If they are not on an opt-out list you may contact them in this manner. That doesn't mean they are expecting an email or to have to react to it such as you requesting more information to proceed.
This would be transaction related based on your description and not advertising other products. It shouldn't fall under the CAN SPAM rules, but again, it can depend on what the email contains and if the customer has opted-out in the past.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell