If you're wondering if it's OK to require that recipients must log into your website before they can unsubscribe from your emails, the answer to that is no-- it's prohibited under US Federal law.
The FTC explicitly clarified this in the May 2008 CAN-SPAM Rule Update. It's on page 104, near the bottom.
Here's what it says:
Section 316.5 Prohibition on charging a fee or imposing other requirements on recipients who wish to opt out. Neither a sender nor any person acting on behalf of a sender may require that any recipient pay any fee, provide any information other than the recipient's electronic mail address and opt-out preferences, or take any other steps except sending a reply electronic mail message or visiting a single Internet Web page, in order to: (a) Use a return electronic mail address or other Internet-based mechanism, required by 15 U.S.C. 7704(a)(3), to submit a request not to receive future commercial electronic mail messages from a sender; or (b) Have such a request honored as required by 15 U.S.C. 7704(a)(3)(B) and (a)(4).
What does that mean? Read carefully: Senders are not allowed to require recipients to "provide any information other than the recipient's electronic mail address and opt-out preferences." That means you can't require them to login to your website before continuing on to a preference center or other page. The only thing a recipient has to give you is their email address, and the opt-out preference. (i.e. do you want to opt-out from all messages, or would you like to opt-out only from certain specific lists.) The law prohibits any requirement that the recipient "take any other steps except sending a reply electronic mail message or visiting a single Internet Web page" when unsubscribing -- meaning it's not OK for it to take five clicks for somebody to unsubscribe. Interact with one page means the unsubscribe link takes them to a web page, where they are either unsubscribed automatically, or push some button on that web page to complete the unsubscribe process. (That would be interacting with that single web page.)
For more information on CAN-SPAM, visit our CAN-SPAM Information Center at http://canspam.etdeliverability.com/
The FTC explicitly clarified this in the May 2008 CAN-SPAM Rule Update. It's on page 104, near the bottom.
Here's what it says:
Section 316.5 Prohibition on charging a fee or imposing other requirements on recipients who wish to opt out. Neither a sender nor any person acting on behalf of a sender may require that any recipient pay any fee, provide any information other than the recipient's electronic mail address and opt-out preferences, or take any other steps except sending a reply electronic mail message or visiting a single Internet Web page, in order to: (a) Use a return electronic mail address or other Internet-based mechanism, required by 15 U.S.C. 7704(a)(3), to submit a request not to receive future commercial electronic mail messages from a sender; or (b) Have such a request honored as required by 15 U.S.C. 7704(a)(3)(B) and (a)(4).
What does that mean? Read carefully: Senders are not allowed to require recipients to "provide any information other than the recipient's electronic mail address and opt-out preferences." That means you can't require them to login to your website before continuing on to a preference center or other page. The only thing a recipient has to give you is their email address, and the opt-out preference. (i.e. do you want to opt-out from all messages, or would you like to opt-out only from certain specific lists.) The law prohibits any requirement that the recipient "take any other steps except sending a reply electronic mail message or visiting a single Internet Web page" when unsubscribing -- meaning it's not OK for it to take five clicks for somebody to unsubscribe. Interact with one page means the unsubscribe link takes them to a web page, where they are either unsubscribed automatically, or push some button on that web page to complete the unsubscribe process. (That would be interacting with that single web page.)
For more information on CAN-SPAM, visit our CAN-SPAM Information Center at http://canspam.etdeliverability.com/
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