Do Not Call (DNC) Policy

Effective Date: January 1, 2025  |  Last Updated: January 1, 2025

1. Overview

DealMako (“we,” “us,” or “our”) is committed to complying with all applicable Do Not Call (DNC) laws and regulations, including the Telephone Consumer Protection Act (TCPA), the FTC's Telemarketing Sales Rule (TSR), and applicable state Do Not Call laws. This policy explains how we manage DNC compliance for our platform and its users.

2. Scope

This policy applies to:

• All users of the DealMako platform who conduct outbound SMS campaigns
• All communications sent through DealMako's messaging infrastructure
• DealMako employees and contractors involved in outreach activities

3. National DNC Registry

DealMako integrates with and requires platform users to comply with the National Do Not Call Registry maintained by the Federal Trade Commission (FTC). Users must:

• Scrub contact lists against the National DNC Registry before initiating campaigns
• Update DNC scrubs at least every 31 days for active campaigns
• Maintain records of all DNC scrub activities for a minimum of 5 years

4. Internal DNC List

DealMako maintains an internal DNC list that is automatically honored across all campaigns. Numbers are added to our internal DNC list when:

• A recipient replies with any opt-out keyword (STOP, UNSUBSCRIBE, CANCEL, END, QUIT, OPTOUT)
• A user manually adds a number to their DNC list
• A number is identified as a litigator or known TCPA plaintiff through our integrated litigator scrub
• A number generates a complaint through any channel

Once a number is added to the internal DNC list, no further messages will be sent to that number without explicit re-consent from the number holder.

5. Opt-Out Handling

5.1 Required Opt-Out Language

All SMS campaigns sent through DealMako must include opt-out instructions. Our platform automatically appends or requires the following language in campaign messages:

“Reply STOP to opt out”

5.2 Processing Opt-Outs

Opt-out requests are processed immediately and automatically:

• Inbound STOP messages trigger immediate suppression
• The opt-out is applied to all future messages from the user's account
• Users cannot override an opt-out suppression without documented re-consent

5.3 Confirmation Messages

Upon receiving an opt-out request, DealMako sends a single confirmation message:

“You have been unsubscribed and will receive no further messages. Reply START to re-subscribe.”

6. State-Specific Requirements

Several states maintain their own DNC registries and laws with requirements that exceed federal standards. DealMako users are responsible for complying with state-specific laws including but not limited to:

Users operating in regulated states should consult the DealMako Compliance Center for state-specific guidance.

7. Number Reassignment Detection

To protect against contacting reassigned numbers (a leading cause of TCPA violations), DealMako employs the following safeguards:

• Pre-campaign number validation via Telnyx Number Lookup API to detect disconnected, reassigned, or ported numbers
• 7-day result caching to minimize lookup costs while maintaining freshness
• Automatic exclusion of numbers flagged as disconnected or reassigned from campaign sends
• Contact-level status tracking with visible badges in the contact management interface

Numbers with a status of disconnected or reassigned are automatically blocked from campaign sends.

8. Litigator Scrub

DealMako integrates a litigator scrub service to identify known TCPA plaintiffs and litigation-prone numbers. This service is run automatically before campaign sends. Numbers identified in the litigator database are blocked from all outbound communications.

9. Record Keeping

DealMako maintains the following records in compliance with TCPA and TSR requirements:

• Opt-out requests and confirmation timestamps (retained indefinitely)
• DNC scrub logs including date, time, and registry version (5 years)
• Campaign send records including recipient, timestamp, and message content (5 years)
• Consent records where applicable (5 years from last contact)

10. User Responsibilities

Users of the DealMako platform are independently responsible for:

1. Obtaining proper consent before texting prospects where required by law
2. Ensuring their contact lists are obtained through lawful means
3. Conducting required DNC scrubs through our platform tools
4. Complying with federal, state, and local telemarketing laws
5. Providing accurate business information during 10DLC brand and campaign registration
6. Not using the platform to send unsolicited messages to consumers

DealMako reserves the right to suspend or terminate accounts that violate applicable telemarketing laws or this DNC Policy.

11. Complaint Handling

If a consumer believes they have received an unwanted communication through DealMako:

• Email: compliance@dealmako.com
• Response time: We will acknowledge complaints within 2 business days and resolve within 10 business days
• We will immediately suppress the complainant's number pending investigation

12. Enforcement and Penalties

Violations of this policy may result in:

• Immediate account suspension
• Permanent account termination
• Reporting to relevant regulatory authorities
• Users may be held individually liable for TCPA violations (up to $1,500 per willful violation)

13. Policy Updates

This policy is reviewed quarterly and updated as needed to reflect changes in applicable law. Users will be notified of material changes via email at least 30 days before the effective date.

14. Contact

For questions about this DNC Policy:

DealMako Compliance Team
Email: compliance@dealmako.com

This policy is provided for informational purposes and does not constitute legal advice. Users should consult qualified legal counsel for guidance on their specific compliance obligations.