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No you should meet the required standards that state you must provide an opt-out on the email.
All promotional emails should already have a removal link. We don't include such a method on emails associated with active services as there is no reason or law to do so.
You may want to fix your links then, because the last two emails I received (before I finally managed to get back into the client area and unsubscribe) looked like this:
SEO is now a valid reason?
I guess it was always the case when you have tons of IPs which do not sell as well as you would have hoped a year back.
It's time to use it again
It's GVH where "Oh look it's raining today" is a good enough reason to give away IP's