Purpose

This SMS Compliance Policy (“Policy”) governs the use of all Short Message Service (SMS), multimedia messaging (MMS), and other text‑based messaging services provided or enabled by United Software Developers Inc., doing business as USD GoPay (the “Company”).

This Policy is incorporated by reference into the Company’s Terms and Conditions and Acceptable Use Policy and applies to all users who access or use SMS or messaging functionality through the Services.

Historical Services and Policy Updates

The Company has provided software platforms and communication‑related services for many years prior to the Effective Date of this Policy.

This Policy represents a consolidated and updated statement of SMS compliance requirements and applies to all continued and future use of SMS messaging features as of the Effective Date, regardless of when you first began using any Company services.

Continued use of SMS messaging functionality on or after the Effective Date constitutes acceptance of this Policy.

Regulatory Framework

You are solely responsible for ensuring compliance with all applicable laws, rules, and industry standards governing SMS communications, including but not limited to:

• The Telephone Consumer Protection Act (TCPA)
• Applicable Federal Communications Commission (FCC) regulations
• State and international messaging laws, where applicable
• Mobile carrier rules and messaging aggregator requirements

The Company does not provide legal advice regarding SMS compliance.

Consent Requirements

You must obtain proper, documented consent from each recipient before sending any SMS message.

Consent must be:

• Explicit (affirmative opt‑in)
• Clear and unambiguous
• Specific to the purpose of the messaging
• Documented and retained by you

You are responsible for maintaining records of recipient consent and providing such records upon request.

Prohibited Messaging Practices

You may not use the Services to send messages that are:

• Unsolicited or sent without proper consent
• Misleading, deceptive, or fraudulent
• Harassing, abusive, or threatening
• Related to illegal or prohibited goods or services
• In violation of carrier policies or applicable laws

The Company strictly prohibits spam, phishing, or bulk messaging practices that violate compliance standards.

Opt‑Out and Recipient Rights

You must honor recipient opt‑out requests immediately.

Required Opt‑Out Practices:

• Support standard opt‑out keywords (e.g., STOP, CANCEL, UNSUBSCRIBE)
• Cease messaging promptly after an opt‑out request
• Maintain suppression lists to prevent further messaging to opted‑out recipients

Failure to honor opt‑out requests is a material violation of this Policy.

Message Content and Identification

You are responsible for ensuring that messages:

• Clearly identify the sender
• Accurately reflect the purpose of the message
• Do not impersonate another person or entity
• Do not contain false or misleading information

Where required, disclosure language must be included in messages or associated opt‑in flows.

Message Delivery and Carrier Limitations

Message delivery is not guaranteed.

Mobile carriers may:

• Block, filter, or delay messages
• Enforce content restrictions
• Suspend traffic due to complaints or compliance concerns

The Company is not responsible for carrier‑level message delivery failures or filtering decisions.

Monitoring, Suspension, and Enforcement

The Company reserves the right, but does not assume the obligation, to:

• Monitor SMS usage for compliance
• Investigate suspected violations
• Suspend or terminate SMS access without notice
• Restrict message throughput or volumes

The Company may suspend or terminate messaging privileges to protect its networks, Payment Partners, messaging providers, or carrier relationships.

User Responsibility and Indemnification

You are solely responsible for your SMS and messaging activities.

You agree to indemnify, defend, and hold harmless the Company from any claims, damages, fines, penalties, or liabilities arising from:

• Failure to obtain proper consent
• Violations of TCPA or messaging regulations
• Recipient complaints or carrier enforcement actions
• Your misuse of SMS Services

Relationship to Other Policies

This SMS Compliance Policy supplements, and does not replace, the Company’s:

• Terms and Conditions
• Privacy Policy
• Acceptable Use Policy

In the event of a conflict, the Terms and Conditions control.

Changes to This SMS Compliance Policy

The Company may update this Policy from time to time. Updates will be posted with a revised “Last Updated” date.

Continued use of SMS messaging functionality constitutes acceptance of the updated Policy.