Messaging Acceptable Use Policy

Scope. This Messaging Acceptable Use Policy governs all use of messaging capabilities provided through the ParagonMCA platform, including any Twilio subaccount, A2P 10DLC brand or campaign registration, toll-free verification, or phone number that CapitalDesk, Inc. provisions, registers, or maintains on your behalf ("Messaging Services"). It applies in addition to our Terms of Service and to Twilio's Acceptable Use Policy and Messaging Policy, which are incorporated by reference. Acceptance is a condition of access to Messaging Services.

Sender registration. Each brokerage is registered as its own sender. You will be registered as a distinct A2P 10DLC brand under your own legal entity, tax ID, business website, privacy policy, and terms of service. You may not send messages under another brokerage's registration, under CapitalDesk's registration, or from any number not provisioned to your account.

Consent. You may send messages only to a recipient who has given you prior express written consent, collected directly by you, for the specific subject matter of the message. Consent must be freely given, unambiguous, separate from any other agreement, and evidenced by a record of the date, the number, and the exact disclosure language shown. You must retain that record for as long as you message the recipient and produce it to us within two business days on request.

Prohibited uses

You may not use the Messaging Services to send:

1. Solicitations for new financing to any recipient who has not affirmatively applied to your brokerage, including any message whose purpose is to generate a new funding application.
2. Messages to numbers obtained from a purchased, rented, licensed, scraped, appended, or otherwise third-party-sourced list, or to any recipient whose consent was given to a party other than you.
3. Third-party or affiliate lead-generation messaging, or messaging on behalf of any funder, ISO, broker, or other party that did not itself obtain the recipient's consent.
4. Promotional or marketing content relating to loans, advances, or other financing, including rate, term, approval-amount, or offer promotion.
5. Debt consolidation, debt reduction, debt relief, debt settlement, credit repair, or third-party debt collection content, whether or not the recipient has consented.
6. Any content in a category prohibited by Twilio or by US carriers, including the categories listed in Twilio's forbidden message categories guidance.
7. Messages that misidentify the sender, omit sender identification, use public URL shorteners, or distribute similar content across multiple numbers to evade filtering.

Permitted uses. Subject to the consent requirements above, the Messaging Services may be used for first-party, non-promotional communication with a merchant who has affirmatively applied to or engaged your brokerage — for example: application status updates, document and information requests, appointment scheduling and confirmation, servicing and account notices, and one-time passcodes or account security alerts for your own platform users. Messages must identify your brokerage by name and must honor STOP, UNSUBSCRIBE, CANCEL, END, and QUIT on receipt.

Opt-out. Opt-out requests are processed platform-wide and immediately. You may not re-message an opted-out number without new express written consent, and you may not attempt to circumvent suppression by using a different number, brand, or channel.

Monitoring and enforcement. We monitor opt-out rates, complaint signals, delivery and filtering data, and message content for consistency with your registered use case. We may audit your consent records at any time. We may suspend or terminate Messaging Services, deregister your brand or campaigns, or terminate your account immediately and without notice for any violation of this policy, and we will do so where required by Twilio or a carrier. Suspension for a violation does not entitle you to a refund.

Responsibility and indemnity. You are the sender of every message you originate and are solely responsible for its content, for consent, and for compliance with the TCPA, state telemarketing and messaging laws, CTIA Messaging Principles and Best Practices, and carrier requirements. You will indemnify and hold harmless CapitalDesk, Inc. against any claim, penalty, fine, carrier pass-through charge, or expense arising from your use of the Messaging Services or your breach of this policy.