Traceback Response Policy

1. Designated Contact

The Company maintains a designated point of contact for traceback and call-origination inquiries, published in the Robocall Mitigation Database under certification RMD0027386.

• Compliance Officer: Joel Vasquez — joel@getlifeassurance.com
• Escalation: James Kelly — jimmy@getlifeassurance.com — (904) 512-8487

Contact details are reviewed at least annually and updated in the Robocall Mitigation Database upon any change.

2. Response Timeline

• Traceback requests are acknowledged within 24 hours of receipt, including weekends and holidays.
• A substantive response identifying the immediate upstream source of the identified call is provided within 24 hours of receipt, or within any shorter period specified by the requesting party or by law.
• Where the Company is the originating provider, the response identifies the originating customer and the basis on which the traffic was accepted.
• Where the Company is an intermediate provider, the response identifies the provider from which the call was received.

The Company does not require a subpoena, legal process, or contractual formality as a precondition to responding to a lawful traceback request.

3. Records Produced

For any call identified by SIP Call-ID and timestamp, the Company produces from call-level records:

• Source IP address of the originating session
• SIP Call-ID
• Call start, answer, and end timestamps
• Originating customer and campaign attribution
• Calling number (caller ID) presented and the DID from which it was drawn
• Called number
• Call disposition, duration, and hangup cause
• Routing path, including the carrier or gateway used
• Where the call was refused by the Company's own controls, the rejection reason

Source IP and SIP Call-ID are captured before any compliance or routing check can reject the call, so a complete record exists even for call attempts the Company blocked. Compliance decisions are written to a trigger-enforced append-only audit log; UPDATE, DELETE and TRUNCATE operations are blocked at the database level, so records cannot be altered after the fact.

4. Customer Obligations

Every customer originating traffic through the Company is contractually required to:

• Respond to a traceback inquiry forwarded by the Company within 24 hours;
• Identify the source of the called number and the campaign under which it was dialed;
• Produce the consent record supporting the call, including the consent disclosure text, timestamp, source URL or channel, and any lead-certification token; and
• Identify their own upstream source where the customer is itself an intermediate provider.

These obligations are conditions of service and are set out in the Company's Acceptable Use Policy.

5. Suspension and Escalation

• Failure by a customer to respond to a traceback within 24 hours results in immediate suspension of that customer's trunk pending response.
• Failure to produce a consent record for an identified call results in suspension and review of all traffic from that customer.
• Evidence of unlawful traffic results in immediate and permanent termination of service and preservation of all associated records.
• Where a traceback identifies a pattern rather than a single call, the Company suspends the affected campaign or customer pending investigation rather than awaiting a second inquiry.

The Company will notify the requesting party of any suspension or termination action taken as a result of a traceback.

6. Recordkeeping

Traceback inquiries, the Company's responses, supporting call records, customer responses, and any suspension or termination action taken are retained for a minimum of five (5) years.

Call-level records are retained in a synchronous, append-only system of record written before the call proceeds, so the record of a call exists independently of the call's outcome.

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.