Email Marketing Policy

This Email Marketing Policy governs how LeaseAccelerator, Inc. and its affiliates, which include LeaseAccelerator Services, LLC (“LAS”) and EZLease, LLC (“EZLease”), (which are collectively referred to below as “we” or “us” and in the possessive “our”) addresses the sending of promotional emails for the purpose of marketing and advertising our products and services in compliance with email laws of the United States, The Controlling the Assault of Non-Solicited Pornography And Marketing Act (CAN-SPAM Act), the European Union, the General Data Protection Regulation (GDPR), Canada’s anti-spam legislation (CASL), and Australia’s Spam Act 2003.

Email header information: “From,” “To,” “Reply-To,” and routing information – including the originating domain name and email address – must identify us or our employee, as the initiator of the message so that the email recipient can recognize who is sending the message.

Email subject line:  The subject line must accurately reflect the content of the message.

Email footer: Email templates, header information, including our company logo and contact details, are to be in the message footer to ensure transparency.

Email content:  Each email message must:

• Clearly indicate that the message is an advertisement.
• Include our valid physical postal address registered with the U.S. Postal Service.
• Include a link to our Privacy Policy,
• Include a clear and conspicuous Opt Out method, using font, color, and type size, describing how the recipient can opt out of getting marketing email from us in the future (e.g., unsubscribe link). This may include the option to opt out of certain types of messages but must always include the option to opt out of all marketing messages from us.

Determining email requirements:  When sending messages, first determine whether the primary purpose of the message fits within one of the five categories of a “transactional or relationship” message as set out in the CAN-SPAM Act. If it meets one of the five criteria, it does not need to include an unsubscribe link.

If it does not meet any of the five criteria, you must include information for recipients to opt out of further marketing messages.

In accordance with the CAN-SPAM Act, the primary purpose of an email is transactional or relationship if it consists only of content that:

1. Facilitates, completes, or confirms a commercial transaction that the recipient already has agreed to;
2. Gives warranty, recall, safety, or security information about a product or service the recipient bought;
3. Notifies the recipient about a change in the terms or features of a membership, subscription, account, loan or other ongoing commercial relationship; notifies the recipient of a change in their standing with respect to that ongoing commercial relationship; or provides regular, periodic account balance information to the recipient;
4. Provides information about an employment relationship or employee benefits; or
5. Delivers goods or services as part of a transaction that the recipient already has agreed to.

Opt out approach

Any opt-out mechanism we offer must:

• • Be able to process opt-out requests for at least 30 days after the original message is sent.
  • Honor an email recipient’s opt-out request within 10 business days.
  • Be free of charge.
  • Not require the recipient to provide any personally identifying information beyond an email address, or make the recipient take any step other than sending a reply email or visiting a single page on an Internet website as a condition for honoring an opt-out request.

Once an opt out request is received, we must not sell or transfer those email addresses outside LeaseAccelerator, even in the form of a mailing list.

Mailing lists

• Build our mailing lists using registration forms for lead magnets that may include content, webinars, trials, and demonstrations, as well through our, and other, go-to-market subscription platforms.
• Regularly review mailing lists to avoid sending emails to individuals who have previously asked to be removed.

Non-US opt-in consent 

When using email marketing outside the US, we must:

• Offer an opt-in mechanism for email recipients in Canada, the European Union, and Australia.
• Document consent of opt-in.
• Maintain consent records in our customer data platform.
• Regularly review consents to avoid sending emails to individuals outside of the United States who have not provided consent.