ACCEPTABLE USE POLICY FOR MESSAGING, CALLS, AND ACCOUNTS

Last modified: July 2025

I. INTRODUCTION
This Acceptable Use Policy for Messaging, Calls, and Accounts (hereinafter referred to as the “AUP”) is an integral part of our main Terms of Use, Privacy Policy applicable to the App and is a binding legal agreement between you (“user”, “you”, “your”) and BP Mobile LLC (“we”, “us”, “our”). The AUP establishes the essential rules you must follow when using the App Services, focusing on three primary aspects:
- Your Account(s): the terms and restrictions governing the creation, maintenance and deactivation of your Account(s) in the App;
- Calling Regulations: rules pertaining to fraudulent calling practices;
- Messaging Policy: the policy governing the content and transmission of messages using phone numbers you got via the App.
Your full compliance with this AUP is a material condition of your access to and use of the App Services. Please be aware that any failure to adhere to the rules and prohibitions set forth herein constitutes a material breach of our Terms of Use. Any non-compliance will result in immediate enforcement actions, which may be taken at our sole discretion and without prior notice. Depending on the type of violation, such enforcement actions include, without limitation:
- blocking of your user Account(s) within the App, which is accompanied by barring the associated device(s) from using the App Services;
- revocation of your right to use the phone number(s) provided via the App and allocated to your Account(s);
- the suspension or permanent termination of all communication functions associated with the phone number(s) and your corresponding Account(s) within the App; communication functions include calling and messaging services (i.e. your ability to make/receive calls and send/receive messages using phone number(s) you got via the App).
In most cases, our standard and presumed response to any violation of this AUP is the simultaneous and combined application of all enforcement actions specified above. For certain kinds of the AUP violations, we may choose to apply enforcement actions partially or in stages. In the following sections of the AUP you can find examples of enforcement actions for specific categories of violations; however, these examples do not limit our absolute right to determine the appropriate response in any instance of the AUP violation.
We reserve the right to monitor your calling, messaging and Account(s) activity related to the phone number(s) assigned to you through the App to ensure compliance with this AUP.
We urge you to read this entire AUP carefully to understand your responsibilities as a user of our App.

II. PROHIBITED ACCOUNT PRACTICES
To maintain the operational integrity and security of the App Services and to prevent fraud, we require all users to adhere to certain standards and limitations related to Account creation and deactivation. Accordingly, the Account practices enumerated below are strictly prohibited and any engagement therein will result in the immediate application of the enforcement actions outlined in this AUP.
Exceeding Account Creation Limits. A user is prohibited from creating, maintaining, or using more than 2 (two) App Accounts per device. Exceeding this limit will result in the immediate blocking of all App Accounts associated with the violating device, forfeiture of phone numbers held within those Accounts, as well as the blocking of the device itself from creating new Accounts and using App Services, including its calling and messaging functions.
Account Cycling (Serial Re-creation of Accounts). In the context of this AUP Account Cycling is defined as the repeated or systematic deactivation and subsequent re-registration of Accounts within the App. This practice is considered fraudulent because it is a method used to unfairly gain benefits intended for new users, such as promotional offers, new free or trial phone numbers. The determination of whether a user's activity constitutes Account Cycling will be made at our sole discretion, based on factors such as the frequency and timing of deactivations and registrations. Any user found to be engaging in Account Cycling will be subject to the same enforcement actions that apply in case of Exceeding Account Creation Limits.

III. FRAUDULENT AND ABUSIVE CALLING PRACTICES
You hereby agree not to use the App Services, including phone number(s) assigned to you through the App, to engage in, facilitate, or otherwise participate in fraudulent, abusive, or illicit calling activities. The use of the App Services for any purpose other than for reasonable and legitimate personal or business communication is strictly prohibited.
Forbidden calling practices include, but are not limited to, the following.
Volumetric Call Abuse, which can be defined as: a) originating of unreasonably excessive number of outgoing calls to, or receiving of unreasonably excessive volume of incoming calls from, the same single telephone number within any given period; or b) making an unusually high number of calls to many different phone numbers in a relatively short period.
High-Velocity Call Sequences. Placing multiple successive calls to the same number or to different numbers either immediately or after an unusually short interval between the termination of the previous call and the initiation of the next.
Such patterns as Volumetric Call Abuse or High-Velocity Call Sequences are strictly prohibited, as they are presumed to be indicative of non-genuine communications such as spam, harassment, automated dialing (robocalling), or traffic pumping, rather than good-faith communications initiated manually by a person.
Excessive call duration, which is understood as maintaining excessively long call sessions or engaging in any calling activity that, in our sole determination, vastly exceeds reasonable, good-faith usage patterns for a typical user.
The Activity beyond the Fair Usage Cap. Enormous use of the App calling and/or messaging features beyond reasonable Fair Usage Cap, which we establish and apply in our sole discretion in order to prevent misuse, ensure network integrity, security, and the App Services availability for all users.
Determination of Violations and Confidentiality of Enforcement Metrics. We apply and rely on Enforcement Metrics to detect the fraudulent and abusive calling practices enumerated above and to record the corresponding violations of this AUP. These Enforcement Metrics consist of quantitative limits, thresholds, algorithms, and other internal criteria designed to flag violations and trigger appropriate enforcement actions.
Please be aware that the applicable Enforcement Metrics are our confidential information and will not be disclosed. The non-disclosure of our Enforcement Metrics is a deliberate and critical security measure that is designed to achieve two legitimate objectives:
- Preventing circumvention of the AUP by malicious actors. The disclosure of our applicable Enforcement Metrics would provide a "roadmap" for malicious actors. It would allow them to understand the precise limits of our detection systems and engineer their abusive activities to circumvent them, thereby undermining the purpose of this AUP;
- Ensuring our AUP enforcement capabilities are not compromised. The effectiveness of our fraud and abuse detection systems depends on their confidentiality. Revealing our Enforcement Metrics would compromise our ability to adapt to new and evolving threats, thereby weakening the security and integrity of the App Services for good-faith users.
Accordingly, you hereby agree and acknowledge that the determination of any violation of this AUP is made at our sole and absolute discretion, based on our Enforcement Metrics and internal compliance systems. This approach ensures that our enforcement mechanisms remain robust and effective, thereby safeguarding the App Services against security incidents and degradation.
Consequences of violations. Any breach of this AUP related to fraudulent or abusive calling practices shall result in a set of immediate and comprehensive enforcement actions. The standard enforcement response includes the simultaneous blocking of the offending user's Account(s) within the App, linked device(s), forfeiture of all associated phone number(s), which is accompanied by the termination of the App communication functions (calling and messaging). We reserve the right, at our sole and absolute discretion, to impose a lesser penalty for a first-time, minor violation, which may be limited to a temporary suspension of the App communication services. However, any subsequent violation of any kind will automatically and irrevocably result in the standard, comprehensive set of enforcement actions described herein.

IV. MESSAGING POLICY

This Section IV of the AUP (“Messaging Policy”) explains the rules for using messaging services and functionalities available through the App. It covers three main topics:
Prohibited Message Content: What you are not allowed to send in messages.
Consent: Your legal duty to get permission before messaging someone.
Security: How we detect and block spam or harmful messages to protect our users and comply with the law.
Just like with our other rules, breaking this Messaging Policy will have serious consequences. If you fail to follow these rules, we will take a set of enforcement actions, which include: immediate termination of your Account(s), forfeiture of assigned phone number(s), and blocking of your linked device(s) from further use of the App Services (including calling and messaging functions).

Operational text messages that we may send you. You understand and agree that you may receive text messages concerning the status of phone numbers you got via the App, credits you bought to make calls, as well as about other aspects regarding your phone numbers and operation of the App, such as warnings and notifications about forthcoming Account blocking.

Unwanted messaging detection and prevention mechanisms. To be able to provide you with phone numbers and other accompanying Services available within the App (including messaging services), we engage third parties that act as our cloud communications service providers and data processors (hereinafter - “Providers”). Both we and our Providers apply message filtering systems that are designed to protect all participants involved in the messaging industry, to detect and prevent any fraudulent activity, spam, abuse, violations of applicable laws, policies, and regulations. As we act proactively, the content of all messages you send using phone numbers you got via the App is subject to prior collection and monitoring.

User permission for message content collection and monitoring. You hereby grant us and Providers your relevant permission for collecting, processing, storing, and monitoring the content of all messages you send using phone numbers you got via the App for the following purposes:

- prevention of spam, abuse, illegal and fraudulent activity;

- ensuring compliance with laws, rules and regulations applicable in the messaging industry, as well as with the messaging policies of Providers.

Basic rules and regulations that shall apply to all messages you send using phone numbers you got via the App are provided below in the questions and answers format.

• Which categories of messages are prohibited and constitute sufficient grounds for blocking an Account and imposing other accompanying enforcement actions?

It is strictly prohibited to use phone numbers you got via the App to send messages that constitute and/or contain the following types of content (“objectionable content’):

• Spam, which we define as unsolicited messages with duplicate, near duplicate or similar content sent to one person or to multiple people over the past few days. To detect fraudulent spam activity, we check each of your last messages and compare it with the pool of your previous messages sent over the past few days. If we detect spam activity (at least 10 duplicate, near duplicate or similar messages over the past few days, we’ll send you the corresponding warning about forthcoming Account blocking. If you still continue spamming activities, your Account (including phone number) will be blocked.
• Content related to high-risk financial services (examples include messages pertinent to cryptocurrency, loans, such as student loans, short term high-interest loans, payday loans).
• Content connected to third-party lead generation services (use cases include activities aimed at obtaining, buying, selling or sharing of consumer information).
• Content concerning debt collection or forgiveness (use of messaging services as a channel for debt collection, debt consolidation, debt reduction, for credit repair programs).
• Content regarding “get rich quick” schemes (use cases include offering, promotion of deceptive work-from-home programs, risk investment opportunities, pyramid schemes).
• Content that is in any way related to cannabis, CBD, fireworks, other substances/articles that are illegal in applicable jurisdictions. Note that even if in your applicable jurisdiction and/or in the jurisdiction where the message recipient lives such substances/articles as cannabis, CBD, fireworks are legalized, messages related to them are not permitted and sending such messages can serve as a basis for your Account blocking. Moreover, if there is a reasonable suspicion that you use phone number you got via the App to send messages in any way connected to cannabis business (inter alia, sale, promotion and/or marketing of any cannabis product), your Account shall be subject to unconditional blocking, regardless whether or not your messages explicitly contain the term “cannabis”, images or links to cannabis websites.
• Content involving any offers for prescription medication that cannot be sold over-the-counter.
• Content in any way related to gambling, including but not limited to gambling apps and websites.
• Content covering "S.H.A.F.T." (sex, hate, alcohol, firearms, tobacco) use cases. This may include but is not limited to absolute prohibition for sex, hate speech, firearms and vaping-related message traffic. Sending messages related to tobacco and/or alcohol also often serves as a common ground for Account blocking, because sending such messages requires the implementation of additional age gating procedures and mechanisms for obtaining proper consent from every message recipient.
• Content that is intentionally designed to evade message filtering mechanisms. Examples of prohibited practices include the use of intentionally misspelled words, leetspeak, which is understood as replacement of letters with similar-looking numbers and characters to circumvent the messaging filters. The spamming technique of snowshoeing, which is defined as sending similar or identical messages using multiple source numbers with the intent to avoid filters, is also prohibited.
• Content with links, especially URL shortener links. Try to avoid sending messages that contain links, especially shortened URLs. These messages are at high risk of being filtered, as they are often used in fraudulent schemes.
• Content that constitutes and/or contains the elements of fraud, scam, unsolicited, deceptive marketing and promotions or phishing.
• Malicious content, such as malware or viruses.
• Content containing hate speech, profanity, harassment, violence, abuse, defamation, libel, or that originates from a hate group.
• Sexually explicit or suggestive content.
• Content that is pornographic or related to the adult entertainment industry, prostitution, human trafficking.
• Other types of content that can reasonably be considered as illegal, harmful, unwanted, inappropriate, objectionable, confirmed to be criminal misinformation, or that otherwise poses threat to the public, or the origin of which is falsified or misrepresented.

The above list of objectionable content is not exhaustive. To learn more information about prohibited categories of content and communications, please review the relevant policies of our Providers:

• Telnyx: Acceptable Use Policy for Messaging;
• Twilio: Acceptable Use Policy, Messaging Policy: SMS, MMS, Conversations, Third-Party Messaging Platforms

You undertake to comply with all requirements contained in the policies listed above while using the App.

NOTE THAT ALL CATEGORIES OF MESSAGES WITH OBJECTIONABLE CONTENT SHALL BE SUBJECT TO VERIFICATION BY THE FILTERING SYSTEMS AND UNWANTED MESSAGING DETECTION AND PREVENTION MECHANISMS, REGARDLESS OF WHETHER YOU OBTAIN CONSENT FROM YOUR MESSAGE RECIPIENTS TO RECEIVE MESSAGES WITH SUCH CONTENT.

• Is it required to obtain the consent of the recipient prior to sending the first message? How should such consent be properly obtained?

When you use the phone number you got via the App to send messages, you agree to take into account and comply with the requirements regarding the recipient’s consent to receive messages from you (including possible forms, scenarios of obtaining such consent), opt-out mechanisms, as well as with sender identification requirements.

Misrepresentation of your identity (spoofing) is strictly prohibited. You may not use the message body or the phone number in a way that would lead the recipient to believe you are another individual.

• Consent Requirements

If an individual sends a message to you, the individual’s inbound message to you constitutes both consent and proof of consent. Remember that the consent is limited only to that particular conversation. Unless you obtain additional consent, don't send messages that are outside that conversation.

Individual’s consent is implied when you have a prior relationship, provided that individual provided their phone number to you, and has taken some action to trigger the potential communication, and has not expressed a preference to not receive messages from you. Actions can include a button press, alert setup, appointments, or order placements. Examples of acceptable messages in these scenarios include appointment reminders, receipts, one-time passwords, order/shipping/reservation confirmations, drivers coordinating pick up locations with riders, and repair persons confirming service call times.

If you intend to send messages to someone with whom you have a personal connection, the consent can be received verbally. If you have been in contact with the individual and this individual did not express disagreement to receive messages from you, then consent is implied and there’s no need to provide proof of consent.

• Which third-party service providers can access the message content associated with phone numbers I got via the App?

As indicated above, we engage Providers as our cloud communications service providers and data processors.Providers may collect, monitor and use records of your message content to investigate security incidents, detect and prevent network exploits and abuse, spam or fraudulent activity. We may also integrate the AI-powered content management and moderation tools to verify that the message content complies with the applicable laws and policies. The most up-to-date list of Providers and AI-powered tools is presented in Section IV of the Privacy Policy for the iOS version of the App or the Privacy Policy for the Android version of the App

• What can I do if I think that my messages were filtered erroneously and my Account was blocked by mistake?

If you reasonably believe that your messages were in full compliance with our AUP and your phone number/Account was blocked by mistake, please contact us via the contact form, which is available in both the iOS and Android versions of the App. We’ll carefully review your messages and determine if an error occurred on our part.

V. CHANGES TO THE AUP
We may modify or update this AUP at any time. All changes take effect the moment we post the revised version on this webpage. You are solely responsible for periodically reviewing this AUP to ensure you are aware of any updates.

Copyright © 2018-2025 BP Mobile - LLC