Email Marketing & Anti-Spam Policy

1. CAN-SPAM Compliance

Evolution Workforce abides by all requirements of the U.S. CAN-SPAM Act for commercial emails. We understand that CAN-SPAM applies to all marketing emails – including business-to-business communications – and we strictly adhere to its standards to avoid spam and ensure lawful messaging. In particular, every marketing email we send is designed to meet the following criteria:

• Accurate Sender Information: Our emails always accurately identify Evolution Workforce as the sender. The “From,” “To,” and reply-to addresses and associated routing information clearly reflect our company name and domain. We do not use false or misleading header information or pretend to be anyone other than Evolution Workforce.

• Honest Subject Lines: The subject line of our emails truthfully represents the content of the message. We do not use deceptive subject lines or tactics that mislead recipients about what the email contains.

• Identification as Advertisement: If an email contains promotional content or constitutes a commercial solicitation, we make sure it’s clear that it’s a marketing message. We include language or formatting that notifies the recipient that the email is an advertisement or contains promotional material, as required by law.

• Physical Mailing Address: Every marketing email includes our valid physical postal address in the footer. Our current mailing address is 888C 8^th Ave, Unit 122, New York, NY 10019, which is clearly listed in email footers. This ensures recipients know our legitimate business location as required by CAN-SPAM.

• Clear Opt-Out Instructions: All marketing emails from Evolution Workforce include a clear and conspicuous explanation of how to opt out of future emails. Typically, this is provided via an “Unsubscribe” link at the bottom of the email. The opt-out language is easy to see, read, and understand, informing recipients that they can stop receiving marketing messages at any time.

• Prompt Honor of Unsubscribe Requests: We honor all opt-out requests promptly and within the timeframe required by law. Specifically, if a recipient unsubscribes or otherwise asks to be removed from our mailing list, we will stop sending marketing emails to that address within 10 business days or sooner. Our unsubscribe mechanism remains functional for at least 30 days after we send an email, and we monitor it to ensure requests are properly captured.

• No Third-Party List Sharing of Opt-Outs: When someone opts out of our emails, we will not sell, rent, or transfer their email address to any third party for marketing purposes. The only exception is that we may share such addresses with contracted service providers solely for the purpose of facilitating suppression (ensuring the address is blocked from future mailings) in compliance with CAN-SPAM. We do not provide our email lists to outside parties to market to, nor do we purchase lists from third parties.

• Accountability for Compliance: Even when we use third-party email services or tools (such as HubSpot or Mailchimp) to distribute our emails, Evolution Workforce remains responsible for ensuring compliance with anti-spam laws. We carefully select email service providers that support compliance (for example, by automatically including our address and unsubscribe links), and we monitor our email campaigns. We do not attempt to contract away our legal responsibility — both Evolution Workforce and any vendor we use can be held responsible for compliance, so we diligently oversee our email practices.

By following these CAN-SPAM guidelines, we aim to not only stay within the law but also uphold our reputation and deliver emails that are respectful of our recipients’ time and consent.

2. Marketing Consent Rules

We prioritize a permission-based approach to email marketing. This section outlines how we obtain and manage consent for different types of contacts, as well as our practices regarding email list sourcing:

• Website Sign-Ups and Subscribers: For individuals who sign up on the Evolution Workforce website (such as to receive newsletters, updates, or to inquire about our services), we obtain explicit consent before sending marketing emails. Our sign-up forms include clear language (and a checkbox acknowledgment when required) indicating that by providing their email address, the user agrees to receive marketing or promotional communications from us. For example, our standard web form process requires users to explicitly accept our Privacy Policy and Terms of Use and opt in to communications. We may also employ a confirmation email (double opt-in) when appropriate, meaning the subscriber must confirm their email address and interest by clicking a link in a follow-up email. This ensures that we only send emails to people who genuinely want to hear from us, reducing unwanted messages and ensuring compliance with best practices and platform requirements.

• Client and Prospect Communications: If you are an existing client of Evolution Workforce or have engaged with us in a business context, we may send you relevant information about our services, updates, or new offerings. We consider our clients and known business contacts to have a legitimate interest in our services. However, we still respect your choices – any marketing-related email to clients or past prospects will include an unsubscribe option, and we will honor any opt-out request just as we would for non-clients. We do not assume that having a business relationship gives us unlimited license to send marketing emails; we treat all recipients with the same respect for their preferences.

• Cold Outreach to Businesses: As part of our growth efforts, Evolution Workforce may occasionally engage in carefully targeted outreach to businesses (especially U.S.-based companies) that have publicly posted job listings or otherwise indicated a potential need for our services. We approach such outreach with sensitivity and compliance in mind. This means:

  • We only use business contact information that is publicly available (for example, an email address provided on a company’s website or job posting for recruitment contacts) or that was obtained through lawful means. We do not use automated harvesting tools in violation of any platform’s terms, and we respect any indications that a business does not wish to be contacted.

  • Our cold outreach emails clearly explain why we are contacting the business. For instance, we might note that we saw a job posting for a role and want to introduce Evolution Workforce’s employer-of-record services as a solution for hiring international talent. We make it evident that the email is a one-time introduction or part of a limited campaign, and not part of a mass spam mailing.

  • Even in a first-contact scenario, we include all the CAN-SPAM required elements (identification, our address, and an unsubscribe mechanism). Recipients of these outreach emails can easily opt out of any future communications. If a business indicates that it is not interested or requests no further contact, we will promptly refrain from sending additional emails to that business contact.

  • We do not send repeated unsolicited emails to the same prospect if there is no response or if they have opted out. Our policy is to give businesses the information once or a small number of times in a respectful manner, and then desist unless they engage with us or consent to further communication. This approach ensures that our cold outreach efforts remain within legal bounds and do not cross into harassment or spam.

• No Purchasing of Email Lists: Evolution Workforce does not buy bulk email lists from third-party sources for marketing purposes. Our contact lists are built organically — through website sign-ups, networking, direct inquiries, referrals, and research into companies that fit our target profile. By refraining from using purchased or scraped lists, we help ensure that the people we email have a higher likelihood of expecting to hear from us or having an interest in our services. It also helps maintain compliance with industry best practices and the terms of service of our email platforms.

3. Unsubscribe Mechanisms

Stopping future emails from Evolution Workforce is simple and user-friendly. We have put multiple mechanisms in place to ensure that anyone who no longer wishes to receive our marketing communications can easily opt out:

• Unsubscribe Link in Every Email: Every marketing or promotional email we send contains an “Unsubscribe” link (usually located at the bottom of the email). This link is clearly labeled and easy to find. By clicking it, a recipient can automatically remove themselves from our mailing list or at least from that specific type of mailing. We use email marketing tools (currently HubSpot, and potentially Mailchimp in the future) which automatically include and manage this unsubscribe link and process.

• One-Click or Simple Process: Our unsubscribe process is designed to require no more than a single action. Recipients will not be made to log into an account, enter a password, or fill out any survey in order to unsubscribe (though we may optionally ask for feedback on why they are unsubscribing, such feedback is not required to complete the opt-out). In most cases, clicking the unsubscribe link immediately flags that email address as unsubscribed in our system. In some cases, it may direct the user to a preference center or confirmation page – but even then, the option to fully opt out of all marketing emails is prominently provided and can be accomplished with one additional click.

• Email or Contact Opt-Out: In addition to the automated link, recipients can also opt out by contacting us directly. For example, replying to a marketing email with a request to “unsubscribe” or “stop” will be honored. Users may also email us at our official contact (such as a support or info email address provided in the message or on our website) to ask to be removed. We treat these requests the same as if the person had clicked the formal unsubscribe link; our team will manually ensure the email address is suppressed in our mailing lists.

• No Fees or Barriers: We do not charge any fee or impose any onerous requirements for unsubscribing. Opting out is free and straightforward. We will never require a recipient to submit any personal information beyond the email address (which we already have) to effectuate an unsubscribe. For instance, we won’t force someone to provide a reason for unsubscribing or to navigate through multiple pages of offers to confirm their choice.

• Timely Processing: As mentioned in the CAN-SPAM section, we process unsubscribe requests promptly – generally immediately via the automated system, and in no case later than 10 business days from the request. Our email service platform continuously updates our subscription lists, and we regularly sync and review opt-out requests to make sure no unsubscribed address is accidentally contacted. Once you have opted out, that email address is tagged in our systems so that it will not be included in future marketing sends.

• Scope of Unsubscribing: Our unsubscribe mechanism typically removes you from all general marketing communications from Evolution Workforce. We may provide options for selective unsubscribing (for example, the ability to unsubscribe from newsletter emails but still receive product announcements, if applicable), but the default action will always include the ability to stop all marketing emails from us. If you opt out of all marketing emails, we will not send further promotional communications to you. However, please note that this does not affect transactional or relationship emails: if you are a client or user of our services, we may still send emails for non-marketing purposes, such as account information, legally required notices, responses to specific inquiries, or other service-related communications. Those emails are considered separate from marketing communications and are governed by our other agreements and policies.

• Confirmation and Issues: After you unsubscribe, you may receive a final confirmation message, or the system may simply stop sending to you. If you ever find that you have unsubscribed but are still receiving marketing emails from us after 10 business days, please contact us at info@evolution-workforce.com so we can investigate and resolve the issue. We take opt-out compliance seriously and will work to promptly correct any oversight.

• No Resubscription Without Consent: Once unsubscribed, your email remains off our marketing list unless you take an action to resubscribe or otherwise give us permission again. For example, if you unsubscribed but later sign up on our website with the same address to download a new whitepaper and you opt in to emails at that time, we will treat that as a new consent (though we may send a quick confirmation in case it was not you, to be safe). Absent a new affirmative consent from you, we will not re-add unsubscribed addresses to our active marketing lists, even if our system may retain the data for record-keeping.

4. Transparency About Email Practices

Evolution Workforce believes in being transparent about how we conduct our email marketing, what recipients can expect from us, and how we handle information related to email campaigns. This commitment to transparency builds trust and ensures that our practices align with our values and legal obligations. Key aspects of our email practices include:

• Honest and Open Communication: We strive to ensure that recipients know why they are getting an email from us. In every marketing email, we may include a brief statement such as, “You are receiving this email because you signed up on our website” or “You are receiving this because we thought our services could assist your business based on your recent job posting,” etc. Our goal is that no recipient should be left wondering how we got their contact information. We only send emails to contacts obtained in the ways described in the consent section above, and we’re upfront about that origin.

• Sender Identification: Our emails clearly identify Evolution Workforce and, when applicable, a specific department or team (for instance, “Evolution Workforce Sales” or “Evolution Workforce Marketing Team”). We do not attempt to hide our identity or mask our sending email address. Typically, our marketing emails will come from a recognizable email address (such as *@evolution-workforce.com) and include our name in the sender field. We also include contact information (such as our company address and sometimes phone number or a general contact email) in the footer of each email. This level of identification aligns with legal requirements and also assures recipients that the email is legitimately from us, not a phishing attempt.

• Content and Frequency: We aim to send content that is relevant, professional, and valuable to our recipients. Our emails may include company news, updates on our services, industry insights, case studies, or special promotions related to Evolution Workforce’s employer-of-record and remote workforce solutions. We avoid irrelevant or excessive emailing. In terms of frequency, we strive not to overload anyone’s inbox. For instance, we might send a monthly newsletter and occasional announcements when we have important information to share, but we do not send daily marketing emails to individuals unless there’s a specific, consented-to reason. We want our communications to be anticipated and welcome, not intrusive. The content will always be presented in a tasteful and lawful manner — free of any misleading claims, and compliant with decency standards and other content regulations.

• Use of Marketing Service Providers (HubSpot/Mailchimp): As mentioned, we currently utilize HubSpot as our customer relationship management (CRM) and email marketing platform. HubSpot helps us manage subscriber lists, track email engagement, and ensure compliance (by automatically including the required unsubscribe link and physical address in emails). We may in the future use Mailchimp or similar email service providers for some campaigns or if we transition platforms. Any provider we use is a well-established company that likewise adheres to anti-spam laws and has their own strict compliance standards. By using these platforms, we also benefit from additional safeguards: for example, these platforms have systems to prevent high-volume spam and often will not allow emails to be sent unless they meet basic compliance criteria. They also keep records of subscription status (opt-ins and opt-outs) which help us maintain accurate records. We remain transparent that your email address and certain engagement data (opens, clicks, etc.) may be processed by these third-party platforms on our behalf solely for the purpose of executing our email campaigns. We have agreements in place with such providers to ensure they protect your information and do not use it for their own purposes beyond providing the service to us.

• Privacy and Data Protection: Handling email addresses involves handling personal data. Our use of your email and any other personal information in the context of email marketing is governed by our Privacy Policy. In summary, any personal data we collect (such as your name, email address, company, etc. when you sign up or correspond with us) is used in accordance with that Privacy Policy – which means we use it for the stated purposes (e.g., to send you emails you requested or that we believe are of legitimate interest), and we protect it with appropriate security measures. We do not sell personal data to third parties. Within Evolution Workforce, access to email marketing lists is restricted to authorized personnel who need to use it for marketing or customer relations purposes. We maintain safeguards to prevent unauthorized access or misuse of your contact information.

• Confidentiality and Content Approval: We are mindful of our client relationships and confidentiality obligations when crafting email content. We will never disclose confidential details about any client, partner, or individual in our marketing emails. If we reference a client’s success story or use a testimonial, we will do so only with that client’s permission and in line with any agreements (such as the MSA) we have with them. For example, our MSA generally allows us to mention a client’s name and the general nature of services provided unless the client requests otherwise, but it forbids revealing confidential information. We strictly abide by that: any case study or mention will be factual, generic in describing the service (e.g., “helped X company hire remote engineers in Y country”), and approved internally (and by the client if needed) before being sent out. Should a client ever ask us not to use their name or story in our marketing, we will immediately cease any such reference out of respect for that request. Our marketing team and legal team coordinate to ensure all email content meets our legal and contractual obligations, as well as our high standards for professionalism.

5. Compliance Monitoring and Updates

We actively monitor changes in email marketing laws and best practices. As regulations evolve or as our reach expands, we may update this policy and our procedures to maintain compliance. If the U.S. laws change or state-level anti-spam laws impose additional requirements, we will adjust accordingly. Any significant changes to this Email Marketing & Anti-Spam Policy will be communicated by updating the policy on our website (with a new effective date) and/or through an email notification or announcement on our site. We encourage recipients and users to periodically review this policy for the latest information on our practices.

6. Contact and Questions

Transparency includes being available to answer questions. If you have any questions about this policy or our email practices, or if you believe you have received an email from us that violates this policy or your preferences, please contact us at info@evolution-workforce.com. We will respond and address concerns promptly. Your feedback is important to us as we continuously strive to improve our communications and ensure they are welcome and compliant.

By adhering to this Email Marketing & Anti-Spam Policy, Evolution Workforce demonstrates our commitment to ethical marketing, respect for our audience’s choices, and compliance with the law. We value the trust of our users and clients and will continue to earn it through responsible email practices.