The objective of these Guidelines is to enable wanted messages and prevent unwanted or deceptive messages.The SkySwitch Messaging Platform supports superior quality and high-integrity communications. To protect consumers and the ecosystem from abuse, SkySwitch enforces guidelines designed to promote best practices for the exchange of messages. Spam or unwanted messaging is prohibited.The viability of the messaging ecosystem is dependent on consumer perception of messaging as a trusted and convenient communication environment. These Guidelines are intended to preserve the credibility and utility of the ecosystem. Message senders acting in bad faith to thwart or undermine the spirit of these Guidelines should expect to experience penalties. Messaging EnforcementPolicy enforcement is performed at several points during message delivery including: SkySwitch policy management systems Aggregator policy management systemsCarrier policy management systems (e.g., T-Mobile, Verizon Wireless, Sprint, AT&T Wireless) Messaging ViolationsViolations of Guidelines may result in one or more of the following resolutions taken by the SkySwitch Messaging Platform, aggregator, or carrier:  Blocking of individual messages Blocking of phone numbers Repeated violation may result in termination of messaging or other network servicesA2P Messaging Best PracticesThis section contains a complete deep dive into the best practices that should be followed to ensure the deliverability of messaging along with the reasoning behind why certain messaging practices are forbidden. Best Practices OverviewThis section contains a list of best practices to follow when using A2P messaging. These guidelines are very brief, and the later sections dive deeply into the reasoning behind these best practices if more information is needed.Always use campaign IDs for 10DLC/A2P and always verify use cases for Toll-Free before sending traffic.Always maintain a very low opt-out (STOP reply) from your recipients (>1% is considered acceptable).Ensure you have clear opt-in from your recipients before sending messages.Use shortened, branded URLs for the highest deliverability levels when sending links in the message body and make sure the links are functional.Opt-in language should be specific to a single brand and "Call to Action."Never use shared URL shortening services (such as free URL shortening services) as they may be used by spammers and could result in messaging traffic being blocked by carriers.Always give users easy ways to opt-out of messages (i.e. text STOP to unsubscribe).Identify your business and regularly include program reminders.Consumer Consent As described in the CTIA Messaging Principles and Best Practices Guide, the messaging ecosystem should operate consistently with relevant laws and regulations, such as the  TCPA and associated FCC regulations regarding consumer consent for communications. Regardless of  whether these rules apply and to maintain consumer confidence in messaging services, non-consumer (A2P) message senders should: Obtain a consumer’s consent to receive messages generally.Obtain a consumer’s express written consent to specifically receive marketing messages.Ensure consumers have the ability to revoke consent. Consent may vary upon the type of message content exchanged with a consumer.  The following table provides examples of the types of messaging content and the associated consent that should be expected. The examples below do not constitute or convey legal advice and should not be used as a substitute for obtaining legal advice from qualified counsel. Reference to “business” below is used as an example of a non-consumer (A2P) message sender. Individual service providers may adopt additional consumer protection measures for non-consumer (A2P) message senders, which may include,  for example, campaign pre-approval, service provider vetting, in-market audits, or unwanted message filtering practices that are tailored to facilitate the exchange of wanted messaging traffic.Types of Messaging Content & Associated Consent PrinciplesConversational Informational PromotionalConversational messaging is a back-and-forth conversation that takes place via text. If a Consumer texts a business first and the business responds quickly with a single message, then it is likely conversational.  If the consumer initiates the conversation and the business simply responds, then no additional permission is expected.Informational messaging is when a consumer gives their phone number to a business and asks to be contacted in the future. Appointment reminders, welcome texts, and alerts fall into this category because the first text sent by the business fulfills the consumer’s request.  A consumer needs to agree to receive texts for a specific informational purpose when they give the business their mobile number.Promotional messaging is a  message sent that contains a sales or marketing promotion. Adding a call to action (e.g., a coupon code to an informational text)  may place the message in the promotional category.  Before a business sends promotional messages, the consumer should agree in writing to receive promotional texts.  Businesses that already ask consumers to sign forms or submit contact information can add a field to capture the consumer’s consent.The first message is only sent by a  consumer Two-way conversationThe first message is sent by the consumer or business One-way alert or two-way conversationThe first message is sent by  the business One-way alertMessage responds to a specific requestMessage contains information Message promotes a brand,  product, or servicePrompts consumer to buy something, go somewhere, or otherwise take actionIMPLIED CONSENT If the consumer initiates the text message exchange and the business only responds to each consumer with relevant information, then no verbal or written permission is expected.EXPRESS CONSENT The consumer should give express permission before a  business sends them a text message. Consumers may give permission over text, on a form, on a website, or verbally. Consumers may also give written permission.EXPRESS WRITTEN  CONSENT The consumer should give express written permission before a business sends them a text message.  Consumers may sign a form, check a box online, or otherwise provide consent to receive promotional text messages.Clear and Conspicuous Calls-to-Action A “call-to-action” is an invitation to a consumer to opt-in to a messaging campaign. The call-to-action for a  single-message program can be simple. The primary purpose of disclosures is to ensure that a consumer consents to receive a message and understands the nature of the program. Message senders should display a clear and conspicuous call-to-action with appropriate disclosures to consumers about the type and purpose of the messaging consumers will receive. A call-to-action should ensure consumers are aware of:  The program or product description; The phone number(s) or shortcode(s) from which messaging will originate;The specific identity of the organization or individual being represented in the initial message; Clear and conspicuous language about opt-in and any associated fees or charges; and  Other applicable terms and conditions (e.g., how to opt-out, customer care contact information, and any applicable privacy policy). Calls-to-action and subsequent messaging should not contain any deceptive language, and opt-in details should not be obscured in terms and conditions (especially terms related to other services). Consumer Opt-In Message senders should support opt-in mechanisms, and messages should be sent only after the consumer has opted-in to receive them. Opt-in procedures reduce the likelihood that a consumer will receive an unwanted message. It can also help prevent messages from being sent to a phone number that does not belong to the consumer who provided the phone number (e.g., a consumer purposefully or mistakenly provides an incorrect phone number to the message sender). Depending upon the circumstances, a consumer might demonstrate opt-in consent to receive  messaging traffic through several mechanisms, including but not limited to:Entering a phone number through a websiteClicking a button on a mobile webpageSending a message from the consumer’s mobile device that contains an advertising keywordInitiating the text message exchange in which the message sender replies to the consumer only  with responsive informationSigning up at a point-of-sale (POS) or other message sender on-site locationOpting-in over the phone using interactive voice response (IVR) technologyWhile the common short code handbook is a separate document specific to the common short code program, the common short code handbook has additional examples of opt-in consent which may be helpful to message senders. Message senders should also document opt-in consent by retaining the following data where applicable: Timestamp of consent acquisition; Consent acquisition medium (e.g., cell-submit form, physical sign-up form, SMS keyword, etc.)Capture of experience (e.g., language and action) used to secure consent; Specific campaign for which the opt-in was provided; IP address used to grant consent; Consumer phone number for which consent to receive messaging was grantedIdentity of the individual who consented (name of the individual or other identifier (e.g., online user name, session ID, etc.)). Confirm Opt-In Confirmation for Recurring Messages Message senders of recurring messaging campaigns should provide consumers with a confirmation message that clearly informs the consumer they are enrolled in the recurring message campaign and provides a clear and conspicuous description of how to opt-out. After the message sender has confirmed that a consumer has opted-in, the message sender should send the consumer an opt-in confirmation message before any additional messaging is sent. The confirmation message should include:  The program name or product description;  Customer care contact information (e.g., a toll-free number, 10-digit phone number, or help command instructions);  How to opt-out;  A disclosure that the messages are recurring and the frequency of the messagingClear and conspicuous language about any associated fees or charges and how those charges will be billed. Consumer Re-Opt-In on Toll-Free Numbers A consumer may opt-in to a toll-free A2P campaign by texting the word “UNSTOP” to the sender’s toll-free number. This keyword is not case sensitive and triggers opt-in only when sent as a single word. Example of valid re-opt-ins: • UNSTOP including variations such as unstop, Unstop, or UNStop Single Opt-In per Campaign Opt-ins are not transferrable. A consumer opt-in to receive messages should not be transferable or assignable. A consumer opt-in should apply only to the campaign(s) and specific message sender for which it was intended or obtained. Renting, Selling, or Sharing Opt-In Lists Message senders should not use opt-in lists which have been rented, sold or shared to send messages.  Message senders should create and vet their own opt-in lists. Consumer Opt-Out Opt-out mechanisms facilitate consumer choice to terminate messaging communications, regardless of whether consumers have consented to receive the message. Message senders should acknowledge and  respect consumers’ opt-out requests consistent with the following guidelines: Message senders should ensure consumers have the ability to opt-out of receiving messages at  any timeMessage senders should support multiple mechanisms of opt-out, including phone call, email, or  textMessage senders should acknowledge and honor all consumer opt-out requests by sending one final opt-out confirmation message per campaign to notify the consumer that they have opted out successfully. No further messages should be sent following the confirmation message.Message senders should state in the message how and what words affect an opt-out.  Standardized “STOP” wording should be used for opt-out instructions, however, opt-out requests with normal language should also be read and acted upon by a message sender except where a  specific word can result in unintentional opt-out. The validity of a consumer opt-out should not be impacted by any de minimis variances in the consumer opt-out response, such as capitalization, punctuation, or any letter-case sensitivities. Examples of valid opt-out messages: STOP including variations such as Stop or STop Quit Cancel Unsubscribe SPAMHigh Opt-Out Rate Message senders who receive high volumes of opt-outs could be flagged and indicative of poor sending practices. In the case that the daily opt-out rate is 5% or higher, the toll-free carrier or other carriers may monitor the campaign. The carrier may reach out for campaign and opt-in details and/or suspend services of high opt-out rate flagged campaigns at its discretion, not to be unreasonably exercised. “Daily opt-out rate” is the total number of subscribers who received a campaign’s SMS divided by the number of opted-out subscribers who received a campaign’s SMS in a 24-hour period. Maintaining and Updating Consumer Information Message senders should retain and maintain all opt-in and opt-out requests in their records to ensure future messages are not attempted (in the case of an opt-out request) and consumer consent is honored to minimize unwanted messages. Message senders should process phone deactivation files regularly (e.g., daily) and remove any deactivated phone numbers from any opt-in lists. Privacy and Security Message senders should address both privacy and security comprehensively in the design and operation of messaging campaigns. SkySwitch is not responsible or liable for any security or breaches experienced by the message sender. Maintain and Conspicuously Display a Clear, Easy-to-Understand Privacy Policy  Message senders should maintain and conspicuously display a privacy policy easily accessed by the consumer (e.g., through clearly labeled links) that clearly describes how the message sender may collect, use, and share information from consumers. All applicable privacy policies should be referenced and accessible from the initial call to action. Message senders also should ensure that their privacy policy is consistent with applicable privacy law and their treatment of information is consistent with their privacy policy. Implement Reasonable Physical, Administrative, and Technical Security  Controls to Protect and Secure Consumer Information Message senders should implement reasonable security measures for messaging campaigns that include technical, physical, and administrative safeguards. Such safeguards should protect consumer information from unauthorized access, use, and disclosure. Message senders should conduct regular testing and monitoring to ensure such controls are functioning as intended. Conduct Regular Security Audits Message senders should conduct either a comprehensive self-assessment or third-party risk assessment of privacy and security procedures for messaging campaigns on a regular basis and take appropriate action to address any reasonably foreseeable vulnerabilities or risks. Content This section details guidelines and restrictions regarding what type(s) of content can be included in A2P messaging.Prevention of Unlawful Activities or Deceptive, Fraudulent, Unwanted or Illicit  Content  Message senders should use reasonable efforts to prevent and combat unwanted or unlawful messaging traffic, including spam and unlawful spoofing. Specifically, message senders should take affirmative steps and employ tools to monitor and prevent unwanted messages and content,  including for example content that: (1) is unlawful, harmful, abusive, malicious, misleading,  harassing, excessively violent, obscene/illicit, or defamatory;(2) deceives or intends to deceive (e.g.,  phishing messages intended to access private or confidential information); (3) invades privacy; (4)  causes safety concerns; (5)incites harm, discrimination, or violence;(6)is intended to intimidate;(7)  includes malware;(8)threatens consumers; or(9)does not meet age-gating requirements. Message senders can also review the common short code handbook for further examples of unwanted message content. Further, message senders should take steps to ensure marketing content is not misleading and complies with the Federal Trade Commission’s (FTC) Truth-In-Advertising rules. Embedded Website Links Message senders should ensure links to websites embedded within a message do not conceal or obscure the message sender’s identity and are not intended to cause harm or deceive consumers. Where a web address (i.e., Uniform Resource Locator (URL)) shortener is used, message senders should use a shortener with a web address and IP address(es) dedicated to the exclusive use of the message sender. Web addresses contained in messages as well as any websites to which they redirect should unambiguously identify the website owner (i.e., a person or legally registered business entity) and include contact information, such as a postal mailing address. Embedded Phone Numbers Messages should not contain phone numbers that are assigned to or forward to unpublished phone numbers unless the owner (i.e., a person or legally registered business entity) of such phone numbers is unambiguously indicated in the text message. Text-Enabling a Phone Number for Non-Consumer (A2P) Messaging An authentication and validation process should be used to verify the message senders’ authority to enable non-consumer (A2P) messaging for a specific phone number. Message senders should only enable non-consumer (A2P) messaging with a phone number that the message sender has been assigned by a provider of telecommunications or interconnected Voice over Internet Protocol  (VoIP) services. Message ClassRisk Level Use Case Campaign Type TPM A Standard-Low 2FA/ Authentication  /Customer care/ Marketing  / Mixed /Operations /  Higher EducationDeclared/Mixed  Marketing1800 B Standard-Low Declared/Mixed  Marketing1800 C Standard-Medium Declared Use case 300 D Standard-Medium Mixed/ Marketing 300 E Standard-High Declared Use case 30 F Standard-High Mixed/ Marketing 30 T Basic-High Low volume Mixed Low volume Mixed 75 G Special Group messaging (Pools)  Bridge servicesNon-commercial 600 P Special Charity 60 S Special Social Engagement 60000 Q Special Political messaging 3000 X Special Emergency services /Public  Safety3000 Z Special Large CSP trial offers with  strict control and MNO audit  rights (MO Opt in)60 Y Special Trusted (Carrier  Exemptions)1800 W Special-Trusted Less Trusted (Carrier  Exemptions)1800 Political Messaging Political campaigns should abide by the M3AAWG Mobile Messaging Best Practices for Political Programs Best Practices. T-Mobile Political Messaging To run 10DLC messaging campaigns on the T-Mobile network, a special registration and third-party verification check is required (Campaign Verify). This is required to ensure the authenticity of the political entity. Political candidates are required to send extended information that includes the following  requirements: The campaign must be on a dedicated application address 10DLC only: Vetting must be confirmed through Campaign Verify (www.campaignverify.org) • Campaign Verify Token FEC Committee ID Politician/Organization Name Politician/Organization Website A2P Toll-Free Messaging in Canada The Canadian market is continuing to evolve with regard to texting over A2P routes. Please reference our entire Best Practices for adherence on Canadian networks. Additionally, we have included the rules below, which should be followed.Opt-Out Opt-out must be below 1% Stop Language Campaigns must send stop language on the first and 5th messages or once a month for continued customer awareness. However, sending it on every message is recommended. Single Number Sending If a single number gets blocked with the Canadian carriers, please do not move traffic to another number. Brand Identity Messages should always identify who the sender of the message is. Message Frequency The number of messages sent to a subscriber should not exceed 10 in a month. If there is an expectation that the subscriber will receive multiple messages, then that should be stated during the opt-in process.Customer Support Keywords Campaigns should support HELP, INFO, and STOP as well as all French translations and send a  bounce back in the corresponding language of the keyword. False Positives SkySwitch monitors on behalf of customers, but we encourage any issues to be reported to support@skyswitch.com Data Rates May Apply Verbiage When a customer receives a message termination (MT) with a link to a website, messages must  also state that “Data rates may apply.”