When submitting a 10DLC Campaign for approval, per carrier code of conduct, the privacy policies and the terms and conditions must be found in a clear, conspicuous place next to where the phone number is entered by the consumer. To check this, we review the website listed by the Brand. In any situation where the end user is required to provide a phone number for the purposes of messaging (the carriers consider every required phone number as an opportunity for messaging opt in), then the privacy policy and terms and conditions must be present.
Additionally, the privacy policy CANNOT allow for the sharing or selling of end user information to third parties and affiliates. This includes but is not limited to:
- Sharing of end user information for marketing purposes.
- Sharing of end user information for purposes of lead generation.
- Sharing of end user information for purposes of purposes of third party analytics.
In short, the privacy policy must be clear that the information of end users if protected (this applies to call use cases, political included).
The Terms and conditions must not contradict the privacy policy or the opt in route described therein:
- It cannot state that end user information will be shared
- If the end user opts in to 10DLC traffic, then the terms and conditions should state that opt in and opt out occurs via the 10DLC number. IE, a short code opt out route is not acceptable. There should be consistency between the information presented in the opt in CTA (call to action) and the T&C and privacy policy.
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