ANTI-SPAM COMMITMENT

Giroux is committed to providing transparency to outside parties with respect to the compliance of the organization’s electronic communication with Canada’s Anti-Spam Legislation, and its relevant rules and  regulations  (hereinafter  “CASL”).  

To that end, the Giroux Anti-Spam Commitment is a formal statement of rights and obligations made available to outside parties. It is intended to inform Canadian outside parties of:

This document also includes a series of answers to questions about spam and Giroux’s practices.

Application and scope

This Anti-Spam Commitment generally applies to any commercial electronic messages (“CEM”) sent by Giroux to outside parties and is protected by a range of business procedures, processes and policies to ensure that such communications are done in compliance with CASL. Giroux, in its electronic communications with Canadian outside parties, has to comply with the rules established by CASL and enforced by the Canadian Radio-television and  Telecommunications  Commission,  the  Competition  Bureau  and  the  Privacy  Commissioner  of Canada. CASL regulates all CEM, which are messages that include among their purposes, the encouragement of participation in a commercial activity.

What is Giroux doing to comply?

Giroux has adopted this Anti-Spam Commitment to provide transparency to outside parties with respect to the compliance of the organization’s electronic communication practices with CASL, as well as undertaken, amongst others, the following initiatives:

Giroux CASL compliant consent forms.  The consent of outside parties is necessary in order for Giroux to send a CEM. This consent typically must be “express”, but in certain circumstances consent can be “implied” and in others, messages are specifically exempt from consent requirements. Giroux has modified certain consent forms in order to ensure that the express consent obtained from recipients is in compliance with CASL. You can have your email address removed from Giroux’s mailing lists at any time, although even if you unsubscribe to receiving CEM  from  Giroux, you may  still receive  electronic messages from Giroux  which relate to  an ongoing business relationship or which are exempt under CASL.

Giroux email footers.  Giroux has modified its email footers to manage CASL’s consent requirements. Under CASL, all CEM sent must include certain prescribed content. For example, Giroux must clearly identify Giroux as the party sending the CEM, provide a method whereby the recipient can readily contact Giroux, such as a mailing address and one of (i) a telephone number with active response voicemail, (ii) an email address, or (iii) a web address; and provide a working unsubscribe mechanism. In consequence, CASL compliant email footers have been updated on all email communications (emails and mass mailings) sent from Giroux, in order to ensure compliance with CASL.

Giroux unsubscribe mechanisms.  Giroux has incorporated unsubscribe mechanisms into all CEMs, in order to manage CASL’s consent requirements. Under CASL, each CEM must provide a working unsubscribe mechanism, which must be processed within a maximum of 10 business days. In consequence, Giroux has set up a uniform process in order to ensure that all unsubscribe requests will be complied with. You may at any time unsubscribe from receiving CEMs from Giroux by following the process laid out in the electronic message you receive, or by contacting caslcompliance@arpentage.com. However, even if you unsubscribe to receiving CEM from Giroux, you may still receive electronic messages from Giroux which relate to an ongoing business relationship or which are exempt under CASL.

Why are you receiving a CEM from Giroux?

Types of CEMs Giroux may send you from time to time could include the following:

If you have received a CEM from Giroux and you believe that you should not have received it, please assess as to whether you have provided consent to receive CEMs from Giroux, or if an exemption applies.

When is an electronic message exempt under CASL?

If you are receiving an electronic communications from Giroux, it may be a message that is  exemptunder
CASL. This would be the case if the message is one the following:

In certain situations, your consent is not required for certain types of messages sent by Giroux, although you may still unsubscribe from future transmission of similar messages. The type of messages where Giroux does not need your consent is an electronic message that:

If you have received a message that you believe is a CEM, and you should not have, please forward this email to unsubscribecanada@arpentage.com and we will address the situation (within 10 business days).

Social media

You may be contacted by an Giroux employee via social media, such as LinkedIn, if you are connected on the social network with the Giroux employee, or if you have indicated through your preference settings the fact that you are open to receiving messages about new business opportunities or ventures. You may also be contacted if you have conspicuously published your electronic address (for instance, on a social media website), have not indicated that you did not wish to receive CEM, and the CEM sent is in connection with your business role and function.

What do you do if you no longer wish to receive CEM from Giroux?

At Giroux, we take the respect of laws very seriously. You may unsubscribe at any time from receiving CEMs, by following the process in the email footer or by contacting unsubscribecanada@arpentage.com, and we will remove you from our mailing list within ten (10) business days.

Amendment of this anti-spam commitment

From time to time, Giroux will review and update this Anti-Spam Commitment as required to keep current with rules and regulations, new technologies, standards, our business practices and outside parties’ concerns. We will post any Anti-Spam Commitment changes on this page and, if the changes are significant, we will provide a more prominent notice (including, as the case may be, email notification of Anti-Spam Commitment changes).

Questions or concerns about this anti-spam commitment?

Please communicate with our designated CASL Compliance Advisor:

Email: caslcompliance@arpentage.com

This Anti-Spam Commitment was last updated March 13, 2015

Please note that both the English and French versions of our Anti-Spam Commitment have equal legal value.