Effective Date: September 15, 2026
This Policy is incorporated by reference into the Telure Seller Agreement and the Telure Client Agreement. Every Seller must follow it on every call. Every Client must design Listings consistent with it.
Outbound sales calling is regulated by federal law, by the law of every state a call touches, and in some cases by the law of the state a caller sits in. The rules below are the operating standard for the Platform. Where the law that applies to a particular call is stricter than this Policy, the stricter rule governs.
1. Scope
1.1 This Policy applies to every telephone call, video meeting, voicemail, and message placed or sent in connection with Sales Services, whether placed through the Platform calling tools or by any other means permitted by a Listing.
1.2 This Policy applies to Sellers, to any person a Seller permits to act under their account, and to Clients in their design of Listings and their provision of Client Materials.
1.3 This Policy states minimum requirements. It does not describe every obligation that may apply to a Seller's or a Client's own business.
2. Business-to-Business Calling Only
2.1 Listings on the Platform are limited to business-to-business Sales Services. Sales Services may be performed only to induce a business to purchase, or to schedule a meeting concerning the purchase of, goods or services for business use.
2.2 A Seller may not knowingly place a Sales Services call to a residential telephone line or to a personal wireless number.
2.3 If a Seller learns during a call that the number reached is a personal, residential, or wireless number, the Seller must end the call, mark the number in the Platform, and not call it again under any Listing.
2.4 The federal business-to-business exemption from the Telemarketing Sales Rule does not extend to calls that induce the retail sale of nondurable office or cleaning supplies. Listings offering those goods are not permitted.
2.5 Business-to-business status is a defense that the caller must be able to prove. Sellers and Clients must treat every number as potentially protected and must follow the do-not-call requirements in Section 5 regardless of whether an exemption is believed to apply.
3. Required Disclosures
3.1 Promptly after the called party answers, and before any sales presentation, the Seller must disclose:
(a) the Seller's name;
(b) the name of the Client on whose behalf the call is placed, as the seller of the goods or services;
(c) that the purpose of the call is to sell, or to schedule a meeting concerning, goods or services; and
(d) the nature of those goods or services.
3.2 The recording disclosure required by the Telure Call Recording Consent and Disclosure must be delivered at the beginning of the call, before any substantive discussion.
3.3 If the Seller transfers the call, or the subject of the call changes to different goods or services, the disclosures in Section 3.1 must be made again for the new subject.
3.4 A Seller may not begin a call with a survey, a research pretext, a "quick question," a claimed prior relationship that does not exist, a claimed referral that did not occur, or any other framing that obscures the sales purpose.
4. Calling Hours
4.1 Sales Services calls may be placed only between 8:00 a.m. and 9:00 p.m. in the called party's local time.
4.2 The called party's local time is determined by the time zone of the number's area code unless the Seller has better information about the Prospect's actual location, in which case the Seller must use that information.
4.3 Several states impose narrower calling windows, restrict calling on Sundays or holidays, or limit the number of calls to the same number in a period. Where a Listing covers a state with a narrower window, the Listing must state that window and the Seller must observe it.
4.4 Where a Prospect asks to be called at a specific time, the Seller may call at that time if it falls within the permitted window.
5. Do Not Call
5.1 Stop requests. If a Prospect asks not to be called again, asks to be removed from a list, or expresses that they do not wish to receive further calls, the Seller must: (a) end the sales presentation immediately; (b) confirm the request; (c) record the request in the Platform before the end of the Seller's session; and (d) never call that number again under any Listing.
5.2 A stop request applies to every number associated with the Prospect record and is permanent. It is not limited to the Listing on which it was received.
5.3 Internal suppression. Telure maintains an internal suppression list built from stop requests, complaints, wrong-number reports, and Client-supplied suppression data. Numbers on that list are blocked from dialing through the Platform calling tools. A Seller may not attempt to circumvent a block.
5.4 Registry scrubbing. Each Client is responsible for screening the Prospect records it supplies against the National Do Not Call Registry and any applicable state do-not-call list, for maintaining its own entity-specific do-not-call records, and for re-screening any list in use for more than thirty (30) days at least every thirty-one (31) days.
5.5 Telure may independently screen Prospect records before making them available for dialing and may remove records at its discretion. Telure's screening does not relieve a Client of its obligation under Section 5.4.
5.6 A Seller must not call a number the Seller knows or has reason to believe is on a do-not-call list, even if it appears in a Listing's Prospect records.
6. Prohibited Dialing Methods
6.1 Every Sales Services call must be placed by a natural person manually dialing or manually initiating a single telephone number.
6.2 The following are prohibited on the Platform and under every Listing:
(a) an automatic telephone dialing system, a predictive dialer, a power dialer, or any system that dials without a human initiating each individual call;
(b) an artificial or prerecorded voice message of any kind, whether delivered on answer or left as a message;
(c) an artificial intelligence voice agent, voice clone, synthetic voice, or conversational voice bot, whether autonomous or assisting a human;
(d) soundboard or avatar technology in which recorded audio clips are played to simulate a live conversation;
(e) ringless voicemail or any technology that deposits a message without placing a call;
(f) call spoofing, caller identification alteration, neighbor spoofing, or the display of any number the Seller is not authorized to use; and
(g) any tool that circumvents the Platform's call logging, recording, or suppression functions.
6.3 Telephone numbers used for Sales Services must be assigned to or authorized for the Seller or provided by Telure, must accurately identify the caller, and must be capable of receiving return calls.
7. Voicemail and Messaging
7.1 A Seller may leave a live-spoken voicemail only if the Listing permits it. The voicemail must state the Seller's name, the Client's name, the purpose of the call, and a telephone number the Prospect can call to stop future calls.
7.2 A Seller may not leave a prerecorded or artificial voice message under any circumstance.
7.3 A Seller may not send a text message, SMS, or MMS in connection with Sales Services unless the Listing expressly permits it and the Client has represented that it holds the consent required by applicable law for that number. Absent both, text messaging is prohibited.
7.4 Email sent in connection with Sales Services must comply with the CAN-SPAM Act, including accurate header and subject information, identification of the message as an advertisement, a valid physical postal address, and a functioning opt-out mechanism honored within ten (10) business days.
7.5 A Seller may not contact a Prospect through a personal channel, including a personal mobile number, personal social media account, or home address, absent the Prospect's request.
8. Truthfulness
8.1 A Seller may not make, and a Client may not instruct, encourage, incentivize, or design a Listing that causes a Seller to make, any false or misleading statement, including about:
(a) the cost, quantity, quality, performance, or characteristics of the goods or services;
(b) any material restriction, limitation, or condition;
(c) any material aspect of a refund, cancellation, exchange, or repurchase policy;
(d) any material aspect of a guarantee or warranty;
(e) an affiliation with, endorsement by, or approval from any person or government agency;
(f) the identity of the seller or the purpose of the call;
(g) the Prospect's obligation to pay, to attend, or to act; or
(h) urgency, scarcity, or a deadline that does not exist.
8.2 The misrepresentation prohibitions in 16 C.F.R. § 310.3(a)(2) and § 310.3(a)(4) apply to business-to-business calls. A call being business-to-business is not a defense to a deceptive statement.
8.3 A Seller may use only claims about a Client's goods or services that the Client has supplied or approved, and may not improvise a claim. If a Prospect asks a question the Seller cannot answer accurately, the Seller must say so and offer to follow up.
8.4 A Seller may not state or imply that Telure sells, endorses, guarantees, or stands behind a Client's goods or services.
9. Prospect Information
9.1 A Seller may use Client lead data only to perform the Listing for which it was provided, and may not export, copy, retain, resell, or reuse it.
9.2 A Seller may not request or record a Prospect's Social Security number, payment card number, bank account number, government identification number, date of birth, or health information.
9.3 A Seller may not accept payment from a Prospect or process any transaction.
9.4 A Seller must report to Telure any suspected data exposure, misdirected communication, or request by a Prospect to access or delete their information.
10. Recording
10.1 All Sales Services calls placed or received through the Platform calling tools are recorded.
10.2 The Telure Call Recording Consent and Disclosure governs the disclosure a Seller must deliver, what to do if a Prospect objects, and how recordings are retained and accessed. It is incorporated into this Policy.
10.3 A Seller may not record a call by any means other than the Platform calling tools, and may not disable, pause, or circumvent recording except through a function the Platform provides for that purpose.
11. Recordkeeping
11.1 Telure retains, for the periods stated in the Telure Privacy Policy and in no event less than five (5) years where 16 C.F.R. § 310.5 applies: call detail records including the calling number, the called number, the date, the time, the duration, and the disposition; call recordings and transcripts; stop requests and suppression entries; Listing versions and Conversion definitions; Seller identity and eligibility records; and Client suppression and scrubbing certifications.
11.2 Each Client must retain the records applicable to it under 16 C.F.R. § 310.5 and other applicable law, including consent records and substantiation for claims made about its goods or services. A Client may not rely on Telure's retention to satisfy its own obligation.
11.3 A Seller must not delete, alter, or obscure any Platform record.
12. State Requirements
12.1 A number of states impose obligations stricter than federal law on outbound sales calls, including narrower calling windows, state do-not-call registries, mandatory registration or bonding of telephonic sellers, specific disclosure scripts, restrictions on call frequency, and private rights of action. States with notable telemarketing statutes include Florida, Oklahoma, Washington, Maryland, Michigan, and New Jersey, and the list changes each legislative session.
12.2 Each Client is responsible for determining whether its calling program requires registration, bonding, or licensing in any state, and for obtaining it. A Listing may not go live in a state where the Client has not satisfied that requirement.
12.3 Telure may restrict Listings by state. Where Telure restricts a state, a Seller may not call Prospects in that state under any Listing.
12.4 A Seller is responsible for any requirement that applies to the Seller by reason of the Seller's own location.
13. Reporting and Escalation
13.1 A Seller must report to Telure promptly: any complaint by a Prospect about the call, the Client, or the Platform; any statement by a Prospect that they are represented by counsel or intend to take legal action; any contact from a regulator or attorney general; any demand letter; and any call that the Seller believes may have violated this Policy, including the Seller's own.
13.2 A Seller who reports their own good-faith mistake promptly and accurately will have that fact weighed in their favor in any compliance review.
13.3 A Client must report to Telure promptly any regulatory inquiry, complaint, demand, or litigation concerning calls placed through the Platform.
13.4 Reports go to compliance@telu.re.
14. Enforcement
14.1 Telure monitors calls placed through the Platform, including by automated review of recordings and transcripts and by human review, for compliance with this Policy.
14.2 A violation of this Policy may result in a compliance finding, the withholding or reversal of a Conversion Payout for a Conversion obtained through the violating call, suspension, or Deactivation, as described in the Telure Seller Code of Conduct, Rating and Deactivation Policy.
14.3 The following are grounds for immediate Deactivation without prior warning: calling a number after a stop request; using an artificial or prerecorded voice, an AI voice agent, or an autodialer; recording without delivering the required disclosure; spoofing caller identification; misrepresenting identity or purpose; and fabricating a call or a Conversion.
14.4 A violation of this Policy by a Client, including supplying unlawfully obtained lead data or designing a Listing that requires prohibited conduct, is grounds for immediate suspension of the Client's Listings and termination of the Telure Client Agreement.
15. Changes
15.1 Telure may amend this Policy. Telure will give notice of a material change at least fourteen (14) days before it takes effect, except that a change required to comply with a new legal requirement may take effect immediately on notice.
15.2 The version of this Policy in effect at the time of a call governs that call.