SMS Policy

DTS Technical Support Services Public Policy on Digital Communications, Solicitation, and Marketing (PPDCSM)

Effective Date: September 15, 2025 Governing Jurisdiction: State of Florida, United States

1.0 Purpose, Scope, and Applicability

1.1 Purpose: The purpose of this policy is to ensure that all digital communications, solicitations, and marketing activities conducted by or on behalf of DTS Technical Support Services (“DTS” or “the Company”) comply with all applicable federal and state laws, as well as industry best practices. This policy is designed to protect the privacy of consumers, mitigate legal and financial risk to the Company, and maintain the highest standards of ethical communication.

1.2 Scope: This policy governs all commercial and marketing-related electronic communications sent by the Company, including but not limited to:

• Short Message Service (SMS) text messages
• Multimedia Messaging Service (MMS) text messages
• Voice calls, including those using an artificial or prerecorded voice
• Electronic mail (email)

This policy applies to communications directed to both current and prospective customers. Purely informational (transactional) communications are subject to specific sections of this policy as noted herein, particularly regarding consent revocation.

1.3 Applicability: This policy applies to all DTS employees, contractors, and any third-party agents, vendors, or lead generators acting on behalf of the Company. All such parties are required to read, understand, and adhere to this policy at all times.

2.0 Governing Regulations and Definitions

2.1 Governing Principle: DTS shall comply with all applicable communications laws. Where federal, state, and local laws differ, DTS will adhere to the strictest applicable standard for any given communication.

2.2 Definitions:

• Automatic Telephone Dialing System (ATDS):
  • TCPA (Federal) Definition: Equipment which has the capacity to store or produce telephone numbers to be called, using a random or sequential number generator; and to dial such numbers.  
  • FTSA-Type (State) Definition: An automated system for the selection and dialing of telephone numbers. This definition, applicable in states like Florida, does not require the use of a random or sequential number generator. The Company must assess its technology against the specific definition in the recipient’s jurisdiction.  
• Prior Express Written Consent (PEWC): An agreement, in writing, bearing the signature of the person called that clearly and conspicuously authorizes the seller to deliver advertisements or telemarketing messages using an ATDS or an artificial/prerecorded voice to the specific telephone number provided. The disclosure must state that consent is not a condition of purchase. An electronic signature is valid.  
• Marketing (or Commercial) Message: Any electronic communication the primary purpose of which is the commercial advertisement or promotion of a commercial product or service.  
• Informational (or Transactional) Message: A communication that facilitates, completes, or confirms a commercial transaction that the recipient has previously agreed to enter into. Examples include appointment reminders, service outage notifications, and order confirmations. Such messages must not contain any marketing or promotional content.  
• Revocation of Consent (Opt-Out): Any indication by a consumer, through any reasonable means, that they no longer wish to receive communications from the Company.  

3.0 Protocols for Obtaining Prior Express Written Consent

3.1 Requirement: The Company must obtain Prior Express Written Consent (PEWC) from a consumer before sending any Marketing Message to their wireless number using an ATDS or an artificial/prerecorded voice.

3.2 Method of Consent: Consent must be obtained via an affirmative action by the consumer. Pre-checked boxes on web forms are strictly prohibited. Valid methods include:  

• The consumer checking an unchecked box on a web or application form.
• The consumer replying affirmatively (e.g., with “YES”) to a text message invitation.
• A signed and dated paper consent form.

3.3 Required Disclosures at Point of Consent: All requests for consent must include clear and conspicuous disclosures containing the following elements:

• Identification: Clearly state that the consumer is consenting to receive messages from DTS Technical Support Services.
• Purpose: State the nature of the messages (e.g., “promotional offers,” “service updates,” “marketing alerts”).
• Technology: Disclose that messages may be sent using an automatic telephone dialing system or other automated technology.
• No Condition of Purchase: Explicitly state that “Consent is not a condition of any purchase.”
• Reference to Terms: Provide a direct hyperlink to the Company’s full Terms of Service and Privacy Policy.

3.4 Third-Party Lead Generation: The use of contact lists or leads acquired from any third party for the purpose of sending Marketing Messages via an ATDS is subject to a rigorous due diligence process by the Legal department. The third party must provide indisputable proof that the PEWC they obtained meets all requirements of this policy, including providing DTS with the timestamp, source, IP address, and exact disclosure language presented to the consumer.

4.0 Required Disclosures for All Digital Communications

4.1 SMS/MMS Communications: In compliance with CTIA guidelines, the following procedures are mandatory:

• Confirmation Message (Double Opt-In): Upon a consumer’s initial opt-in, a confirmation message must be sent immediately. This message must include:
  • The program name (e.g., “DTS Tech Alerts”).
  • The expected message frequency (e.g., “Up to 4 msgs/month”).
  • The “Msg & Data rates may apply” disclaimer.
  • Clear instructions for opting out (“Reply STOP to cancel”) and getting help (“Reply HELP for help”).
  • A link to the Terms of Service and Privacy Policy.  
• Subsequent Messages: The Company’s name must be clearly identified in the body of subsequent messages where practical. Periodic reminders of opt-out instructions should be included in ongoing campaigns.

4.2 Email Communications: All commercial emails must comply with the CAN-SPAM Act:

• The “From” and “Reply-To” fields must be accurate and identify DTS.
• The subject line must not be deceptive.
• The message must be clearly identified as an advertisement.
• The message must include a valid physical postal address for DTS.
• The message must contain a clear and functional unsubscribe link.  

5.0 Procedures for Honoring Consumer Opt-Out and Consent Revocation

5.1 Honoring Revocation: The Company will honor any consumer request to revoke consent.

• Timeframe: All opt-out requests must be processed and reflected across all communication systems within 10 business days of receipt.  
• Method of Revocation: The Company must recognize and process opt-out requests made through any reasonable means. This includes, but is not limited to, reply texts with keywords such as “STOP,” “END,” “CANCEL,” “UNSUBSCRIBE,” and “QUIT,” as well as informal language like “stop texting me.” It also includes verbal requests made to company representatives and requests sent via email or web form.  

5.2 Centralized Suppression List: DTS will maintain a Centralized Suppression List. All customer-facing systems (e.g., CRM, marketing automation platforms, support ticketing systems) must be integrated with this list. An opt-out request received through any channel must update the Centralized Suppression List in near-real-time, thereby preventing further communications from any other system.

5.3 Confirmation of Opt-Out: The Company may send one, and only one, final text message immediately following an opt-out request to confirm that the request has been received and processed. This message must be neutral in tone and must not contain any marketing content.  

6.0 Do-Not-Call (DNC) List Management and Procedures

6.1 National DNC Registry: Before conducting any telemarketing campaign, the Company must scrub its calling list against the most recent version of the National DNC Registry. The version of the registry used must have been obtained no more than 31 days prior to the date of the call.  

6.2 Internal DNC List: The Company’s Centralized Suppression List (see Section 5.2) will serve as its internal DNC list. Any consumer who requests to be placed on this list must not receive any further Marketing Messages from the Company, unless they provide new PEWC. Records of DNC requests must be maintained for a minimum of five years.  

7.0 Record-Keeping, Auditing, and Proof of Compliance

7.1 Consent Records: For every consumer who provides PEWC, the Company must maintain a clear and readily accessible electronic record for a minimum of five years from the date the consent is revoked. This record must include:

• The consumer’s phone number.
• The date, time, and source (e.g., website URL) of the consent.
• The IP address of the consumer at the time of consent, if obtained online.
• A copy or screenshot of the exact disclosure language and consent form to which the consumer agreed.  

7.2 Auditing: The Legal and Compliance department will conduct semi-annual audits of all digital marketing programs to ensure adherence to this policy.

8.0 Employee Training and Policy Enforcement

8.1 Training: All employees and contractors involved in marketing, sales, customer support, and IT roles that manage communication systems must complete a mandatory annual training program on this policy and relevant laws.

8.2 Enforcement: Violation of this policy may result in disciplinary action, up to and including termination of employment or contract, in addition to any personal liability that may be incurred under the law.