This policy sets out how CallBlade complies with the Telephone Consumer Protection Act of 1991 (47 U.S.C. § 227), the Federal Communications Commission's implementing rules (47 C.F.R. § 64.1200), and state laws that impose additional telemarketing, dialing, consent, and messaging requirements, often called "mini-TCPA" laws. It applies to every call and text CallBlade places or handles, on every campaign, for every client.

This policy applies to all CallBlade employees, contractors, supervisors, and agents, regardless of where they are physically located. United States consumer protection law governs every call to a United States phone number. An agent's location never changes the rules.

CallBlade treats federal law as the minimum. Where a state law is stricter than federal law, the stricter rule governs calls to consumers in that state. Where CallBlade's own internal standards are stricter than any law, CallBlade's standards govern. When there is any doubt, the most protective rule for the consumer applies.

CallBlade will not place a call or send a message that requires consent unless the client has certified that the required consent exists and is documented.

Prior Express Written Consent (PEWC) is required before any telemarketing or marketing call or text made using an automatic telephone dialing system, an artificial or prerecorded voice, or an AI-generated voice. PEWC must be a written agreement, signed by the consumer (electronic signatures under the E-SIGN Act are acceptable), that clearly authorizes the seller to deliver marketing calls or texts using that technology to a specific phone number, and that states consent is not a condition of purchase.

Prior Express Consent is required before any non-marketing (informational) call or text to a wireless number using an autodialer or artificial or prerecorded voice.

State consent rules. Several states require prior express written consent for sales calls or texts made using any automated system for selecting or dialing numbers, a broader standard than federal law. CallBlade requires clients running campaigns into those states to hold consent that meets the state standard.

Consent is seller-specific. CallBlade will only call on behalf of the seller the consumer actually agreed to hear from. Consent given to one company does not authorize calls on behalf of another.

Consent documentation. Clients must be able to produce, on CallBlade's request and within two (2) business days, the consent record for any number called, including the date and time, the source (web page, form, recorded call), the exact consent language presented, the consumer's IP address or equivalent, and any third-party verification certificate.

Consumers may revoke consent at any time and by any reasonable means, including verbally on a call, by replying to a text with words such as STOP, QUIT, END, REVOKE, OPT OUT, CANCEL, or UNSUBSCRIBE, by email, or through any other clear expression that they do not want further contact. CallBlade honors every revocation under its Do Not Call Policy, immediately and permanently.

No telephone solicitation will be placed to a number on the National Do Not Call Registry or an applicable state Do Not Call list unless a documented exemption applies, such as PEWC from the consumer or a valid Established Business Relationship under federal rules. Calling data is scrubbed against the National Registry and applicable state lists before dialing, using registry data no more than thirty-one (31) days old. A registry exemption never overrides a consumer's direct request not to be called.

Phone numbers change hands. Consent from a previous owner of a number does not transfer to the new owner. CallBlade requires clients that rely on consent collected more than ninety (90) days before calling to check their data against the FCC's Reassigned Numbers Database or an equivalent service. If a CallBlade agent learns that a number now belongs to someone else, the number is suppressed immediately.

Under FCC rules, voices generated by artificial intelligence are "artificial" voices under the TCPA. Any prerecorded, artificial, or AI-generated voice call must:

• have the consent required by Section 4 before it is placed;
• identify the business responsible for the call at the beginning of the message;
• provide the business's telephone number during or after the message; and
• for marketing calls, offer an automated opt-out mechanism, announced within two (2) seconds of the identification, that immediately records the opt-out and ends the call.

See the AI Voice Agent Policy for additional standards.

Text messages are treated as calls under the TCPA and under several state laws. For every SMS or MMS campaign:

• the consent required by Section 4 must exist before the first message;
• every marketing message identifies the sender and explains how to opt out;
• opt-out keywords are processed automatically and immediately;
• a single confirmation of the opt-out may be sent, with no further marketing content, and no other message follows;
• messages are sent only during permitted calling hours for the recipient's location; and
• numbers used for business texting are registered with carriers under applicable 10DLC or toll-free verification programs.

Covered in detail in Telemarketing Standards.

Any violation of this policy is grounds for immediate campaign suspension, disciplinary action up to and including termination, and termination of the client relationship. See Agent Training, QA & Enforcement.