Consent & TCPA Practices

Last reviewed: [set date after counsel review] · Review cadence: quarterly

Consent capture methodology

• One-to-one consent. Consent is captured for the specific party who will contact the consumer, identified by name at the point of capture — not blanket "marketing partners" consent.
• Clear and conspicuous disclosure. The consent language appears adjacent to the action that grants it, unbundled from other terms, in plain language.
• Affirmative action. Consent requires an unambiguous act (checkbox, button, verbal confirmation) — never pre-checked or implied.
• Evidence retained per event. For every lead and call: the exact language displayed, method of consent, timestamp, page or call context, and technical metadata (e.g., IP, session) where applicable.

Disclosure language handling

• Landing pages disclose who is collecting information, who may contact the consumer, and by what channels.
• Vertical-specific disclosures (e.g., third-party marketing organization language in Medicare) are required in creative and call flows where regulation demands them.
• Publisher landing flows are reviewed at onboarding and re-reviewed on material change; see publisher vetting.

Call recording practices

• Calls are recorded with disclosure consistent with applicable one- and two-party consent laws.
• Recordings are linked to the billable event record and available to the advertiser for the campaign they own.
• Access to recordings is role-restricted and logged.

DNC scrubbing

• Outbound contact is scrubbed against the National DNC Registry and applicable state lists before dialing.
• Internal suppression lists are honored network-wide; a consumer's opt-out with one campaign suppresses across our system.
• Scrub logs are retained and auditable. See the DNC policy.

Record retention & audit trail

• Consent records, recordings, and source-chain data are retained for a defined schedule aligned to regulatory expectations and contractual commitments.
• Every billable event can be traced end to end: publisher → campaign → creative → consent → delivery → disposition.
• Audit exports are available to advertisers for their campaigns and to regulators on lawful request.