A. Our "No Spam" CASL Promise
Canada's Anti-Spam Legislation ("CASL") allows recipients to control the commercial electronic messages ("CEMs") they receive. Fogler, Rubinoff LLP ("FR") respects the choices of our clients and contacts to determine whether they would like to receive CEMs from us. The anti-spam elements of our policy for compliance with CASL include:
- subject to exceptions permitted by CASL (such as the exception for certain business-to-business CEMs and the exception for CEMs sent via certain electronic messaging systems)
(a) checking that we have consent before sending CEMs
(b) setting out our sender identification information on CEMs; and
(c) providing an unsubscribe mechanism for those on our CEM distribution lists;
- effecting unsubscribe requests promptly and in any event no later than 10 business days after receipt; and
- keeping records of consents and unsubscribes.
If you currently subscribe to any FR CEMs, you may unsubscribe at any time.
If you would like to sign up for such CEMs or revise your preferences, please go to FR's subscription and preference centre.
B. Our Other CASL Promises
CASL also regulates or prohibits certain other activities in the digital marketplace and therefore our compliance with CASL also includes:
No Unsolicited Software Installation
- not installing, or causing to be installed, software (including upgrades) on another person's computer or other device without that person's consent (obtained via appropriate disclosures based on whether or not the software is intrusive all as defined under CASL) and, where we have installed software and in the circumstances required under CASL, to help uninstall such software;
- not to collect personal information through illicit access to the computer systems of others through means such as spyware;
No Address Harvesting
- not to engage in electronic address harvesting – namely, the use of a computer program to indiscriminately collect electronic addresses, such as email addresses, which commitment includes:
(a) following due diligence to avoid inadvertently harvesting, or using harvested email addresses; and
(b) taking appropriate precautions when:
(i) working with a third party that has been contacted to do email marketing on our behalf; and
(ii) buying a list from a vendor to do email marketing in-house;
No Deceptive Electronic Messages
- not sending, or causing to be sent, electronic messages that are deceptive, especially in connection with the subject line, locator or sender information of the electronic message; and
No Alteration of Transmission Data
- not altering the transmission data in electronic messages (which results in the messages being delivered to different destinations without express consent).
If you have questions about our CASL Policy, please contact our CASL Policy Administrator:
Marketing and Business Development Manager
Fogler, Rubinoff LLP
77 King Street West, Suite 3000, P.O. Box 95
Toronto, Ontario, M5K 1G8
This policy was last updated and is effective as of June 16, 2017.