Hi Richard,

First I agree with John Taylor. I do agree that you need to cover your butt.
I would say that anyone that comes into your system could/would be considered
a marketing partner.

You should amend your Privacy Statement to include that you may share your subscribers
data with trusted marketing partners.

As well, amend your opt in statement to say something similar to this:

"I agree to receive email marketing from you and your marketing partners."

Then put some language into your system when people join that identifies them as marketing partners.

DISCLAIMER: I am not an attorney and this should not be considered to be legal advice.

Also - I would be interested in learning more about how to participate in your system.
Get ahold of me and lets see what we can do together.

Best of Success,

- Ty Hall