This is a draft for a Colorado lawyer to review. It is not legal advice and it was not written by a lawyer.
Last changed: 15 September 2026
Written for you, the client, rather than for a regulator. It says what goes out under your name, because it goes out under your name and you should know what it says before it does.
1. The messages are from you
Not from Carverpoint. They carry your business name, they come from your own domain, and if somebody replies, it reaches you.
That is a deliberate choice and it costs us something. Sending from your domain means setting up mail authentication on it and warming it up slowly, which is more work than blasting from ours. It is worth it because a review invitation from a stranger's marketing domain looks like what it is, and because the reply belongs with you.
2. What is in every message, without exception
| What | Why |
|---|---|
| Your real business name in the body | So nobody has to guess who is writing |
| Your real postal address | Required by federal law on every commercial email. It is yours, not ours, because the message is from you |
| An honest subject line | Required, and it is also just correct |
| A plain statement that it is a marketing message | The cautious reading of the law, and it costs one line |
| An unsubscribe link that works | Required, and see section 3 |
| The words "honest" and "good or bad" | This is the sentence that proves the invitation went to everybody rather than only to the happy ones |
| One review link, the same one for everybody | Same reason |
If any of those is missing, the message will not send. That is a check in the software, not a habit.
You will need to give us a real postal address. If you work from home and would rather not print it, a mailbox service costs a few dollars a month and is the usual answer. What is not an option is leaving it out.
3. Unsubscribes are honored immediately
The law gives ten business days. We do it on the spot.
Somebody who unsubscribes is out of every campaign of yours from that moment. There is no "we will remove you within ten days" and no confirmation step designed to make people give up.
Unsubscribes are kept per business, not shared across every Carverpoint client. So somebody could unsubscribe from you and still hear from a different business we work with. That costs you nothing but it does mean the list is not as clever as it could be. The reason is that merging those lists would mean combining your customer information with somebody else's, which is precisely the thing dpa.md says we will not do. We would rather explain the trade than make it quietly.
4. Pacing, and why this takes months
We do not send your whole list on a Tuesday.
Two reasons and both of them are about protecting you. Google can freeze new reviews on a profile and put a public notice on it when a burst arrives, and that notice is visible to your customers. And a spike of complaints on a fresh domain damages the domain you also send invoices from.
So it goes out in a paced sequence over six to ten weeks, with the sending rate climbing gradually, and it stops by itself if complaints rise above a threshold. That is why this is a months long product rather than a weekend one.
5. What is measured, and what is not
Measured: messages sent, with the time, the link and a fingerprint of the wording for each one. Bounces. Complaints. Unsubscribes. Clicks on our own redirect.
Not measured: opens. Not zero. Not measured. The invisible image that measures an open is itself a signal that pushes mail toward the spam folder, and since Apple started opening messages on people's behalf the number means very little anyway. We would rather have the delivery.
A click is not a review. Your report says so in those words. No platform tells anybody which review came from which email. Anybody showing you a dashboard that does is guessing from timing, counting clicks and calling them reviews, or gating.
6. What you can check, without asking us
Your report shows how many different review links and how many different message bodies the campaign actually sent, read back out of the send log rather than out of the settings.
If either number is more than one, the campaign was gated, whatever anybody claims, and the report says so in capital letters. That is there so you can audit us rather than trust us.
7. What is refused
Everything in acceptable-use.md section 1. No incentives, no filtering, no asking for a rating or a feeling, no surveys or routers, no pressure, no Yelp, and no text messages to your customers at any price.
Copy you write yourself goes through the same checker as copy we write, and there is no override.
8. The penalties, so you know what is being avoided
Each violating email carries a federal penalty of up to $53,088. The two enforcement cases worth knowing were both about the two things cold email templates leave out: the unsubscribe mechanism and the postal address.
Both of us are on the hook for those, jointly. The cost of complying is one footer.
Separately, incentives and filtering fall under the Federal Trade Commission's reviews rule, at up to $53,088 per violation, and that rule reaches a contracted third party by name as well as the business itself.
Nobody is going to be fined for a compliant campaign. This section exists so that when somebody cold calls you offering a hundred reviews by Friday, you know what they are actually selling you.