1. Policy Statement

DemandTech is unwavering in its commitment to full compliance with Canada’s Anti-Spam Legislation (CASL).

CASL (An Act to Promote the Efficiency and Adaptability of the Canadian Economy by Regulating Certain Activities that Discourage Reliance on Electronic Means of Carrying Out Commercial Activities) regulates the sending of commercial electronic messages (CEMs) to or from Canada. DemandTech, located at Regal Tower, Business Bay, Dubai - 00000, ensures that all CEMs sent to Canadian recipients or using Canadian systems adhere to CASL’s strict requirements for consent, content identification, and unsubscribe mechanisms.

This policy applies to all employees, contractors, affiliates, and third-party vendors acting on behalf of DemandTech. Our goal is to foster trust with our B2B audience by ensuring transparent, compliant, and respectful communication practices.

2. Policy Details

This CASL Compliance Policy provides a comprehensive framework for ensuring that DemandTech’s electronic communications comply with all aspects of CASL. It covers:

• Obtaining and documenting consent for sending CEMs
• Ensuring proper identification and contact information in CEMs
• Providing clear and accessible unsubscribe mechanisms
• Maintaining accurate records of consents and relationships
• Ensuring third-party compliance with CASL

Additional internal procedures, guidelines, and training programs may be implemented to support this policy and ensure ongoing compliance.

3. Application and Scope

This policy applies to:

• All DemandTech employees, contractors, and representatives who send or authorize CEMs to or from Canada
• All systems, platforms, or tools used to send CEMs, including email marketing platforms (e.g., HubSpot, Mailchimp)
• Third-party vendors or partners sending CEMs on behalf of DemandTech

The policy covers all CEMs sent to Canadian recipients or originating from Canadian systems, regardless of the sender’s location.

4. Consent Requirements

Under CASL, DemandTech must obtain consent before sending CEMs, unless an exemption applies. We recognize two types of consent:

• Express Consent: Obtained when you explicitly agree to receive CEMs, such as by checking a box during webinar registration or subscribing to our newsletter. Express consent must be:
  • Clear and affirmative (e.g., an unchecked box or opt-in form)
  • Separate from other terms (e.g., not bundled with website terms of use)
  • Verifiable (e.g., timestamped records in our CRM)
• Implied Consent: Applies in specific circumstances, such as:
  • Existing Business Relationship (EBR): You have engaged with us (e.g., downloaded a whitepaper or attended a webinar) within the past 2 years.
  • Publicly Available Contact: Your business contact information is published online (e.g., company website) without restrictions on commercial use.
  • Inquiry-Based Exemption: You have contacted us with an inquiry, allowing CEMs related to that inquiry for up to 6 months.

Verbal consent (e.g., during a phone call) is documented with details such as date, time, and context. All consent records are stored securely in our CRM system (e.g., Salesforce, HubSpot) for compliance verification.

5. Form and Content of Commercial Electronic Messages

Every CEM sent by or on behalf of DemandTech must include the following mandatory elements:

• Sender Identification: Clearly identify DemandTech as the sender.
• Contact Information: Include our physical mailing address: Regal Tower, Business Bay, Dubai - 00000, and a valid email or phone number.
• Unsubscribe Mechanism: Provide a clear, free, and functional unsubscribe option (e.g., a clickable link or reply instruction) that remains active for at least 60 days after the message is sent.
• Purpose Clarity: Clearly state the commercial purpose of the message (e.g., promoting a webinar or whitepaper).

We ensure that all CEMs are truthful, non-misleading, and compliant with CASL’s formatting requirements.

6. Storage of Consent and Relationship Details

DemandTech maintains detailed records of all consents and business relationships to demonstrate CASL compliance. These records include:

• Consent Details: Date, time, method (e.g., form submission, verbal agreement), and specific permissions granted.
• Relationship Details: Evidence of EBRs, such as content downloads, webinar registrations, or inquiries.
• Contact Information: Business email, phone, or other details provided by you.

Records are stored securely in our CRM system and retained for a minimum of 3 years after the last interaction, unless a longer retention period is required by law. Inactive contacts are reviewed periodically, and data is anonymized or deleted after 3 years of inactivity.

7. Definition of Commercial Electronic Messages (CEMs)

A Commercial Electronic Message (CEM) is any electronic message (e.g., email, SMS, direct message) that encourages participation in a commercial activity, such as promoting DemandTech’s services, content, or events. Examples include:

• Invitations to register for webinars
• Notifications about new whitepapers or case studies
• Offers for sponsored or co-branded content
• Announcements of industry events or promotions

Exempt Messages include:

• Transactional messages (e.g., content download confirmations)
• Customer support responses
• Responses to direct inquiries from users
• Messages required by law or regulation

We carefully categorize messages to ensure only CEMs are subject to CASL’s consent and content requirements.

8. Third-Party Compliance

Any third-party vendors or partners (e.g., email marketing providers, event organizers) sending CEMs on behalf of DemandTech must:

• Sign a CASL-compliant data processing agreement
• Adhere to our consent and content requirements
• Maintain accurate records of consents and communications
• Provide unsubscribe mechanisms consistent with CASL

We conduct due diligence on all third parties and regularly audit their compliance to ensure alignment with CASL standards.

9. Unsubscribe Mechanism

You can unsubscribe from our CEMs at any time.
To stop receiving marketing emails or other CEMs, use one of the following methods:
→ Visit our Unsubscribe Page
→ Click the “Unsubscribe” link in any CEM
→ Email dpo@demandtech.com with the subject “Unsubscribe”

Unsubscribe requests are processed within 10 business days, as required by CASL. You may continue to receive transactional or non-commercial messages (e.g., content download confirmations) unless you request complete data deletion (see Section 4.8 of the Privacy Policy).

10. Policy Administration

This CASL Compliance Policy is maintained and overseen by DemandTech’s Compliance Team, led by our Compliance Officer. The team is responsible for:

• Developing and updating internal CASL procedures
• Training employees and contractors on CASL requirements
• Monitoring compliance across all departments and systems
• Addressing user inquiries or complaints related to CEMs

The policy is reviewed at least annually to ensure alignment with CASL regulations and industry best practices.

11. Review and Approvals

The CASL Compliance Policy undergoes a formal review process annually or whenever significant regulatory changes occur. Reviews are conducted by the Compliance Team, with input from legal counsel specializing in Canadian privacy law.

Any amendments to this policy require approval from DemandTech’s Board of Directors or an authorized executive committee. Approved changes are communicated to all relevant stakeholders, including employees, contractors, and third-party vendors.

12. Enforcement and Audit Procedures

DemandTech enforces strict adherence to this CASL Compliance Policy. Violations, such as sending CEMs without consent or failing to include required content, may result in:

• Internal disciplinary action, up to and including termination
• Contractual penalties for third-party vendors
• Reporting to regulatory authorities, if required

We conduct regular audits of our email marketing practices, consent records, and third-party compliance to ensure ongoing adherence to CASL. Audit findings are reviewed by the Compliance Team and addressed promptly.

13. Contact Information

For questions, concerns, or complaints regarding our CASL compliance or CEM practices, please contact:

Canadian residents may also contact the Canadian Radio-television and Telecommunications Commission (CRTC) to report suspected CASL violations.