IMpower Solutions - Acceptable Use Policy (AUP)

Effective Date: December 11, 2025

This Acceptable Use Policy ("AUP") describes prohibited uses of the software, APIs, and messaging services provided by OwnerListens, Inc. d/b/a IMpower Solutions ("IMpower," "we," "us").

This AUP is incorporated by reference into the IMpower Terms of use. By using our Services, you agree to comply with this AUP. We reserve the right to remove you from the platform and terminate your account immediately if you violate these rules.

1. The "Golden Rule": Consent & Opt-In

You may only send messages to individuals who have given you prior express consent to be contacted.

• Opt-In Required: You must obtain consent before sending the first message. Consent cannot be bought, sold, or exchanged.
• Identify Yourself: Every message must clearly identify you (the sender) or the business you represent.
• Honor Opt-Outs: You must acknowledge and process all opt-out requests (e.g., STOP, UNSUBSCRIBE, CANCEL) immediately. You may not alter or obscure the functionality of these keywords.

2. Prohibited Content (The "Never" List)

You may not use the Services to send, transmit, or host any content that:

• Is Illegal: Violates any applicable law, regulation, or statute in the jurisdiction of the sender or recipient.
• Promotes Violence or Hate: Incites violence, promotes hate groups, or discriminates based on race, ethnicity, religion, gender, disability, or sexual orientation.
• Is Fraudulent or Deceptive: Includes phishing, "smishing," social engineering, or false claims.
• Infringes Rights: Violates intellectual property, privacy, or publicity rights of others.
• Contains Malicious Code: Viruses, trojans, worms, or other harmful scripts.
• Compromised Data: Includes social security numbers, passport numbers, or unencrypted Personal Health Information (PHI) subject to HIPAA (unless you have a signed BAA with us and are using a designated HIPAA-compliant tier).

3. Carrier Restrictions (SHAFT-C & High Risk)

(Note: While these restrictions are based on US carrier standards, we apply high safety standards globally. Exceptions for specific content (e.g., alcohol marketing in the UK) may be granted solely at IMpower’s discretion and subject to local law and age-gating requirements.)

Messaging carriers (Verizon, AT&T, T-Mobile, etc.) strictly prohibit certain content, even if it is legal in your jurisdiction. You may not send messages related to:

• S.H.A.F.T. (Sex, Hate, Alcohol, Firearms, Tobacco):
  • Sex: Adult content, pornography, prostitution, or solicitation.
  • Hate: (See Section 2).
  • Alcohol: Marketing or sales of alcohol (unless age-gated and strictly approved via special carrier registration).
  • Firearms: Guns, ammunition, and weapons.
  • Tobacco/Vaping: Tobacco products, e-cigarettes, vapes, or paraphernalia.
• Cannabis & CBD: Strictly Prohibited. Carriers block all messages related to marijuana, cannabis, CBD, Kratom, or paraphernalia, regardless of state or federal legality (e.g., the "Farm Bill" loophole does not apply to carrier policy).
• High-Risk Financial Services:
  • Payday loans, short-term high-interest loans, or auto title loans.
  • Debt collection, debt forgiveness, or credit repair.
  • "Get rich quick" schemes, multi-level marketing (MLM), or work-from-home scams.
  • Stock tips or speculative trading advice.
• Gambling: Online gambling, sports betting, or sweepstakes (unless properly registered and age-gated).

4. Prohibited Practices (Evasion & Abuse)

You may not use the Services to:

• Snowshoeing: Spreading message traffic across many phone numbers (10DLC or Toll-Free) to dilute reputation or evade spam filters.
• Number Cycling: Rapidly adding and releasing phone numbers to evade blocks.
• Sender ID Spoofing: In jurisdictions allowing Alphanumeric Sender IDs (e.g., the UK/EU), you may not use a Sender ID that impersonates another brand, government agency, or entity. Your Sender ID must accurately identify your business. We reserve the right to block unregistered or misleading Sender IDs.
• Spoofing: Falsifying the sender ID or otherwise masking the origin of a message.
• Public Emergency Services: You may not use the Services to contact 9-1-1 or other emergency service providers.
• Scraping: Harvesting data from our platform via unauthorized bots or scrapers.

5. Messaging Compliance (TCPA, GDPR, Etc.)

• 10DLC Registration (US): If sending via local long codes (10DLC) in the US, you must register your Brand and Campaign with The Campaign Registry (TCR). We facilitate this, but you must provide accurate data. "Grey route" or unregistered traffic is prohibited.
• WhatsApp Policies: If using WhatsApp, you must comply with the WhatsApp Business Messaging Policy and Commerce Policy.
• Telemarketing (US): If sending marketing messages, you must comply with the TCPA (Telephone Consumer Protection Act) and TSR (Telemarketing Sales Rule), including Do-Not-Call list scrubbing and specific consent requirements.
• EU/UK Compliance (GDPR & PECR): If messaging recipients in the UK or EU, you must comply with the GDPR, UK GDPR, and the Privacy and Electronic Communications Regulations (PECR). This includes ensuring a valid legal basis for processing (e.g., specific consent or "soft opt-in" for existing customers where legally permitted) and providing a free, easy-to-use opt-out method in every marketing communication.

6. Monitoring, Enforcement & Termination

We do not police every message, but we reserve the right to:

• Monitor traffic patterns and content (where legally permissible) to detect violations.
• Use automated filters to block messages that resemble spam or violate this AUP.
• Remove you from the platform and terminate you as a customer immediately, without notice, if you violate these rules.

7. Pass-Through Fines & Penalties

Carriers (e.g., T-Mobile) impose severe fines for AUP violations. If your traffic causes IMpower to be fined by a carrier, aggregator, or regulator, you agree to pay those fines in full.

• Example: T-Mobile currently levies fines up to $10,000 per violation for "Severity 0" violations (Social Engineering, Phishing, or Content that violates SHAFT).

8. Reporting Abuse

If you receive unwanted messages from an IMpower number or observe a violation of this policy, please report it to: [email protected]

We investigate all reports and take appropriate action.