TCPA Compliance Policy

1. What Is the TCPA?

The Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, is a federal law that restricts telephone solicitations and the use of automated telephone equipment. Key provisions relevant to our operations include:

• Restrictions on calls to numbers listed on the National Do Not Call Registry
• Required disclosure of the caller's identity and purpose
• Calling hour restrictions (8 AM – 9 PM local time of the called party)
• Prohibition on calls to numbers on a company's internal Do Not Call list
• State-level telemarketing laws that may impose additional restrictions

Cold Call Collect engages exclusively in B2B (business-to-business) outreach. While some TCPA provisions apply differently to B2B calls than to consumer calls, we maintain compliance standards that meet or exceed all applicable requirements.

2. Consent Policy

Cold Call Collect operates under a prior express consent framework. Specifically:

B2B Outreach

For calls to business lines and direct business numbers of employees acting in their business capacity, we rely on the established business relationship and the prospect's publicly listed professional contact information. We do not use autodialing equipment or pre-recorded messages without the appropriate level of consent.

Wireless Numbers

When a contact's number may be a wireless (cell) number, we take additional steps to verify that appropriate consent exists before calling, or we rely solely on methods that do not require consent under the applicable B2B exemption.

Consent Documentation

We maintain records of the basis on which each contact was included in a campaign. Clients are required to represent and warrant that all contacts provided have been lawfully obtained and may be contacted under applicable law.

3. National DNC Registry Compliance

Cold Call Collect subscribes to and regularly accesses the National Do Not Call Registry maintained by the Federal Trade Commission (FTC). Our process includes:

• Scrubbing all contact lists against the National DNC Registry prior to campaign launch
• Re-scrubbing lists at least every 31 days for ongoing campaigns
• Maintaining a registered Subscription Account Number (SAN) with the FTC
• Honoring DNC registrations within 30 days of a consumer's registration date

4. Internal Do Not Call List

In addition to the National DNC Registry, Cold Call Collect maintains an internal Do Not Call (iDNC) list. Any individual who requests not to be called is added to our iDNC list within 5 business days of the request and is honored indefinitely.

Our iDNC list is:

• Maintained in a secure database
• Scrubbed against all new and ongoing campaigns
• Shared with clients upon request for the contacts generated through their campaigns
• Never sold or shared with third parties

5. Calling Hours & Restrictions

All outreach calls are made within the legally permitted hours of 8:00 AM to 9:00 PM local time of the party being called. We use time-zone detection tools to ensure compliance regardless of where our callers are located.

We do not make calls on federal holidays as a matter of best practice, though this is not legally required for B2B calls.

6. Caller Identification

All calls made by Cold Call Collect on behalf of clients include:

• Truthful identification of the caller's name at the beginning of each call
• Disclosure of the client company on whose behalf the call is being made (where applicable)
• A callback number that the called party can use to request placement on the Do Not Call list
• Accurate Caller ID transmission — we never spoof or falsify caller ID information

7. Record Keeping

Cold Call Collect maintains the following records for a minimum of 4 years:

• DNC scrub reports and scrub dates for each campaign
• Internal DNC list with opt-out dates and methods
• Call logs including date, time, number called, and disposition
• Consent documentation provided by clients
• Training records for all staff

These records are available to clients upon written request and to regulatory authorities as required by law.

8. Staff Training

All Cold Call Collect callers and campaign managers receive TCPA compliance training that covers:

• Overview of TCPA requirements and penalties
• Proper caller identification and disclosure requirements
• How to handle opt-out requests immediately and correctly
• Calling hours and geographic time zone compliance
• State-specific telemarketing laws applicable to their campaigns

Training is completed at onboarding and refreshed annually. Records of completed training are maintained.

9. Client Obligations

Clients who engage Cold Call Collect's services agree to:

• Provide only contact lists that have been lawfully obtained
• Represent that outreach to the provided contacts is legally permissible
• Provide their current internal Do Not Call list before campaign launch and update it promptly as new opt-outs are received outside our campaigns
• Indemnify Cold Call Collect against any TCPA claims arising from Client's provision of improperly obtained or unlawfully solicited contact information

Cold Call Collect reserves the right to refuse or suspend any campaign that presents TCPA compliance concerns.

10. How to Opt Out

If you have received a call from Cold Call Collect and wish to be placed on our Do Not Call list, you may request opt-out through any of the following methods:

• By phone: Tell the caller "please add me to your Do Not Call list" — requests made verbally during a call are honored immediately
• By email: [DNC-EMAIL] — include your phone number and "DNC Request" in the subject line
• By phone: Call our compliance line at [DNC-PHONE]
• By mail: Cold Call Collect — DNC Request, [YOUR BUSINESS ADDRESS]

Opt-out requests are processed within 5 business days and honored for a minimum of 5 years.

11. Reporting Potential Violations

If you believe you have received a call from Cold Call Collect that violates the TCPA or this policy, please contact our compliance team immediately. We take all reports seriously and investigate all complaints promptly.

You may also file a complaint with:

• The Federal Trade Commission (FTC): donotcall.gov
• The Federal Communications Commission (FCC): fcc.gov
• Your state attorney general's consumer protection office

12. Contact Compliance Team

For compliance questions, opt-out requests, or to report a concern:

• Email: [DNC-EMAIL]
• Phone: [DNC-PHONE]
• Mail: Cold Call Collect — Compliance Department, [YOUR BUSINESS ADDRESS]

We aim to respond to all compliance inquiries within 2 business days.