Acceptable Use & Fair Usage Policy

1. About this policy

1.1 This policy forms part of your contract with PRASMO LTD ("Prasmo", "we", "us"). Words defined in our Customer Service Terms have the same meaning here.

1.2 It applies to you and to everyone who uses the Services through your Account, including your Users and End Users. You must make sure they follow it.

1.3 We support legitimate business communications of every kind, including high-volume, contact-centre, dialler, international, messaging and wholesale traffic. Most of this is agreed once, at onboarding, as your traffic profile (section 4). A small number of uses are never allowed (section 2).

1.4 Fair usage does not mean we may arbitrarily restrict ordinary contracted traffic. Any volumes, concurrency, destinations or limits that matter commercially will be stated in your Order Form or Approved Use Schedule.

1.5 We provide Services using a number of network and messaging partners. The laws of every country where your Communications are sent or received apply, not only UK law.

2. Never allowed

You must not use the Services, or allow them to be used:

1. for anything unlawful, fraudulent or deceptive, including scams, phishing, impersonation or obtaining money or information under false pretences;
2. to generate, route or take part in Artificially Inflated Traffic, International Revenue Share Fraud, traffic pumping or access stimulation, or calls or messages made mainly to earn revenue or exploit rates;
3. to make nuisance, silent, abandoned, threatening, abusive or harassing Communications, or to cause annoyance, inconvenience or anxiety in breach of the Communications Act 2003 or similar laws elsewhere;
4. to present a Presentation Number or sender identity that is false, invalid, not dialable, not in service or that you are not authorised to use, or to forge or alter caller identity, headers or signalling unlawfully;
5. to make unlawful marketing calls or send unlawful marketing messages, including calls or messages without the consent the law requires, calls to numbers on the UK Telephone Preference Service or Corporate TPS without valid consent, or robocalls in breach of US or Canadian law;
6. to scan number ranges, or to make calls designed to test whether numbers are live;
7. to interfere with, overload or attack any network, system or service, or to try to gain unauthorised access to them;
8. to send or store content that is illegal, hateful, defamatory or obscene, or that infringes anyone's intellectual property, privacy or other rights;
9. to make false or hoax calls to emergency services, or to interfere with anyone's access to them;
10. for anyone subject to UK, US or UN sanctions, or in breach of sanctions or export-control law;
11. to connect unlawful GSM gateways or SIM boxes, or otherwise bypass interconnect arrangements unlawfully;
12. to evade restrictions, controls, fraud systems, sanctions or contractual limits, or to obscure the true source, nature or responsibility for traffic; or
13. in any way that could reasonably be expected to bring Prasmo or its network partners into disrepute or expose us to regulatory action.

3. Consent, recording and marketing

3.1 Every Communication made through our Services must have the consent or other lawful basis the law requires. This applies to making the Communication and to processing it, including recording, transcription, analytics and analysis by software or artificial intelligence.

3.2 You may consent only on behalf of Numbers allocated to you. You cannot consent to Communications on a Number that is not yours.

3.3 If you record Communications, you must give the notices the law requires and have a lawful basis for recording. You must also store, secure and delete recordings lawfully.

3.4 If you make marketing calls, you must:

1. screen against the TPS and Corporate TPS for UK numbers (and the equivalent do-not-call registers elsewhere), unless you hold valid consent from the person called;
2. keep and honour your own do-not-call list;
3. present a Presentation Number that can be called back and that identifies you or the organisation you call for;
4. identify the caller at the start of each call;
5. obtain prior express consent before making automated or prerecorded marketing calls, where the law requires it; and
6. keep evidence of consents and screening for at least [TO CONFIRM: period].

3.5 Claims-management and pensions marketing calls are subject to extra legal restrictions. You must not make them unless the law allows it and they are included in your agreed traffic profile.

4. Your agreed traffic profile

4.1 The following uses are available once they are included in your Approved Use Schedule, which we agree with you during onboarding. You may add them later by request:

1. outbound telemarketing, lead generation or sales campaigns;
2. any automated, predictive, progressive or power dialler, or any system that places calls automatically;
3. contact-centre traffic above the concurrency in your Order Form;
4. answer-machine or voicemail detection;
5. recorded-message or automated voice broadcasting;
6. international termination to destinations not already opened on your Account;
7. business messaging (section 7);
8. wholesale, transit or carrier traffic, or resale of the Services to others; and
9. any traffic above the volumes in your Approved Use Schedule.

4.2 What we ask for. During onboarding, or when you ask to change your profile, we will ask for:

1. your business and the businesses you call or message for;
2. the purpose of the Communications and who will receive them;
3. the source and evidence of consent, or your screening process;
4. the dialling or messaging technology and settings you will use;
5. expected volumes, concurrency and destinations;
6. the Presentation Numbers or sender identities you will use and your authority to use them;
7. your call scripts or message templates; and
8. your complaints-handling process.

4.3 Our decision. We aim to respond to change requests within 5 Business Days. Some uses also need the agreement of our network partners, which can take longer, and we will tell you if so. Approval may carry conditions, such as volume caps, permitted destinations, Presentation Numbers, monitoring, test periods or regular evidence of compliance. Approval covers only the use described. Any material change needs a new approval.

4.4 Standards for approved outbound calling. You must:

1. comply with Ofcom's persistent misuse policy, including its limits on abandoned and silent calls and its requirements for information messages, and with equivalent rules in other countries you call;
2. not use answer-machine detection unless it is included in your agreed traffic profile;
3. not re-dial a number that has returned an invalid-number response; and
4. keep call records for each campaign for at least [TO CONFIRM: period].

4.5 We may refuse a request where we or our network partners cannot support the use lawfully or safely. We will give our reasons where we can, and we will try to find an alternative route or arrangement.

5. Caller ID (Presentation Numbers)

5.1 Every call must carry accurate calling line identification, including any privacy marking. The Presentation Number must be a valid, dialable number that is in service and that you or your End User are authorised to use.

5.2 If you present a number we did not allocate to you, you must be able to prove your authority to use it within 2 Business Days of our request.

5.3 You must not present a UK number on calls that start outside the UK unless the law and your Approved Use Schedule allow it.

5.4 Calls to the United States and Canada are subject to caller-ID authentication (STIR/SHAKEN). You must provide the information needed to attest your calls correctly, and you must answer traceback requests within 24 hours.

5.5 We and our network partners may block, alter or withhold the display of calls with a Presentation Number that does not comply, where the rules require it.

6. Numbers

6.1 You must use Numbers only for the purpose and number type they were allocated for, in line with the numbering rules of the relevant country.

6.2 You must bring allocated Numbers into use within 30 days. You must tell us promptly when a Number is no longer needed.

6.3 Some countries and number types need documents, a local address or proof of identity. You must provide these, keep them accurate, and tell us of any change.

6.4 If you sub-allocate Numbers to End Users, you must first carry out know-your-customer checks in line with Ofcom's good practice guidance. You must also record an accurate emergency location address for each Number.

6.5 We may withdraw Numbers that are unused or misused, or that a Regulator or network partner requires us to withdraw.

7. Business messaging

This section applies where we supply SMS, RCS, WhatsApp or other messaging services.

7.1 You must register sender IDs, brands and campaigns where the destination country or network requires it. This includes UK sender ID registration and US 10DLC or toll-free verification. You must not use generic or misleading sender IDs.

7.2 You must send marketing messages only with the consent the law requires. Every marketing message must include a simple, free way to opt out, and you must act on opt-outs promptly.

7.3 You must not send messages that are spam; that promote content prohibited by the destination country or network (for example, some gambling, cannabis, firearms, adult or high-risk lending content); or that impersonate another organisation.

7.4 We may require further know-your-customer checks, sender ID verification and ongoing monitoring of your messaging traffic, and may apply volume limits, where the law or our network partners require it.

8. Fair usage

8.1 Where a Service is sold with an allowance, bundle, inclusive usage or unlimited-style description, it is intended for genuine business communications consistent with your agreed profile. It must not be used in a way that is materially inconsistent with that profile, creates disproportionate network or partner impact, or circumvents the commercial basis on which the Service was supplied.

9. Traffic patterns we review

We monitor traffic to protect you, other customers and the network. The following will usually trigger a review, and may lead to immediate restriction under clause 11.1 of the Customer Service Terms:

1. sudden rises in volume, concurrency or spend;
2. calls or messages to high-risk or premium destinations you have not used before;
3. a high proportion of very short calls, or a low answer rate;
4. a high rate of rejected, invalid-number or failed calls;
5. complaints or traceback requests from call recipients, other networks or Regulators; and
6. Presentation Numbers or sender IDs that fail validation.

10. Security

You must keep your equipment and Account secure, as set out in clause 7 of the Customer Service Terms. We recommend that you:

1. use IP allow-lists;
2. bar destinations you do not need;
3. set spend limits;
4. use strong passwords and two-factor authentication where available; and
5. disable unused extensions and API keys.

11. How we respond

11.1 We act in proportion to the risk. Depending on how serious the issue is, we may:

1. contact you for information;
2. issue a warning;
3. apply conditions or limits;
4. restrict specific Numbers, routes, destinations or traffic;
5. suspend Services; or
6. end the Contract.

11.2 Where we reasonably suspect fraud, scam traffic, spoofing, Artificially Inflated Traffic or a threat to the network, we may act immediately and without notice.

11.3 Where practicable, we will contact you before or promptly after taking action, and we will restore Services in line with clause 11.5 of the Customer Service Terms.

11.4 You must co-operate with our investigations and give us the information we ask for within the time set in clause 19 of the Customer Service Terms. Where a Regulator or network partner requires it, we may share information about the Communications and about you.

12. Charges

You remain responsible for charges generated through your Services, systems or credentials, including where they have been compromised, as set out in the Customer Service Terms.

13. Reporting misuse

Anyone can report suspected fraud, security compromise or misuse of our Services to info@prasmo.com. Please include the number, date and time, destination and any other relevant details. We will investigate reports and act where appropriate.

14. Changes

We may update this policy in line with clause 20 of the Customer Service Terms. The current version and its effective date are published on our website.

PRASMO LTD · Registered in England and Wales · Company number 17296533 · 128 City Road, London, United Kingdom, EC1V 2NX