Acceptable Use Policy for Messaging

This Acceptable Use Policy for Messaging (“AUP”) is an integral part of the Terms of Use and Privacy Policyand constitutes a binding legal agreement between you (“user,” “you,” “your”) and innovage.io LLC (“we,” “us,” “our”) regarding your use of the Inovomobile application (the “App”).

I. Introduction

Intended use.Inovo is designed exclusively for person-to-person (P2P) communication. This principle is the foundation of this AUP, and all rules outlined below exist to preserve the integrity of the App as a P2P service. P2P communication includes both personal conversations and an individual's own professional communications, such as discussing work-related matters with clients or colleagues. Any use of the App for automated, bulk, high-volume, or marketing messaging is strictly prohibited and constitutes a material violation of this AUP. All messages must be composed and sent personally by a verified human account holder to recipients they know or have a prior relationship with.

This AUP governs three primary aspects of your use of the App:

• Your Account(s): terms and restrictions governing the creation, maintenance, and deactivation of your Account(s).
• Calling Regulations: rules pertaining to fraudulent and abusive calling practices.
• Messaging Policy: rules governing the content and transmission of messages sent using phone numbers obtained via the App.

Your full compliance with this AUP is a material condition of your access to and use of the App. Any failure to adhere to the rules set forth herein constitutes a material breach of our Terms of Use. Non-compliance may result in immediate enforcement actions taken at our sole discretion and without prior notice, including:

• blocking of your Account(s) and barring the associated device(s) from using the App;
• revocation of your right to use the phone number(s) provided via the App;
• suspension or permanent termination of all calling and messaging functions associated with your phone number(s) and Account(s).

In most cases, our standard response to any violation is the simultaneous application of all enforcement actions listed above. We reserve the right to monitor your calling, messaging, and Account activity to ensure compliance with this AUP.

II. Prohibited Account Practices

To maintain the security and integrity of the App and prevent fraud, all users must adhere to the following account standards. Violations will result in the immediate enforcement actions described in this AUP.

Exceeding Account Creation Limits

A user may not create, maintain, or use more than 2 (two) App Accounts per device. Exceeding this limit will result in the immediate blocking of all App Accounts associated with the violating device, forfeiture of associated phone numbers, and blocking of the device itself from creating new Accounts or using App Services.

Account Cycling

Account Cycling is defined as the repeated or systematic deactivation and re-registration of Accounts within the App. This practice is prohibited because it is used to fraudulently obtain benefits intended for new users, such as promotional offers or trial phone numbers. The determination of whether activity constitutes Account Cycling is made at our sole discretion, based on the frequency and timing of deactivations and registrations. Users found to be engaging in Account Cycling are subject to the same enforcement actions as those who exceed Account Creation Limits.

III. Calling Regulations

You agree not to use the App, including any phone number(s) assigned to you, to engage in, facilitate, or participate in fraudulent, abusive, or illicit calling activities. Use of the App for any purpose other than legitimate P2P communication is strictly prohibited.

Forbidden calling practices include but are not limited to:

Volumetric Call Abuse

Originating an unreasonably excessive number of calls to, or receiving an unreasonably excessive volume of calls from, the same number within any given period; or making an unusually high number of calls to many different numbers in a short period.

High-Velocity Call Sequences

Placing multiple successive calls to the same number or to different numbers with unusually short intervals between the end of one call and the start of the next.

Volumetric Call Abuse and High-Velocity Call Sequences are prohibited as they are presumed to indicate non-genuine communications (such as spam, harassment, robocalling, or traffic pumping) rather than good-faith manual communications.

Excessive Call Duration

Maintaining excessively long call sessions or engaging in any calling activity that, in our sole determination, vastly exceeds reasonable good-faith usage patterns.

Activity Beyond Fair Usage

Use of the App's calling and/or messaging features beyond a reasonable Fair Usage Cap, which we establish and apply in our sole discretion to prevent misuse and ensure network integrity and availability for all users.

Enforcement Metrics

We apply internal Enforcement Metrics (quantitative limits, thresholds, and algorithms) to detect the practices described above. These Enforcement Metrics are confidential and will not be disclosed, as doing so would enable malicious actors to circumvent them. The determination of any violation is made at our sole and absolute discretion based on these internal systems.

Any breach related to fraudulent or abusive calling will result in immediate and comprehensive enforcement actions: simultaneous blocking of the offending Account(s) and linked device(s), forfeiture of all associated phone number(s), and termination of calling and messaging functions. We reserve the right, at our sole discretion, to impose a lesser penalty for a first-time minor violation. Any subsequent violation will automatically result in the full set of enforcement actions.

IV. Messaging Policy

This section explains the rules for using messaging services available through the App.

Prohibited Message Content

It is strictly prohibited to use phone numbers obtained via the App to send messages that contain any of the following types of content:

• Spam: unsolicited messages with duplicate, near-duplicate, or similar content sent to one or more people over a short period. We check each outgoing message against your recent message history. If we detect spam activity (at least 10 duplicate or similar messages in a short period), we will issue a warning. Continued spamming will result in Account and phone number blocking.
• High-risk financial services: messages related to cryptocurrency, loans (including student, short-term, payday, or high-interest loans).
• Third-party lead generation: activities aimed at obtaining, buying, selling, or sharing consumer information.
• Debt collection or forgiveness: debt collection, consolidation, reduction, or credit repair programs.
• “Get rich quick” schemes: deceptive work-from-home programs, risky investment opportunities, pyramid schemes.
• Controlled or illegal substances/articles: content related to cannabis, CBD, fireworks, or other substances or articles that are illegal in applicable jurisdictions. Even if such substances are legal in your jurisdiction, messages related to them are not permitted. Reasonable suspicion of cannabis-related business use will result in unconditional Account blocking, regardless of whether messages explicitly mention cannabis.
• Prescription medication: offers for medications that cannot be sold over the counter.
• Gambling: content related to gambling apps, websites, or services.
• S.H.A.F.T. content: sex, hate speech, alcohol, firearms, and tobacco. Messages involving these topics are subject to absolute prohibition or require additional age-gating and consent procedures that users of this App cannot fulfill.
• Filter evasion: intentionally misspelled words, leetspeak (replacing letters with similar-looking numbers or characters), or snowshoeing (sending identical or similar messages from multiple source numbers to avoid filters).
• Links and shortened URLs: messages containing links, especially shortened URLs, are at high risk of being filtered as they are frequently used in fraudulent schemes.
• Fraud, scams, and phishing: content that constitutes or contains elements of fraud, unsolicited or deceptive marketing, or phishing.
• Malicious content: malware, viruses, or similar harmful content.
• Hate speech and harassment: content containing hate speech, profanity, harassment, threats, violence, abuse, defamation, or content originating from a hate group.
• Adult and explicit content: sexually explicit or suggestive content, pornography, content related to the adult entertainment industry, prostitution, or human trafficking.
• Other harmful content: any content that can reasonably be considered illegal, harmful, unwanted, inappropriate, objectionable, or that poses a threat to the public or whose origin is falsified or misrepresented.

The above list is not exhaustive. All categories of messages with objectionable content are subject to filtering regardless of whether you obtain consent from recipients.

Consent Requirements

When using a phone number obtained via the App to send messages, you agree to comply with applicable consent and opt-out requirements:

• Inbound message as consent: if a recipient sends a message to you first, that inbound message constitutes consent for that specific conversation only. Do not send messages outside the scope of that conversation without obtaining additional consent.
• Implied consent: consent is implied when you have a prior relationship with the individual, they have given you their phone number, and they have taken some action (such as placing an order, scheduling an appointment, or setting up an alert) that implies an expectation of communication. Acceptable message types in this context include appointment reminders, receipts, one-time passwords, order or shipping confirmations, and similar transactional messages.
• Personal relationships: if you have a personal connection with the recipient and they have not expressed an objection to receiving messages from you, consent is implied and no formal proof of consent is required.
• No spoofing: misrepresentation of your identity (spoofing) is strictly prohibited. You may not use the message body or phone number in a way that leads the recipient to believe you are another individual.
• Opt-out and help. Anyone receiving messages from an Inovo number may reply STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, QUIT, OPTOUT, or REVOKE at any time to stop receiving further messages from that number. Reply START to resubscribe. Reply HELP or INFO for assistance. Message frequency varies. Message and data rates may apply.

Message Monitoring

To provide phone numbers and messaging services, we engage third-party cloud communications providers (“Providers”). Both we and our Providers apply message filtering systems designed to detect and prevent spam, fraud, abuse, and violations of applicable laws and regulations. The content of all messages you send using phone numbers obtained via the App is subject to collection and monitoring for these purposes.

By using the App you grant us and our Providers permission to collect, process, store, and monitor the content of messages you send via the App for the purposes of:

• prevention of spam, abuse, illegal activity, and fraud;
• ensuring compliance with laws, regulations, and the messaging policies of our Providers.

Our current Providers whose messaging policies also apply to your use of the App include:

• Telnyx Acceptable Use Policy
• Twilio Acceptable Use Policy

You agree to comply with all requirements contained in those policies.

Disputed Blocks

If you reasonably believe that your messages were fully compliant with this AUP and your phone number or Account was blocked in error, please contact us at support@innovage.io. We will carefully review your messages and determine whether an error occurred on our part.

Operational Messages from Inovo

You understand and agree that you may receive text messages from Inovo concerning the status of your phone number(s), credits, and other aspects of App operation, including warnings about forthcoming Account blocking.

V. Changes to This AUP

We may modify or update this AUP at any time. All changes take effect the moment the revised version is posted. You are solely responsible for periodically reviewing this AUP to stay informed of any updates.

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