This Acceptable Use Policy ("AUP") establishes the rules governing use of the Repen Platform. Violation of this AUP may result in immediate suspension or termination of your account without refund and may be reported to regulatory authorities. This AUP is incorporated into the Terms of Service by reference.

Repen is a technology platform. You — the Customer — are the caller, seller, and responsible party under all applicable telemarketing and consumer protection laws. Nothing in this AUP or the Terms of Service shifts that legal responsibility to Repen.

3.1 Permitted Use

You may use the Platform exclusively for lawful, legitimate business purposes — specifically, to automate AI-powered outbound voice calls to individuals who have provided Prior Express Written Consent as defined under the TCPA and FCC regulations directly to your business. Calls must relate to the product or service the lead originally expressed interest in, and must comply with all applicable laws.

3.2 Call Compliance — Prohibited Conduct
Consent Violations

• Calling any individual without obtaining, documenting, and retaining Prior Express Written Consent (PEWC) that satisfies all TCPA and FCC requirements effective as of the date of the call

• Calling individuals whose numbers appear on the National Do Not Call Registry, your internal suppression list, or any applicable state DNC list, without a valid, documented exemption

• Failing to honor any opt-out, revocation, or do-not-call request within the period required by applicable law (currently ten (10) business days under April 2025 FCC rules)

• Using leads obtained through scraping, purchasing lists, data aggregators, or any means other than direct, individual opt-in to your specific offer

• Placing calls outside the legally permitted time window of 8:00 AM to 9:00 PM in the called party's local time zone

• Calling phone numbers without first checking them against the FCC Reassigned Numbers Database (RND) where required

Fraudulent, Deceptive, or Abusive Conduct

• Misrepresenting your identity, company name, phone number (including caller ID spoofing), product, or offer

• Configuring agents to deny being AI or claim to be a human when the lead sincerely inquires — this is a violation of FCC rules, FTC guidance, and applicable state law

• Impersonating any named individual, brand, or organization without documented authorization

• Using false urgency, fabricated scarcity, misleading pricing, or other deceptive sales tactics

• Engaging in any act constituting wire fraud, mail fraud, or telemarketing fraud under 18 U.S.C. §§ 1341 and 1343

Harassment and Discrimination

• Placing repeated or continuous calls designed to harass, threaten, intimidate, or abuse any person

• Configuring agents to use language that demeans or discriminates against individuals on the basis of race, ethnicity, national origin, religion, sex, gender identity, sexual orientation, disability, or any other protected characteristic

Platform Abuse

• Circumventing or attempting to circumvent usage metering, billing mechanisms, or plan restrictions

• Probing, scanning, or testing Platform vulnerability without prior written authorization from Repen

• Uploading malware, viruses, or any malicious code to the Platform

• Placing unreasonable load on Platform infrastructure or engaging in denial-of-service attacks

• Reselling, sublicensing, or white-labeling access to the Platform without Repen's express written consent

3.3 Restricted Industries

Use of the Platform in the following industries requires prior written approval from Repen and submission of additional compliance documentation:

• Debt collection and financial recovery (subject to FDCPA requirements)

• Healthcare and medical services (subject to HIPAA, state licensure, and enhanced consent requirements)

• Political campaigns, candidate solicitation, and issue advocacy

• Financial services and investment products (subject to FINRA, SEC, or state securities regulation)

• Sweepstakes, prize promotions, and any campaign with mandatory purchase requirements

• Any industry currently subject to a consent decree, regulatory order, or enforcement action related to outbound calling

3.4 Content Requirements

All agent scripts and call content deployed through the Platform must:

1. Identify the calling organization by name at or before the start of the substantive portion of the call

2. Disclose that the caller is an AI or automated voice system (see Section 8 for applicable timing requirements)

3. Provide an opt-out mechanism during each call, including recognition of natural language opt-out phrases such as "stop calling," "remove me," or "I'm not interested"

4. Provide a callback number and the name of the business upon request

5. Comply with all FTC truth-in-advertising standards and applicable consumer protection laws

6. Not solicit or collect sensitive personal information — including Social Security numbers, financial account numbers, full payment card numbers, or health information — without appropriate safeguards, disclosures, and legal authorization

3.5 Record-Keeping Obligations

You must maintain records sufficient to demonstrate compliance with applicable law, including at minimum:

• Consent records for each called party (timestamp, IP address, consent source URL, and the specific language of consent)

• Evidence that the consent specifically identifies your company as an authorized caller

• Opt-out and suppression list records with timestamps

• DNC scrub records and Reassigned Numbers Database query results

• Call scripts and any material changes, with effective dates

Records must be retained for a minimum of five (5) years, or longer if required by applicable law.

3.6 Enforcement

Repen may investigate any suspected violation of this AUP. Upon confirming or reasonably suspecting a violation, Repen may take any or all of the following actions:

• Issue a formal written warning

• Require immediate removal or correction of non-compliant agent scripts

• Suspend account access pending investigation

• Permanently terminate the account

• Report the violation to relevant regulatory authorities (FCC, FTC, state attorneys general)

Termination for AUP violation does not entitle Customer to any refund.