This Messaging and Calling Policy forms part of the Terms of Service and the Acceptable Use Policy. It applies to every text message, call, voicemail, email and AI-agent interaction sent from an REI Vantage instance.
REI Vantage is software. You send your communications from your own Twilio and other accounts, and you are responsible for them. This policy sets the minimum standard for using our software. It is not legal advice, and meeting it does not guarantee that you comply with the law. Telemarketing law in the United States changes often, varies by state and is heavily litigated. Get advice from a qualified US lawyer before you start outreach.
1. Register accurately
- Register your business and each messaging use case accurately with your carrier, through A2P 10DLC brand and campaign registration or toll-free verification as applicable.
- Send only messages that match the use case, sample messages and opt-in description you registered.
- Use your own registered numbers for your own business. Do not lend, share or pool numbers or registrations across businesses.
2. Have the consent the law requires
- Get every consent the law requires before you text or call. Under the TCPA and carrier rules, marketing texts and calls using automated technology or an artificial or prerecorded voice generally require prior express written consent.
- Consent belongs to the business it was given to. You cannot buy, rent, borrow or transfer consent, and a purchased or skip-traced list does not come with consent.
- Do not assume a message is exempt because it offers to buy a property rather than sell something. Courts have disagreed on that question and may look at the purpose of your whole campaign, not just the wording of one message.
- Keep a record of how and when each person consented, and of the wording they agreed to.
3. Respect Do Not Call lists
- Before calling or texting for telemarketing, scrub your list against the National Do Not Call Registry, every applicable state Do Not Call list, and your own internal Do Not Call list.
- Maintain an internal Do Not Call list across all your numbers and channels, and keep a written policy for it as the TCPA requires.
- We strongly recommend scrubbing against a known-litigator list and checking the FCC Reassigned Numbers Database before contacting a number you have not contacted recently.
- Never turn off REI Vantage's Do Not Call and suppression checks for marketing campaigns.
4. Honour opt-outs immediately
- Treat STOP, STOPALL, UNSUBSCRIBE, CANCEL, END and QUIT, and any other reasonable way a person says they do not want further contact (for example "don't text me" or "wrong number"), as an opt-out.
- An opt-out on one channel is an opt-out on every channel for that purpose, including calls.
- Stop contacting the person as soon as practicable and within any deadline set by law. You may send one confirmation message that does not contain marketing.
- Never re-add a person who has opted out unless they give new consent of their own accord.
5. Identify yourself
- Your first message to a person must name your business and say how to opt out (for example "Reply STOP to opt out"). Repeat the opt-out instructions regularly.
- Respond to HELP with your business name and a way to contact you.
- Display accurate caller ID that someone can call back. Never spoof or hide caller ID.
6. Respect timing and frequency limits
- Contact people only between 8 a.m. and 9 p.m. in the recipient's local time zone, or any narrower window, day restriction or holiday restriction that a state law sets. REI Vantage applies quiet hours based on the recipient's area code and property address. You are responsible for the result where those are unreliable.
- Follow state limits on how often you may contact the same person about the same subject.
- Do not send unsolicited messages in bulk.
7. Do not evade carrier filtering
Carriers filter messages to protect their subscribers. You must not use techniques designed to get around that filtering, including:
- rotating numbers, sending identical campaigns from many numbers, or spreading traffic across numbers to avoid volume limits ("snowshoeing");
- varying words, characters or spelling to disguise repeated content from filters, such as message spinning or character substitution intended to evade detection;
- using public URL shorteners, or links that hide their destination; or
- registering one use case and sending messages for another.
Personalising a message with a recipient's name or property address is fine.
8. Calls, voicemail and recordings
- Calls that use an artificial or prerecorded voice, including AI-generated or cloned voices, require the consent the TCPA requires for those calls.
- Ringless voicemail is treated as a call under the TCPA, so the same consent and Do Not Call rules apply.
- Several states require every party's consent before a call is recorded. If you record or transcribe calls, announce it at the start of every call.
9. AI agents
- If an AI agent texts or talks to people for you, it must say it is automated where the law requires, and should do so whenever a person asks.
- An AI agent must stop contacting a person who opts out, and must hand over to a human when asked or when it cannot help.
- You are responsible for the prompts, scripts and instructions you give an AI agent, and for every message or call it sends.
10. Email and mail
- Commercial email must comply with the CAN-SPAM Act. It must include an accurate sender, a non-deceptive subject line, your physical postal address and a working unsubscribe link, and you must honour unsubscribes within 10 business days.
- Letters and postcards must not be misleading. They must not imitate government or legal notices, and they must comply with any state rules on solicitations to homeowners in foreclosure.
11. Keep records
Keep records of consent, opt-outs, Do Not Call scrubs and message logs for at least five years, and longer if a claim or investigation is pending. REI Vantage stores much of this in your instance, and you are responsible for keeping your instance and backups.
12. Enforcement
If a carrier, Twilio, a regulator or a recipient reports a problem, we may ask for information about your campaign, and you must answer promptly. We may suspend Support, Updates, Data Services or features of your instance, or end your licence, under the Terms of Service where we reasonably believe this policy has been breached.