I'm doing a job for a very large mortgage company (if I said the name, you'd know it). They have literally tens of thousands of mortgage brokers they work with across the country. They want me to set up an email campaign for groups around the country, inviting them to attend a corporate seminar about ways in which they can help boost these brokers' business. Mind you, these are existing customers of this company, who regularly receive emails from them, BUT they have not ever actually opted in to receive this invitation. Would you say this counts as SPAM or not? I was planning on having a link in the email where the recipient could respond with "Please do not contact me regarding this query again," or something like that.
If you take a look at a document we've prepared,
It kind of sounds like since these users haven't explicitly agreed to receiving emails that they might not be allowed.
Surely it depends on the answer to this:
"these are existing customers of this company, who regularly receive emails from them"
Are these 'regular emails' promotional messages/newsletters or just account management type regular messages?
If the latter, then definately no.
If the former, IMHO it would be OK as the invitation campaign is same type of promotional email they arlready receive.