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Marketing Communications Compliance Statement

Last Updated: October 7, 2026

1. Overview

Laws in each of the markets Breakout Learning serves regulate commercial electronic messages — marketing email and similar electronic communications — by requiring a lawful basis for sending them, clear identification of the sender, and a working way to opt out. Breakout Learning Inc. is committed to handling all electronic communications with faculty, staff, students, and institutional contacts, wherever they are located, in a manner consistent with these requirements.

This statement summarizes the single standard Breakout Learning applies to all commercial electronic messages and then describes how that standard maps to the requirements of each jurisdiction in which Breakout Learning markets its services.

2. Scope

This statement covers commercial electronic messages sent by or on behalf of Breakout Learning — principally email — whose purpose is to promote Breakout Learning's products and services. It does not cover transactional and service messages, which are described below.

Breakout Learning applies one standard globally: opt-in consent, transparent sender identification, and a functioning unsubscribe mechanism in every message. This standard meets or exceeds the requirements of each jurisdiction listed in this statement.

3. Consent

Breakout Learning relies on a lawful basis of consent before sending commercial electronic messages:

  • Express consent. Marketing opt-in is collected through unchecked consent checkboxes on web forms and scheduling pages. Consent language identifies Breakout Learning as the sender, states the purpose of the communication, and advises recipients of their right to unsubscribe at any time. Pre-ticked boxes are not used.
  • Implied consent (“soft opt-in”). Where local law permits, Breakout Learning may rely on implied consent arising from an existing business relationship — for example, with an institution or individual that has purchased, or inquired about, Breakout Learning's services — limited to communications about similar products and services and to the timeframes permitted in that jurisdiction. Every such message carries the same unsubscribe mechanism as a consent-based message.
  • Records of consent. Consent source, type, and date are recorded in Breakout Learning's customer relationship management system to support the demonstrability of consent and to evidence the basis on which each contact is messaged.

4. Sender Identification

Commercial electronic messages sent by Breakout Learning identify Breakout Learning Inc. as the sender, use accurate header information and non-deceptive subject lines, and include valid contact information, including a physical mailing address.

5. Unsubscribe Mechanism

Every commercial electronic message includes a functioning, free-of-charge unsubscribe mechanism that requires nothing more than visiting a single web page, with no fee, login, or information beyond the recipient's email address. Unsubscribe requests take effect automatically through Breakout Learning's marketing platform and are honored promptly — in all cases within five business days, which meets or exceeds the timeframe required in every jurisdiction covered by this statement. The unsubscribe mechanism remains functional for at least 60 days after a message is sent.

Suppression of unsubscribed contacts is enforced automatically. Unsubscribed addresses are not sold, transferred, or shared, except as needed to honor the request.

6. Transactional and Service Messages

Messages that deliver a product or service the recipient is entitled to receive — such as session results, account notifications, and responses to direct requests — are treated as service communications and are kept separate from marketing content. They are not subject to marketing consent and do not contain promotional material.

7. Jurisdiction-Specific Notes

The standard described above applies everywhere Breakout Learning sends commercial electronic messages. The notes below identify the principal law in each jurisdiction and the points on which it adds to, or differs from, that common standard.

7.1 Canada — Canada's Anti-Spam Legislation (CASL)

  • Law. Canada's Anti-Spam Legislation (S.C. 2010, c. 23), enforced by the Canadian Radio-television and Telecommunications Commission (CRTC). The underlying personal information is handled in accordance with PIPEDA, as described in the Canada section of our Privacy Policy.
  • Consent. Express consent is collected as described above. Implied consent is relied on only within the categories and timeframes CASL defines — for example, an existing business relationship within the two-year and six-month windows the Act sets.
  • Identification and unsubscribe. Each message identifies Breakout Learning and provides a mailing address and contact information. The unsubscribe mechanism remains valid for at least 60 days after sending, and requests are honored well within the 10 business days CASL allows.

7.2 United States — CAN-SPAM Act

  • Law. Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (15 U.S.C. §§ 7701–7713) and the FTC's CAN-SPAM Rule (16 C.F.R. Part 316), enforced by the Federal Trade Commission.
  • Consent. CAN-SPAM is an opt-out regime and does not require prior consent. Breakout Learning nonetheless applies its opt-in standard to recipients in the United States.
  • Content and unsubscribe. Messages use accurate header information and subject lines, are identified as commercial where they are sent without the recipient's prior affirmative consent, include Breakout Learning's valid physical postal address, and provide an opt-out that requires no fee or information beyond an email address. Opt-outs are honored well within the 10 business days the Act allows. Breakout Learning remains responsible for commercial messages that third parties send on its behalf.

7.3 European Union — GDPR and the ePrivacy Directive

  • Law. Regulation (EU) 2016/679 (GDPR) and Article 13 of Directive 2002/58/EC (ePrivacy Directive), as implemented in the national law of each Member State; enforced by national data protection and telecommunications authorities.
  • Consent. Unsolicited marketing email to individuals requires prior consent meeting the GDPR standard — freely given, specific, informed, and unambiguous. The “soft opt-in” in Article 13(2) — contact details obtained in the context of a sale, used for similar products or services, with an opportunity to object at collection and in every message — is relied on only where the applicable national law permits it.
  • Right to object. Objections to direct marketing under Article 21 GDPR are honored immediately and free of charge, and processing for direct-marketing purposes ceases on objection. International transfers of contact data are made on the basis described in our Privacy Policy.

7.4 United Kingdom — UK GDPR and PECR

  • Law. The UK GDPR, the Data Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), as amended, including by the Data (Use and Access) Act 2025; enforced by the Information Commissioner's Office (ICO).
  • Consent. PECR regulation 22 requires consent, or the soft opt-in, for unsolicited marketing email to individual subscribers. Breakout Learning applies its opt-in standard regardless of whether an address belongs to an individual or a corporate subscriber, and honors the UK GDPR right to object in all cases.

7.5 Switzerland — Unfair Competition Act and FADP

  • Law. Article 3(1)(o) of the Federal Act against Unfair Competition (UCA) and the revised Federal Act on Data Protection (FADP, in force since 1 September 2023).
  • Requirements. Mass advertising by electronic means requires the recipient's prior explicit consent, correct sender identification, and a free and easy means of refusing further messages, all of which Breakout Learning's standard provides. The UCA's existing-customer exception — advertising for similar products to customers who provided their address at the time of purchase — is relied on only within those limits.

7.6 Australia — Spam Act 2003

  • Law. Spam Act 2003 (Cth) and the Spam Regulations 2021, enforced by the Australian Communications and Media Authority (ACMA).
  • Requirements. Commercial electronic messages are sent only with the recipient's express or inferred consent, accurately identify Breakout Learning with contact details that remain valid for at least 30 days, and include a functional unsubscribe facility. Unsubscribe requests are honored within five business days, as the Act requires.

7.7 India — Digital Personal Data Protection Act

  • Law. Digital Personal Data Protection Act, 2023 (DPDP Act) and the Digital Personal Data Protection Rules, 2025, as they come into force.
  • Requirements. Contact details of individuals in India are processed for marketing on the basis of consent, which may be withdrawn at any time with the same ease with which it was given; withdrawal is honored through the unsubscribe mechanism described above. Inquiries may also be directed to the Grievance Officer identified in our Privacy Policy.

7.8 South Africa — POPIA

  • Law. Protection of Personal Information Act 4 of 2013 (POPIA), section 69, together with the Information Regulator's Guidance Note on Direct Marketing; enforced by the Information Regulator.
  • Requirements. Unsolicited electronic direct marketing is sent only with the data subject's consent, or to existing customers in respect of similar services where the opportunity to object was given at the time of collection and in every message (section 69(3)). Consent is requested from a data subject only once (section 69(2)). Each message identifies Breakout Learning and provides an address to which an opt-out request may be sent (section 69(4)).

8. Ongoing Governance

Breakout Learning maintains this posture through:

  • Standardized, account-wide consent configuration applied to web forms and scheduling pages;
  • Periodic review of marketing contact records and consent documentation;
  • Monitoring of changes to the laws listed in this statement, with updates to this statement as requirements evolve;
  • Alignment of consent language with the organization's broader privacy commitments under its Privacy Policy.

9. Contact

Breakout Learning has appointed a Data Protection Officer responsible for privacy and data-protection matters, including those relating to electronic communications. Inquiries regarding this statement, consent, or unsubscribe requests may be directed to:

For full details on how Breakout Learning collects, uses, and protects personal information, please refer to our Privacy Policy. Additional compliance and security information is available in our Trust Center.