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CASL Law

Policy Statement

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This document outlines Rapid Force Technologies’ policy and is intended to provide readers with reasonable assurance that

  1. Rapid Force Technologies’s clients and prospective clients in Canada are always reached in the same manner when receiving commercial electronic messages

  2. Rapid Force Technologies employees who send commercial electronic messages from and/or to a computer system(s) in Canada are fully compliant with CASL.

The Anti-Spam Policy and accompanying processes (the “CASL Procedures “) of Rapid Force Technologies are designed to guarantee that all CEMs sent by or on behalf of Rapid Force Technologies, or using a Rapid Force Technologies email address or domain, conform with CASL.

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Policy regulations

The Anti-Spam Policy defines Rapid Force Technologies’s duties under CASL and commercial electronic communications sent to Rapid Force Technologies customers, prospective clients, and others, where applicable. Rapid Force Technologies may from time to time include additional anti-spam rules, techniques, or practices.

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Application

This Policy applies to employees of Rapid Force Technologies who may send CEMs from and/or to a computer system(s) in Canada or to an electronic address that will be accessible from a computer system in Canada. The Anti-Spam Policy has been established in line with CASL rules, and Rapid Force Technologies is committed to CASL compliance. All additional Rapid Force Technologies regulations and procedures must be interpreted in accordance with the Anti-Spam Policy and in accordance with CASL in order to avoid damaging and deceptive spam in Canada.

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Agreement

Rapid Force Technologies obtains affirmative, opt-in permission before delivering a CEM to anybody who has not had an established business relationship with Rapid Force Technologies within two years of the date the CEM is delivered unless there is a demonstrable basis for implicit consent or an exception to consent. Unless there is a good proven cause for inferred consent or an exception to consent, Rapid Force Technologies Obtains explicit, opt-in authorization for the sending of CEMs to Rapid Force Technologies prospects.

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The request for permission cannot be included in an electronic communication unless the message is transmitted with implicit approval. Permission must be requested individually inside a message (e.g., by affirmatively choosing a checkbox) and cannot be bundled as a prerequisite of agreement approval. Verbal consent is authorized when a record of the details of the consent is retained in a database.

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Form and Content of CEMs

The following are some general summaries of the CASL form and content standards that all CEMs must meet:

comprises the sender’s name, postal address, phone number(s), email address(es), and a link to a web page where the recipient may unsubscribe from receiving CEMs from Rapid Force Technologies and its subsidiaries and affiliates, as well as a clear description of how to do so.

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If Rapid Force Technologies uses a third-party service provider to deliver CEMs on its behalf, Rapid Force Technologies will make every effort to ensure that the CEMs are sent in line with CASL.

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Cataloging of relationship specifics

CASL compliance necessitates the keeping of records describing contacts with consumers and potential clients.

Each Rapid Force Technologies business unit is required to create and keep verifiable records in its Client Relationship Management (CRM) system documenting the relationships that give rise to implied consent, as well as verifiable records of express, opt-in consents obtained from Rapid Force Technologies clients and prospective clients. Customers are defined as organizations or people that have at least one open account or contractual connection with Rapid Force Technologies at the time of the transaction. For the purposes of this Policy, organizations or individuals who have terminated their final remaining account or canceled their contract with Rapid Force Technologies are not considered Rapid Force Technologies customers.

 

In order to monitor customer and prospect contacts, each CRM system requests and records implicit permission or explicit, opt-in authorization in compliance with the CASL Procedures.

Once Rapid Force Technologies stops delivering CEMs to a customer or prospect, records of explicit, opt-in consent and evidence of the relationships that give rise to implied consent are kept for at least three years.

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Business electronic communications

All Rapid Force Technologies workers who send CEMs from or to a computer system(s) in Canada must follow this Policy as well as any relevant CASL laws and regulations.

A “CEM” is a kind of electronic communication that contains material (text, hyperlinks, photographs, or attachments) that:

a. promotes, offers, or advertises Rapid Force Technologies products or services, employees, or connections;

b. solicits business for Rapid Force Technologies or its employees or contacts; and

c. any other analogous statement that encourages commercial activity participation.

Examples include invitations to promotional events (such as webcasts or Rapid Force Technologies events), marketing mailings, and so on.

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The messages listed below are not necessary to comply with CEM requirements:

Notices needed by law, such as communications delivered to comply with a regulatory obligation (e.g., substantial changes, mandatory account activity information, and so on); and responds to requests, queries, or complaints.

 

Internal emails transmitted between Rapid Force Technologies staff using a device owned or furnished by Rapid Force Technologies or a Rapid Force Technologies email account should be about Rapid Force Technologies. Rapid Force Technologies staff may not send each other offers, promotions, advertising, or suggestions unrelated to Rapid Force Technologies' business without the specific permission of the internal recipient.

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Abidance by third parties

Third-party contracts with service providers that may send CEMs on Rapid Force Technologies’s behalf must contain provisions requiring the service provider to comply with CASL, including CEM form and content standards.

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Unsubscribe tool

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Any CEM that does not come under one of the aforementioned exclusions must include a viable unsubscribe method that enables consumers to withdraw their consent or make do-not-contact requests in a timely manner that allows Rapid Force Technologies to handle the request within 10 days of its submission. This information must be included in the database used to monitor contacts with customers and prospective prospects.

Any emails sent in line with CASL requirements must include an “unsubscribe” option. Stop receiving our commercial electronic messages at any time by clicking the “unsubscribe” link.

https://rapfortech.com/unsubscribe/

or by emailing dpo@rapfortech.com with ‘Unsubscribe’ in the subject line.

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Responsibility for Policy Management

The Compliance department of each XpertLync legal entity is responsible for adhering to the Anti-Spam Policy, which is examined, amended as needed, and approved once a year. Any modifications or deviations from this Policy must be authorized by the XpertLync Board or its equivalent.

 

Evaluation and endorsements

This Policy will be reviewed and changed as needed by XpertLync Compliance, with permission from the appropriate XpertLync Board or equivalent. This Policy must be changed on an annual basis or as needed.

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Performance and analysis

XpertLync retains the right to conduct random audits to ensure compliance with this Policy and any procedures linked to it. In the event that this Policy or any related procedures are breached, disciplinary action may be taken in accordance with the Global Human Resources Disciplinary Process.

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