Version 1.0 • Effective October 23, 2025 • Owner: Legal & Compliance ([email protected]) • Scope: United States & Canada
Registered Address: 7901 4th St N, STE 300, St. Petersburg, FL 33702 • Phone: (727) 620-4229 • Website: https://37-dimensions.com
1) Purpose & Scope
This Policy establishes mandatory rules for sending commercial electronic messages (CEM) by or on behalf of 37 Dimensions LLC, including email, SMS/text, instant messaging, and direct messages on social platforms. It applies to all employees, contractors, and third-party vendors who initiate or facilitate messaging on our behalf (collectively, “Associates”). The Policy addresses compliance with Canada’s Anti‑Spam Legislation (CASL), the U.S. CAN‑SPAM Act, the U.S. Telephone Consumer Protection Act (TCPA) for SMS/telephony, and carrier/industry guidelines (e.g., CTIA and A2P 10DLC registration rules).
2) Governance & Ownership
Legal & Compliance owns this Policy and oversees interpretation, enablement, and enforcement. Business and Marketing leaders are responsible for operationalizing controls. IT/Security maintains technical safeguards (SPF/DKIM/DMARC, suppression lists, access controls). Vendors must contractually agree to abide by this Policy.
Questions: [email protected] • Report suspected violations immediately to Legal & Compliance.
3) Key Definitions
- Commercial Electronic Message (CEM): An electronic message that has, as one of its purposes, encouraging participation in a commercial activity (e.g., promotion, sale, offer, business development).
- Electronic Address: Email account, SMS/text number, instant messaging/social account, or similar destination.
- Express Consent: Recipient explicitly agrees (e.g., checked box, signed form, double opt‑in).
- Implied Consent (CASL): Limited situations such as existing business relationships, published business contact for inquiries, or business card exchange—time‑bounded and context‑specific.
- Unsubscribe Mechanism: A clear, simple, and free method to opt out of future CEM (e.g., link in email; STOP for SMS).
4) Legal Framework (Summary)
- Canada (CASL): Requires consent (express or certain implied categories), identification, contact details, and a working unsubscribe mechanism active for at least 60 days; unsubscribe requests must be processed without delay, within 10 business days. Enforcement by CRTC, Competition Bureau, and OPC.
- United States (CAN‑SPAM): Consent is not required for email to adults, but messages must not be deceptive; must include identification, a valid physical postal address, and a functioning opt‑out processed within 10 business days.
- United States (TCPA/State laws): SMS/robocalls typically require prior express consent (and for marketing SMS, prior express written consent). Provide STOP/HELP keywords; maintain opt‑in/opt‑out logs; follow CTIA and carrier policies, including A2P 10DLC registration and campaign rules.
5) Consent Requirements & Standards
A) Email to U.S. recipients (CAN‑SPAM): Consent is not required, but all content rules apply. Honor opt‑outs within 10 business days.
B) Email to Canadian recipients (CASL): Obtain express or valid implied consent before sending CEM. Maintain evidence of consent and the context (e.g., transaction date, business inquiry).
C) SMS/Text in U.S. & Canada (TCPA/CASL/CTIA): Obtain opt‑in consent (for marketing, written consent). Present disclosure at sign‑up: message frequency, carrier rates (“Msg & data rates may apply”), HELP/STOP instructions, link to Terms & Privacy.
6) Exemptions (CASL examples)
- Personal or family relationships.
- Intra‑company communications among Associates.
- Responses to inquiries; transactional/service messages related to a product/service the recipient uses.
- Enforcement of legal/contractual rights.
Note: Adding promotional content to an otherwise exempt message may remove the exemption.
7) Content Standards for All CEM
- Honest Headers/Subject Lines: No false or misleading transmission information or subject lines.
- Identification: Clearly identify 37 Dimensions LLC as sender (or the applicable 37 Dimensions brand/division).
- Contact Info: Include a valid physical postal address (7901 4th St N, STE 300, St. Petersburg, FL 33702) and at least one of: phone (727) 620-4229, email, or web address.
- Unsubscribe: Provide a clear opt‑out method (link in email; STOP for SMS). Keep the opt‑out channel active for ≥60 days (CASL). Process opt‑outs within ≤10 business days.
- No Harvesting/Random Generators: Do not use harvested lists or purchased data without documented compliant consent and prior due diligence.
- Sensitive Verticals: Ensure additional vetting for financial products, healthcare, or age‑restricted content.
8) Footer & SMS Templates
Email Footer (example):
37 Dimensions LLC • 7901 4th St N, STE 300, St. Petersburg, FL 33702 • (727) 620-4229 • https://37-dimensions.com
You received this message because you opted in or have an existing relationship with us. To manage communications or unsubscribe, click here: {{unsubscribe_link}}
SMS Disclosure (example):
“By subscribing, you consent to receive recurring messages from 37 Dimensions. Msg & data rates may apply. Msg frequency varies. Reply STOP to opt out, HELP for help. Terms: https://37-dimensions.com/terms • Privacy: https://37-dimensions.com/privacy”
9) Preference Center & Consent Capture
- Maintain a Preference Center to obtain and manage express consent; support double opt‑in for higher‑risk campaigns.
- Log consent source (form, checkbox, SMS keyword), timestamp, IP/device, disclosure text presented, and campaign.
- Provide self‑service updates for email address changes and preferences.
10) Unsubscribe Processing & Suppression
- Unsubscribes are processed promptly and within 10 business days at most.
- Maintain a centralized suppression list synchronized across CRM, MAP, SMS and support tools.
- Prohibit re‑subscribing without a new, documented opt‑in.
11) Vendor & Platform Controls
- Use platforms supporting opt‑in logs, suppression lists, and footer insertion.
- Implement SPF, DKIM, and DMARC; monitor reputation/feedback loops.
- For SMS, maintain A2P 10DLC brand/campaign registrations; adhere to carrier/CTIA codes of conduct.
- Perform due diligence on data providers (consent provenance, refresh cadence).
12) Recordkeeping & Retention
- Keep consent and unsubscribe records for at least 3 years from last send, or longer if required by law or litigation hold.
- Retain campaign content, audience definitions, and send logs for auditability.
13) Training & Attestations
- All Associates involved in outbound communications must complete annual anti‑spam training and acknowledge this Policy.
- New hires complete training before gaining access to marketing or outbound tools.
14) Monitoring, Audits & Enforcement
- Legal & Compliance conducts periodic audits of consent, content, and suppression workflows.
- Violations may result in disciplinary action up to termination and referral to regulators.
- Incident response: pause campaigns, preserve logs, notify Legal, and remediate root causes.
15) Cross‑Border Messaging
- When sending to recipients located in Canada, CASL applies regardless of sender location.
- If a sender reasonably believes the message will be accessed outside Canada, ensure compliance with that country’s laws and platform policies.
- For multinational campaigns, use the strictest applicable rule when in doubt.
16) Roles & Responsibilities
- Marketing/BD: obtain consent, maintain lists, ensure footer/templates, honor unsubscribes.
- Sales/CS: avoid adding promotional content to transactional/exempt communications without confirming consent.
- IT/Security: maintain email authentication, access controls, logs, and integrations.
- Vendors: adhere to this Policy; enable exports for audit; report complaints within 24 hours.
17) Policy Review & Updates
This Policy is reviewed at least annually or upon material legal/regulatory changes. Latest version is maintained by Legal & Compliance.
Appendix A — Decision Tree (When Can We Send?)
1) Is the message transactional or a response to a request? If yes, generally allowed (ensure no promotional content).
2) If promotional: Do we have valid consent? (Express for CASL; written for marketing SMS under TCPA.)
3) Include identification, contact info, and a working unsubscribe (email link; STOP for SMS).
4) Log consent and update suppression lists as needed.
Appendix B — Sample Consent Language
Email/Web forms: “I agree to receive emails from 37 Dimensions, and I can unsubscribe anytime via the link in each email.”
SMS: “I agree to receive recurring marketing texts from 37 Dimensions at the number provided. Consent is not a condition of purchase. Msg & data rates may apply. Reply STOP to opt out, HELP for help. Terms & Privacy links provided.”
Appendix C — Examples of Exempt Messages
- Service announcements strictly related to a product the recipient uses (e.g., maintenance notices).
- Responses to an explicit inquiry or quote request.
- Inter‑Associate communications. (Do not add promotional content.)
Appendix D — Footer & SMS Templates (Copy‑Ready)
Email footer template:
37 Dimensions LLC • 7901 4th St N, STE 300, St. Petersburg, FL 33702 • (727) 620-4229 • https://37-dimensions.com
Manage preferences or unsubscribe: {{unsubscribe_link}} • This message complies with CAN‑SPAM/CASL requirements.
SMS template:
“37D Alerts: Your request is confirmed. Reply STOP to opt out, HELP for help. Msg & data rates may apply.”