Messaging Policy

Why this policy exists

Anthony Oliva registers brands and campaigns with The Campaign Registry and passes traffic to mobile network operators through our connectivity partners. That makes us accountable, upstream, for the traffic our customers originate.

This policy is the standard we hold every customer to. It is contractual: it is incorporated into our Terms of Service and sits alongside our Acceptable Use Policy. It reflects the CTIA Messaging Principles and Best Practices, the Telephone Consumer Protection Act, the Federal Communications Commission’s rules on consent revocation, and the individual messaging policies of AT&T, T-Mobile, and Verizon.

If a rule here is stricter than the law, follow the rule here. Carrier requirements frequently exceed the statutory minimum.

Consent is mandatory

You must obtain prior express consent from the recipient before sending any message. Consent must be:

• Given by the recipient, not by a third party, a list vendor, or a lead generator.
• Specific to your business. Consent belongs to the brand named in the call-to-action. It is never transferable, assignable, or resalable.
• Specific to the program. A separate opt-in is required for each use case. Consent to receive appointment reminders is not consent to receive marketing.
• Documented. You must retain a verifiable record.
• Freely given. Consent to receive marketing messages may never be a condition of purchase or of receiving a service.

Marketing and promotional messaging requires prior express written consent. Informational and transactional messaging requires prior express consent, which may be oral.

Required call-to-action disclosures

Whatever the channel, the point at which you collect consent must clearly disclose all of the following before the recipient acts:

1. The brand or program name doing the sending
2. The type of messages the recipient will receive
3. The message frequency, for example “message frequency varies” or “up to 4 messages per month”
4. The exact phrase “Message and data rates may apply”
5. Opt-out instructions, for example “Reply STOP to unsubscribe”
6. Help instructions, for example “Reply HELP for help”
7. A link to your Terms and Conditions
8. A link to your Privacy Policy

Consent language must not be buried inside general terms of service. It must be visible at the moment of consent.

Web form opt-in

If you collect consent on a website:

• The consent checkbox must be unchecked by default.
• The form must be submittable without checking it. A required SMS consent checkbox is a forced opt-in and will be rejected.
• SMS consent must be separate from consent to email, phone calls, or general terms.
• Links to your Terms and your Privacy Policy must be adjacent to the checkbox, not only in the page footer.
• The page must be served over HTTPS with a valid certificate and must be publicly reachable without a login.
• If your opt-in sits behind authentication, you must host screenshots of the full flow at a public URL and supply that URL at registration.

Our own SMS alerts sign-up page is built to this standard and can be used as a reference implementation.

Other opt-in channels

We strongly recommend a double opt-in confirmation for any consent collected outside a website form.

Proof of consent

You must be able to produce proof of consent for any recipient, on request, within 24 hours. Carriers and aggregators can demand it at any time, and failure to produce it can result in campaign suspension for you and reputational damage for every brand on the same route.

Retain, at minimum: the timestamp, the source of consent, the IP address for web opt-ins, the exact disclosure text presented, and the full opt-out history. Keep it for the life of the subscription plus four years.

Opt-out handling

We process opt-outs at the platform level, but you remain responsible for honoring them in your own systems.

• STOP, UNSUBSCRIBE, CANCEL, END, and QUIT are honored automatically on every number, in any letter case, and cannot be disabled.
• One final confirmation message may be sent. It must not contain marketing content, a link, or a request to reconsider.
• After opt-out, no further messages may be sent to that number for that program.
• Consistent with FCC rules, opt-out requests made by any reasonable means must be honored within 10 business days. This includes email, a phone call, a reply in plain language, or a request to your staff. You must have a process that carries these requests across channels.
• Re-obtaining consent after an opt-out requires a fresh, documented opt-in. You may not send a message asking the recipient to opt back in.

HELP handling

Every number must respond to HELP with the program name and a way to reach a human, whether or not the sender is subscribed. Our platform provides a default HELP responder; if you override it, your replacement must contain the program name plus an email address or phone number.

Message content standards

• Identify the brand in the message, ideally at the start. A recipient must never have to guess who is texting.
• Include opt-out language in recurring programs. Including it in every message is best practice.
• No public URL shorteners. Use a branded domain or a dedicated shortener you control. Shared shorteners are blocked by carriers.
• Links must resolve to a working page on a domain associated with your registered brand.
• No misleading sender identity, and no content that implies a relationship that does not exist.
• Message content must match the use case declared in your campaign registration. Sending marketing under a customer care campaign is a violation.

Campaign registration

All A2P traffic to United States numbers must be registered before it is sent.

1. Brand registration. Your legal business name and EIN must match your IRS records exactly. The address must be a physical address, not a PO box. Your website must be live, secure, and display the same business name.
2. Campaign registration. You declare the use case, provide a detailed description, supply sample messages, describe the opt-in flow, and give public URLs for your Terms and your Privacy Policy.
3. Carrier review. Direct connect aggregators review the submission on behalf of the carriers. Reviewers are human and they open your website.
4. Throughput assignment. Carriers assign message throughput based on your brand trust score and use case.

We review every submission before it goes upstream and will tell you what needs fixing rather than letting it fail. Registration and vetting fees charged by The Campaign Registry, the aggregators, and the carriers are passed through to you at cost.

Sole proprietors, political messaging, and other special use cases carry additional vetting requirements. Contact us before you submit.

Volume and throughput

Do not exceed your assigned throughput. Do not distribute a single program across multiple numbers or campaigns to increase volume or dilute reputation. Traffic that ramps abnormally may be throttled while we verify the source of the recipient list.

Monitoring and enforcement

We screen traffic for prohibited content, spam patterns, and consent anomalies. High complaint rates, high opt-out rates, elevated delivery failure to invalid numbers, and abnormal duplication all trigger review.

Where a problem is found we will contact you and, depending on severity, throttle, suspend, or terminate. Where carrier rules require immediate action, we act first and notify afterwards. The escalation path is described in our Acceptable Use Policy.

Reporting

Report suspected violations to abuse@anthonyoliva.com or through our abuse reporting form. Recipients who want to stop receiving messages sent through our platform can use our opt-out form and we will trace the traffic to its origin.

How to reach us

Questions about this document can be sent tolegal@anthonyoliva.com. Privacy requests go toprivacy@anthonyoliva.com. Abuse reports go toabuse@anthonyoliva.com or through ourabuse reporting form.

ANTHONY OLIVA, INC.
6724 Thompson Road, Syracuse, NY 13211, United States
+1 (332) 231-6423
support@anthonyoliva.com