CASL and electronic communications

1. About this policy

This policy explains how Corpshore Canada, the Canadian operation of Corpshore Solutions Corporation, complies with Canada's Anti-Spam Legislation ("CASL") when it sends commercial electronic messages, and what you can expect when you receive email from us. CASL is enforced by the Canadian Radio-television and Telecommunications Commission, and non-compliance can attract administrative monetary penalties of up to ten million dollars for a corporation. We take our obligations under it seriously. Our head office is at The Exchange Tower, 130 King Street West, Suite 1900, Toronto, Ontario M5X 2A2, Canada, and you can reach our Privacy Officer at privacy@corpshore.ca.

2. What CASL covers

CASL applies to commercial electronic messages, which are electronic messages, such as email, that encourage participation in a commercial activity, for example a newsletter about our services or an invitation to an event. It requires that, before we send such a message, we have consent, that the message identifies us and gives our contact information, and that the message contains a working unsubscribe mechanism. This policy describes how we meet each of those requirements. A message counts as commercial if, considering its content, any links in it, and the contact information it gives, it would be reasonable to conclude that one of its purposes is to encourage a commercial activity, whether or not there is any expectation of profit.

3. Consent

We send commercial electronic messages only where we have consent. We rely on two kinds of consent.

• Express consent. You give express consent by taking a clear, affirmative action to opt in, for example by ticking an unchecked box that is not bundled with any other request, when you subscribe to a newsletter or ask to receive marketing email. We do not use pre-checked boxes, and we do not treat silence or inaction as consent. When you give express consent, we record the date, the exact wording you agreed to, and how you gave it.
• Implied consent. In the limited circumstances CASL allows, we may rely on implied consent, for example where you have an existing business relationship with us that falls within the timeframes CASL sets, or where you have conspicuously published or provided your business electronic address without a statement that you do not want unsolicited messages, and our message relates to your role or business. We treat implied consent as time-limited in accordance with CASL and we do not rely on it beyond the periods the law allows.

3a. Unbundled, unchecked opt-in

When we ask for express consent through a form on our site, the request to receive marketing communications is separate from any other request, it is presented with an opt-in control that is not pre-checked, and it is worded so you understand what you are agreeing to receive and from whom. Agreeing to be contacted about a specific enquiry, proposal or discovery call is a separate matter from agreeing to receive marketing, and we do not treat one as the other. You can give one without the other.

4. How we identify ourselves

Every commercial electronic message we send identifies us as the sender, or identifies us and any person on whose behalf the message is sent, and gives a mailing address and either a telephone number, an email address or a web address at which we can be reached. Our messages state that they come from Corpshore Canada and include our head office mailing address at The Exchange Tower, 130 King Street West, Suite 1900, Toronto, Ontario M5X 2A2, Canada and a contact route. This information stays valid for at least sixty days after we send the message, so you can always tell who sent a message and how to reach us.

5. Unsubscribe

Every commercial electronic message we send includes a clearly worded and easy-to-use unsubscribe mechanism that lets you tell us you no longer wish to receive commercial electronic messages from us. The mechanism is valid for at least sixty days after we send the message. When you unsubscribe, we give effect to your request without delay and in any event within ten business days, and we do not require you to do anything more than send the request or visit a single web page. Our newsletters and marketing email are delivered through Zoho Campaigns, and the unsubscribe link in each message is honoured within this timeframe.

6. Records of consent and unsubscribe

Because CASL places the burden of proving consent on the sender, we keep records of the consent we rely on, including the wording, the date and the method, and records of unsubscribe requests and how we gave effect to them. We keep proof of consent for three years after the consent is withdrawn or the relationship ends, so that we can demonstrate compliance. Our newsletters and marketing email run through Zoho Campaigns, which records subscription, consent and unsubscribe events, and we handle the personal information involved in accordance with our privacy policy.

6a. How we manage our sending lists

We build our marketing lists only from people who have given valid consent or from whom we may rely on implied consent within the limits CASL sets. We do not buy lists of addresses, we do not use software to generate or harvest addresses, and we do not send commercial electronic messages to an address collected by such means. When consent expires or is withdrawn, we stop sending commercial electronic messages to that address, and we suppress it so it is not added back by mistake. We review our lists periodically to remove addresses for which we can no longer demonstrate a valid basis.

7. Transactional and other exempt messages

Some messages are not commercial electronic messages, or are exempt from some of CASL's requirements. For example, a message that responds to your enquiry, confirms a discovery-call booking, or provides information about a transaction you have entered into is a transactional or exempt message. We may send such messages on the basis of your request or the relationship, and we still identify ourselves clearly. This policy does not restrict our ability to send messages the law requires or permits without express consent.

8. Software and links

CASL also restricts the installation of software on another person's device without consent, and the alteration of transmission data. We do not install software on your device through our messages, and our messages link only to our own site or to resources we describe. Please treat any message that appears to come from us but asks for sensitive information or directs you to an unfamiliar address with caution, and report it to privacy@corpshore.ca.

8a. Accountability and our people

Compliance with CASL is a shared responsibility. The people who plan and send our commercial electronic messages are expected to follow this policy, to confirm that a valid basis exists before a message is sent, to include the required identification and unsubscribe mechanism, and to give effect to unsubscribe requests promptly. We treat a failure to follow this policy as a serious matter, because non-compliance can expose the organisation and, in defined circumstances, individuals to significant liability.

8b. Messages sent on behalf of others

Where a message is sent on behalf of more than one person, or promotes another party, CASL requires each of them to be identified and requires consent that covers each of them. We do not send commercial electronic messages on behalf of a third party unless the required consent and identification are in place, and we do not lend our sending infrastructure to anyone who cannot demonstrate the same.

9. How to manage your preferences

You can unsubscribe from our marketing email at any time using the link in any such message, or by contacting privacy@corpshore.ca. Unsubscribing from marketing does not stop transactional or service messages that relate to a request you have made or an engagement you have with us. If you believe you have received a message from us that does not comply with this policy, please tell us so we can correct it, and we will treat your report as an unsubscribe request in any event.

9a. Existing business and non-business relationships

CASL recognises certain relationships that can give rise to implied consent for a limited time, such as an existing business relationship arising from a purchase, contract or enquiry within defined periods, and an existing non-business relationship arising from certain memberships or donations. Where we rely on such a relationship, we do so only within the timeframes CASL allows, we still identify ourselves and include a working unsubscribe mechanism, and we stop sending once the relationship-based basis expires unless you have given express consent in the meantime.

10. Changes to this policy

We may update this policy as our communications practices or the law change. The date at the top of this page shows when it was last revised. Please review it from time to time. If you have questions about how CASL applies to messages you receive from us, contact our Privacy Officer at privacy@corpshore.ca.