Originally Posted by Ferus

Not true. It fall under "harvested email" since you cannot guarantee that the user you have previously identified, is indeed the one you now send an email, because your identification is based on a PROFILE rather than an audit-able user-validation process..

This have been verified by https://www.twobirds.com


and if you end up buying their service, keep this in mind:

The law makes clear that even if you hire another company to handle your email marketing, you can’t contract away your legal responsibility to comply with the law. Both the company whose product is promoted in the message and the company that actually sends the message may be held legally responsible.