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Compliance · Section 10

Robocall Mitigation & Acceptable Use

Effective
May 19, 2026
Last updated
May 19, 2026

Section A describes our Robocall Mitigation program, the regulatory footing of Rojo Services LLC, and how we vet Customers, scrub lists, and respond to tracebacks.

Section B is the Acceptable Use Policy that every Customer accepts on activation. It is incorporated into the Terms of Service.

The four commitments that govern every voicemail on the Platform:

  1. Opt-in only. Prior express consent on file for every recipient, producible within 24 hours. No purchased, scraped, brokered, or skip-traced lists.
  2. One contact per recipient per week. A hard platform-wide cap of one voicemail per recipient in any rolling seven-day window, enforced across every operator and not overridable without documented compliance review.
  3. IVR opt-out + platform-wide blacklisting. Every voicemail includes an IVR opt-out path. Opt-outs propagate to every operator on the Platform in under ten minutes and are permanent.
  4. 24-hour traceback.Full per-call provenance — operator, list, consent, script, send window, disposition — returned within 24 hours of any carrier, ITG, FCC, or state-AG request.

These four are the spine of Section A and are restated in operational detail in Sections 4–8 below.

Section A — Our Robocall Mitigation Program

1. Our Position

Rojo Services LLC dba Rojoring.com operates a ringless-voicemail platform. The FCC has confirmed that every direct-to-voicemail delivery is a “call” under the Telephone Consumer Protection Act, and every recipient is owed the same protections they would receive from any other voice channel.

A ringless-voicemail business that depends on non-consented contact is not a business; it is a multi-year FCC enforcement timeline with a payroll. The program below is designed so that Rojo Ring traffic is welcome on every downstream carrier and so that every Customer is operating from a defensible legal posture.

2. Regulatory Footing

  • Legal Entity: Rojo Services LLC (Puerto Rico LLC) dba Rojoring.com
  • FCC Registration Number (FRN): filing in progress; published here once issued.
  • FCC Form 499 Filer ID: filing in progress; published here once issued.
  • D.C. Agent for Service of Process: designation in progress.
  • Robocall Mitigation Database (RMD): filed and current; recertification observed annually between February 1 and March 1.
  • STIR/SHAKEN attestation: Rojo Ring originates traffic from numbers under direct caller-ID-authentication review. The full attestation posture is documented in our filed RMD plan and is available to carriers and regulators on request to [email protected].
  • Industry Traceback Group (ITG): we participate and respond to every traceback within 24 hours.

We update our FRN and RMD records within 10 business days of any change to corporate structure, services, or contact information.

3. Customer Vetting (Know-Your-Customer)

We do not self-serve activate. Every account is reviewed before it can send a single voicemail:

  1. Identity verification of the business entity (registration documents, EIN/Tax ID, principal identification).
  2. OFAC and sanctions screening.
  3. Regulatory history check (open or recent FCC, FTC, or state-AG actions related to telemarketing).
  4. Intended-use review of sample scripts, target verticals, and message cadence.
  5. List-sourcing attestation, describing and documenting how recipient lists were collected and how consent was obtained.
  6. Acceptable Use Policy acceptance (Section B below).

Applications that cannot satisfy any element are declined. Customers found to have misrepresented any element are immediately suspended.

4. Consent Verification and Recordkeeping

Every voicemail delivered through the Platform requires the Customer to attest to prior express consent for that recipient. Customers must maintain a per-recipient consent record containing timestamp, source channel, exact consent language presented, IP address (or comparable identifier), and campaign categories covered; produce that record within 24 hours of any request; and include ringless-voicemail / pre-recorded-call contact explicitly in the consent language. Our Platform requires Customers to either upload proof at list-import time or link the list to a consent system we can audit.

5. Do-Not-Call and Suppression

  • National DNC Registry scrubbing within 31 days of every send.
  • State DNC registries for every state with a published list.
  • Platform-wide internal suppression list — any opt-out anywhere is suppressed everywhere.
  • Customer-specific internal DNC maintained by each Customer.
  • Litigator and complainant flags applied automatically.

Opt-outs are processed within 24 hours and honored indefinitely.

6. Throttling and Quiet Hours

  • Per-recipient daily-frequency cap.
  • Per-Customer rate ceiling tuned to carrier ingestion tolerances.
  • Delivery window 8:00 a.m. to 9:00 p.m. recipient local time, applied automatically.
  • Stricter state-specific windows where applicable.

Customers cannot override these limits without documented compliance review.

7. Call Analytics and Anomaly Detection

We monitor for high burst rates, repeated calls to small sets of numbers, abnormal disposition codes, abrupt list-mix changes, and matches against known-bad-reputation sets. Flagged Customers are throttled or paused pending review.

8. Tracebacks

We respond within 24 hours with full per-call provenance: originating Customer, list reference, consent record, script, send window, and disposition. A traceback resolving to non-consented or unlawful traffic results in immediate suspension.

9. Audit and Continuous Improvement

  • Annual third-party program review by external compliance counsel.
  • Quarterly internal audit of consent records, suppression lists, and analytics false-negative rates.
  • Annual training for all Rojo Ring staff on TCPA and state mini-TCPAs.
  • RMD recertification February 1 – March 1 each year.

10. Contact for Regulators, Carriers, and the ITG

Section B — Acceptable Use Policy

This Acceptable Use Policy is incorporated into the Terms of Service. Breach of any provision is a material breach and authorizes immediate suspension.

1. Consent

You will not send a voicemail to any number unless, at the time of delivery, you hold prior express consent (and, for telemarketing, prior express written consent) from that recipient, documented and producible within 24 hours.

2. Prohibited Sources

You will not upload, send to, or otherwise process: purchased, brokered, or rented lists you did not first-party collect; scraped, harvested, or skip-traced lists; leaked or unlawfully obtained lists; lists where the consent record cannot be produced per recipient; or lists targeting minors.

3. Prohibited Content

You will not use the Platform for messages that are deceptive, fraudulent, or scam-related; that impersonate any government agency, court, law enforcement, tax authority, utility, employer, healthcare provider, or financial institution; that promote illegal activity, unregistered securities, illegal lotteries, cryptocurrency pump schemes, unauthorized debt relief or credit repair, or counterfeit goods; that are harassing or stalking; that target minors; that use AI-cloned voices of real people without documented written consent; or that relate to cannabis, prescription drugs, firearms, adult content, or political fundraising unless documented as lawful in every jurisdiction touched and the relevant compliance program activated.

4. Caller ID and STIR/SHAKEN

You will use only caller-ID numbers you legitimately control. You will not spoof for the purpose of defrauding or causing harm (Truth in Caller ID Act). You will cooperate with our STIR/SHAKEN attestation process.

5. Quiet Hours and Frequency

You will not attempt to disable or circumvent the Platform's quiet-hours, time-zone, throttling, or frequency-cap controls.

6. Opt-Outs

You will honor opt-outs received through any channel within 24 hours, will not re-contact, and will not segment or “wash” your list to re-target opted-out numbers under a different brand.

7. Identification

Every voicemail must clearly state your business name, a callback number you control and answer, and a working opt-out instruction.

8. Records

You will retain consent records, list provenance, scripts, send schedules, and opt-outs for at least 5 years.

9. Cooperation

You will cooperate within 24 hours with any traceback or compliance inquiry from us, a carrier, the ITG, the FCC, the FTC, or a state attorney general.

10. Suspension

We may suspend immediately for any suspected breach, any unproduced consent record, any traceback returning unlawful traffic, or any analytics flag consistent with unlawful robocalling. Reinstatement requires a written corrective-action plan accepted by our compliance team.

Reporting Abuse