Opt-out of receiving email newsletters is best tied to an account or email address. mail?

Question

Law in IT

Why is it better to link unsubscribe from mass mailings: to a user account or to a specific email address? mail?
If you link disclaimer to an account, how realistic is the following scenario?

1. Client A comes to the organization, with the help of a consultant, creates an account for a personal account with a link to the address "[email protected]" and at the same time gives written consent to receive newsletters to the specified address.
   
2. Client B comes to the organization, creates an account linked to "[email protected]", but does not give consent to receive mailings.
   
3. Client B comes home and changes his email address in his account. mail to "[email protected]". Client A changes the address to "[email protected]", a confirmation email is sent to client B at "[email protected]". Client B visits his old email "[email protected]" and accidentally confirms the change of email address. mail.
   
4. A mass mailing is launched, client B, who did not agree to receive mailings, receives an advertising letter.
   
5. Client B files a complaint against the organization with OFAS.
   
6. The organization does not have a written consent to receive mailings from client B, the organization is fined.
   

Answer 1

item 1. Art. 18 Federal Law of March 13, 2006 N 38-FZ "On Advertising": Distribution of advertising over telecommunication networks, including through the use of telephone, facsimile, mobile radiotelephone communications, is allowed only with the prior consent of the subscriber or addressee to receive advertising. At the same time, advertising is recognized as distributed without the prior consent of the subscriber or addressee, unless the advertising distributor proves that such consent has been obtained. The advertiser is obliged to immediately stop the dissemination of advertising to the address of the person who applied to him with such a demand.

The organization does not have a written consent to receive mailings from client B, the organization is fined.

Written consent is required if the mailing is sent to mobile subscribers.