Correct. Technically in this case they are in the clear because what people see on Google is what they will get when they click on the link. What is currently

Correct. Technically in this case they are in the clear because what people see on Google is what they will get when they click on the link. What is currently penalized is when you do this without checking the referrer and show everyone a sign-up screen. That'll get you penalized in a serious hurry.