What you may send down our trunks, and what ends the account.

01 Who this applies to

This Acceptable Use Policy (the “AUP”) applies to Everglades Communications LLC (“Everglades”, “we”, “us”) and to every customer that sends or receives traffic across our network (“you”). It is incorporated into the Terms of Service by reference and forms part of your agreement with us.

It applies equally to your own traffic and to traffic you carry for anybody else. If you resell our capacity, you are responsible for your customers’ conduct as if it were your own, you must impose terms on them at least as strict as this AUP, and you must be able to identify the originating party behind any call on request. “My customer sent it” is not a defense under this policy.

02 Your core obligation

You may use the service only for lawful communications that you are authorized to send, to parties who have agreed to receive them, identified by a number you have the right to use.

Everything below elaborates that sentence. Where this policy is silent on a specific practice, the sentence above still governs, and we will read it as written rather than hunt for a gap in the list.

03 Consent, and how we expect you to prove it

If your campaign requires the called party’s consent, you must hold that consent before the call is placed, and you must be able to produce it.

• Telemarketing or advertising calls placed with an automatic telephone dialing system or an artificial or prerecorded voice, to a wireless or a residential number, require prior express written consent meeting 47 C.F.R. § 64.1200(f)(9). Non-telemarketing calls placed with such equipment or voice to a wireless number require prior express consent. 47 U.S.C. § 227(b)(1)(A)(iii); 47 C.F.R. § 64.1200(a)(1)–(3).
• All telephone solicitations, however they are dialed, are subject to the do-not-call rules at 47 U.S.C. § 227(c) and 47 C.F.R. § 64.1200(c)–(d), and to the Telemarketing Sales Rule, 16 C.F.R. Part 310, where you or your client is a seller or telemarketer.
• Consent does not travel with a lead. We require consent naming you specifically as the calling or selling party. Consent obtained through a page, form or disclosure naming multiple sellers, “marketing partners”, or an unnamed category of businesses does not satisfy this AUP, whether or not it satisfies federal law. The FCC’s one-to-one consent rule was vacated in Insurance Marketing Coalition Ltd. v. FCC, 127 F.4th 1179 (11th Cir. 2025) and is not currently in force federally; several states, including Maryland (Md. Code, Com. Law § 14-3201 et seq.), impose a single-seller requirement by statute. Single-seller consent is our contractual standard in every state.
• Abandonment. Where the Telemarketing Sales Rule applies, you must observe 16 C.F.R. § 310.4(b)(1)(iv) — abandoning no more than three percent of answered calls, measured per campaign over 30 days, connecting a live representative within two seconds of the called party’s greeting, and playing the required identification message on an abandoned call. Predictive-dialer pacing that breaches this rule shows up directly in the telemetry in section 08.

Records of consent must identify the consenting party, the number, the date, the method of capture, and the exact disclosure shown or read at the moment of capture. Retain them for at least five years and produce them to us within two business days of a written request.

Suppression and do-not-call

• Scrub against the National Do Not Call Registry at intervals no longer than 31 days, and against applicable state registries.
• Maintain an internal do-not-call list, honor a revocation made through any reasonable means, and apply it across every campaign you run — not only the one that produced the request. Revocation of consent for one type of message is presumed to revoke consent for all robocalls and robotexts from you.
• Honor a revocation within a reasonable time not exceeding ten business days, and immediately where the request is made during a live call. 47 C.F.R. § 64.1200(a)(10).
• Observe calling-hour restrictions based on the called party’s actual location, which for a wireless or ported number may not match the time zone of the area code — no earlier than 8:00 and no later than 21:00 local time federally, and tighter where state law requires, including 8:00 to 20:00 in Florida and Oklahoma. These limits apply to all telephone solicitations regardless of consent.

Several states impose obligations stricter than federal law, including Florida, Oklahoma, Washington and Maryland. Compliance with the TCPA alone is not compliance with this AUP.

04 Traffic we prohibit outright

The following are prohibited regardless of consent, disclosure or your reading of the law. Any of them is grounds for immediate suspension without notice.

Fraud and impersonation

• Impersonating a government agency, court, law-enforcement body, tax authority or benefits administrator.
• Impersonating a bank, card issuer, payment processor, carrier, utility, retailer, delivery service or technology company, including their fraud-alert departments.
• Technical-support scams, refund and overpayment scams, invoice-redirection fraud, grandparent and family-emergency scams, and any pretext designed to move money or to obtain credentials, one-time passcodes or remote access to a device.
• Fraudulent charity, disaster-relief, debt-relief, credit-repair, warranty, insurance, immigration-service, lottery and prize solicitations.

Traffic-shape abuse

• Illegal robocalling, including any prerecorded or artificial-voice campaign lacking the consent that campaign requires.
• Wangiri and other one-ring schemes designed to provoke costly call-backs.
• International revenue share fraud, and any arrangement in which you or a counterparty benefits from artificially generated termination minutes.
• Access stimulation and traffic pumping, and any scheme designed to inflate intercarrier compensation.
• Autodialed blasting to sequential or randomly generated ranges, and wardialing of any kind.
• Snowshoeing — spreading a campaign thinly across many numbers, trunks, sub-accounts or entities to stay under monitoring thresholds — and rotating numbers to evade blocking or analytics labeling.

Content

• Threats, harassment, stalking, intimidation, or repeated calls placed to annoy or abuse the recipient.
• Content that is obscene as a matter of law, or that sexually exploits a minor.
• Marketing of controlled substances, unapproved pharmaceuticals or firearms in violation of applicable law.
• Debt collection traffic that violates the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq., or Regulation F, 12 C.F.R. Part 1006, where either applies to you or to the party on whose behalf you call — including exceeding the call-frequency presumptions in 12 C.F.R. § 1006.14(b)(2)(i) (more than seven calls within seven consecutive days about a particular debt, or a call within seven days of a telephone conversation about that debt), calling at a time or place known to be inconvenient, continuing after a cease-communication request, or communicating with a consumer you know to be represented by an attorney. If you or your client is a first-party creditor collecting its own debt, say so at onboarding; different rules apply and we will assess the traffic accordingly.
• Recording calls without the consent every applicable state requires. Several states, including California and Florida, require the consent of all parties. Contact centers record by default; it is your obligation to confirm the rule for each jurisdiction you dial.

We also prohibit any use that violates the Telemarketing Sales Rule, the Truth in Caller ID Act, the Computer Fraud and Abuse Act, or the sanctions and export-control programs administered by the U.S. Office of Foreign Assets Control.

05 Caller identification

Every call you originate must present a telephone number that:

• you have the right to use, either because we assigned it to you or because you can evidence authorization from the party to whom it is assigned;
• is a valid North American Numbering Plan number in a working, assigned range — not one that is unassigned, unallocated, invalid or reserved;
• can be dialed back, and reaches either you or the party on whose behalf the call is made; and
• does not belong to a government body, an emergency service, a hospital, or an unrelated business or individual.

Transmitting misleading or inaccurate caller identification with intent to defraud, cause harm or wrongfully obtain anything of value violates the Truth in Caller ID Act (47 U.S.C. § 227(e)) and ends your account. Neighbor spoofing — selecting a caller ID to match the called party’s prefix in order to lift answer rates — is prohibited on our network whether or not a regulator has yet characterized your particular implementation as unlawful.

06 STIR/SHAKEN and attestation

Where Everglades originates a call onto the PSTN as the originating voice service provider and holds a valid Service Provider Code token and STI certificate, the call is authenticated under the STIR/SHAKEN framework and 47 C.F.R. §§ 64.6300–64.6308. Where we do not originate the call, or where authentication is performed by an upstream or downstream provider, the attestation applied is that provider’s and we make no representation as to it. Our current caller-ID authentication status and Robocall Mitigation Database filing are available on request. The attestation a call receives reflects what can be verified about it:

Attestation is a statement about what we know, not a quality badge and not an endorsement of your campaign. You may not represent to any third party that Everglades has attested to the lawfulness of your traffic. Removing, altering, forging or replaying an Identity header, or presenting another party’s certificate, is a material breach of this AUP.

If you are a voice service provider, gateway provider or intermediate provider, you must have a current certification on file in the Robocall Mitigation Database before we will accept any traffic from you, and you must give us your filing details at onboarding and whenever we ask. Federal law prohibits us from accepting traffic directly from a provider that is not listed in that database, and requires us to block all traffic from a provider removed from it — 47 C.F.R. § 64.6305(f)–(g). We will suspend your service immediately, without notice and without liability, if your certification lapses or is removed. You must also maintain your own robocall mitigation program where the FCC requires one.

07 Numbers, DIDs and toll-free

Numbers assigned to you remain subject to numbering authority rules and to the reclamation provisions of the Terms of Service. You may not:

• acquire numbers in quantities disproportionate to your demonstrated use case, or warehouse numbers you do not intend to use;
• cycle numbers to escape analytics labeling, blocking or complaint attribution;
• use toll-free numbers in a way that circumvents Responsible Organization rules or applicable toll-free traffic policies; or
• transfer or resell numbers to a party that has not cleared our onboarding review.

08 The telemetry we watch

Our policy is to monitor traffic continuously and to act on patterns rather than only on complaints. The indicators below are the ones most likely to open a review. They are review triggers, not contractual thresholds, and they are read together rather than in isolation.

We may throttle capacity, reduce your calls-per-second, or hold traffic to specific destinations while a review is open. We will tell you when we do.

09 Traceback: a 24-hour obligation

We cooperate fully with the Industry Traceback Group, the Federal Communications Commission, the Federal Trade Commission, state attorneys general and law enforcement. A substantive response identifies the immediate upstream source of the call, the originating customer where you are that source, the campaign, and the consent record relied upon.

Failure to respond within 24 hours, or a pattern of responses that cannot be reconciled with our own call records, is independently grounds for suspension — separately from whatever the underlying traffic turns out to be.

10 Network abuse, security and fraud

You must not, and must not permit anyone else to:

• attempt to gain unauthorised access to our systems, other customers’ accounts, or any interconnected network;
• conduct SIP scanning, registration flooding, credential stuffing or brute-force attacks, whether against our infrastructure or from it;
• launch or participate in a denial-of-service attack, or generate traffic designed to degrade any network;
• circumvent, or attempt to circumvent, any authentication, rate limit, IP restriction, channel cap or fraud control we apply; or
• leave your own endpoints, PBX or credentials unsecured against toll fraud.

You are responsible for traffic originated with your credentials, including traffic resulting from a compromise of your systems. Tell us immediately if you suspect a compromise — we would far rather stop the bleeding with you than bill you for it.

11 How we enforce this policy

Our response is proportionate to what we find, and to what you do about it.

We may skip any of these steps and suspend immediately where traffic appears to be causing ongoing harm, where a regulator or upstream carrier requires it, or where the conduct falls under section 04. We are not obliged to give notice before doing so, and suspension does not relieve you of charges already incurred.

Where we terminate for cause, we may report the circumstances to upstream carriers, the Industry Traceback Group and relevant authorities, and may decline to serve related entities and principals.

12 Reporting abuse

If you believe traffic on our network violates this policy, write to abuse@evergladescomms.com. Where you can, include the calling and called numbers, the date and time with time zone, and a description of the call. Our commitment is to acknowledge reports within one business day.

If you received an unwanted call and want it stopped, that address reaches a person, not a queue. You do not need to be a customer to use it.

13 Changes to this policy

We may update this AUP as law, regulation and fraud practice change. Material changes take effect 30 days after we post them and notify account contacts. Where a change is required by law, by a regulator, or by an upstream carrier on shorter notice, it takes effect on the notice period that law, regulator or carrier requires, and never before we notify you. No change to this AUP applies retroactively to traffic sent before the change takes effect. If a material change adversely affects the traffic you were approved to send, you may terminate without penalty by written notice within 30 days of our notice. Continuing to send traffic after a change takes effect is acceptance of it.