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#869865 - 12/10/07 06:07 PM Email Advertising
Marnie Offline
Gold Star
Joined: Nov 2007
Posts: 437
Our marketing department is considering sending marketing emails to our existing customers, using a third party vendor. Our current privacy policy says we don't share except for servicing, etc., so I am wondering if by using the 3rd party, we would have to change this and provide the opt out disclosures as we will now be sharing for marketing purposes. If we merely give this firm the customers email address and nothing more, would we have to change the privacy policy as long as we disclosure on the email a link where they can notify us to discontinue emails?

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#871915 - 12/12/07 11:18 PM Re: Email Advertising Marnie
Baker Offline
Platinum Poster
Joined: Nov 2005
Posts: 777
Washington State
Aren't you only using the vendor to provide a service for your bank? It doesn't sound like you are sharing their information with the vendor for them to market their own product to them. I think that would make a difference.

I would think that you are still only using a servicing vendor and would only need to provide the opt out for e-mail advertisements under CAN SPAM.

This is just my opinion off the top of my head.

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#1178652 - 05/07/09 10:26 PM Re: Email Advertising Baker
tjbanker Offline
Gold Star
Joined: Jun 2002
Posts: 310
This same marketing option is being investitated at our institution. I am versed in the CAN-SPAM Act but I am wondering about Privacy. If we state in our Privacy Policy that we may disclose information to companies that perform marketing services on our behalf such as name, address, do I need to modify the privacy policy to include email addresses? I am thinking yes. I am also checking out the confidentiality agreement of the third party email marketer and we will have the opt out feature in the emails. Any advice is appreciated. Thanks!

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