Canada’s Anti-Spam Legislation (CASL) Compliance Policy
Last Updated: October 30, 2025


Table of Contents

1. Policy Statement

TechB2BSolutions and/or its related corporations (collectively “TechB2BSolutions”)

This document sets forth the policy of TechB2BSolutions and is designed to provide reasonable assurance that (i) a consistent process is followed with respect to the dissemination of commercial electronic messages to TechB2BSolutions clients and prospective clients in Canada, and (ii) TechB2BSolutions employees sending commercial electronic messages from and/or to a computer system(s) in Canada comply with the requirements of CASL.

The TechB2BSolutions Anti-Spam Policy (“Anti-Spam Policy”) and related procedures (the “CASL Procedures”) require that all TechB2BSolutions employees sending CEMs (Commercial Electronic Messages) 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 TechB2BSolutions, or using an TechB2BSolutions email address or using a device owned or provided by TechB2BSolutions, comply with CASL.

2. Policy Details

The Anti-Spam Policy describes TechB2BSolutions’ commitments relating to the provisions of CASL and electronic messages of a commercial nature sent to TechB2BSolutions clients, prospective clients, and others, as applicable. From time to time, TechB2BSolutions may implement additional policies, procedures and/or practices as it relates to anti-spam measures.

3. Application

This Policy applies to TechB2BSolutions employees 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 TechB2BSolutions’s operations, the Anti-Spam Policy has been adopted in compliance with the requirements of CASL, and TechB2BSolutions is committed to complying with CASL. All other TechB2BSolutions 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.

5. Form and Content of CEMs

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

TechB2BSolutions takes steps to require that any third-party service provider who sends CEMs on behalf of TechB2BSolutions complies with CASL.

6. Storage of Relationship Details

A key component of complying with CASL involves maintaining records of TechB2BSolutions’s relationships with clients and prospective clients.

Each business unit of TechB2BSolutions 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 TechB2BSolutions clients and prospective clients.

Clients” are defined as those organizations or individuals who have at least one open account or a contractual relationship with TechB2BSolutions at the relevant time. Organizations or individuals who have closed their last remaining account or terminated their contract with TechB2BSolutions are not considered TechB2BSolutions 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 TechB2BSolutions ceases sending CEMs to the TechB2BSolutions client or prospect.

7. Commercial Electronic Messages

All TechB2BSolutions employees 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:

  1. promotes, offers, or advertises TechB2BSolutions or TechB2BSolutions’s products or services, or employees, or contacts;
  2. solicits business for TechB2BSolutions or TechB2BSolutions’s employees or contacts; and
  3. any other similar message that encourages participation in commercial activity.

Examples include:

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

Messages that TechB2BSolutions employees email each other internally using a device that TechB2BSolutions owns or provides, or using an TechB2BSolutions email address, should be related to TechB2BSolutions. TechB2BSolutions employees may not internally email each other offers, promotions, advertisements, or referrals unrelated to TechB2BSolutions business without the internal recipient’s verbal consent.

8. Compliance by Third Parties

All third-party contracts with service providers who may send CEMs on behalf of TechB2BSolutions must contain contractual clauses obligating the service provider to comply with CASL including the form and content requirements of CEMs.

9. 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 TechB2BSolutions 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 TechB2BSolutions and its subsidiaries, and 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://techb2bsolutions.com/unsubscribe
→ Or emailing: dpo@techb2bsolutions.com with ‘Unsubscribe’ in the subject line.

10. Policy Administration

The Anti-Spam Policy is maintained by the Compliance department of each TechB2BSolutions 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 TechB2BSolutions Board or equivalent.

11. Review and Approvals

TechB2BSolutions Compliance is responsible for the review and revision of this Policy, subject to the approval of the respective TechB2BSolutions Board or equivalent. This Policy is subject to review on an annual basis, or otherwise as needed.

12. Enforcement and Audit

Compliance with this Policy, and any related procedure, may be reviewed by TechB2BSolutions 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 Human Resources Disciplinary policy or procedure.

13. Contact Information

Data Protection & Compliance Officer
TechB2BSolutions
The Citadel Tower, Business Bay, Dubai - 00000, UAE
Email: dpo@techb2bsolutions.com