TCPA Compliance

1. Our Commitment

Every outbound SMS sent through the CraftsmenLeads platform passes through our 10-step compliance engine before delivery. This engine performs the following checks in order:

1. Phone area code lookup to determine state and timezone
2. Quiet hours verification for the consumer's state
3. Sunday restriction check (where applicable by state law)
4. Holiday restriction check
5. Consent level verification
6. Federal Do Not Call (DNC) registry check
7. State-specific DNC list check (where applicable)
8. AI disclosure status verification
9. Rate limit check
10. Opt-out list check

If any check fails, the message is blocked, queued for later delivery, or modified as appropriate. A non-compliant message is never sent.

2. How We Obtain Consent

CraftsmenLeads operates on an implied consent model. A consumer initiates contact by calling our client's business phone number. When that call is missed, the consumer has demonstrated intent to reach the business, and we respond via SMS to follow up on their inquiry. Key aspects of our consent framework:

• The consumer initiates contact by placing a call to a business
• Our SMS response is directly related to the consumer's inquiry
• We do not use purchased lists, rented lists, or any third-party contact databases
• We do not send marketing messages unrelated to the consumer's original call
• Every consent event is recorded in our append-only consent log with timestamp, phone number, and consent type

In accordance with the FCC's one-to-one consent rule (effective January 27, 2025), consent obtained through CraftsmenLeads applies only to communications from the specific business the consumer contacted. We do not transfer, share, or aggregate consent across multiple businesses. Each client's consent records are isolated and independently maintained.

3. AI Disclosure

Every first message in a conversation clearly discloses the AI and automated nature of the interaction. We believe in full transparency:

• The first SMS identifies the message as coming from an automated AI assistant
• The business name is clearly identified in the message
• The consumer is informed they can request human follow-up at any time
• AI disclosure status is tracked per conversation and verified before every outbound message

4. Opt-Out Rights

Consumers may opt out of SMS communications at any time. We honor the following opt-out keywords immediately and irrevocably:

In compliance with the FCC's April 2025 consent revocation rules, consumers may revoke consent through any reasonable means, including:

• Replying STOP, UNSUBSCRIBE, CANCEL, QUIT, END, REVOKE, or OPT-OUT to any SMS message
• Emailing compliance@craftsmenleads.com with their phone number
• Calling our support line and requesting removal

We process revocations in real time (typically within seconds) and guarantee completion within 10 business days across all systems. Upon revocation, we send one confirmation message within 5 minutes containing no promotional content. The opt-out remains in effect until the consumer explicitly opts back in by replying START.

5. Quiet Hours

We enforce state-specific quiet hours to ensure messages are only sent during permitted times:

• Federal baseline: no messages before 8:00 AM or after 9:00 PM in the consumer's local time
• State-specific rules are applied where they are more restrictive than the federal baseline
• Sunday and holiday restrictions are enforced where required by state law
• If a message falls within quiet hours, it is queued and delivered at the next permitted time
• Timezone is determined by the consumer's phone area code

6. Message Frequency

We enforce strict limits on message frequency to prevent excessive contact:

• Per conversation: Maximum of 12 message exchanges per conversation
• Per day: Maximum of 6 SMS messages per phone number per day
• Session timeout: Conversations automatically close after 4 hours of inactivity
• When limits are reached, the conversation is gracefully handed off to the business for direct follow-up

7. DNC Compliance

We check phone numbers against Do Not Call registries before sending any message:

• Federal DNC: We check against the National Do Not Call Registry maintained by the FTC
• State DNC: We check against state-specific DNC lists where applicable
• Internal DNC: We maintain our own opt-out list and check it before every outbound message
• Any phone number found on a DNC list is blocked from receiving automated messages

8. Record Keeping

We maintain comprehensive records to demonstrate compliance:

• Consent events: Append-only log of all consent records, including timestamp, phone number, consent type, and source. Never modified or deleted
• Opt-out events: Complete record of all opt-out requests and their processing
• Compliance checks: Every compliance engine decision is logged with full details, including which checks passed and which triggered blocks
• Conversation transcripts: Full SMS conversation history
• Retention period: All consent and compliance records are retained for a minimum of 5 years, aligning with the TCPA statute of limitations

9. Emergency Messages

Our system includes regex-based emergency detection for situations involving gas leaks, carbon monoxide, flooding, or other life-safety emergencies. If an emergency is detected:

• The AI conversation immediately terminates
• A pre-written safety message is sent directing the consumer to call 911
• The client is notified immediately via email and SMS alert
• No further automated messages are sent to that phone number for that conversation

Emergency detection uses deterministic pattern matching (not AI) to ensure reliability.

10. Autodialer Classification

CraftsmenLeads processes missed calls from stored phone numbers in the order they are received. In accordance with the Supreme Court's ruling in Facebook v. Duguid(2021), our system does not use a random or sequential number generator to store or produce phone numbers, and therefore does not constitute an Automatic Telephone Dialing System (ATDS) under 47 U.S.C. § 227(a)(1). Notwithstanding this classification, we obtain and document consent for all SMS communications as a defensive best practice.

11. Complaints and Inquiries

If you believe you have received a message from CraftsmenLeads in error, or if you have any concerns about our SMS practices, please contact our compliance team:

CraftsmenLeads LLC
Compliance Team
Email: compliance@craftsmenleads.com
Website: craftsmenleads.com

We investigate all complaints promptly and take corrective action where necessary.