Legal Document

Messaging Policy

Last Updated: February 20, 2026

Introduction

This Messaging Policy describes how SMS and voice messaging works on the Willow CSR platform and sets forth the compliance requirements for all users. By using our Services, you agree to comply with this policy and all applicable laws governing SMS and voice communications.

This policy is incorporated into and forms part of our Terms of Service.

Rank Capture Grow LLC, operating as Willow CSR ("Willow CSR," "we," "us," or "our") reserves the right to suspend or terminate accounts that violate this policy, and to report violations to carriers and regulatory authorities.

A2P 10DLC Compliance

Willow CSR treats all messaging transmitted via our platform as Application-to-Person ("A2P") messaging. All A2P messages originating from Willow CSR are:

  • Registered with The Campaign Registry (TCR)
  • Compliant with 10DLC (10-Digit Long Code) carrier requirements
  • Subject to CTIA guidelines and best practices
  • Monitored for compliance with this policy

Subscribers are assigned dedicated phone numbers that are registered under Willow CSR's approved A2P 10DLC campaign. This registration is included in your White-Glove Setup fee.

How Willow Voice Works — Call to Action & Consent Flow

When a customer calls a business using Willow CSR and the call goes unanswered, Willow answers based on your configured timing and delivers the following voice greeting:

"Hi, I'm Willow, the AI assistant for [Business]. We're currently helping another customer. The fastest way to get things started is by text. To receive a text message about your request, press 1. Message and data rates may apply. To leave a voicemail, press 2."

Consent is captured when the customer presses 1 (DTMF input). This explicit mechanical action constitutes express consent to receive SMS messages related to their inquiry. The consent mechanism is deterministic — no speech recognition, no interpretation, no ambiguity.

If the customer does not press 1, no SMS is sent. The call proceeds to voicemail. This is a fail-closed system — absence of consent means absence of messaging.

Verify this flow: Call (225) 457-3575 to experience the consent process directly.

Consent Requirements

Express Consent

Prior to any SMS being sent, customers must provide express consent via DTMF input: customer presses 1 after hearing the voice disclosure containing AI identification and "Message and data rates may apply."

What Constitutes Valid Consent

  • Customer-initiated contact (inbound call to your business)
  • Clear disclosure of SMS messaging before consent
  • AI assistant disclosure in voice greeting
  • Explicit affirmative DTMF keypress
  • Disclosure of message and data rates

What Does NOT Constitute Valid Consent

  • Silence or failure to opt-out
  • Pre-checked boxes on web forms
  • Consent buried in terms and conditions
  • Consent obtained for a different business or purpose
  • Purchased or third-party lead lists

Consent Records

Willow CSR logs all consent events with the following information:

  • Timestamp: Date and time of consent (UTC)
  • Phone Number: Customer's phone number (normalized E.164 format; encrypted at rest)
  • Consent Method: numeric_dtmf
  • DTMF Digit: Specific key pressed (1)
  • Business ID: Subscriber business identifier
  • Call SID: Twilio Call SID for audit trail

Retention: Consent records are retained for 5 years to support compliance verification and legal defense.

These records are available upon request for carrier inquiries or regulatory audits.

Required Disclosures

All Willow CSR communications include the following required disclosures:

Voice Greeting

  • AI assistant identification ("I'm Willow, the AI assistant")
  • Business identification
  • Clear offer to continue via SMS
  • Instructions for consent (Press 1)
  • Alternative option (Press 2 for voicemail)
  • "Message and data rates may apply"

First SMS

  • Business identification ("Hi, this is Willow with [Business]")
  • Opt-out instruction ("Reply STOP to opt-out")

Subsequent SMS Messages

  • Clear identification of sending business
  • Relevant, conversational content related to customer inquiry
  • Opt-out reminder as needed

Opt-Out Handling

Customers can opt out of receiving SMS messages at any time by replying with any of the following keywords:

STOP | STOPALL | UNSUBSCRIBE | CANCEL | END | QUIT

These keywords are recognized in English, Spanish, Mandarin, French, and Portuguese.

Upon Receiving an Opt-Out

  1. Immediate Cessation: All SMS messaging stops immediately
  2. Confirmation: A single confirmation message is sent: "You have been unsubscribed and will not receive further messages from [Business]."
  3. Permanent Logging: The opt-out is recorded permanently in our suppression list
  4. No Re-Contact: The phone number cannot receive further messages until the customer re-initiates contact and provides new consent
  5. Suppression Survives: Opt-out records are permanent and platform-wide per provisioned number. Account deletion, re-registration, or number reassignment does not reset suppression status. Suppression persists for the lifetime of the platform.

Message Frequency and Content

Frequency

  • Message frequency varies based on customer interaction
  • Messages are limited to the scope of the customer's inquiry
  • We do not send recurring marketing messages
  • We do not send promotional broadcasts

Content Standards

All messages must be directly related to the customer's inquiry, clearly identify the sending business, provide value to the customer (quotes, scheduling, information), and maintain professional, appropriate tone.

Prohibited Content

S.H.A.F.T. Content

  • S — Sex: Adult content, pornography, escort services, sexually explicit material
  • H — Hate: Content promoting hatred, discrimination, violence against any group
  • A — Alcohol: Promotion or sale of alcoholic beverages
  • F — Firearms: Promotion or sale of weapons, ammunition, explosives
  • T — Tobacco: Promotion or sale of tobacco, vaping, e-cigarettes

Prohibited Industries

  • Cannabis, CBD, kratom, or paraphernalia products, and marketing of any substance federally classified as a controlled substance, regardless of state-level legality
  • Gambling, lottery, casino, or betting services
  • Payday loans, high-interest lending, debt collection
  • Debt consolidation or credit repair programs
  • Cryptocurrency promotions or investment schemes
  • Multi-level marketing or pyramid schemes
  • "Get rich quick" schemes
  • Third-party lead generation services
  • Affiliate marketing that buys, sells, or shares consumer information
  • Political campaign messaging
  • Prescription medication offers

Willow CSR reserves the sole and absolute discretion to determine industry eligibility, independent of TCR campaign approval status. Approval by The Campaign Registry or any carrier does not guarantee continued access to the Services if Willow CSR determines, in its sole judgment, that the Subscriber's industry, content, or messaging practices present unacceptable compliance risk.

Prohibited Activities

  • Spam: Unsolicited messages or bulk messaging
  • Phishing: Deceptive messages to obtain personal information
  • Fraud: Impersonation, scams, misrepresentation
  • Harassment: Threatening, abusive, or intimidating content
  • Cold Outreach: Messages without proper consent
  • Lead Selling: Capturing leads for resale to third parties
  • Malware: Links to malicious content or viruses

Subscriber Responsibilities

Compliance

  • Ensuring your use case complies with this Messaging Policy
  • Complying with all applicable laws (TCPA, FCC AI Voice Ruling, CTIA guidelines, state laws)
  • Maintaining accurate business information in your account
  • Responding appropriately to customer inquiries escalated by Willow

Prohibited Actions

You may NOT: import phone numbers without proper direct consent; use Willow CSR for cold outreach or marketing; transfer consent obtained for one business to another; misrepresent your business identity; or use the platform for any prohibited industry or content.

Carrier Compliance

Carrier Requirements

Willow CSR maintains compliance with major carrier requirements including AT&T, Verizon, T-Mobile, and US Cellular.

Throughput and Delivery

Message delivery is subject to carrier filtering and throttling. Willow CSR does not guarantee message delivery. Carriers are not liable for delayed or undelivered messages.

Carrier Audits

Carriers may request compliance documentation at any time. Willow CSR maintains complete consent records, message logs, opt-out records, and business verification documents.

Enforcement

Violations

  • Minor: Warning and requirement to correct behavior
  • Moderate: Temporary suspension pending review
  • Severe: Immediate termination without refund
  • Illegal: Termination and report to authorities

Appeals

If you believe your account was suspended in error, contact info@rankcapturegrow.com within 7 days with relevant documentation.

Changes to This Policy

Willow CSR may update this Messaging Policy to reflect changes in carrier requirements, regulations, or best practices. Material changes will be communicated via email to Subscribers.

Contact

General Support
Email: info@rankcapturegrow.com
Website: willowcsr.com

Registered Agent
Rank Capture Grow LLC, operating as Willow CSR
201 Rue Beauregard, Ste. 202
Lafayette, LA 70508

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