Acceptable Use Policy

1. Customer Warranties

Every customer warrants, on a continuing basis and with respect to every call originated:

• That it holds the level of consent required by law for the number dialed and the dialing technology used, including prior express written consent where required for wireless numbers;
• That the dialing list has been scrubbed against the National Do-Not-Call Registry and applicable state registries within the preceding 31 days;
• That the dialing list has been scrubbed against the customer's internal do-not-call list and against known TCPA litigator lists;
• That reassigned-number screening has been performed against the FCC Reassigned Numbers Database using the consent date as the query date;
• That every calling number presented is owned by the customer or used with the express authorization of the number's subscriber;
• That calls are placed only within permitted calling hours at the called party's location; and
• That the customer holds all licenses and registrations required for the traffic it originates.

2. Prohibited Traffic

The following are prohibited without exception and result in immediate termination:

• Calls placed without the consent required by law
• Caller ID spoofing with intent to defraud, cause harm, or wrongfully obtain anything of value
• Traffic pumping, access stimulation, or artificially inflated traffic
• Number rotation designed to evade carrier analytics (“snowshoeing”)
• Calls to emergency services, government inbound lines, or numbers appearing on industry Do-Not-Originate lists
• Impersonation of a government agency, financial institution, carrier, or any entity the customer is not authorized to represent
• Traffic originated on behalf of an undisclosed third party
• Calls to numbers on the National Do-Not-Call Registry absent a recognized exemption
• Any traffic prohibited by the TCPA, the Telemarketing Sales Rule, the Truth in Caller ID Act, or applicable state law

3. Caller ID Requirements

• Every calling number presented must be a valid, allocated, answerable number.
• Return calls to any presented number must reach a live agent or a compliant voicemail identifying the seller and providing a do-not-call mechanism.
• Customers may not present a number they neither own nor are expressly authorized to use, and must produce that authorization on request.
• The Company rejects, at its session border controller, any call presenting a calling number outside the authorized inventory for that customer.

4. Screening and Suppression Obligations

Customers are responsible for screening their own dialing lists before traffic reaches the Company's network. Where the Company also operates a screening control at the network layer, that control is a second line of defense and does not relieve the customer of its own obligation.

Customers must:

• Honor any do-not-call request immediately, and in all cases within 24 hours;
• Maintain an internal do-not-call list and apply it as a suppression file on every campaign;
• Honor revocation of consent received by any reasonable means, including verbally on a call, by reply text, email, or voicemail;
• Suppress any number the Company notifies them of, immediately and across all campaigns; and
• Apply attempt limits and retry rules that prevent uncontrolled repeat dialing of any contact.

5. Evidence on Demand

Customers must produce, within 24 hours of a request by the Company:

• The consent record for any identified call, including the disclosure text presented, timestamp, consumer IP address, source URL or channel, and any lead-certification token;
• Evidence of Do-Not-Call, litigator, and reassigned-number scrubbing for the campaign; and
• Caller ID ownership or authorization documentation for any presented number.

Inability to produce these records within 24 hours is itself grounds for suspension, independent of whether the underlying call was lawful.

6. Network Controls

The Company operates the following controls on the call path, before traffic reaches any upstream carrier. These controls protect the Company's network and its carrier relationships; they do not substitute for the customer's own compliance obligations.

• Per-customer concurrency and calls-per-second limits
• Destination restriction to the North American Numbering Plan; N11, 976, 900 and designated high-risk NPAs are refused
• High-risk prefix blocking
• Calling number validation against authorized inventory
• Calling-hour enforcement based on the recipient's local time, derived from destination NPA-NXX
• Suppression and litigator screening, refusing matched calls before they leave the Company's network
• Per-number daily usage limits and area-code-matched number assignment
• Call-level logging of every attempt, including every refusal and its reason
• Emergency traffic suspension

7. Suspension and Termination

The Company may suspend or terminate service immediately, without prior notice, where it determines that:

• Traffic violates this policy or applicable law;
• A customer has failed to respond to a traceback or produce requested evidence within 24 hours;
• Traffic patterns indicate fraud, artificial inflation, or analytics evasion; or
• An upstream carrier or regulatory authority identifies the customer's traffic as non-compliant.

Suspension is a protective measure and is not a determination of liability. The Company preserves all records associated with suspended or terminated traffic.

8. Recordkeeping

Call detail records, screening decisions, refusal reasons, customer warranties, evidence produced under Section 5, and suspension or termination actions are retained for a minimum of five (5) years.

Compliance decisions are written to a trigger-enforced append-only audit log; UPDATE, DELETE and TRUNCATE operations are blocked at the database level.

This policy is reviewed at least annually and upon any material change in applicable law. A copy of this policy is available on request at (904) 512-8487.