Previous clients who have provided their information to purchase are fair game. As long as you follow the CAN-SPAM Act guides as you mentioned in your post, you are perfectly in your rights to send them an email promotion on products you have sold them in the past. If they have purchased in the past, then they established their interest in what you have to offer. If they opt-out from the initial email, then you have to respect their request per the CAN-SPAM Act. But if they don't they are essentially opting in to your emails.
I would suggest that on future purchasers, you ask them to opt-in to your emails on purchase.
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