"Transactional or relationship content – which facilitates an already agreed-upon transaction or updates a customer about an ongoing transaction;" From ftc web

"Transactional or relationship content – which facilitates an already agreed-upon transaction or updates a customer about an ongoing transaction;" From ftc website. This doesn't seem to fall under that category. Edit: More from site. A. The primary purpose of an email is transactional or relationship if it consists only of content that: facilitates or confirms a commercial transaction that the recipient already has agreed to; gives warranty, recall, safety, or security information about a product or service; gives information about a change in terms or features or account balance information regarding a membership, subscription, account, loan or other ongoing commercial relationship; provides information about an employment relationship or employee benefits; or delivers goods or services as part of a transaction that the recipient already has agreed to.