TCPA & Compliance Policy

1. How to stop contact

2. Our commitment

PVN LLC (“PVN,” “we”), which operates NetEnroll, is committed to conducting outreach in compliance with the Telephone Consumer Protection Act (47 U.S.C. § 227) and its implementing rules (47 C.F.R. § 64.1200), the Federal Trade Commission's Telemarketing Sales Rule (16 C.F.R. Part 310), applicable state telemarketing and do-not-call statutes, and industry messaging standards including the CTIA Messaging Principles and Best Practices.

We treat consent as something to be evidenced, not assumed, and we treat a revocation as immediate and permanent unless the consumer later gives new consent.

3. Scope of this policy

This policy addresses two different kinds of contact, and it is important not to confuse them:

• Our own outreach. Calls and messages PVN sends, including messages to licensed insurance producers about the NetEnroll platform and messages sent to consumers in connection with an inquiry they submitted.
• Outreach by licensed agents. Calls and messages an Agent makes after a consumer is connected to them. The Agent is the caller for those communications and is independently responsible for compliance, as described in Section 11.

Nothing in this policy is legal advice, and it does not create a defense for any third party. Agents must obtain their own counsel.

4. Prior express written consent

We do not make a telemarketing call or send a marketing text using an automatic telephone dialing system, an artificial or prerecorded voice, or an AI-generated voice to a wireless number without prior express written consent, or another basis permitted by law such as an established business relationship where that basis is legally sufficient for the type of call.

To qualify as prior express written consent, the agreement must:

• be a written agreement, which may be electronic and signed under the E-SIGN Act, bearing the signature of the person called;
• clearly authorize the seller to deliver advertisements or telemarketing messages using an automatic telephone dialing system or an artificial or prerecorded voice;
• include the specific telephone number to which the person authorizes the messages to be delivered;
• clearly and conspicuously identify the specific seller or sellers authorized to contact the consumer; and
• state clearly that the person is not required to sign the agreement, directly or indirectly, as a condition of purchasing any property, goods, or services.

Consent must be obtained through a mechanism the consumer affirmatively completes. We do not accept pre-checked boxes, consent bundled invisibly into other terms, consent obtained through a list purchase where no evidencing record exists, or consent given to one seller and repurposed for another.

4.1 What we record

For each consent we rely on, we retain a record that includes:

• the exact consent language displayed to the consumer;
• the URL of the page or form where consent was given, and a copy or reproduction of it;
• the date and time of the submission;
• the IP address and browser user agent of the submitting device;
• the telephone number and the other field values submitted; and
• the identity of the lead source or partner, where the consent was obtained by one.

5. The disclosure we require

The following is the form of disclosure we require on any web form used to generate inquiries directed to NetEnroll. It must appear adjacent to the submit control, in a legible size and contrast, and must not be pre-checked or hidden behind a link alone.

[Seller Name] must be replaced with the specific, named entity that will place the calls. It may not be a generic reference to partners, affiliates, or marketing networks.

6. Automated technology and AI voice

Where we use an automatic telephone dialing system, an artificial or prerecorded voice, or an AI-generated voice for a call subject to the TCPA, we do so only with consent of the type required for that call, and:

• we identify the entity responsible for initiating the call at the start of the message;
• we state a telephone number that can be used to reach that entity;
• prerecorded telemarketing calls include an automated interactive opt-out mechanism announced at the outset and available throughout the call; and
• we do not use AI-generated voice in a manner intended to impersonate a specific real person or to mislead a consumer about who is calling.

7. SMS and MMS program terms

Replying STOP ends messages from the program that sent the message. We send a single confirmation of the opt-out and then stop. We do not require you to reply to that confirmation, and we do not send further messages asking you to reconsider. We will not re-enroll a number that has opted out unless the consumer provides new consent.

We do not send messages containing content prohibited by carrier and industry rules, and we do not use number rotation, snowshoeing, or similar techniques to evade carrier filtering or opt-out handling.

8. Do-not-call practices

8.1 Internal do-not-call list

We maintain an internal do-not-call list. A number is added promptly upon request and remains on it indefinitely. Personnel who place or arrange calls are trained on the list and on this policy before contacting consumers, and the list is available to them at the time of contact. A written copy of this policy is available on demand, free of charge, using the contact details in Section 15.

8.2 National and state registries

We scrub against the National Do Not Call Registry maintained by the Federal Trade Commission and against applicable state do-not-call registries before conducting telemarketing outreach, except where an exemption applies, such as calls made with prior express written consent or within an established business relationship permitted by the relevant rule. Registry data is refreshed on the schedule required by the applicable rule.

8.3 Calling practices

• Telemarketing calls are placed only between 8:00 a.m. and 9:00 p.m. in the called party's local time zone.
• We transmit accurate caller identification, including a name and a telephone number that can be called back and that is answered during regular business hours.
• We do not use spoofed, misleading, or unassigned caller identification.
• We identify ourselves and the purpose of the call promptly.
• We honor reassigned number data where available and cease contacting numbers identified as reassigned.

9. Revoking consent

A consumer may revoke consent at any time, through any reasonable means. We do not require a specific word, form, or channel. A revocation communicated by text reply, by telling a caller, by voicemail, by email, or by letter is effective.

We treat a revocation as applying to all marketing calls and texts from us, on every channel and for every program, not only to the channel or program through which it was received. We process revocations promptly and in any event within the period required by law, which for automated calls and texts is no more than ten business days from receipt.

After revocation we may still send messages that are not advertising or telemarketing where the law permits, such as a one-time confirmation of the opt-out or a transactional notice about an existing account. A revocation record is retained indefinitely so that the number is not contacted again in error.

10. Call recording and monitoring

Calls made or received through the platform may be recorded or monitored for quality assurance, training, dispute resolution, and compliance. Recording laws vary: some states require the consent of all parties. Where a call may be recorded, notice must be given at the outset and the required consent obtained before recording begins. Agents are responsible for meeting the requirements of every state in which they speak with consumers. Recordings are handled as described in our Privacy Policy.

11. Obligations of agents

An Agent who receives a call or consumer information through NetEnroll is an independent business and is the caller for any subsequent outreach they make. We do not verify licensing; each Agent is responsible for holding whatever authority the law requires.

Responsibility between PVN and an Agent is allocated by control: what happens before a call is connected or consumer data is delivered is ours, and what an Agent originates afterwards is the Agent's. That allocation, and the indemnities that follow from it, are set out in Section 7.2 of the Terms of Service.

As a condition of using the platform, each Agent agrees to:

• comply with the TCPA, the Telemarketing Sales Rule, state telemarketing and do-not-call law, applicable insurance and CMS marketing rules, and any licensing requirement that applies to them;
• maintain their own internal do-not-call list and honor every request received directly or relayed by us;
• contact a consumer only about the program for which the call was routed, and not use consumer information for unrelated marketing;
• not sell, transfer, broker, or re-market consumer information received through the platform;
• obtain their own consent before initiating automated calls or texts, and not rely on a consent record naming a different seller;
• respect calling-time restrictions in the consumer's local time zone;
• obtain any recording consent required in the consumer's state; and
• notify us promptly of any complaint, regulatory inquiry, demand, or litigation relating to a consumer routed through the platform.

We may suspend or terminate routing to an Agent who does not meet these obligations. Suspension is not a finding of liability, and it does not limit any other remedy.

12. Lead source diligence

Where consumer inquiries reach us through a marketing partner or lead source, we require that partner to represent that consent was obtained in the form described in Section 4, to supply the consent record on request, and to permit audit of consent documentation. We may suspend or terminate a source that cannot produce records, that supplies numbers on a do-not-call registry without a valid basis, or that generates a pattern of complaints. We do not knowingly accept inquiries generated by misrepresentation about the identity of the seller, the purpose of the form, or an affiliation with a government program, Medicare, or the Health Insurance Marketplace.

13. Compliance records

We retain consent records for at least five years from the date of consent or the last contact, whichever is later, which exceeds the four-year federal limitations period for TCPA claims. Do-not-call and revocation records are retained indefinitely. Call detail records and messaging metadata are retained as described in our Privacy Policy. Records subject to a legal hold are preserved until the hold is released.

14. Complaints and escalation

If you believe you received a call or message in error, or that this policy was not followed, contact us using the details in Section 15. Tell us the telephone number that was contacted, the date and approximate time, and anything you remember about the caller. We will:

1. add the number to our internal do-not-call list immediately;
2. identify the source of the contact and the consent record relied on, if any;
3. tell you what we found and what we did; and
4. suspend the source or Agent responsible where the facts warrant it.

You may also file a complaint with the Federal Communications Commission at consumercomplaints.fcc.gov, with the Federal Trade Commission at reportfraud.ftc.gov, or with your state attorney general. You can register your number on the National Do Not Call Registry at donotcall.gov.

15. Contact us

For do-not-call requests, consent record requests, complaints, or a free written copy of this policy: