Anti-Spam Policy

1Purpose

We want to keep communications lawful and spam-free.

This Policy outlines rules to prevent the use of Horizon for sending unsolicited communications, including SMS, email, or other messages, and to ensure compliance with applicable anti-spam laws, such as the CAN-SPAM Act (U.S. law regulating commercial email) and TCPA (Telephone Consumer Protection Act, governs SMS and calls).

2Prohibited Activities

Don't send spam or misuse Horizon's communication tools.

You are prohibited from using the Service to:

• Send unsolicited commercial messages without prior express consent.
• Use deceptive or misleading headers, subject lines, or sender information.
• Send messages to purchased, rented, or third-party lists without verified consent.
• Transmit harmful content, including malware or phishing links.
• Send messages that do not include a clear way to opt out.
• Exceed message frequency beyond what was disclosed during opt-in.
• Send messages outside the hours permitted by law (typically 8am-9pm recipient's local time).

3Consent Requirements

You must get permission before contacting people.

• You must obtain prior express written consent from recipients before sending SMS, email, or other communications through Horizon.
• Consent must be clear, informed, and documented, per applicable laws like the TCPA.
• You must provide recipients with an easy way to opt out of future communications.
• Consent records must be maintained and available for audit if requested.

3.1 Valid Opt-In Methods

Acceptable methods for obtaining consent include:

• Web Form: A sign-up page on your website with clear disclosure.
• Paper/In-Person: A signed consent form completed in person.
• Keyword Opt-In: Recipients texting a keyword (e.g., "JOIN", "START") to your number.

3.2 Required Disclosures

At the point of opt-in, you must disclose:

• The identity of the organization sending messages.
• The type of messages to be sent (e.g., promotional, appointment reminders).
• Message frequency expectations.
• That message and data rates may apply.
• How to opt out (e.g., "Reply STOP to unsubscribe").

4A2P 10DLC Registration Compliance

Register your business properly to send SMS.

All users sending SMS through Horizon must complete A2P 10DLC registration with accurate information:

4.1 Registration Requirements

• Legal Business Name: Must exactly match official tax registration documents.
• Business Registration Number: EIN for U.S. companies (DUNS not accepted).
• Physical Business Address: Valid street address in U.S. or Canada.
• Website URL: Public-facing site demonstrating business legitimacy.
• Business Contact: Authorized representative with valid contact information.
• Use Case Description: Clear explanation of messaging purpose with sample messages.

4.2 Campaign Verification

• Campaigns must accurately describe message content and purpose.
• Sample messages must be representative of actual messages sent.
• Political campaigns must disclose fundraising content accurately.
• Misrepresentation of campaign type or content may result in campaign revocation.

5Twilio Messaging Policy Compliance

Follow Twilio's rules for all SMS through Horizon.

Horizon uses Twilio for SMS delivery. All messages must comply with Twilio's Messaging Policy:

5.1 Message Content Standards

• Messages must be truthful and not misleading.
• Sender identification must be clear and accurate.
• Commercial messages must be clearly identified as such.
• No promotion of illegal products or services.
• No adult content, gambling, or other restricted content categories without proper approval.

5.2 Opt-Out Handling

• Honor all STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, QUIT, REVOKE, and OPTOUT keywords, and any other reasonable request to stop.
• Process opt-out requests within 24 hours.
• Send confirmation of opt-out when requested.
• Maintain opt-out lists and prevent re-subscription without new consent.

5.3 Message Delivery Best Practices

• Send messages only during appropriate hours (8am-9pm recipient's local time).
• Do not exceed disclosed message frequency.
• Use URL shorteners sparingly; shared public shorteners may trigger spam filters.
• Avoid excessive use of capital letters, special characters, or emojis.

6Compliance with Laws

Follow all anti-spam laws when using Horizon.

You are responsible for ensuring all communications comply with applicable anti-spam and privacy laws, including but not limited to:

• CAN-SPAM Act (U.S.) for email communications.
• TCPA (U.S.) for SMS and automated calls.
• GDPR (EU) for data protection and consent requirements.
• CCPA (California) for consumer privacy rights.
• CASL (Canada) for commercial electronic messages.
• Other regional anti-spam laws applicable to your recipients.

7User Responsibilities

You're responsible for your messages and data.

• Maintain accurate and up-to-date recipient lists with valid consent records.
• Include clear sender identification and opt-out mechanisms in all communications.
• Regularly review and remove recipients who have opted out.
• Ensure your messages are truthful, not misleading, and relevant to recipients.
• Keep records of consent for at least 4 years or as required by applicable law.
• Respond promptly to recipient complaints or inquiries.

8Monitoring and Enforcement

We watch for spam and may suspend violators.

• InvictusIX may monitor communications sent through the Service to ensure compliance with this Policy.
• Violations may result in immediate account suspension or termination without notice.
• We may cooperate with legal authorities in cases of illegal spam activity.
• Carrier-reported spam complaints may trigger automatic review and suspension.

8.1 Violation Consequences

Depending on severity, violations may result in:

• Warning and required corrective action.
• Temporary suspension of messaging capabilities.
• Permanent termination of account.
• Reporting to carriers and regulatory authorities.
• Financial liability for carrier fines and penalties.

9Reporting Spam

Let us know if you receive or suspect spam.

If you believe you have received spam through Horizon or suspect misuse of the Service, please report it to us immediately at spamreport@invictusix.com. Provide details such as:

• The sender name or number.
• Message content.
• Date and time received.
• Any other relevant information.

We investigate all reports and take appropriate action against violators.

10Contact Information

Reach out with questions or concerns.

For questions or support regarding this Anti-Spam Policy, contact us at:

Invictus Interactive LLC
6545 Market Ave. North, Ste 100
North Canton, OH 44721
Email: support@invictusix.com
Phone: (216) 365-8132