CASL Policy

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Definitions:

Canada’s Anti-Spam Policy (CASL): An act to promote the efficiency and adaptability of the Canadian economy by regulating certain activities that discourage reliance on electronic means of carrying out commercial activities, and to amend the CRTC Act, the Competition Act and PIPEDA.

Electronic address: An address used in connection with the transmission of an electronic message to an electronic mail account, and instant messaging account, a telephone account or similar account.

Electronic message: A message sent by any means of telecommunication, including text, sound, voice or image.

Commercial electronic message (CEM): CEMs are commercial electronic messages that encourage participation in commercial activity. Even if a commercial message is not sent with an expectation of garnering profit, it still qualifies as a CEM.

Commercial activity: Any transaction of commercial character, regardless of whether there is an expectation of profit or not.

Express Consent: Permission obtained when a recipient “opts in” to receive CEMS. Consent can be oral or written and could be an unedited audio recording, paper or electronic checkbox on a website. Express consent never expires unless the recipient chooses to unsubscribe. Crowe Soberman will maintain records of all contacts for whom express consent exists.

Unsubscribe: A withdrawal of consent to receive CEMs.

Policy Guidelines:

All partners, employees, contractors, vendors and any other person sending CEMs on behalf of Crowe Soberman adhere to the following policies:

All CEMs from Crowe Soberman LLP contain:

• Full contact information. This includes the sender’s first name, last name, title, company name, company mailing address, direct telephone number, fax number, email address and company web address.
• If a CEM is to be sent on behalf of another party at Crowe Soberman, the name of this party and the sender will both be included, in addition to the information listed above.
• An unsubscribe link will be clearly visible.

Unsubscribe Requests:

• All unsubscribe requests will be managed within ten days of receipt. Employees will not send any further communication by electronic means to the unsubscribed party.

Compliance with CASL is of utmost importance and all employees actively participate in maintenance of corporate compliance. Crowe Soberman encourages its employees to take a proactive approach in identifying potential problems or violations of CEM delivery by promptly reporting issues to the CASL Compliance Team immediately.