LeadWire Messaging Policy

1. Overview

LeadWire LLC (“LeadWire,” “we,” “our,” or “us”) provides a messaging platform that enables businesses to communicate with their customers via SMS and MMS text messages (“messages”). This Messaging Policy describes how automated text messages are sent through the LeadWire platform, how consumers consent to receive messages, and the controls implemented to comply with applicable messaging regulations. LeadWire is committed to complying with all applicable regulations including: – Telephone Consumer Protection Act (TCPA) – CTIA Messaging Principles and Best Practices – A2P 10DLC messaging requirements – Carrier messaging policies

2. Types of Messages

Businesses using the LeadWire platform may send the following categories of messages to consumers who have provided consent: Promotional Messages – Discounts, promotions, coupons, or special offers – Product launches or new services – Event announcements or marketing campaigns Transactional Messages – Order confirmations or purchase receipts – Appointment reminders or service updates – Delivery notifications Customer Care Messages – Support responses – Service updates – Queue or request notifications Political Campaigns – Require a campaign vetting ($95 one time) – Only 527 tax-exempt organizations – Must be registered in local, state, or federal election authority. Businesses are responsible for registering the appropriate campaign type for each messaging use case.

3. Consumer Consent (Opt-In Requirements)

LeadWire requires its customers to obtain prior express consent before sending messages. Consent may be collected through the following approved methods: Web Forms Consumers voluntarily enter their phone number through a signup form that clearly discloses: – The brand sending the messages – Message purpose – Expected message frequency – Notice that message and data rates may apply – Instructions to opt out Text-to-Join Keywords Consumers initiate messaging by texting a keyword (for example: JOIN, DEALS, or SUBSCRIBE) to a designated phone number. In-Store or Point-of-Sale Opt-In Consumers may provide consent during checkout or in physical locations when disclosures are clearly presented. QR Codes or Digital Sign-Up Links Consumers scan a QR code or visit a link that leads to a compliant signup form. All opt-in flows must clearly state that consent is not a condition of purchase. LeadWire does not allow purchased, rented, or third-party lead lists.

4. Message Frequency Disclosure

All opt-in methods must clearly disclose expected message frequency. Example disclosure: Message frequency varies but typically ranges from 1–5 messages per month.

5. Opt-Out Mechanism

Consumers may opt out of receiving messages at any time. LeadWire supports industry-standard opt-out keywords including: STOP UNSUBSCRIBE CANCEL END When a consumer sends an opt-out request: – The phone number is immediately added to a suppression list. – The consumer receives a confirmation message stating they will no longer receive messages.

6. Help & Customer Support

Consumers may request assistance by replying HELP. The system will respond with: – Brand identification – Customer support contact information – Instructions for opting out Example response: For assistance, contact the brand sending the messages. Reply STOP to unsubscribe.

7. Message Content Restrictions

LeadWire strictly prohibits the use of its platform for disallowed messaging categories including but not limited to: SHAFT content – Sexually explicit content – Hate speech – Alcohol promotions to restricted audiences – Firearms or weapons promotion – Tobacco or vaping promotions Other prohibited uses include: – Gambling or sweepstakes that violate carrier rules – Illegal products or services – Fraudulent or deceptive messaging – Phishing attempts or impersonation – High-risk financial services not compliant with regulations LeadWire actively monitors messaging traffic and may suspend accounts that violate messaging policies.

8. Regulatory Non-Compliance Fees

Federal and industry regulations governing Application-to-Person (A2P) text messaging (including but not limited to Telephone Consumer Protection Act (TCPA) requirements, CTIA messaging guidelines, and mobile carrier/campaign registry rules) require that all SMS/MMS traffic sent through LeadWire adheres to the use-case standard, brand and content for which it was registered. Failure to comply with these requirements (including but not limited to sending content on behalf of, or referencing, a different brand than the one registered for the campaign; prohibited content (see section 7), excessive complaint rates, or other violations flagged by upstream messaging carriers or industry compliance bodies) may result in administrative, recovery, or penalty fees assessed against your brand. Where such fees result from a customer’s use of the platform, we reserve the right to pass through the full cost of these fees to the responsible customer’s account, including but not limited to the following:

Fee Type	Description	Amount
Severity-0 Non-Compliance Fee	Assessed per incident for critical/urgent violations requiring immediate carrier or provider action	$1,000 per incident
Audit Assistance Fee	Assessed per incident when our provider is required to support a carrier, CTIA, or other industry audit involving a customer’s messaging traffic	$250 per incident

Fee amounts reflect current industry compliance recovery costs as of the date of this policy and are subject to change without notice as carrier and regulatory requirements evolve. We will notify affected customers of any such fee, along with a reasonable explanation of the underlying compliance issue, prior to or concurrent with billing. Customers may dispute a passed-through fee by contacting support@leadwireapp.com within 10 days of notice. Customers remain solely responsible for ensuring their messaging campaigns, content, and consent practices comply with all applicable laws and carrier requirements. Repeated or unresolved non-compliance may result in suspension or termination of messaging services in addition to any fees assessed.

9. Data Privacy

LeadWire processes consumer phone numbers and messaging data in accordance with its Privacy Policy. LeadWire: – Does not sell or share consumer phone numbers with third parties for marketing purposes – Uses consumer data solely to facilitate messaging services – Implements security safeguards to protect personal information Consent to receive text messages is not transferable and will not be shared with third parties.

10. Record Keeping

LeadWire requires customers to maintain records of consumer consent, including: – Timestamp of opt-in – Source of consent (form, keyword, POS, etc.) – Disclosure language presented at the time of opt-in These records may be required during carrier audits or compliance reviews.

11. Compliance Monitoring

LeadWire maintains internal controls to ensure messaging compliance, including: – Campaign registration and vetting – SHAFT content monitoring – Automated opt-out enforcement – Messaging throughput controls – Abuse reporting and investigation LeadWire reserves the right to suspend or terminate accounts that violate messaging regulations.

12. Changes to This Policy

LeadWire may update this Messaging Policy periodically to reflect regulatory changes or improvements in messaging compliance practices.