I would feel uncomfortable doing anything with this without consent, and even then some of the non-EEA issues would still need close attention.
I can see why orgs might want to use it. In some circles FB is a more widely used and popular channel. Under 25s see email as a formal/bills type channel, so I'm not sure how effective that is. FB has a different vibe.
Nevertheless, I'm advising my guys that we stay clear of it for the time being - we should already be engaging most of them on FB anyway through our official page - and it seems perilous at the moment.
Matt
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