Do-Not-Call (DNC) Policy

Overview

PVN LLC ("the Company") conducts and supports outbound calling in compliance with the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, the FCC's implementing rules at 47 C.F.R. § 64.1200, the FTC's Telemarketing Sales Rule (TSR), 16 C.F.R. Part 310, and applicable state telemarketing laws. This policy applies to all outbound calls placed by the Company, its agents, and its representatives, on its own behalf or on behalf of any seller.

1. National Do-Not-Call Registry

The Company subscribes to the National Do-Not-Call Registry through its Subscription Account Number (SAN) for all area codes it dials.
All calling lists are scrubbed against the National DNC Registry no less frequently than every 31 days before dialing. No number appearing on the Registry is dialed unless a recognized exemption applies (prior express written consent or an established business relationship as defined by law).
Applicable state Do-Not-Call registries are scrubbed on the same cadence for all states dialed.

2. Internal Do-Not-Call List

Any consumer who requests not to be called is added to the Company's internal DNC list immediately, and in all cases within 24 hours of the request.
Internal DNC requests are honored regardless of any consent or business relationship, are entity-specific and campaign-wide, and are retained for a minimum of five (5) years.
The internal DNC list is applied as a suppression file on every campaign prior to dialing, without exception.

3. Additional Suppression

Calling lists are scrubbed against known TCPA litigator databases via a third-party suppression API prior to every dialing session.
Wireless numbers are identified and dialed only where the required level of consent exists for the dialing technology used.
Calls are placed only between 8:00 a.m. and 9:00 p.m. local time at the called party's location, or within narrower windows where state law requires.

4. Agent Training and Enforcement

All agents are trained on this policy before placing any calls and at least annually thereafter. Training records are maintained.
Agents must honor any do-not-call request on the call in which it is made, confirm it to the consumer, and record it in the dialer disposition immediately.
Violations of this policy by any agent or vendor result in corrective action up to and including termination of the relationship.

5. Recordkeeping

The Company retains DNC scrub logs, suppression files, SAN documentation, consent records, and internal DNC entries for a minimum of five (5) years.

This policy is reviewed at least annually and upon any material change in applicable law. A copy of this policy is available on request at (904) 512-8487.