Absolutely. If I've made a purchase within the last two years, you can send me a message, but if I've subscribed for a free service—I didn't buy anything—maybe you can't send me a message. I say “maybe” because we're left scrambling to interpret the law. It's too prescriptive to make sense to business, let alone to the legal community who have to interpret it.
On October 17th, 2017. See this statement in context.