approved through the Sendar dashboard before first use. Registration requires verification of your identity and your authority to use the sender ID.
• Alphanumeric Sender IDs: Limited to 11 characters. Must accurately represent your registered business name or brand. Subject to carrier approval, which may take up to 5 business days.
• Numeric Sender IDs: Must be valid phone numbers that you own or are authorised to use. Ownership may need to be verified.
• Prohibited Sender IDs: You must not use sender IDs that impersonate government agencies (e.g., "CBN", "EFCC", "NCC", "INEC"), emergency services (e.g., "112", "199"), financial institutions you do not represent, or any entity without written authorisation.
• Carrier Restrictions: Some carriers reserve the right to block or modify sender IDs. Sendar is not liable for carrier-imposed restrictions on your sender ID.
• Shared Short Codes: Where shared short codes are used, you must comply with all usage guidelines and not monopolise shared resources.

7. Messaging Frequency & Volume Limits

• Promotional Messages: You should not send more than 3 promotional messages per recipient per day, or 10 per week, unless the recipient has explicitly consented to higher frequency.
• Transactional Messages: No hard frequency limit, but messaging patterns that suggest abuse may trigger automated review.
• Time Restrictions: Promotional messages should not be sent between 9:00 PM and 8:00 AM Nigerian time (WAT), unless the recipient has opted in to receive messages at any time.
• Rate Limits: API rate limits apply to all accounts. Exceeding rate limits will result in throttling, not message loss.
• Volume Spikes: Sudden, unexplained spikes in message volume may trigger an automatic review and temporary throttling.

8. API-Specific Rules

• Credential Security: You are solely responsible for securing your API keys and secret tokens. Never expose credentials in client-side code, public repositories, or unsecured storage.
• Rate Limiting: Respect published rate limits. Automated retry logic must implement exponential backoff.
• Webhook Security: Validate webhook signatures on all incoming payloads.
• Data Handling: Any personal data received via API responses or webhooks must be handled in compliance with the NDPA 2023.
• Testing: Use the sandbox environment for testing. Do not use production endpoints for load testing without prior written approval.
• Reverse Engineering: You must not reverse-engineer, decompile, or otherwise attempt to discover the source code of the Sendar API or Platform.
• Resale: You must not resell or redistribute API access to third parties without Sendar's prior written consent.

9. User Responsibility & Indemnification

You are fully and solely responsible for:

• The content, accuracy, and legality of all messages sent through your account
• Obtaining and maintaining valid consent from all message recipients
• Complying with all applicable Nigerian laws and regulations
• Ensuring that your use of the Platform does not infringe the rights of any third party
• Securing your account credentials, API keys, and any systems that interface with the Sendar Platform
• The actions of any employees, agents, contractors, or third parties who access the Platform using your credentials

You agree to indemnify, defend, and hold harmless Sendar Technologies Ltd., its directors, officers, employees, agents, and affiliates from and against any and all claims, liabilities, damages, losses, costs, and expenses arising from or in connection with: (a) your use of the Platform; (b) your message content; (c) your violation of this Policy, our Terms & Conditions, or any applicable law; (d) your infringement of any third-party rights; or (e) any complaint, claim, or regulatory action from a message recipient or regulatory authority relating to your messages.

10. Enforcement & Consequences

Sendar enforces this Policy through a progressive enforcement framework. However, Sendar reserves the absolute right to skip any step and proceed directly to suspension or termination where the violation is severe, poses immediate risk, or is required by law or regulatory order.

1. Warning: For first-time minor violations, Sendar may issue a written warning via email specifying the violation and required corrective action. You will have 48 hours to remedy the violation.
2. Throttling & Restrictions: Repeated minor violations or moderate violations may result in message rate throttling, temporary restriction of specific channels, or suspension of specific sender IDs.
3. Account Suspension: Serious violations or continued non-compliance after warning will result in immediate account suspension. During suspension: all messaging is halted, API access is revoked, wallet credits are frozen, and access to the dashboard is restricted to read-only.
4. Account Termination: Severe violations, repeated serious violations, or violations that expose Sendar to legal or regulatory risk will result in permanent account termination.
5. Credit Forfeiture: Upon account termination for policy violation, all remaining wallet credits are permanently forfeited with no right to refund.
6. Regulatory Reporting: Sendar may report violations to the NCC, NDPC, EFCC, Nigeria Police Force, or other relevant authorities.
7. Legal Action: Sendar reserves the right to pursue legal action against users whose violations cause material damage to Sendar.

11. Platform Abuse & Security

The following activities constitute platform abuse and are strictly prohibited:

• Attempting to gain unauthorised access to Sendar systems, other user accounts, or carrier networks
• Using the Platform to conduct denial-of-service attacks or message flooding against any target
• Exploiting Platform vulnerabilities instead of reporting them through our responsible disclosure programme
• Manipulating message delivery reports, analytics, or billing data
• Creating multiple accounts to circumvent enforcement actions, rate limits, or credit restrictions
• Using automated tools to scrape, crawl, or extract data from the Platform beyond what is available through the API
• Interfering with or disrupting the Platform's infrastructure, networks, or services
• Benchmarking or competitive analysis of the Platform without prior written consent

Any suspected platform abuse will result in immediate investigation and may lead to instant account termination and reporting to law enforcement.

12. Industry-Specific Requirements

• Financial Services: Messages must comply with CBN consumer protection regulations. Financial product marketing must include required disclaimers.
• Healthcare: Messages containing health information must comply with patient confidentiality requirements.
• Political Messaging: Political campaign messages must comply with INEC regulations on political advertising.
• Gambling & Betting: Messages promoting gambling or betting services must comply with NLRC guidelines.
• Telecoms: Value-added service providers must comply with NCC VAS regulations.

13. Reporting Abuse

If you become aware of any misuse of the Sendar Platform, or if you receive unwanted messages sent through Sendar, you can report abuse through the following channels:

• Email: abuse@sendar.io
• Dashboard: Use the "Report Abuse" feature in the Sendar dashboard
• Phone: +234 707 893 1282

When reporting abuse, please provide: the date and time of the message, the sender ID or phone number, the message content (or a screenshot), and any other relevant details. All abuse reports are investigated within 24 hours. The identity of reporters is kept confidential.

14. Service Level & Liability Disclaimer

Sendar provides messaging infrastructure on a best-effort basis. Unless you have a separate, signed Enterprise Service Level Agreement (SLA):

• Sendar does not guarantee any specific uptime percentage, message delivery rate, or delivery speed.
• Message delivery depends on factors outside Sendar's control, including carrier networks, recipient device status, network congestion, and DND settings.
• Sendar shall not be liable for any loss of revenue, business, or opportunity resulting from message delivery delays, failures, or platform downtime.
• Sendar's total liability for any claim arising from your use of the Platform shall not exceed the total credits purchased by you in the three (3) months preceding the claim.

15. Regulatory References

• Nigeria Data Protection Act 2023 (NDPA)
• Nigeria Data Protection Commission (NDPC) Implementation Framework
• Nigerian Communications Commission (NCC) Consumer Code of Practice Regulations
• NCC Short Code and DND Regulations
• Cybercrimes (Prohibition, Prevention, etc.) Act 2015
• Federal Competition and Consumer Protection Act (FCCPA) 2018
• National Information Technology Development Agency (NITDA) Act
• Central Bank of Nigeria (CBN) Consumer Protection Framework (for financial messaging)
• Government-Assigned Identifier Database (GAID) Framework

16. Changes to This Policy

Sendar may update this Policy at any time to reflect regulatory changes, new enforcement practices, or emerging messaging standards. Material changes will be communicated via email and dashboard notification at least 14 days before taking effect. Your continued use of the Platform after the effective date constitutes acceptance of the updated Policy.

For questions about this Policy, contact support@sendar.io or abuse@sendar.io.