Telgorithm Acceptable Use Policy

Last Updated: October 2, 2026 · Effective: October 2, 2026

This Acceptable Use Policy (“AUP”) is incorporated into and forms part of the Telgorithm Terms of Service (the “Terms”). Capitalized terms not defined in this AUP have the meanings given in the Terms. This AUP has three parts: Part A (General Acceptable Use), Part B (Messaging Policy), and Part C (Pass-Through Terms, including the Participating Carrier requirements in Appendix 1). In case of conflict, Part C prevails over Parts A and B.

Part A — General Acceptable Use

This AUP describes rules that apply to any party (“Customer”) using the Application-to-Person (A2P) type messaging platform (“Telgorithm Platform”) provided by Telgorithm Inc. (“Telgorithm”) and any user of any software application or service made available by Customer that interfaces with the Telgorithm Platform (“End User”). The examples described in this AUP are not exhaustive. Customer is responsible for its End Users’ compliance with this AUP.

Inappropriate Content or Users. Do not use the Telgorithm Platform to transmit or store any content or communications (commercial or otherwise) that is illegal, harmful, unwanted, inappropriate, objectionable, confirmed to be criminal misinformation, or otherwise poses a threat to the public. This prohibition includes use of the Telgorithm Platform by a hate group or content or communications that originate from a hate group or are exploitive, abusive, or hate speech.

Prohibited Activities. Do not use the Telgorithm Platform to engage in or encourage any activity that is illegal, deceptive, harmful, violating others’ rights, or harmful to Telgorithm’s business operations or reputation, including:

Service Integrity Violations. Do not violate the integrity of the Telgorithm Platform, including:

Data Safeguards. Customer is responsible for determining whether the Telgorithm Platform offers appropriate safeguards for Customer’s use of the Telgorithm Platform, including, but not limited to, any safeguards required by Applicable Laws, prior to transmitting or processing, or prior to permitting End Users to transmit or process, any data or communications via the Telgorithm Platform.

The Campaign Registry Guidelines. Customer must adhere to and stay in compliance with all registration guidelines set forth by The Campaign Registry as provided by Telgorithm.

Part B — Telgorithm’s Messaging Policy

This Messaging Policy is part of this AUP and applies to SMS and MMS messaging channels. To ensure all messages are received, unhindered by filtering or other similar blockers, Telgorithm strives to work with Customers so that messages are sent with the consent of the message recipient, and that those messages comply with all applicable laws and communications industry guidelines or standards.

Messaging. Telgorithm treats all messaging transmitted via Telgorithm Platform, regardless of use case or phone number type (e.g., long code or toll-free), as A2P messaging. All A2P messages originating from Telgorithm are subject to this Messaging Policy, which covers rules and/or prohibitions regarding:

If Customer provides its own End Users with the ability to send messages through Telgorithm Platform, for example as an independent software vendor, Customer is responsible for the messaging activity of its End Users. Customer must ensure that any messaging activity generated by its End Users is in compliance with Telgorithm’s policies.

Consent/Opt-in. Consent cannot be bought, sold, or exchanged. For example, Customer cannot obtain the consent of message recipients by purchasing a phone list from another party. Aside from Alternative Consent Requirements noted below, Customer must meet each of the consent requirements listed below. If Customer is a software or platform provider using Telgorithm Platform for messaging within its application or service, Customer must require its End Users to adhere to these same requirements.

Alternative Consent Requirements. While consent is always required and the consent requirements noted above are generally the safest path, consent can be received differently in the following scenarios:

Periodic Messages and Ongoing Consent. To send messages to a recipient on an ongoing basis, Customer should confirm the recipient’s consent by offering them a clear reminder of how to unsubscribe from those messages using standard opt-out language (defined below). Customer must also respect the message recipient’s preferences in terms of frequency of contact. Customer also needs to proactively ask individuals to reconfirm their consent as set forth by local regulations and best practices.

Identifying Yourself as the Sender. Customer must identify itself as the sender in every message it sends, except in follow-up messages of an ongoing conversation.

Opt-out. The initial message sent to an individual needs to include the following language: “Reply STOP to unsubscribe,” or the equivalent using another standard opt-out keyword, such as STOPALL, UNSUBSCRIBE, CANCEL, END, and QUIT.

Individuals must have the ability to revoke consent at any time by replying with a standard opt-out keyword. When an individual opts out, Customer may deliver one final message to confirm that the opt-out has been processed, but any subsequent messages are not allowed. To send any additional messages to an individual who has opted out, Customer must obtain consent again.

Usage Limitations

Prohibited Content. The key to ensuring that messaging remains a great channel for communication and innovation is preventing abusive use of messaging platforms. That means Telgorithm never allows certain types of content on Telgorithm Platform, even if a Customer obtains consent from recipients for that content. Telgorithm prohibits sending any content that is illegal, harmful, unwanted, inappropriate, objectionable, confirmed to be criminal misinformation, or otherwise poses a threat to the public, even if the content is permissible by law. Other prohibited uses include:

Country-Specific Rules. All messages should comply with the rules applicable to the country in which the message recipient lives.

Age and Geographic Gating. Additional restrictions apply to messages that include content in any way related to alcohol, firearms, gambling, tobacco, or other adult content. In addition to obtaining consent from every message recipient, Customer must ensure that no message recipient is younger than the legal age of consent based on where the recipient is located. Customer also must ensure that the message content complies with all applicable laws of the jurisdiction in which the message recipient is located or applicable communications industry guidelines or standards. Customer needs to be able to provide proof that it has in place measures to ensure compliance with such restrictions.

Messaging Policy Violation Detection and Prevention Evasion. Customers may not use our Telgorithm Platform to evade Telgorithm’s or a telecommunications provider’s unwanted messaging detection and prevention mechanisms. Examples of prohibited practices include:

Violations of AUP. When a violation of these principles is identified, where possible, Telgorithm will work with Customers in good faith to get them back into compliance with this policy. However, for protection of the continued ability of all Customers and End Users to freely use Telgorithm Platform for legitimate purposes, violations of this AUP by Customer or any End User may result in the immediate suspension or termination of Customer’s or End User’s use of the Telgorithm Platform, or civil and/or criminal liability. In any such event, Customer is still liable for any and all outstanding charges accumulated through the use of the Telgorithm Platform, including uses in violation of this AUP, the laws of any applicable jurisdiction, or applicable communications industry guidelines or standards. In addition, Telgorithm may investigate incidents that are contrary to this AUP and provide requested information to third parties who have provided notice to Telgorithm stating that they have been harmed by Customer or its End Users’ failure to abide by this AUP. Telgorithm’s failure to enforce this policy does not amount to a waiver of any of its rights hereunder. Violations of this AUP, including any prohibited content or communications, may be reported to https://www.telgorithm.com/help. Customer agrees to immediately report any violation of this AUP to Telgorithm and provide cooperation, as requested by Telgorithm, to investigate and/or remedy that violation.

Changes to This AUP. Telgorithm may update this AUP, including Part C, in accordance with Section 13(c) of the Terms.

Part C — Pass-Through Terms

This Part C is incorporated into and forms part of the Telgorithm Terms of Service (the “Agreement” or the “Terms”) through this AUP. Capitalized terms not defined in this Part C have the meanings given in the Terms of Service. As used in this Part C, “Message” and “Messages” mean SMS Messages and MMS Messages, and references to “SMS Messages,” “SMS message,” or “SMS” include MMS Messages except where the context requires otherwise. “Deactivated MDN” means a mobile directory number (“MDN”) that a Participating Carrier, or a vendor of a Participating Carrier or of Telgorithm, has identified to Telgorithm as deactivated, disconnected, ported away, or reassigned.

Participating Carrier Requirements

A “Participating Carrier” means a mobile network operator with whom Telgorithm or its vendors have an agreement to allow for termination of SMS Messages on its network. Carrier-specific requirements for AT&T, T-Mobile (including the former Sprint network), and Verizon are set out in Appendix 1. Telgorithm may add, remove, or change Participating Carriers and may update Appendix 1 at any time to reflect requirements imposed by Participating Carriers, effective upon posting of the updated AUP. The Participating Carrier associated with the recipient network determines the process, requirements, and guidelines for classification of SMS Messages as application-to-person (A2P), and Telgorithm shall, in its reasonable discretion, enforce and apply such process, requirements, and guidelines to Customer’s SMS message traffic.

Customer Compliance

Customer will (i) ensure that its users, clients, subscribers, employees, agents, representatives and third-party contractors when accessing the Telgorithm Platform comply with Telgorithm’s acceptable use policy as stated in the Pass-Through Acceptable Use Policy set forth below (“Pass-Through AUP”); (ii) not use the Telgorithm Platform to send any Unwanted Messages (defined below) or any SMS Messages in violation of the Participating Carrier Requirements; (iii) strictly adhere to the CTIA Guidelines for SMS-IP interoperability for anti-abuse; and (iv) notwithstanding any limitation of liability set forth in the Agreement, defend, indemnify, and hold harmless Telgorithm from and against any and all costs, losses, damages and expenses, including reasonable attorneys’ fees arising from or relating to any third party claims or fines arising from Customer’s, Customer’s Participating Subscribers’, employees’, agents’, representatives’ and third-party contractors’, violation of the provisions of the Pass-Through AUP. Customer acknowledges and agrees that Participating Carriers may impose fines for Customer’s failure to comply with this obligation or any other obligation in this Agreement, in which case such fines will be passed through from Telgorithm to Customer.

Use Cases; Audit

Customer is responsible for the evaluation and qualification of its use cases to ensure such use cases adhere to Participating Carrier Requirements and the Pass-Through AUP. Telgorithm has the right to audit all such use cases prior to enabling the Telgorithm Platform for Customer, and Customer shall provide such use cases to Telgorithm. Upon request, Customer shall make available to Telgorithm all its use cases for review and approval, which approval may be withheld in its sole discretion prior to implementation of the Telgorithm Platform for Customer. Notwithstanding any limitation of liability set forth in this Agreement, Customer shall fully indemnify, defend, and hold harmless Telgorithm for any loss, damage, claim, cost or expense, including reasonable attorneys’ fees, resulting from any SMS Messages or the unauthorized use of the Telgorithm Platform or any violation of this Agreement by Customer.

Changes

Customer acknowledges and agrees that:

In the event any legal or industry regulation is enacted or comes into force during the term of this Agreement, Telgorithm hereby reserves the right to make any and all modifications to the Telgorithm Platform or the terms and conditions in this Agreement that are necessary in order to fully comply with all such regulations without Customer’s consent (notwithstanding anything to the contrary in the Terms). Telgorithm shall make all commercially reasonable efforts to notify Customer of any such modifications to the Telgorithm Platform via email as soon as reasonably practicable.

A Participating Carrier’s participation within the messaging industry is not mandatory and that any Participating Carrier may, in its sole discretion, participate, not participate or terminate its current participation within the messaging industry at any time, and further, that Telgorithm has no control over any given Participating Carrier’s participation, non-participation or termination of its participation. Customer acknowledges that each Participating Carrier may elect to allow or not allow the transmission of SMS messages to and/or from its network at any time without prior notice, and that each Participating Carrier may require Telgorithm or its vendors to cease transmitting SMS messages to and/or from the Participating Carrier’s network immediately and without prior notice.

SMS Message use cases and/or messaging programs (“Programs”) previously approved can be re-evaluated at any time by the Participating Carriers, and Participating Carriers have the right to revoke a previously approved Program or classification in its sole discretion. Further, Participating Carriers reserve the right to monitor Customer’s SMS Messaging traffic and audit all Programs, and Telgorithm may share the results of the audit, including Customer’s traffic reports, with the Participating Carriers.

From time to time, a Participating Carrier may request Telgorithm to provide information regarding subscribers’ consent to receive SMS Messages from Customer. Customer agrees that it will reasonably assist Telgorithm to provide relevant information in response to such Participating Carrier’s request.

Upon Telgorithm’s notice to Customer of Deactivated MDN information received by Telgorithm (which notice may be provided through the Subscription Services, including via API or Customer’s account interface), Customer shall, within twenty-four (24) hours of such notice, (a) update its systems to bar all Messages from being sent to the Deactivated MDNs, and (b) update the status of such MDNs in its systems. Telgorithm may block or reject Messages addressed to Deactivated MDNs. Customer remains solely responsible for compliance with the Telephone Consumer Protection Act, other applicable law, and the Participating Carrier Requirements with respect to reassigned, ported, and deactivated numbers, including by means available to Customer independently of Telgorithm, whether or not Telgorithm provides any Deactivated MDN information.

Customer acknowledges that Telgorithm does not own the database information contained in the SMS routing database, and the data is only as accurate as the data that exists in the applicable records as input by service providers and providers of telecommunications related services.

Telgorithm will use commercially reasonable efforts to deliver all SMS Messages to Customer’s subscribers. Telgorithm, however, will bear no liability to Customer, subscribers or any third parties for failing to deliver SMS Messages for any reason outside the reasonable control of Telgorithm.

Pass-Through Acceptable Use Policy

Customer shall comply with the Pass-Through AUP set forth below:

Customer will comply with the Participating Carrier Requirements, the CTIA Guidelines, and all applicable laws and regulations, including, but not limited to, the Telephone Consumer Protection Act (TCPA), FTC Truth in Advertising Rules, CAN-SPAM Act, any FCC regulations regarding the provision and revocation of consumer consent for communications, as well as any other applicable laws or relevant industry standards for SMS messaging.

Customer represents and warrants that Customer or its subscribers are the owners, agents or authorized licensees of all rights, title and interest in and to any intellectual property, proprietary rights or other rights relating to any and all data, text, pictures, video, or any other type of form of information contained in the body of any SMS message.

Customer will not send any Unwanted Messages or Inappropriate Content, or any messages or content that violates or infringes any copyright, patent, trademark or trade secret or right of privacy or publicity or any other personal or proprietary right of any third parties. “Unwanted Messages” means: (i) unsolicited bulk commercial messages (i.e., spam); (ii) “phishing” messages intended to deceive (such as attempting to access private or confidential information through deception); (iii) messaging that contains or links to content that is abusive, harmful, deceptive, fraudulent, misleading, malicious, unlawful, harassing, threatening, discriminatory, bullying, excessively profane, obscene, defamatory, libelous; promotes or glamorizes alcohol abuse, illegal drug use or use of tobacco products; causes safety concerns; incites harm or violence; and (iv) is intended to intimidate; includes malware, threatening or otherwise inappropriate content. Further, Unwanted Messages include messages which required an opt-in that was not obtained, messaging that does not respect subscriber opt out requests, or does not contain proper age gating, and as otherwise set forth in the Participating Carrier Requirements, the CTIA Guidelines or Federal Trade Commission Truth in Advertising Rules. “Inappropriate Content” means any and all Content that (i) violates Applicable Law (meaning any law, regulation, rule, order, or award of any government authority applicable to a Party, its business, or the subject matter of this Agreement, including but not limited to the following United States statutes and any regulations relating thereto: the Telephone Consumer Protection Act, the Telephone Consumer Fraud & Abuse Prevention Act, and the Controlling the Assault of Non-Solicited Pornography and Marketing [CAN-SPAM] Act, any FCC regulations regarding the provision and revocation of consumer consent for communications); (ii) is unsolicited, including without limitation, bulk messages, spam or other unsolicited commercial or other advertising material; (iii) causes the introduction of “viruses,” “worms,” “Trojan horses,” “bombs,” “cancelbots,” “phishing” or other similar destructive computer programming routines; (iv) violates any CTIA Guidelines or violates any Participating Operator requirements, conditions, or codes of practice; (v) constitutes “hate speech” or is obscene, offensive, threatening, defamatory, libelous, promotes or glamorizes alcohol abuse, illegal drug use or use of tobacco products, discriminatory, harassing, bullying, harmful, deceptive or intentionally misleading or inaccurate for commercial gain; (vi) infringes or misappropriates the intellectual property or proprietary information of any person including but not limited to copyright, patent, trademark or trade secret or right of privacy or publicity or any other personal or proprietary right of any subscriber or third party; or (vii) as well as any other applicable laws or relevant industry standards for SMS messaging.

Customer will take reasonable measures to prevent SMS Messages from containing any virus, Trojan horse, worm, back door, trap door, time bomb, drop-dead device, timer, clock, counter or other limiting routine, as well as any other instructions, designs, software routines, or hardware components designed to disable, erase, or otherwise harm software, hardware, data, text or any other information stored in electronic form.

Customer will obtain each subscriber’s affirmative opt-in consent before sending SMS Messages to such subscriber (“Participating Subscribers”). Customer must also honor and manage the opt-in and opt-out process for both automated and group SMS Message traffic by providing each Subscriber a readily available opt-out mechanism to revoke consent in accordance with messaging industry standards and applicable law. Both automated and group messaging traffic must be opted into by the subscriber, and the opt-out policy must be included in the body of each message. Customer will only send SMS Messages to Participating Subscribers.

Without limiting the foregoing, Customer agrees not to use the Telgorithm Platform to transmit or disseminate any of the following: (i) unsolicited material to persons or entities that have not agreed to receive such material or to whom Customer, Participating Subscribers or other end users do not otherwise have a legal right to send such material; (ii) material or data that infringes or violates any third party’s intellectual property rights, including patent, copyright, trademark, or trade secret, rights of publicity, privacy, or confidentiality, or the rights or legal obligations of any wireless service provider or any of its customers or subscribers; (iii) material or data that is false or misleading, likely to mislead or deceive, illegal, harassing, coercive, defamatory, libelous, abusive, threatening, obscene, contains sexually suggestive or explicit Content, or otherwise objectionable materials that are harmful to minors or excessive in quantity, or materials the transmission of which could diminish or harm the reputation of Telgorithm or any third-party service provider involved in the provision of the Telgorithm Platform; (iv) viruses, Trojan horses, worms, time bombs, cancelbots, or other computer programming routines that are intended to damage, interfere with, intercept or expropriate any system, data, or personal information; (v) any signal or impulse that could cause electrical, magnetic, optical, or other technical harm to the equipment or facilities of Telgorithm or any third party; or messages that are not in compliance with the regulations, orders or directions issued by any legal, governmental, or regulatory authority or body. “Content” means information, text, data, images, and sound recordings. This Pass-Through AUP may be updated in accordance with Section 13(c) of the Terms. Customer will defend, indemnify, and hold harmless Telgorithm from and against all third party claims or fines arising from Customer’s, Participating Subscribers’, any other subscribers or end users’, employees’, agents’, representatives’ and third-party contractors’, violation of the Pass-Through AUP.

Telgorithm may suspend the Telgorithm Platform, with advance notice unless advance notice is not feasible or practicable under the circumstances, if: (i) necessary to comply with applicable laws, regulations, or requirements of wireless service providers, Short Code providers/licensors, mobile industry associations, regulatory/governmental authorities or other third parties related to the Telgorithm Platform; or (ii) a law or regulatory action prohibits, impairs or makes impractical the provision of the Services; (iii) there is use of the Telgorithm Platform which Telgorithm determines may create liability or may be fraudulent, illegal, unauthorized or in violation of the Pass-Through AUP; or (iv) there is unauthorized use or disclosure of Telgorithm confidential information (as identified in the Agreement) or Customer’s ID or passwords. Telgorithm has a right of suspension and/or termination with immediate effect if the Customer sends traffic which leads to operators’ end-users’ complaints. Telgorithm may provide notice of such termination by email (provided normal evidence of delivery is retained by Telgorithm). Telgorithm and Customer will engage in good faith discussions, as soon as reasonably practicable, to discuss mutually beneficial ways to resolve any issues arising from such suspension.

Content Indemnification

Notwithstanding any limitation of liability set forth in this Agreement, Customer will defend, indemnify, and hold harmless Telgorithm from and against any and all costs, losses, damages and expenses, including reasonable attorneys’ fees arising from or relating to any third party claims or fines alleging that any SMS messages, the Content of any SMS messages, or the volume of any of the SMS messages, (i) infringes or misappropriates any intellectual property right of any person, (ii) contains Inappropriate Content or violates any Applicable Law or (iii) arises from or relates to any SMS messages in violation of the provisions of this Agreement.

User Information

Customer acknowledges that in connection with Customer’s, Participating Subscribers’, any other subscribers or end users’, use of the Telgorithm Platform, Telgorithm may receive various user information and data (collectively “User Information”). Telgorithm exercises no control whatsoever over any Content or User Information, including the Content of messages and information that may be transmitted or generated using the Telgorithm Platform. Telgorithm’s responsibilities are limited to storing and transmitting the User Information to and from Customer, Participating Subscribers, any other subscribers or end users, and other third parties identified by the foregoing. Telgorithm has no obligation or responsibility to review, monitor, filter or edit User Information in order to determine whether any such User Information may violate applicable law or regulation or to prevent a violation of applicable law or regulation, or to avoid the creation of liability to, or on the part of, Customer, users, Subscribers or any third party. Customer is solely responsible for all User Information and Content and transmissions thereof and use of the Telgorithm Platform. Telgorithm reserves the right to monitor Customer’s, Participating Subscribers’, any other subscribers or end users’ use of the Services to verify compliance with the terms and conditions of the Pass-Through AUP. Telgorithm will not use or disclose User Information except: (i) as required by law, regulation or third parties (e.g., wireless service providers) involved in providing the Telgorithm Platform, (ii) to provide and/or invoice Customer for the Telgorithm Platform, or (iii) to protect Telgorithm, its facilities, network, service, customers or third parties.

Disclaimer

Customer acknowledges that Telgorithm’s provision of the Telgorithm Platform is dependent on the facilities, networks, connectivity of third parties, including third party wireless service providers, mobile network operators, and third party aggregators (collectively, “Third Party Factors”) over which Telgorithm has no control. Telgorithm will have no liability for any degradation, reduction, interruption, termination or suspension of the Telgorithm Platform related to any issues deemed by Telgorithm to be outside Telgorithm’s control. Neither Telgorithm, its suppliers, nor any third party: (i) Will be liable to Customer or any third party for messages that are deleted or not delivered, regardless of the reason for deletion or non-delivery including, without limitation, message processing or transmission errors or failures; and (ii) makes any representations or warranties regarding the quality, reliability, timeliness or security of the services or that the Telgorithm Platform will be error-free, uninterrupted, or free from unauthorized access or not infringe third party rights.

Appendix 1 — Participating Carrier Message Requirements

Customer shall comply with the then-current messaging codes of conduct, guidelines, and requirements of each Participating Carrier (including the T-Mobile and AT&T Messaging Codes of Conduct), the CTIA Messaging Principles and Best Practices, and the Telephone Consumer Protection Act and its implementing regulations, in each case as updated from time to time. Telgorithm has no obligation to publish or distribute Participating Carrier codes of conduct or guidelines or to notify Customer of changes to them; current copies are available from Telgorithm upon request.

Verizon Participating Carrier Message Requirements for SMS Messages designated as Non-Consumer (A2P) SMS (in Verizon’s sole discretion and in accordance with Verizon’s definition of same, which will be shared by Telgorithm upon request):

Customer acknowledges that Verizon does not treat its messaging service as a HIPAA-compliant channel. Customer shall not use the Services to transmit PHI (as described in the DPA) and remains solely responsible for its own HIPAA compliance.

Customer shall, if requested by Verizon, engage a reputable third-party security firm (subject to approval by Verizon) to conduct an annual vulnerability and penetration testing of Customer’s websites performing functions related to the Telgorithm Platform. These tests must verify that Customer’s security controls on the websites are adequate to ensure the integrity of opt-in/opt out controls and the confidentiality of confidential information, including but not limited to data related to Verizon subscribers. Customer shall resolve promptly any high or medium risk vulnerabilities identified as a result of these tests.

Customer will, and will ensure its clients, comply with the following when utilizing the Telgorithm Platform to send SMS messages to Verizon:

T-Mobile (including the former Sprint Network) Participating Carrier Message Requirements for SMS Messages designated as Non-Consumer (A2P) SMS (in T-Mobile’s sole discretion and in accordance with T-Mobile’s definition of same):

AT&T Participating Carrier Message Requirements for SMS Messages designated as Non-Consumer (A2P) SMS (in AT&T’s sole discretion and in accordance with AT&T’s definition of same):