Canada’s Anti-Spam Legislation (CASL) Compliance Policy

Policy Statement

This policy outlines Faeb Crunch’s commitment to complying with Canada’s Anti-Spam Legislation (CASL) regarding the sending of commercial electronic messages (CEMs) to clients, prospects, and other recipients within Canada. Our Anti-Spam Policy and related CASL procedures ensure that all communications adhere to legal standards.

Policy Scope

This policy applies to all Faeb Crunch employees who send CEMs from or to Canadian computer systems or to electronic addresses accessed in Canada. All internal procedures must align with this policy to prevent unsolicited messages and ensure CASL compliance.

Consent Requirements

Faeb Crunch obtains express, opt-in consent before sending CEMs to individuals without an existing business relationship in the past two years, unless implied consent or CASL exemptions apply. Verbal consent is acceptable if properly documented. Consent must not be bundled with other agreements and must be clearly distinguishable.

Message Requirements

• Clearly identify the sender
• Provide accurate contact information
• Include a functional and easy-to-use unsubscribe mechanism

Third-party providers sending messages on behalf of Faeb Crunch must also comply with CASL.

Record Keeping

All consent and client relationship records must be stored in CRM systems and retained for at least three years from the last CEM sent.

Permitted Exceptions

CASL does not apply to the following types of messages:

• Messages to existing clients about ongoing services
• Internal business communications
• Legally required messages or notices
• Responses to client or customer inquiries

Third-Party Compliance

All vendor and service provider contracts must include terms requiring compliance with CASL when sending messages on behalf of Faeb Crunch.

Unsubscribe Process

Each CEM must contain an easy unsubscribe option, such as:

• A direct unsubscribe link
• Email to dpo@faebcrunch.com with the subject "Unsubscribe"

All unsubscribe requests must be honored within 10 business days.

Policy Ownership and Review

The Faeb Crunch Compliance Department is responsible for the ongoing review and maintenance of this policy. It is reviewed annually and any significant updates must be approved by company leadership.

Enforcement and Monitoring

Failure to follow this policy may result in disciplinary action in accordance with Faeb Crunch’s internal HR policies. Regular audits will be conducted to ensure compliance.