Policy Statement


This document sets forth the policy of Hatmarketing and is designed to provide reasonable assurance that (I) a consistent process is followed with respect to the dissemination of commercial electronic messages Hatmarketing and prospective clients in Canada, and (ii)Hatmarketing sending commercial electronic messages from and/or to a computer system(s) in Canada comply with the requirements of CASL.


The Hatmarketing Anti-Spam Policy (“Anti-Spam Policy”) and related procedures (the “CASL Procedures”) require that all Hatmarketing 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 Hatmarketing,or using a Hatmarketingemail address or using a device owned or provided by Hatmarketing, comply with CASL.


Policy Details


The Anti-Spam Policy describes Hatmarketingcommitments relating to the provisions of CASL and electronic messages of a commercial nature sent Hatmarketing, prospective clients, and others, as applicable. From time to time, Hatmarketingmay implement additional policies, procedures and/or practices as it relates to anti-spam measures.




This Policy applies Hatmarketingwho 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 Hatmarketing operations, the Anti-Spam Policy has been adopted in compliance with the requirements of CASL, and Hatmarketingis committed to complying with CASL. All other Hatmarketing 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.




Hatmarketing 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 Hatmarketing with in 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, Hatmarketing also obtains express, opt-in consent for the sending of CEMs toHatmarketing 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.


Form and Content of CEMs


All CEMs are required to comply with the form and content requirements of CASL, generally described as follows:


identifies the sender;

the sender’s mailing address;

the sender’s telephone number or email address or link to a webpage; and

an unsubscribe mechanism or withdrawal of consent from receiving CEMs from Hatmarketing and its subsidiaries


Hatmarketingtakes steps to require that any third-party service provider who sends CEMs on behalf of Hatmarketing complies with CASL.


Storage of Relationship Details


A key component of complying with CASL involves maintaining records of Hatmarketing relationships with clients and prospective clients.


Each business unit of Hatmarketing 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 Hatmarketingand prospective clients. “Clients” are defined as those organizations or individuals who have at least one open account or a contractual relationship with HatmarketingSat the relevant time. Organizations or individuals who have closed their last remaining account or terminated their contract with Hatmarketingare not considered Hatmarketing 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 ceases sending CEMs to the Hatmarketing client or prospect.


Commercial Electronic Messages


All Hatmarketing 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:


promotes, offers or advertises Hatmarketing or Hatmarketing products or services, or employees, or contacts;

solicits business for Hatmarketing employees or contacts;  and

any other similar message that encourages participation in commercial


Examples include promotional event invitations (e.g., webcasts or Hatmarketing events), marketing newsletters, etc.


The following messages do not have to comply with the requirements applicable to CEMs:


messages sent Hatmarketing about their business;

internal communications aboutHatmarketing business (including communications with Hatmarketingoffices outside Canada);

legally required notices, such as messages that are sent to comply with a regulatory requirement (e.g., material changes, required account activity information, etc.); and

responses to requests, inquiries or


Messages that Hatmarketing email each other internally using a device that Hatmarketing owns or provides, or using an Hatmarketingemail address, should be related to. Hatmarketing may not internally email each other offers, promotions, advertisements, or referrals unrelated to Hatmarketing business without the internal recipient’s verbal consent.


Compliance by Third Parties


All third-party contracts with service providers who may send CEMs on behalf of Hatmarketing must contain contractual clauses obligating the service provider to comply with CASL including the form and content requirements of CEMs.


Unsubscribe Mechanism


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 Hatmarketing 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 Hatmarketing . 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 or by emailing with ‘Unsubscribe’ in the subject line.


Policy Administration


The Anti-Spam Policy is maintained by the Compliance department of each XpertLync 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 XpertLync Board or equivalent.


Review and Approvals


XpertLync Compliance is responsible for review and revision of this Policy, subject to approval of the respective XpertLync Board or equivalent. This Policy is subject to review on an annual basis, or otherwise as needed.


Enforcement and Audit


Compliance with this Policy, and any related procedure, may be reviewed by XpertLync 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.