You should speak with appropriate legal counsel.
That being said, there are some docs here and online describing each scenario in more detail. Your understanding of implied and customer implied isn't accurate so please do additional research. Marketo had a good set of slides from a lawyer that can help.
Could you please provide any direct link to the available docs? Thanks!
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It's pretty similar to the GDPR changes, make sure to send double opt-in email to those who fill out forms from Canada and Germany