Terms & Policies
Acceptable Use Policy
Updated:
This Acceptable Use Policy (the “AUP”) governs Customer’s and its authorized users’ access to and use of the Commons platform and related messaging and calling services (the “Services”). This AUP is incorporated into and forms part of the Software as a Service Agreement between Customer and Robin Voice, Inc. d/b/a Commons (“Company”). Capitalized terms not defined herein have the meanings set forth in the applicable Software as a Service Agreement. Customer is responsible for all acts and omissions of its authorized users and for all messaging and calling activity conducted through the Services.
1. Lawful Use
Customer may use the Services only in compliance with all applicable federal, state, and local laws and regulations, including:
The Telephone Consumer Protection Act (TCPA)
The CAN-SPAM Act, where applicable
Federal Communications Commission (FCC) rules and regulations
Applicable state telemarketing and consumer protection laws
Campaign finance and political disclosure laws
CTIA Messaging Principles and Best Practices
All applicable carrier guidelines and 10DLC registration requirements
Customer is solely responsible for determining the legality of its messages and its use of the Services.
2. Consent Requirements
Customer represents and warrants that:
Before sending a communication through the Services, it has obtained any legally required prior express consent or prior express written consent, or otherwise has a legally sufficient basis to send the communication without such consent.
It maintains records sufficient to substantiate any required consent or other basis on which it relies.
It honors all opt-out and unsubscribe requests promptly and in compliance with applicable law.
It does not send messages to any recipient who has revoked consent, except for a legally permitted neutral confirmation message or through an approved re-subscription process supported by legally sufficient consent.
Customer must treat any clear request by a recipient not to receive further messages, calls, robocalls, robotexts, or similar communications as a revocation or opt-out request to the extent required by applicable law. Customer may not designate an exclusive method for revocation where applicable law requires recognition of other reasonable methods. Company may process opt-outs, suppression events, carrier notices, complaints, or other revocation signals through the Services, but Customer remains solely responsible for determining and honoring its legal obligations across all communication channels.
Company does not verify consent or any other basis asserted by Customer and assumes no responsibility for Customer’s compliance with applicable requirements. These obligations apply to all communications sent through the Services, including communications initiated individually, in batches, on a schedule, or through automated or AI-assisted features. The availability, configuration, or name of a delivery mode does not determine whether consent is required or establish compliance with applicable law, carrier, registry, platform, or vendor requirements.
3. Prohibited Messaging Conduct
Customer shall not use the Services to:
Send messages using purchased, rented, scraped, or harvested contact information unless the information was lawfully obtained and may be lawfully used for the intended messaging purpose.
Send unsolicited commercial messages where consent is required.
Impersonate any person or entity or misrepresent sender identity.
Transmit unlawful, fraudulent, misleading, defamatory, threatening, abusive, harassing, obscene, or otherwise objectionable content.
Promote violence, discrimination, or illegal activity.
Engage in phishing, social engineering, or deceptive practices.
Circumvent carrier filtering systems or evade compliance safeguards.
Transmit malware, malicious code, or harmful content.
Send repetitive or high-volume messages likely to generate excessive complaints or carrier filtering.
Infringe upon any intellectual property, privacy, or publicity rights.
Use any account, sender identity, phone number, messaging campaign, or messaging workflow designated for Official Government Communications to conduct Campaign Activity, or otherwise disguise, commingle, or misclassify Campaign Activity as Official Government Communications.
4. Sensitive Data and Minors
Customer shall not use the Services to intentionally collect, transmit, store, or process:
Social Security numbers
Financial account numbers
Health information subject to HIPAA
Biometric identifiers
Government-issued identification numbers
Any other highly sensitive personal information
Customer acknowledges that such information may be provided by end users in unsolicited inbound communications. Customer remains responsible for determining whether and how to respond to or process such information in compliance with applicable law.
Customer shall not knowingly send messages to individuals under thirteen (13) years of age.
If Customer intends to use the Services in connection with regulated data categories, Customer must obtain Company’s prior written approval.
5. Political Disclosure Compliance
Customer is solely responsible for ensuring that all required political disclaimers, attribution statements, sponsorship notices, fundraising disclosures, caller-identification notices, artificial, prerecorded, or AI-generated voice disclosures, and campaign-finance disclosures are included where required by applicable federal, state, local, platform, carrier, or vendor rules. Company may provide fields, classifications, or workflow support that format or append customer-supplied disclosure information. Customer remains responsible for accurately classifying the sender and communication, providing complete and current information, reviewing any resulting disclosure for the applicable message and jurisdiction, and determining whether any additional disclosure is required. Company does not review or approve message content, call scripts, voice content, or disclosure language for legal sufficiency.
6. Artificial, Prerecorded, or AI-Generated Voice
Customer shall not use the Services to initiate or transmit calls or messages containing artificial, prerecorded, synthetic, cloned, or AI-generated voice content unless Customer has obtained any legally required consent, made all required disclosures, and satisfied all other legal requirements applicable to the communication. Customer is solely responsible for determining whether any message, media, voice, call, agent, script, response, or workflow requires prior express consent, prior express written consent, artificial-voice disclosure, caller identification, political disclaimer, call-recording notice, or other legal or regulatory compliance.
7. Platform Integrity
Customer shall not:
Reverse engineer, decompile, or attempt to derive source code from the Services.
Attempt unauthorized access to systems or networks.
Interfere with or disrupt the Services or related infrastructure.
Conduct denial-of-service activity.
Bypass usage limits, throughput controls, or technical safeguards.
8. Carrier and Complaint Compliance
Customer acknowledges that messaging carriers may suspend, filter, or block traffic at their discretion.
Company may suspend, restrict, or terminate access to the Services if:
Customer’s messaging generates excessive complaints, opt-outs, or spam reports;
Carrier guidelines are violated;
Company reasonably believes continued messaging poses legal, regulatory, or carrier risk.
Company may take such action based on complaint rates, opt-out rates, carrier feedback, or other indicators of potential legal, regulatory, or reputational risk. Such determinations are made in Company’s reasonable discretion and may not be based on fixed thresholds.
Customer agrees to cooperate promptly with any compliance inquiry from Company or messaging carriers.
9. Data Source Representation
Customer represents and warrants that all contact information uploaded to or used with the Services was lawfully obtained and may be lawfully used for the intended messaging purpose.
10. Enforcement
Company may, in its sole discretion and without liability:
Suspend or terminate access to the Services;
Block or remove messages;
Limit throughput;
Require additional documentation regarding consent or compliance;
Report unlawful conduct to carriers or appropriate authorities.
Suspension may occur immediately if Company reasonably believes Customer’s use exposes Company to legal, regulatory, reputational, or carrier risk.
11. Changes to this Acceptable Use Policy
Company may update this AUP from time to time. Updated versions will be posted at https://usecommons.com/legal/aup. Continued use of the Services after changes constitutes acceptance of the revised AUP.