Steadworth Telephone Consumer Protection Act (TCPA) Policy

Effective Date: Not Effective Currently

I. Introduction and Purpose

Steadworth, LLC ("Steadworth") is committed to complying with the Telephone Consumer Protection Act ("TCPA") and its implementing regulations. This Policy outlines Steadworth's procedures for contacting consumers via telephone and facsimile in a compliant manner.

II. Policy Statement

Steadworth will comply with all applicable provisions of the TCPA, including:

Obtaining prior express consent for telemarketing calls and text messages to cellular telephone numbers.
Obtaining prior express written consent for telemarketing calls using an automatic telephone dialing system (ATDS) or an artificial or prerecorded voice.
Complying with the National Do Not Call Registry and maintaining an internal do-not-call list.
Providing required disclosures in all telemarketing communications.
Honoring consumer requests to revoke consent or opt out of communications.

III. Scope

This Policy applies to all Steadworth employees and agents involved in contacting consumers via telephone and facsimile.

IV. Definitions

Telemarketing: The initiation of a telephone call or message for the purpose of encouraging the purchase or rental of, or investment in, property, goods, or services.
Automatic Telephone Dialing System (ATDS): Equipment that has the capacity to store or produce telephone numbers to be called, using a random or sequential number generator, and to dial such numbers.
Prior Express Consent: An agreement, either oral or written, from the consumer to receive telemarketing calls or text messages.
Prior Express Written Consent: A written agreement, bearing the signature of the consumer, that clearly authorizes the sender to deliver telemarketing calls or text messages using an ATDS or an artificial or prerecorded voice.

V. Telemarketing Calls and Text Messages

A. Calls to Cellular Telephone Numbers:

Steadworth will obtain prior express consent before making telemarketing calls to cellular telephone numbers.
Steadworth will obtain prior express written consent before making telemarketing calls to cellular telephone numbers using an ATDS or an artificial or prerecorded voice.

B. Text Messages:

Steadworth will obtain prior express consent before sending informational text messages to cellular telephone numbers.
Steadworth will obtain prior express written consent before sending telemarketing text messages to cellular telephone numbers.

VI. Do Not Call Lists

A. National Do Not Call Registry:

Steadworth will not initiate telemarketing calls to telephone numbers registered on the National Do Not Call Registry.

B. Internal Do Not Call List:

Steadworth will maintain an internal do-not-call list and honor consumer requests to be added to the list.

VII. Facsimile Advertisements

Steadworth will only send facsimile advertisements to recipients with whom it has an established business relationship.
All facsimile advertisements will include a compliant opt-out notice.

VIII. Responsibilities

A. Compliance Officer:

The Compliance Officer is responsible for overseeing and implementing this Policy.

B. All Employees:

All employees are responsible for complying with this Policy and reporting any potential violations to the Compliance Officer.

IX. Training

Steadworth will provide regular training to its employees on TCPA compliance.

X. Review and Revision

This Policy will be reviewed and revised periodically to ensure that it remains current and effective.

XI. Conclusion

Steadworth is committed to complying with the TCPA and protecting the privacy of consumers. This Policy is intended to ensure that all employees are aware of their obligations under the TCPA and that Steadworth conducts its telemarketing activities in a compliant manner.

XII. Contact

Any questions or concerns regarding this Policy should be directed to the Compliance Officer at: contact@steadworth.com

Please note: This Policy is intended to supplement, not replace, any other applicable Steadworth policies or procedures.