This document sets forth the policy of Tech World Solutions and is designed to provide reasonable assurance that (I) a consistent process is followed with respect to the dissemination of commercial electronic messages from Tech World Solutions to prospective clients in Canada, and (ii) Tech World Solutions is sending commercial electronic messages from and/or to a computer system(s) in Canada comply with the requirements of CASL.
The Tech World Solutions Anti-Spam Policy (“Anti-Spam Policy”) and related procedures (the “CASL Procedures”) require that all Tech World Solutions personnel 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 comply with CASL, and seeks to ensure that all CEMs sent by or on behalf of Tech World Solutions, or using a Tech World Solutions email address or using a device owned or provided by Tech World Solutions, comply with CASL.
The Anti-Spam Policy describes Tech World Solutions commitments relating to the provisions of CASL and electronic messages of a commercial nature sent from Tech World Solutions to prospective clients and others, as applicable. From time to time, Tech World Solutions may implement additional policies, procedures, and/or practices as it relates to anti-spam measures.
This Policy applies to Tech World Solutions personnel 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 Tech World Solutions operations, the Anti-Spam Policy has been adopted in compliance with the requirements of CASL, and Tech World Solutions is committed to complying with CASL. All other Tech World Solutions 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.
Tech World Solutions 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 Tech World Solutions 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, Tech World Solutions also obtains express, opt-in consent for the sending of CEMs to Tech World Solutions 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. A 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:
Tech World Solutions takes steps to require that any third-party service provider who sends CEMs on behalf of Tech World Solutions complies with CASL.
A key component of complying with CASL involves maintaining records of Tech World Solutions relationships with clients and prospective clients.
Each business unit of Tech World Solutions 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 Tech World Solutions and prospective clients. “Clients” are defined as those organizations or individuals who have at least one open account or a contractual relationship with Tech World Solutions at the relevant time. Organizations or individuals who have closed their last remaining account or terminated their contract with Tech World Solutions are not considered 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 Tech World Solutions ceases sending CEMs to the client or prospect.
All personnel at Tech World Solutions 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 promotional event invitations (e.g., webcasts or Tech World Solutions events), marketing newsletters, etc.
The following messages do not have to comply with the requirements applicable to CEMs:
Messages that Tech World Solutions email each other internally using a device that Tech World Solutions owns or provides, or using a Tech World Solutions email address, should be related to Tech World Solutions business. Tech World Solutions may not internally email each other offers, promotions, advertisements, or referrals unrelated to Tech World Solutions business without the internal recipient’s verbal consent.
All third-party contracts with service providers who may send CEMs on behalf of Tech World Solutions 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 the 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 Tech World Solutions 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 Tech World Solutions 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://techworldsolutions.com/unsubscribe or by emailing info@techworldsolutions.com with ‘Unsubscribe’ in the subject line.
The Anti-Spam Policy is maintained by the Compliance department of Tech World Solutions 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 Tech World Solutions Board or equivalent.
Tech World Solutions Compliance is responsible for the review and revision of this Policy, subject to approval of the respective Tech World Solutions 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 Tech World Solutions 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 Global Human Resources Disciplinary policy or procedure.