Yes! If you have sent or planing to send bulk email to recipients who have not expressly given you a permission to use their email addresses (not registered and agreed to be placed on a specific mailing list), your email is "Uncolisited" or SPAM even if you provide an option for recipients to "Opt-Out" and to stop receiving further emails from you.
Related Articles
You probably need to read the articles "What does Unsolicited Email mean?" "What is you anti-SPAM policy?" and
