Scope: Broadly covers the processing of personal data, including phone numbers, for individuals in the EU/EEA.
Consent: Requires "explicit" consent for marketing purposes. This means consent must be freely given, specific, informed, and an unambiguous indication by a statement or clear affirmative action. Pre-checked boxes are not allowed.
Right to Withdraw Consent: Individuals must be able to withdraw consent as easily as they gave it.
Right to Erasure/Access: Individuals have rights to access their data, correct it, or request its deletion.
Transparency: Comprehensive privacy policies detailing data processing activities are mandatory.
Enforcement: Significant fines for non-compliance, up to €20 million or 4% of global annual turnover, whichever is higher.
Canada's Anti-Spam Legislation (CASL):
Scope: Applies to Commercial Electronic Messages (CEMs), including SMS.
Consent: Requires either "express consent" (explicitly requested south africa phone number list and clearly given) or "implied consent" (e.g., existing business relationship with an expiry). Express consent is preferred for marketing.
Identification: CEMs must include sender identification and contact information.
Unsubscribe: Must include a clearly presented, easily accessible, and functional unsubscribe mechanism.
Enforcement: Administrative monetary penalties can be substantial, up to $10 million per violation for organizations.
Personal Information Protection Law (PIPL) in China:
Scope: Comprehensive data protection law similar to GDPR, covering personal information processing in China.
Consent: Requires "separate consent" for marketing purposes, particularly for cross-border transfers or sensitive personal information.
Individual Rights: Grants robust rights to individuals over their data.
Transparency: Requires clear notice of data processing.
Enforcement: High fines (up to 5% of turnover or RMB 50 million) and potential business suspension.
