Communications Compliance Policy

1. Our commitment

CYG Group Inc. ("CYG Group", "we", "us") builds and operates phone systems, interactive voice response (IVR) systems, voice notifications and SMS/text messaging programs. We are committed to communicating only with people who want to hear from us or from our clients, and to complying with all laws and industry rules that apply to calls and text messages in the United States. These include:

• the Telephone Consumer Protection Act (TCPA) and the Federal Communications Commission (FCC) rules that implement it;
• the Telemarketing Sales Rule (TSR) and the National Do Not Call Registry, administered by the Federal Trade Commission (FTC);
• the Truth in Caller ID Act;
• the CAN-SPAM Act, for any email communications;
• applicable state laws, including those of New York; and
• wireless carrier requirements and the CTIA Messaging Principles and Best Practices.

This policy applies to the communications we send for our own business and to the communications programs we build and operate for our clients.

2. Consent to calls and texts

We contact a person by automated or prerecorded voice call, or by text message, only after they have given the consent the law requires for that type of message:

• Informational and transactional messages (for example alerts, reminders, confirmations and account notices) are sent only with the recipient's prior express consent.
• Marketing or promotional messages, if any are sent, require the recipient's prior express written consent, which clearly authorizes that sender to contact that phone number.
• Consent is never a condition of purchasing any goods or services.
• We do not buy, rent, sell or trade phone number lists, and we do not send messages to numbers obtained from third-party lead lists.

3. How people opt in

Depending on the program, a person may opt in by entering their phone number and checking an unchecked consent box on a web form, by choosing to subscribe from a keypad menu during a phone call to an IVR line, or by texting a keyword to a program's number. At the moment of opt-in, the person is told:

• who will be sending the messages;
• what kind of messages they will receive;
• that message frequency varies;
• that message and data rates may apply;
• that they can reply STOP to opt out and HELP for help at any time; and
• where to find our Privacy Policy and Terms of Service.

A confirmation message is sent when a person subscribes to a text messaging program.

4. Opting out (STOP) and help (HELP)

• Reply STOP, END, CANCEL, UNSUBSCRIBE, QUIT or STOPALL to any text message to stop receiving messages from that program. We send one final message confirming the opt-out and no further messages afterward.
• Reply HELP to receive the program name and our contact information.
• Automated voice calls that require it offer a way to opt out during the call, such as a keypad option.
• You may also opt out by calling (718) 344-7468 or emailing bracha@ivrhost.com.
• We honor opt-out requests made by any reasonable means, and we process them promptly and within the time required by law.

5. What messages we send

Our programs send informational and transactional communications, such as:

• alerts and announcements that subscribers have asked to receive;
• appointment, event and service reminders;
• confirmations, receipts and account notices; and
• responses to messages a person has sent to us.

Message frequency varies by program and by the recipient's activity. Every program identifies the sender by name in its messages.

6. Do Not Call and calling hours

• We maintain an internal do-not-call list and add anyone who asks not to be contacted.
• We do not place telemarketing calls or texts to numbers on the National Do Not Call Registry, or on applicable state registries, unless the person has given prior express written consent or another legal exception applies.
• Telemarketing calls and messages are made only between 8:00 a.m. and 9:00 p.m. in the recipient's local time, or within any narrower hours that state law requires.

7. Caller ID and call identification

• Our calls display accurate caller ID information. We never spoof caller ID or display a number to mislead or defraud.
• Prerecorded and automated calls identify the business or organization responsible for the call at the beginning of the message and provide a telephone number at which it can be reached.
• We place calls through established, licensed carriers that support STIR/SHAKEN caller ID authentication.

8. Carrier and industry standards

• We follow the CTIA Messaging Principles and Best Practices and the policies of our communications providers.
• We register our application-to-person (A2P) messaging brands and campaigns as carriers require, including A2P 10DLC registration and toll-free number verification, and we keep those registrations accurate.
• Messages are sent only for the purpose described in the registered campaign.

9. Prohibited content

We do not send, and we do not allow our systems to be used to send:

• unsolicited or bulk messages to people who have not opted in;
• deceptive, fraudulent, phishing or misleading content;
• content that is illegal, harassing, hateful or threatening; or
• content restricted by carriers, such as messages promoting illegal substances, sexually explicit material, or regulated products without the required controls.

10. Responsibilities of our clients

Organizations that use a phone or messaging system we build or operate must agree to collect and keep valid consent from the people they contact, honor opt-out requests, use accurate sender identification, and follow this policy and the law. We review new programs before they go live, and we may suspend any program that does not meet these requirements.

11. Privacy of mobile information

No mobile information is shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent are not shared with any third parties. Details are in our Privacy Policy.

12. Records and training

We keep records of consent and opt-out requests, including the date, time and method, for as long as needed to show compliance. Everyone who builds or operates our communications systems is expected to follow this policy, and we review it as laws and carrier rules change.

13. Questions and complaints

If you received a call or message you did not expect, or you have any question about this policy, contact us and we will look into it promptly:

CYG Group Inc.
Attn: Bracha Grunfeld, Owner
3 Kerestier Ct Unit 404, Monroe, NY 10950
Phone: (718) 344-7468
Email: bracha@ivrhost.com