CASL Compliance
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> This document has been drafted from standard templates. It has NOT been reviewed by legal counsel. DO NOT publish or enforce until a Canadian lawyer (Ontario-licensed) has reviewed, amended, and approved. > Last drafted: 2026-04-19
CASL Compliance Statement
Company: Aletheos Technologies Inc., an Ontario corporation with its registered office at 4005 Don Mills Road, Toronto, ON M2H 3J9, Canada (hereinafter "Aletheos") Jurisdiction: Province of Ontario, Canada Effective Date: [TO BE SET BY LAWYER UPON APPROVAL] Privacy Officer: privacy@aletheos.tech Version: DRAFT-1.0
1. Introduction and Scope
1.1 This CASL Compliance Statement ("Statement") describes how Aletheos complies with Canada's Anti-Spam Legislation (S.C. 2010, c. 23) ("CASL") in connection with its commercial electronic messages ("CEMs"), electronic marketing, transactional communications, and software installation or update practices.
1.2 CASL applies to all commercial electronic messages sent to or from Canadian electronic addresses. Aletheos is committed to complying with CASL for all CEMs it sends, regardless of whether the recipient is in Canada.
1.3 This Statement is intended for external transparency and should be read together with our Cookie Policy and Privacy Policy.
1.4 Privacy Officer Contact: privacy@aletheos.tech
2. What Is a Commercial Electronic Message (CEM)
2.1 Under CASL, a CEM is any electronic message (including email, SMS, and social media messages) sent to an electronic address that has, as one of its purposes, encouraging participation in a commercial activity — including promoting a product, service, or brand, or promoting a person as a party to a business transaction.
2.2 The following types of messages from Aletheos are CEMs under CASL: (a) Marketing emails (promotions, new features, plan upgrades, special offers); (b) Re-engagement emails to inactive subscribers; (c) Referral program invitations; (d) Newsletters and product updates that include promotional content.
2.3 The following types of messages are not CEMs and are exempt from CASL consent requirements (but are still subject to identification and unsubscribe requirements where practicable): (a) Transactional messages: account confirmations, password resets, invoices, receipts, subscription confirmations, and cancellation confirmations; (b) Security notifications: alerts about suspicious activity or data breach notifications; (c) Service notifications required to perform a contract already in place with the recipient; (d) Messages sent in response to a direct inquiry or complaint from the recipient.
3. Consent Mechanism
3.1 Express Consent Required. Before sending any CEM to a recipient, Aletheos obtains express consent as defined under CASL. Express consent means the recipient clearly agreed to receive CEMs from Aletheos by taking a positive action (e.g., checking a clearly labelled opt-in checkbox).
3.2 How We Obtain Express Consent. Express consent is collected: (a) At account registration, through an unchecked opt-in checkbox (not pre-selected) with text such as: "Yes, I would like to receive product updates, promotions, and news from Aletheos by email. You may unsubscribe at any time." Consent to terms of service does NOT constitute consent to receive CEMs — these are separate checkboxes. (b) Through any other consent form or mechanism that clearly identifies the sender (Aletheos), describes the type of messages to be sent, and includes our mailing address and unsubscribe mechanism.
3.3 Implied Consent. CASL permits sending CEMs on the basis of implied consent in limited circumstances, for example, where there is an existing business relationship within the past 24 months. Aletheos relies on implied consent only to the extent permitted by CASL and maintains records documenting the basis for implied consent where applicable.
3.4 No Bundled Consent. Consent to receive CEMs is never bundled with consent to terms of service, a privacy policy, or any other agreement. Each consent is obtained separately.
4. Sender Identification
4.1 Every CEM sent by Aletheos will clearly identify: (a) Sender Name: Aletheos Technologies Inc.; (b) Mailing Address: 4005 Don Mills Road, Toronto, ON M2H 3J9, Canada; (c) Contact Information: legal@aletheos.tech and/or the applicable team email address; (d) Website: https://aletheos.tech.
4.2 If a CEM is sent on behalf of Aletheos by a third-party service (e.g., SendGrid), both Aletheos and the third party may be identified as senders.
5. Unsubscribe Mechanism
5.1 Every CEM includes an unsubscribe mechanism. Each CEM sent by Aletheos will include a clearly visible and easily accessible unsubscribe link or instruction that allows the recipient to opt out of future CEMs at no cost to them.
5.2 Unsubscribe Processing Time. Aletheos will honor all unsubscribe requests within 10 business days of receiving the request. After this period, Aletheos will not send the recipient any further CEMs, except: (a) Transactional or service messages as described in section 2.3; and (b) Messages for which the recipient subsequently provides new express consent.
5.3 How to Unsubscribe. Recipients may unsubscribe by: (a) Clicking the "Unsubscribe" link in the footer of any CEM; (b) Emailing unsubscribe@aletheos.tech with "Unsubscribe" in the subject line; or (c) Updating communication preferences in their account settings.
5.4 No Conditions on Unsubscribe. Unsubscribing from CEMs is always free and does not require the recipient to log in, create an account, or provide personal information beyond their email address.
6. Record-Keeping
6.1 Aletheos maintains records of all consent obtained for CEMs, including: (a) The method of consent (express or implied); (b) The date and time consent was given; (c) The form or interface through which consent was collected; (d) The version of consent language in place at the time; (e) The identity of the consenting individual (email address).
6.2 Records are retained for a minimum of 3 years after the last CEM sent to the recipient, in accordance with CASL obligations.
6.3 These records are maintained in Aletheos's customer relationship management systems. In the event of a CASL investigation or complaint, Aletheos will cooperate fully with the Canadian Radio-television and Telecommunications Commission ("CRTC").
7. Third-Party Email Service Providers
7.1 Aletheos uses [SendGrid — CONFIRM CURRENT EMAIL PROVIDER] to send CEMs. SendGrid operates as a sub-processor. Aletheos remains responsible for CASL compliance in all messages sent through third-party providers.
7.2 Aletheos will ensure that any third-party email provider it uses complies with applicable Canadian law and CASL's requirements, including implementing unsubscribe suppression lists.
8. Software Installation
8.1 CASL also applies to installing computer programs on recipients' devices. Aletheos's platform is a web-based SaaS application. If Aletheos in the future releases any downloadable software, browser extensions, or desktop agents, it will: (a) Obtain express consent from the user before installation; (b) Clearly describe what the software does, including any feature that collects personal information, alters settings, or communicates with external servers; (c) Provide a clear uninstall mechanism.
9. Compliance Training and Internal Policy
9.1 Aletheos will ensure that all staff and contractors involved in sending CEMs or managing customer communications are trained on CASL requirements before undertaking those activities.
9.2 Aletheos will review this Statement and its internal CASL procedures at least annually.
10. Filing a Complaint
10.1 If you believe Aletheos has sent a CEM in violation of CASL, or has failed to honor your unsubscribe request within 10 business days, you may: (a) Contact us at legal@aletheos.tech with a description of your complaint; (b) File a complaint with the CRTC's Spam Reporting Centre at [https://www.fightspam.gc.ca]; or (c) File a complaint with the Office of the Privacy Commissioner of Canada at [https://www.priv.gc.ca] if the complaint involves personal information.
11. Governing Law and Disputes
11.1 Governing Law: This Statement and Aletheos's CASL compliance obligations are governed by Canada's Anti-Spam Legislation (S.C. 2010, c. 23), the laws of the Province of Ontario, and the federal laws of Canada applicable therein.
11.2 Disputes: Any dispute arising out of or related to this Statement shall be submitted to the courts of the Province of Ontario, Canada.
Contact: legal@aletheos.tech | Privacy Officer: privacy@aletheos.tech Governing Law: Province of Ontario, Canada, and the federal laws of Canada applicable therein. Disputes: Courts of Ontario, Canada.