Do you send product emails through online banking or just transactional emails?

We recently sent our online banking customers an email about getting our App through their online banking email. I am hoping that this is not considered a commercial message. We don't to have to give them the option to stop receiving emails, because we send them information about holidays, fraud tips, and statement alerts.

Do you think the App email crossed the line in to CANSPAM?

Please elaborate. How do the messages get from you to your customers? Are you sending to them to a "GoodCustomer@yourdomain.com" type of email address, or does it all happen inside your online banking system?

We send them to our online banking customers, they get an email to their personal email account saying that they have a message and then they must log into online banking to retrieve it.

The emails to these customers MIGHT be covered, but the actual message is not. CAN-SPAM only applies to "electronic mail messages", and defines that term to include ONLY messages sent through the internet to a person's public email address, ex- "GoodCustomer@yourdomain.com." Messages flowing within a closed private system are not "electronic mail messages", and so they are categorically excluded from coverage, regardless of content.

The "you've got mail" alert messages fit with the definition of an "electronic mail message", so you have to look at their content and decide whether they are "commercial" or "transaction/relationship." If part of your online banking service involves notifications of important service events and options, that sounds a lot like "relationship."