Airgap Networks Inc. Do Not Call (DNC) Policy
Last updated October 25, 2023
1. Policy Statement
Airgap, Inc. (“Airgap”) is committed to compliance with all federal and state laws pertaining to unsolicited telephone marketing calls. This includes the Telemarketing Sales Rule (TSR) and the Telephone Consumer Protection Act (TCPA), as well as applicable state laws and regulations. This policy outlines our procedures and practices regarding DNC compliance and our outbound calling activities.
2. DNC List Maintenance
2.1 Airgap maintains a company-specific Do Not Call list. Any individual may request, at any time, that their telephone number be placed on this list.
2.2 Every telemarketing representative is responsible for capturing and recording the request of an individual not to receive future calls.
2.3 Telephone numbers added to our company DNC list will remain on the list for at least five years.
3. Scrubbing Against National and State DNC Lists
3.1 Before initiating any outbound telemarketing campaign, Airgap scrubs its calling list against the National Do Not Call Registry and, when applicable, state-specific DNC lists.
3.2 Airgap updates and scrubs its calling lists against the National and relevant state DNC list regularly as per the regulation standards.
While most calls are subject to DNC regulations, there are certain exceptions:
Calls made with the express written permission of the individual.
Calls made in response to an individual’s request or inquiry.
Calls made to individuals with whom Airgap has an established business relationship. However, this exception does not apply if the individual has requested to be on the company’s DNC list.
5. Training and Compliance
5.1 All Airgap employees and representatives involved in telemarketing are trained regarding the DNC regulations and our company’s policies and procedures.
5.2 Training is provided upon employment commencement and is refreshed routinely.
5.3 Violations of this policy will result in disciplinary actions, up to and including termination.
6. Outbound Calling Practices
6.1 Purpose: Our outbound calls are mainly for marketing, customer service, or product updates. We always strive to provide value and relevant information to our call recipients.
6.2 Training: All Airgap representatives are trained on DNC regulations and our internal policies. They are instructed to always respect the wishes of call recipients and to immediately update our records when someone expresses a desire not to be called again.
6.3 Call Hours: We respect the recommended calling hours set forth by federal and state guidelines. Typically, our calls are placed between 9:00 AM and 9:00 PM local time of the call recipient.
7. CRM and Data Management
7.1 Information on Leads: Within our Customer Relationship Management (CRM) system, we store relevant details about leads, such as:
Contact information (name, phone number, email, etc.)
Interaction history (previous calls, emails, purchases, etc.)
Preferences or areas of interest
7.2 Outbound Call Records: Every outbound call made is logged in our CRM. Details include:
Date and time of the call
Duration of the call
Name of the representative who made the call
Call outcome (e.g., left voicemail, spoke with lead, etc.)
Any specific notes or follow-up actions required
8. Record Keeping
8.1 Airgap maintains records to demonstrate compliance with DNC regulations. This includes:
The company’s DNC list.
Information used to scrub against the National and state DNC lists.
Documentation of all training materials and training sessions.
8.2 Data Protection: Airgap adheres to strict data protection and privacy policies, ensuring the security and confidentiality of the information stored in our CRM. Only authorized personnel have access to this data.
9. Policy Availability
This DNC policy is available to any individual upon request. We also maintain a clear and conspicuous disclosure of this policy on our company’s website.