Mobile Messaging Opt-In Policy

1. Who holds the consent

Vera Labs LLC provides VERA. Businesses use it to text their own customers and crews. The consent belongs to the business that collected it, and VERA processes it on that business's instructions.

VERA does not build, buy, share, or operate a messaging list of its own. One business's contacts are never visible to another, and a number that opted out of one business is not thereby opted out of another, because the two are separate records under separate accounts.

VERA does not send marketing text messages to its own account holders. Account, billing, and security notices to a VERA account holder are sent by email.

2. How consent is collected

There are three ways a number becomes textable, and all three end in the same consent record.

• The person gave the business their number. Someone requesting an estimate, booking an appointment, or hiring the business gives their mobile number for that job. The business records the consent in VERA and states where it came from, in its own words, such as a booking form, an estimate request, or a phone call. That source is stored and shown on the customer's record.
• The person texted first. Someone who texts the business's number has started the conversation themselves. Replying to a conversation a person opened is not a campaign.
• The person texted START. Someone who previously opted out and then texts START, UNSTOP, YES, OPTIN or OPT-IN is opted back in, and the record shows that is what happened.

3. What the person has to be told

Wherever a business collects a mobile number for texting, the person must be told what they are agreeing to before they agree. Consent is never bundled into an unrelated agreement, is never a condition of purchase, and is never pre-checked.

The disclosure a business is required to present, wherever it collects a number, states: the name of the business that will text them, what kinds 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, and a link to this policy and to the Privacy Policy.

A business collecting marketing consent must present it as a separate, unchecked choice from operational messages, and must say so in the disclosure.

4. What is recorded

Consent is stored against the phone number rather than against a customer record, because that is what the carrier rules are about and because a person can opt out before anyone has matched them to a contact.

• Status. Whether the number is opted in, opted out, or has no consent recorded yet. There is no fourth state, and an absent record is treated as unknown rather than as consent.
• Marketing status. Tracked separately, and separately again from consent to be called. Agreeing to appointment reminders is not agreeing to promotions, and neither is agreeing to be dialed.
• Source and date. Where the business says the consent came from, in plain words, and when it was captured. Shown verbatim on the customer's profile so there is always an answer to the question of why this person may be texted.
• Opt-out details. The date of an opt-out and the literal word the person used, so a withdrawal can be evidenced rather than asserted.

5. Operational messages and marketing are kept apart

Operational messages are the ones a customer is expecting because they hired the business: appointment reminders, arrival notices, estimates, invoices, and job updates. Promotional messages are offers, seasonal campaigns, and referral pushes.

The separation is enforced at the point of sending, not in the settings screen. The gate that every outbound message passes through refuses a promotional message to a number that has not explicitly opted in to marketing, and an unknown status is not consent. Nobody is enrolled into marketing automatically, and opting out clears marketing consent as well, so a person who texted STOP has not left a promotional door open.

6. How consent is withdrawn

Any of these words, sent to the business's number, ends the messaging: STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, QUIT, OPTOUT or OPT-OUT. Matching is case-insensitive and ignores surrounding punctuation, so "Stop." and " STOP " both work.

The opt-out is applied before anything else looks at the message, and without a person in the loop. It blocks automated messages and it also blocks a reply typed by hand by the business, because the rule is about the number rather than about who pressed send. The interface tells the sender why rather than letting the message fail at the carrier.

Exactly one message follows an opt-out: the confirmation that the opt-out worked. It is the only message in the system that is allowed past the consent gate, it carries no other content, and it is capped at one.

A word only counts as an opt-out when it is essentially the whole message. "STOP" ends the messaging; "stop by around 3 if you can" is a sentence about the schedule and does not, because silently unsubscribing a customer who was talking about their driveway is its own kind of failure.

A business must also honor an opt-out made any other way, such as by phone, by email, or in person, by recording it against the number in VERA.

7. HELP

Replying HELP or INFO produces an automatic reply that names the business, says what the number is used for, states that message and data rates may apply, and repeats how to opt out. It contains nothing else.

8. Mobile information is never shared for marketing

Mobile phone numbers and text messaging consent collected for these programs are never sold, rented, or shared with third parties or affiliates for their own marketing or promotional purposes. Phone numbers are shared only with the messaging carrier that delivers the message, and with service providers acting on our instructions, in order to send the message you asked for.

In practice that means one recipient: Twilio, which delivers the message and receives the sending and recipient numbers, the message text, and any picture attached, because it cannot deliver the message otherwise. It is listed with everything else on the Subprocessor List.

Text messaging opt-in data and consent records are excluded from any sharing with third parties for their own purposes. No mobile information is used for advertising, sold, or transferred to a data broker.

9. The messages themselves

Message content, including pictures sent to or from a business, is stored in the business's account so that the conversation is there when someone needs it. Picture messages are held in VERA's own database rather than on a public file host, and are served through a link that expires, so a media attachment is not left addressable on the open internet.

The business controls how long its records are kept and can delete a conversation. Deleting a VERA account deletes its messaging records. Consent and opt-out records may be retained after a conversation is deleted where that is needed to keep honoring the opt-out, which is the one case where holding the record protects the person rather than the business.

10. What is required of a business using VERA

These are conditions of using messaging in VERA, and a breach can suspend messaging for the account.

• Real consent only. Text only numbers given to you, for the purpose you are texting about. Purchased, rented, scraped, or inherited lists are prohibited outright.
• Truthful registration. The legal name, address, and contact details submitted for carrier registration must be those of the real business behind the number.
• Accurate consent sources. The source recorded against a number must describe how consent was actually obtained.
• Honor every withdrawal. Record opt-outs that arrive by any route, and never work around a blocked send by texting from a personal phone instead.
• Your own privacy notice. Keep your own privacy notice accurate about the texting you do, including this disclosure language, since your customers gave their number to you.

11. Questions and complaints

If you received a text and want it stopped, replying STOP is the fastest and most reliable route: it is applied automatically and does not depend on anyone reading an email. For anything else about a specific message, contact the business that sent it. To reach the platform, including to report a business you believe is texting without consent, write to support@myvera.io.

Vera Labs LLC, 8605 Santa Monica Blvd, PMB 241295, West Hollywood, California 90069-4109 US