How we keep your calls defensible
Consent, scrubbing, recording and retention — what we do, and what we can hand you if anyone ever asks.
Customer-initiated contact is the whole design.
Nearly every serious compliance risk in this industry traces back to the same root cause: contacting someone who did not ask to be contacted. Our answer is structural rather than procedural — we do not build products where that can happen.
The consumer sees our ad or finds our page, reads a disclosure naming who will contact them, and takes a deliberate action to start the conversation. That is the only way a record enters our system. There is no purchased list, no scraped data, no aged file being re-worked.
One-to-one, named, unbundled and evidenced
Regulatory expectations have moved firmly toward consent that names a specific business rather than an open-ended list of "marketing partners". We built our flow around that standard.
Named party
The disclosure identifies the specific business the consumer is agreeing to hear from, not a category or an undisclosed partner list.
Affirmative action
Nothing is pre-ticked and nothing auto-advances. The consumer clicks, taps or checks deliberately.
Unbundled
Consent to be contacted is separate from the request for a quote. It is never a condition of receiving the information.
Certified session
TrustedForm or Jornaya captures the page as the consumer saw it, with a certificate ID retained against the record.
Timestamped & sourced
UTC timestamp, originating IP address, user agent, landing page URL and traffic source stored with every record.
Version archived
The exact disclosure wording in force at the moment of consent is archived, so we can reproduce what was shown, not just what is shown today.
Checks that run before anything routes
Every record passes through the following before it reaches a buyer. Any single failure stops it.
- Federal DNC registry — checked in real time
- State DNC registries — where separately maintained
- Internal do-not-contact list — anyone who has asked us to stop
- Known litigator and serial-complainant lists
- Phone validation — line type, carrier and reachability
- Duplicate detection across our delivery history
- Fraud signals — device, velocity and IP reputation
- Geographic verification — stated location against observed signals
What happens on the line
Recording practice varies by state, and we default to the stricter interpretation rather than the convenient one.
- Recording disclosure played before connection
- Two-party consent states handled to the stricter standard
- Named-party introduction on every warm transfer
- Calling hours enforced in the recipient's local time zone
- Vulnerable caller handling — screening agents end rather than transfer
- Recordings retained and available to you on request
- Opt-out honoured immediately and propagated across campaigns
Where the requirements get stricter
Medicare
CMS marketing requirements govern disclosure wording, recording, retention and what constitutes a valid permission to contact. Our creative and IVR language are built against current guidance, including the required statement that we are not connected with or endorsed by any government agency.
Medicare detailsACA marketplace
Our disclosures state plainly that we are not HealthCare.gov, not a state exchange, and not a government body. Subsidy language is kept factual and conditional — we do not advertise guaranteed amounts or promise eligibility.
ACA detailsFinal expense & seniors
Senior-directed marketing gets the closest scrutiny for good reason. Calling windows are narrowed, screening agents are trained to recognise confusion or distress and to end the call rather than transfer, and dropped calls are never billed.
Final expense detailsSMS & email
Text campaigns run on documented opt-in only, with STOP and HELP handled instantly and suppression propagated across every campaign we run. Email follows CAN-SPAM with functioning unsubscribe and accurate sender identification.
The weakest link is usually someone else's traffic
Where we work with third-party publishers, they are the highest-risk part of the chain — and historically the source of most industry complaints. Our affiliate programme is closed rather than open, and participation depends on ongoing review rather than a one-time approval.
- Manual vetting before any traffic is accepted
- Every landing page and creative approved in advance
- Consent language mandated, not left to the publisher
- Certificate capture required on all submissions
- Ongoing monitoring of source-level complaint and return rates
- Immediate suspension on any consent irregularity
Compliance questions buyers raise
Send us your compliance questionnaire
If your carrier or your counsel requires a vendor assessment before you can buy, send it over. We complete these regularly and will tell you plainly where we do not meet a requirement rather than answering around it.
Compliance & due diligence enquiry
Tell us what documentation you need. We respond the same business day.