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I receive many emails those days:

If you haven't given your consent before 2018 May 25 to stay subscribed to our newsletter, we will be forced to remove your email from subscription, in accordance to GDPR.

1) Is it true that if I haven't asked agreement to past customers of my company before May 25, I will have to remove all of them from newsletter subscription?

2) I was thinking about doing such an email in September 2018 when launching a new product:

> 2018 Sept 1st
> You receive this email as a past customer of our service. 
> We are happy to inform that we launch the new product XYZ. 
> [...]  
> By the way, we haven't asked this before so we do it now: do you want to stay subscribed to this newsletter?
>      [ YES ]         [ NO ]           <- big buttons with direct links

Is this fine / GDPR compliant?

Note: I'm based in Europe.

Basj
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  • This question falls under the "legal/regulatory" side of things, and as such is off-topic. We do not want to be the ones to suggest a course of action that ends up getting you on the wrong side of the regulation. Note that GDPR is not about opt-in email marketing but about informing people about how you are using their data and giving them control. – schroeder May 23 '18 at 15:29
  • https://litmus.com/blog/5-things-you-must-know-about-email-consent-under-gdpr suggests that you cannot use your email list in your Sept campaign, because you have not been given consent to use it in this way. – schroeder May 23 '18 at 15:30
  • @schroeder Thank you for the link. Which SE site would be adapted to discuss about data privacy (a more and more important topic in IT field)? – Basj May 23 '18 at 15:32
  • I do not think there is one yet. law.stackexchange.com is the best option. – schroeder May 23 '18 at 15:33
  • Thank you. Last thing: do you think I can ask consent later than May 25? (not at the same time as speaking about new product)? Example (August 2018): `Dear customer, We haven't asked this before so we do it now: do you want to stay subscribed to this newsletter? [ YES ] [ NO ]` – Basj May 23 '18 at 15:34
  • Technically, you would not have consent to ask them in Aug either. I'm not sure regulators might care, but you need to set your systems up before the deadline. – schroeder May 23 '18 at 15:38

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