Effective Date: 01/01/2026
Version: 1.0
Maintained by: Ijadi LLC (“Ijadi”)
This AUP sets the operational rules for using the Ijadi Platform. It implements the customer compliance obligations described in the MSA and applies to every account, user, and campaign on the Platform.
If a provision of this AUP conflicts with the MSA, the MSA controls. If a provision of this AUP conflicts with applicable law, the law controls and the rest of this AUP remains in effect.
This AUP is updated from time to time. Material updates will be communicated with at least thirty (30) days’ notice. Continued use of the Platform after an update constitutes acceptance.
Customer shall not use the Platform to:
2.1 Violate any law, including the Telephone Consumer Protection Act (“TCPA”), 47 U.S.C. § 227; the FCC’s implementing regulations at 47 C.F.R. § 64.1200; the FTC’s Telemarketing Sales Rule, 16 C.F.R. Part 310; CAN-SPAM; any state telemarketing law; or any privacy, consumer protection, or anti-discrimination law.
2.2 Contact any individual without consent sufficient under applicable law for the contact channel and content being used.
2.3 Use, transmit, or store Protected Health Information (“PHI”) as defined under HIPAA unless Customer has executed a separate Business Associate Agreement with Ijadi.
2.4 Use, transmit, or store payment card data subject to PCI-DSS unless Customer has executed a separate written addendum with Ijadi.
2.5 Make calls to numbers on the National Do Not Call Registry, any applicable state DNC registry, or Customer’s internal do-not-call list, except where a recognized exemption applies and is documented.
2.6 Engage in deceptive, fraudulent, harassing, abusive, threatening, or harmful conduct, including impersonation, social engineering, false caller-ID, or pretexting.
2.7 Solicit minors or knowingly contact any number known or suspected to belong to a minor for telemarketing purposes.
2.8 Use the Platform on behalf of any third party without Ijadi’s prior written consent.
2.9 Resell, redistribute, or commercially exploit the Platform or any output of the Platform.
2.10 Reverse engineer, decompile, or attempt to derive the source code of the Platform.
2.11 Bypass, disable, or attempt to circumvent any technical control, rate limit, scrubbing gate, or compliance check.
2.12 Load data known or reasonably suspected to have been obtained in violation of any law, contract, or third-party right.
2.13 Conduct campaigns in jurisdictions where Customer is not properly registered, bonded, or licensed if such registration is required by law.
3.1 National DNC Registry. Customer shall scrub all calling lists against the National Do Not Call Registry within thirty-one (31) days before any campaign launch, in accordance with 47 C.F.R. § 64.1200(c)(2). Numbers identified as DNC-listed must be suppressed from the campaign.
3.2 State DNC Lists. Where Customer’s campaigns are directed to residents of any state that maintains its own do-not-call list (including but not limited to Florida, Indiana, Louisiana, Mississippi, Missouri, Pennsylvania, Tennessee, Texas, and Wyoming), Customer shall scrub against that state’s list within the cadence required by state law (typically 31 days, but Customer is responsible for verifying current requirements).
3.3 Internal DNC List. Customer shall maintain an internal do-not-call list under 47 C.F.R. § 64.1200(d) including: (a) a written DNC policy available on demand; (b) training of all personnel; (c) honoring all DNC requests within ten (10) business days; (d) proper caller identification on every call; and (e) retention of records for at least five (5) years.
3.4 TCPA Litigator Scrubbing. Customer shall scrub all calling lists against a recognized TCPA litigator database (such as TCPA Litigator List, Blacklist Alliance, or equivalent) before any campaign launch. Numbers identified as known TCPA litigators must be suppressed.
3.5 Scrubbing Records. Customer shall retain documentation of every scrub, including date, time, service used, number of records submitted, number flagged, number suppressed, and the identity of the person who ran the scrub. Records shall be produced to Ijadi on request within forty-eight (48) hours.
4.1 Prior Express Written Consent. For any call placed using the Platform’s AI voice functionality, Customer must hold and be able to produce on demand documentary evidence of prior express written consent that:
– (a) was given by the consumer whose number is being called;
– (b) authorizes contact by an artificial or prerecorded voice, including AI-generated voice;
– (c) clearly and conspicuously discloses that consent is not a condition of purchase;
– (d) names Customer (or, where applicable, an entity for which Customer has authority to act) as the entity authorized to call;
– (e) was captured with a date, time, IP address where applicable, and the consent surface (form URL, audio recording, or comparable evidence);
– (f) has not been revoked, withdrawn, or rescinded by the consumer.
4.2 AI Voice Disclosure at Call Outset. At the start of every AI-voice call, Customer shall ensure clear and conspicuous disclosure that the call is made using artificial or prerecorded voice technology, to the extent required by applicable federal or state law. The disclosure shall be:
– (a) in the same language as the rest of the call;
– (b) audible and intelligible;
– (c) delivered before any sales solicitation; and
– (d) included in the audit recording where call recordings are made.
4.3 Identification. At the outset of every call, the Platform shall identify (in addition to the AI-voice disclosure):
– (a) the first and last name of the caller (or the persona name used by the AI voice);
– (b) the legal name of the entity on whose behalf the call is being made;
– (c) the purpose of the call (e.g., real estate solicitation, service inquiry);
– (d) a callback telephone number where the entity may be reached.
These requirements implement S.C. Code § 37-21-40 and equivalent state-law disclosure obligations; Customer is responsible for verifying and complying with the specific disclosure rules in each state where calls are directed.
4.4 Per-Campaign Attestation. Before launching any campaign, Customer shall complete the in-Platform per-campaign attestation, certifying: (i) Customer holds prior express written consent (or applicable exemption) for every number in the campaign; (ii) the calling list was scrubbed against the National DNC Registry, applicable state DNC lists, Customer’s internal DNC list, and a recognized TCPA litigator database within the past thirty-one (31) days; and (iii) Customer is properly registered, bonded, or licensed in each state where the campaign is directed where such registration is required.
5.1 Opt-Out Mechanism. Customer shall provide a clear, automated, interactive opt-out mechanism on every outbound campaign, accessible at the outset of the call (for live and AI-voice calls) and in any follow-up communication.
5.2 Honoring Opt-Outs. Customer shall process every opt-out request — whether received during a call, by reply to a follow-up message, by email, or by any other reasonable means — within ten (10) business days, in accordance with the FCC’s April 2025 revocation rule.
5.3 Internal DNC Update. Every opt-out shall be added to Customer’s internal DNC list immediately and reflected in subsequent scrubbing.
5.4 No Retaliation. Customer shall not re-contact, harass, or attempt to overturn an opt-out request.
6.1 Calling Hours. Customer shall not initiate calls before 8:00 a.m. or after 9:00 p.m. local time at the called party’s location, in accordance with 47 C.F.R. § 64.1200(c)(1). Customer is responsible for honoring stricter state-law calling-hour restrictions where applicable.
6.2 Caller ID. Customer shall transmit accurate caller ID on every outbound call, including: (a) a recognizable caller name; (b) a working callback number; and (c) the legal name of the entity on whose behalf the call is made, where required by law. Spoofing, manipulation, or transmission of inaccurate caller ID is prohibited.
7.1 Registration Required. Customer shall obtain and maintain all required state telemarketing registrations, bonds, and filings before directing outbound campaigns to residents of any state requiring such registration. This includes (without limitation) Florida, Texas, Indiana, Pennsylvania, Louisiana, Kentucky, Colorado, Georgia, Mississippi, Missouri, New York, North Carolina, Ohio, Oregon, South Carolina, Tennessee, Virginia, Washington, West Virginia, Wisconsin, and Wyoming.
7.2 Documentation. Customer shall maintain current copies of all registrations, bonds, and licenses and shall produce them on Ijadi’s request.
7.3 Who Registers. Where Customer holds the telephony account placing the calls (e.g., Customer’s own Twilio sub-account), Customer registers in its own name. Where Ijadi-controlled telephony infrastructure is used in a manner that requires Ijadi registration in a particular state, Ijadi will so register; Customer remains responsible for its own registration obligations.
8.1 Retention Period. Customer shall retain all consent records, scrub receipts, opt-out logs, training records, and other compliance documentation for a minimum of five (5) years from the date of the underlying event.
8.2 Records to Retain. Records shall include, at minimum: (a) consent capture surface (form URL, recording, screenshot); (b) consent date, time, IP address (where applicable), and signing or attesting identifier; (c) DNC and litigator scrub receipts for each campaign; (d) opt-out events with date, time, source, and resolution; (e) personnel training logs; (f) per-campaign attestations.
8.3 Production on Demand. Customer shall produce documentary evidence of consent for any record on the Platform within forty-eight (48) hours of Ijadi’s request. Failure to produce is a material breach of the MSA.
10.1 Scrubbing Gates. The Platform will hard-block any campaign for which the required DNC and litigator scrubs have not been completed within the applicable freshness window (typically 31 days).
10.2 Calling-Hour Gates. The Platform will block call placement outside the 8 a.m.–9 p.m. local-time window at the called party’s location.
10.3 Audit Logging. The Platform records, for each campaign and call: scrub timestamp and result; per-campaign attestation; caller ID configuration; dialing time; opt-out events; call disposition. Logs are retained for not less than four (4) years and are exportable on Customer’s or Ijadi’s request.
10.4 No Substantive Verification. Ijadi’s Platform controls operate on the metadata Customer provides. Ijadi does not independently verify the truthfulness of Customer’s attestations, the authenticity of Customer’s consent records, the accuracy of Customer’s caller ID, or the lawfulness of Customer’s data sourcing. Customer’s representations and attestations are dispositive between the Parties for purposes of allocating compliance responsibility.
10.5 Suspension for AUP Breach. Ijadi may suspend Customer’s access immediately upon any reasonable belief that Customer is breaching this AUP. Suspension does not relieve Customer of any obligation under the MSA, including payment of fees through the end of the current term.
11.1 Investigation. Ijadi may investigate any suspected AUP violation, including by reviewing Customer’s account, campaigns, scrub records, attestations, and audit logs.
11.2 Cooperation with Regulators. Where Ijadi receives a subpoena, civil investigative demand, regulatory inquiry, or pre-suit demand letter referencing Customer’s use of the Platform, Customer shall cooperate fully in producing responsive records at Customer’s expense, and Ijadi may produce responsive records in its possession in accordance with applicable law and the MSA.
11.3 Reporting Suspected Violations. Customer shall report to Ijadi promptly any suspected violation of this AUP by Customer’s personnel or by third parties using Customer’s account.
12.1 Right to Update. Ijadi may update this AUP at any time to reflect changes in applicable law (including FCC, FTC, and state rulemaking) or operational requirements.
12.2 Notice. Material updates will be communicated to Customer with at least thirty (30) days’ notice, except where a shorter period is required by law or the urgency of a regulatory change.
12.3 Acceptance. Continued use of the Platform after the effective date of an update constitutes acceptance of the updated AUP. Material updates may also require affirmative re-acceptance through the Platform.
12.4 Versioning. Each version of this AUP is identified by version number and effective date. Prior versions are retained and available on request.
