Canada’s Anti-Spam Legislation (CASL) Compliance Policy
Last Updated: October 30, 2025
AdvanceTechContent and/or its related corporations (collectively “AdvanceTechContent”)
This document sets forth the policy of AdvanceTechContent and is designed to provide reasonable assurance that (i) a consistent process is followed with respect to the dissemination of commercial electronic messages to AdvanceTechContent clients and prospective clients in Canada, and (ii) AdvanceTechContent employees sending commercial electronic messages from and/or to a computer system(s) in Canada comply with the requirements of CASL.
The AdvanceTechContent Anti-Spam Policy (“Anti-Spam Policy”) and related procedures (the “CASL Procedures”) require that all AdvanceTechContent employees sending CEMs (Commercial Electronic Messages) from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada comply with CASL, and seeks to ensure that all CEMs sent by or on behalf of AdvanceTechContent, or using an AdvanceTechContent email address or using a device owned or provided by AdvanceTechContent, comply with CASL.
The Anti-Spam Policy describes AdvanceTechContent’ commitments relating to the provisions of CASL and electronic messages of a commercial nature sent to AdvanceTechContent clients, prospective clients, and others, as applicable. From time to time, AdvanceTechContent may implement additional policies, procedures and/or practices as it relates to anti-spam measures.
This Policy applies to AdvanceTechContent employees who may be sending CEMs from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada.
With respect to AdvanceTechContent’s operations, the Anti-Spam Policy has been adopted in compliance with the requirements of CASL, and AdvanceTechContent is committed to complying with CASL. All other AdvanceTechContent policies and procedures will be interpreted in a manner that is consistent with the Anti-Spam Policy and that promotes compliance with CASL to seek to deter damaging and deceptive forms of spam from occurring in Canada.
AdvanceTechContent obtains express, opt-in consent, unless a verifiable basis for implied consent or an exception to consent exists, before sending a CEM to anyone who has not had an existing business relationship with AdvanceTechContent within two years before the date on which the CEM is sent. Unless a valid documented basis for implied consent or an exception to consent exists, AdvanceTechContent also obtains express, opt-in consent for the sending of CEMs to AdvanceTechContent prospects.
The request for consent cannot be in an electronic message unless there exists a basis for implied consent to send the message. The request for consent must be sought separately within a communication (e.g. through a separate action such as affirmatively checking a checkbox) and cannot be bundled as a term of acceptance of an agreement. Verbal consent is acceptable where a record of the details of the consent is maintained in a database.
All CEMs are required to comply with the form and content requirements of CASL, generally described as follows:
AdvanceTechContent takes steps to require that any third-party service provider who sends CEMs on behalf of AdvanceTechContent complies with CASL.
A key component of complying with CASL involves maintaining records of AdvanceTechContent’s relationships with clients and prospective clients.
Each business unit of AdvanceTechContent is required to create and maintain in the business unit’s Client Relationship Management (CRM) system (including, but not limited to, Benchmark, Salesforce), verifiable records documenting the relationships giving rise to implied consent, and verifiable records of express, opt-in consents obtained from AdvanceTechContent clients and prospective clients.
“Clients” are defined as those organizations or individuals who have at least one open account or a contractual relationship with AdvanceTechContent at the relevant time. Organizations or individuals who have closed their last remaining account or terminated their contract with AdvanceTechContent are not considered AdvanceTechContent clients for purposes of this Policy.
Implied consent or express, opt-in consent is obtained in accordance with the CASL Procedures and recorded in the applicable CRM system in order to track the client and prospect relationships.
Records of express, opt-in consent and records documenting the relationships giving rise to implied consent are retained for a minimum of three years after AdvanceTechContent ceases sending CEMs to the AdvanceTechContent client or prospect.
All AdvanceTechContent employees sending CEMs from and/or to a computer system(s) in Canada are required to comply with this Policy and related CASL procedures and processes.
A “CEM” is defined as an electronic message that includes content (for instance, text, hyperlinks, images or attachments) that:
Examples include:
The following messages do not have to comply with the requirements applicable to CEMs:
Messages that AdvanceTechContent employees email each other internally using a device that AdvanceTechContent owns or provides, or using an AdvanceTechContent email address, should be related to AdvanceTechContent. AdvanceTechContent employees may not internally email each other offers, promotions, advertisements, or referrals unrelated to AdvanceTechContent business without the internal recipient’s verbal consent.
All third-party contracts with service providers who may send CEMs on behalf of AdvanceTechContent must contain contractual clauses obligating the service provider to comply with CASL including the form and content requirements of CEMs.
CEMs that are not exempt from requirements applicable to CEMs noted above are required to include a form of unsubscribe mechanism to facilitate the withdrawal of consent or do-not-contact requests within a period of time and in a manner that would allow AdvanceTechContent to process that request within 10 days of the date on which the unsubscribe, withdrawal of consent or do-not-contact request was made. This information should be maintained in the applicable database that tracks the client and prospect relationships.
All emails sent by AdvanceTechContent and its subsidiaries, and employees will be compliant with CASL and will include the option to ‘unsubscribe.’
You can ‘unsubscribe’ from our Commercial Electronic Messages at any time by:
→ Visiting: https://advancetechcontent.com/unsubscribe
→ Or emailing: dpo@advancetechcontent.com with ‘Unsubscribe’ in the subject line.
The Anti-Spam Policy is maintained by the Compliance department of each AdvanceTechContent legal entity and will be reviewed and updated, where necessary, and approved on an annual basis. Any changes to, or exceptions from this Policy require the approval of the respective AdvanceTechContent Board or equivalent.
AdvanceTechContent Compliance is responsible for the review and revision of this Policy, subject to the approval of the respective AdvanceTechContent Board or equivalent. This Policy is subject to review on an annual basis, or otherwise as needed.
Compliance with this Policy, and any related procedure, may be reviewed by AdvanceTechContent at any time. Failure to comply with this Policy, as well as any associated procedures, may result in disciplinary action in accordance with the applicable Human Resources Disciplinary policy or procedure.