TCPA Compliance Policy

1. Scope & Applicability

This Policy applies to all voice calls, SMS/MMS messages, ringless voicemail (where permitted), prerecorded or artificial voice messages, and any other telecommunications initiated by or on behalf of BetterFinanceHelp or its Partners.

• Inbound and outbound communications
• Automated and manual dialing
• First-party and third-party (Partner) communications
• Marketing, informational, and transactional messages

2. Regulatory Framework

• Telephone Consumer Protection Act (TCPA)
• FCC rules and declaratory rulings
• Do Not Call Registry (National and State)
• State telemarketing and consumer protection laws
• FTC deceptive practices standards

3. Definitions (TCPA-Aligned)

• "Autodialer/ATDS" – Equipment with the capacity to store or produce telephone numbers to be called using a random or sequential number generator and to dial such numbers.
• "Express Written Consent" – A clear, unambiguous agreement bearing the consumer's signature (including electronic) authorizing calls/texts using an ATDS or prerecorded voice.
• "Marketing Message" – Any communication promoting or advertising products or services.
• "Transactional Message" – Communications related to an existing inquiry, request, or relationship.

4. Consent Collection Standards

Consent is collected at the point of data entry through clear, conspicuous disclosures that are not a condition of purchase.

• Disclosure of automated/prerecorded communications
• Identification of calling/texting parties
• Consent applies to the provided number
• Affirmative action (checkbox, submit action)

5. Consent Data Elements Stored

• Full consent language as displayed
• Date and time (with timezone)
• IP address
• Page URL and form identifier
• User agent and device metadata
• Campaign and traffic source parameters

6. Consent Lifecycle Management

• Consent is logged and retained for evidentiary defense
• Consent is portable across compliant Partners
• Consent may be revoked at any time
• Revocation is honored across all systems

7. Reassigned Numbers & Wrong Party Safeguards

We implement commercially reasonable safeguards to reduce reassigned number risk.

• Carrier and database checks where available
• Opt-out and complaint monitoring
• Immediate suppression upon notice
• Internal escalation and investigation

8. Frequency, Purpose & Time-of-Day Controls

• Communications are purpose-limited to consent scope
• Reasonable frequency caps applied
• Calls/messages limited to permissible hours
• Jurisdiction-specific restrictions enforced

9. Do Not Call (DNC) Compliance

• National Do Not Call Registry honored
• Internal DNC lists maintained
• Immediate DNC flagging upon request
• Partner enforcement of DNC obligations

10. Opt-Out Mechanisms

• SMS: Reply STOP or equivalent keyword
• Email: Unsubscribe link in footer
• Calls: Verbal opt-out or support request
• All opt-outs processed promptly and permanently

11. Partner & Vendor Obligations

Partners receiving leads or consent must contractually agree to:

• Use data only within consent scope
• Honor opt-outs and DNC requirements
• Maintain TCPA compliance programs
• Provide records upon audit or inquiry
• Indemnify for violations caused by Partner conduct

12. Call Recording & Monitoring (Where Permitted)

Calls may be monitored or recorded for quality assurance, compliance, and dispute resolution, subject to applicable state consent laws.

13. Record Retention & Evidence Preservation

• Consent records retained beyond statutory minimums
• Call/SMS logs preserved for defense
• Audit trails maintained
• Legal hold procedures implemented

14. Consumer Complaints & Escalation

• Complaints logged and investigated
• Root-cause analysis performed
• Corrective actions documented
• Partners notified where applicable

15. Enforcement & Disciplinary Measures

Violations of this Policy may result in suspension, termination, contractual remedies, and reporting to regulators where required.

16. Relationship to Privacy Policy & Terms

This TCPA Policy supplements and is incorporated into the Privacy Policy and Terms & Conditions. In the event of conflict, the policy providing greater consumer protection shall control.

17. Changes to This TCPA Policy

We may update this Policy periodically to reflect changes in law, technology, or business practices. Continued interactions after updates constitute acceptance.

18. Contact Information

TCPA Compliance Inquiries: compliance@clearcreditpath.com

Mailing Address: 7345 W SAND LAKE RD STE 210 OF 5837 ORLANDO, FL 32819