SMS/Text Messaging Policy

Effective Date: January 1, 2025Last

Updated: December 21, 2025

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This SMS/Text Messaging Policy (“SMS Policy”) governs, defines, and controls the manner in which Rivvia Sales, LLC (“Rivvia,” “Company,” “we,” “us,” or “our”) collects, records, verifies, stores, uses, and manages consumer and applicant consent for text message communications; the methods by which Short Message Service (“SMS”) and Multimedia Messaging Service (“MMS”) messages are transmitted; the categories and purposes of messages that may be sent; the timing, frequency, and delivery standards applicable to such messages; the procedures for revocation of consent and opt-out requests; the handling, retention, and protection of data associated with SMS communications; and the Company’s compliance with all applicable federal, state, and local laws, regulations, and industry standards, including but not limited to the Telephone Consumer Protection Act (TCPA), Federal Communications Commission (FCC) rules, and Application-to-Person (A2P) 10DLC carrier requirements.

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This SMS Policy applies to all text-based communications sent by or on behalf of Rivvia Sales, LLC, whether such messages are transmitted via manual processes, automated dialing or messaging systems, artificial or prerecorded technologies, Application-to-Person (“A2P”) messaging platforms, short codes, long codes, or toll-free numbers, and whether delivered directly by Rivvia or indirectly through authorized third-party service providers, vendors, or technology partners acting on Rivvia’s behalf. This Policy governs SMS communications sent to prospective applicants, independent contractors, active participants, former participants, or other individuals who have provided a mobile telephone number and valid consent, and applies regardless of the device, carrier, messaging platform, or transmission method used.

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1. Purpose of SMS Messaging

Rivvia Sales, LLC utilizes Short Message Service (“SMS”) and Multimedia Messaging Service (“MMS”) messaging as a supplemental, optional, and convenience-based communications channel to deliver timely, relevant, and informational communications related to its recruiting, independent contractor onboarding, training, and ongoing operational services. SMS messaging is intended to improve responsiveness, reduce delays, and provide clear next-step guidance, but it is not the sole method of communication and is not required in order to access Rivvia services, apply for opportunities, or participate in any Rivvia program.

SMS communications are used strictly for informational, transactional, and operational purposes connected to an individual’s interaction with Rivvia Sales, LLC. Messages are designed to be reasonable in frequency, relevant to the recipient, and aligned with the context in which consent was provided.

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1.1 Permitted SMS Use Cases

SMS messaging may be used for purposes including, but not limited to, the following:

• Confirming receipt of applications, inquiries, or submitted information

• Providing recruiting information, opportunity overviews, and next steps

• Communicating onboarding requirements, documentation requests, and status updates

• Delivering training reminders, orientation notices, and program updates

• Providing scheduling confirmations, reminders, and logistical notices

• Responding to support inquiries or information requests initiated by the recipient

• Sending operational or administrative notifications related to participation with Rivvia

SMS messages are not used to replace legally required disclosures, contractual agreements, or formal documentation, and are not intended to pressure, mislead, or coerce recipients.

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1.2 Use of AI-Assisted Messaging and Automation

SMS communications may be sent by human representatives and/or AI-assisted virtual agents operating on behalf of Rivvia Sales, LLC. AI-assisted messaging may include the use of automated systems, virtual assistants, or artificial intelligence technologies to generate, route, or respond to SMS communications in an efficient and scalable manner.

Any AI-assisted or automated SMS communications are deployed and managed in a manner designed to comply with all applicable laws, regulations, and industry standards, including but not limited to the Telephone Consumer Protection Act (TCPA), Federal Communications Commission (FCC) rules, and A2P 10DLC carrier requirements. AI systems are used to support administrative, informational, and operational messaging functions and are not used to engage in deceptive practices or prohibited content categories.

Where AI-assisted systems are used:

• Messages are sent only to recipients who have provided valid consent or where otherwise permitted by law

• The sender identity is clearly disclosed as Rivvia Sales, LLC

• Opt-out and help instructions are consistently provided

• Messaging content remains within the scope of the stated program purpose

 

1.3 Human Oversight and Escalation

Rivvia maintains human oversight over its SMS and AI-assisted messaging systems. AI-generated or automated communications are subject to monitoring, quality controls, and operational safeguards designed to ensure accuracy, appropriateness, and compliance.

Where appropriate or required, SMS interactions may be reviewed, escalated, or handled by a human representative. AI-assisted messaging does not eliminate access to human support and is intended to complement, not replace, human involvement.

 

1.4 Voluntary Participation and Alternatives

Participation in SMS messaging is voluntary. Individuals are not required to consent to SMS communications as a condition of purchase, application, employment, or participation in Rivvia programs. Alternative communication methods, including email, web-based portals, or direct contact, remain available.

Recipients may opt out of SMS messaging at any time using the opt-out procedures described in this Policy. Opt-out requests are honored promptly and without penalty.

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1.5 Limitations and Boundaries

SMS messaging is used solely within the scope described in this Policy. Rivvia does not use SMS messaging for purposes unrelated to its business operations, does not engage in message blasting without context, and does not use SMS as a substitute for formal agreements, legal notices, or mandatory disclosures.

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2. Program Identification & Transparency

All SMS communications clearly identify the sender.

Program Name: Rivvia Sales Recruiting
Sender Identification May Include:

• Rivvia Sales

• Rivvia Sales Recruiting

• Rivvia

No messages are sent under misleading, masked, or deceptive sender identities.

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2. Program Identification & Transparency

All SMS and MMS communications sent by or on behalf of Rivvia Sales, LLC are transmitted in a manner designed to ensure clear identification, transparency, accountability, and recipient trust. Rivvia maintains strict controls to prevent confusion, deception, or misrepresentation regarding the origin, purpose, or sender of any text-based communication.

SMS messaging is conducted in accordance with applicable federal and state laws, A2P 10DLC carrier policies, and industry best practices for sender identification and transparency.

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2.1 Program Name and Purpose Alignment

All SMS communications are delivered under the following registered program name:

Rivvia Sales Recruiting

This program name accurately reflects the purpose of the messaging program and is used consistently across:

• Opt-in disclosures

• Website policies and notices

• Messaging content

• Carrier registrations and campaign submissions

• Third-party messaging platform configurations

Messages are sent only within the scope of this program and are not repurposed for unrelated communications.

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2.2 Sender Identification Standards

Each SMS message clearly identifies Rivvia Sales, LLC as the sender. Sender identification may include one or more of the following approved identifiers:

• Rivvia Sales

• Rivvia Sales Recruiting

• Rivvia

These identifiers are selected to ensure immediate recognition by recipients and alignment with the context in which consent was provided. Sender names are not abbreviated, altered, or substituted in a manner that could reasonably mislead recipients.

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2.3 Message-Level Transparency Requirements

Rivvia enforces message-level transparency by requiring that SMS communications:

• Clearly identify Rivvia as the sender within the message body

• Use consistent branding and terminology

• State or imply a clear and legitimate purpose related to recruiting or operational support

• Avoid ambiguous phrasing or misleading subject matter

• Align with the content described at the time of opt-in

Messages are not structured to disguise intent, induce confusion, or appear to originate from a different entity.

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2.4 Use of AI-Assisted Messaging and Automation Disclosure

SMS messages may be generated, routed, or responded to by AI-assisted virtual agents or automated messaging systems operating on behalf of Rivvia Sales, LLC. The use of such systems is disclosed in Rivvia’s policies and consent language and is limited to informational, administrative, and operational messaging purposes.

AI-assisted messaging:

• Is deployed in compliance with TCPA, FCC, and A2P 10DLC requirements

• Does not alter or obscure sender identity

• Does not simulate third-party or human identities in a deceptive manner

• Includes appropriate opt-out and help instructions

• Is subject to monitoring, controls, and human oversight

Recipients are not misled as to the source or nature of AI-assisted communications.

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2.5 Prohibition on Masking, Spoofing, or Deceptive Practices

Rivvia strictly prohibits:

• Masking or falsifying sender identities

• Spoofing phone numbers or sender IDs

• Using third-party brands, aliases, or names not clearly affiliated with Rivvia

• Any technical or procedural method intended to conceal the true origin of a message

All messages are sent using carrier-approved long codes, toll-free numbers, or other registered A2P messaging routes associated with Rivvia Sales, LLC and its approved campaigns.

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2.6 Number Management and Registration Controls

Rivvia maintains internal controls governing the provisioning, registration, and use of all messaging numbers, including:

• Registration of numbers with applicable carriers and platforms

• Assignment of numbers to specific approved campaigns

• Monitoring for misuse, anomalies, or unauthorized activity

• Immediate suspension or remediation of numbers that present compliance risk

Numbers are not reused, repurposed, or shared across unrelated programs.

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2.7 Third-Party Messaging Providers and Oversight

Rivvia may engage authorized third-party messaging platforms or service providers to transmit SMS messages. Such providers act solely as processors or delivery agents and are contractually required to:

• Adhere to Rivvia’s identification and transparency standards

• Comply with TCPA, FCC, and carrier policies

• Maintain appropriate data security controls

• Cooperate with audits, investigations, or compliance reviews

Use of third-party providers does not diminish Rivvia’s responsibility for compliance.

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2.8 Consistency Across Channels and Touchpoints

Rivvia ensures consistency in sender identification across:

• SMS messages

• Email communications

• Website disclosures

• Application forms and opt-in language

• Customer support interactions

This consistency is intended to reduce confusion, increase trust, and support informed participation.

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2.9 Consumer Recognition, Trust, and Accountability

Rivvia’s program identification and transparency practices are designed to allow recipients to:

• Easily recognize Rivvia as the sender

• Understand why they are receiving messages

• Exercise opt-out rights without confusion

• Contact Rivvia for assistance or clarification

Transparency is treated as a core compliance and consumer-protection principle.

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2.10 Audit Readiness and Compliance Monitoring

Rivvia maintains procedures to support audits and compliance reviews related to sender identification and transparency, including:

• Documentation of program names and sender identifiers

• Records of carrier registrations and approvals

• Monitoring of message content and delivery practices

• Internal reviews of AI-assisted and automated messaging

These measures are intended to ensure ongoing compliance and rapid remediation of any identified issues.

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3. Eligibility & Authorized Participation

Participation in Rivvia Sales, LLC’s SMS and MMS messaging program is strictly limited to individuals who meet all eligibility and authorization requirements set forth in this Policy. Rivvia maintains eligibility controls to ensure that SMS communications are directed only to appropriate recipients who have the legal authority and capacity to consent to receive text messages.

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3.1 Minimum Age Requirement

Participation in Rivvia’s SMS program is limited to individuals who are eighteen (18) years of age or older. By providing a mobile telephone number and consenting to receive SMS communications, the individual represents and warrants that they have reached the age of majority in their jurisdiction and are legally permitted to engage in communications related to recruiting, independent contractor opportunities, and business services.

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Rivvia does not knowingly initiate SMS communications with minors and maintains procedures designed to prevent messaging individuals under the age of eighteen.

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3.2 Authorized Subscriber or Customary User Requirement

SMS messages are sent only to mobile numbers provided by individuals who represent that they are either:

• The authorized subscriber of the mobile telephone number; or

• The customary user of the mobile telephone number with authority to consent to receive SMS messages at that number

Individuals must have control over and regular access to the mobile device associated with the number submitted. Rivvia does not knowingly send SMS messages to numbers where the recipient lacks authority, such as numbers belonging to third parties, family members, employers, or shared devices, unless lawful consent has been obtained from the authorized user.

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3.3 Legal Capacity to Provide Consent

Participation in Rivvia’s SMS program requires that the individual possess the legal capacity to provide valid consent under applicable law. By opting in, the individual represents that they:

• Are legally capable of entering into communications and providing consent

• Are not restricted or prohibited from doing so by law

• Are not acting on behalf of another individual without authorization

Rivvia does not accept consent from individuals who lack legal capacity, including those subject to guardianship or similar legal limitations, unless valid authorization is provided.

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3.4 Representations and Warranties by Participants

By opting in to receive SMS communications, participants represent and warrant that:

• The mobile number provided is accurate and current

• They have authority to consent to SMS communications at that number

• They will promptly update Rivvia if the number changes or is reassigned

• They understand SMS participation is voluntary and may be revoked at any time

Providing false, misleading, or unauthorized information may result in suspension or termination of SMS communications.

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3.5 Reassigned Numbers and Number Validation

Rivvia employs commercially reasonable measures to reduce the risk of messaging reassigned or incorrect numbers, including internal controls, opt-out mechanisms, and monitoring for delivery errors or complaints.

If Rivvia becomes aware that a number has been reassigned or that consent is no longer valid, SMS communications to that number will be discontinued promptly.

3.6 AI-Assisted Messaging Safeguards Related to Eligibility

Where AI-assisted or automated messaging systems are used, such systems are configured to respect eligibility and authorization requirements, including:

• Sending messages only to numbers with documented consent

• Honoring age and authority representations provided at opt-in

• Enforcing opt-out and suppression lists

• Preventing continued messaging where consent is withdrawn or invalid

AI-assisted messaging does not override eligibility restrictions or consent controls.

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3.7 No Knowing Messaging to Unauthorized Recipients

Rivvia Sales, LLC does not knowingly send SMS messages to:

• Minors

• Individuals who lack authority over the mobile number provided

• Numbers obtained without valid consent

• Numbers on internal do-not-text or suppression lists

If Rivvia receives notice or has reason to believe that a number is associated with an ineligible or unauthorized recipient, messaging will cease.

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3.8 Ongoing Eligibility Monitoring

Eligibility is not a one-time determination. Rivvia reserves the right to:

• Reconfirm eligibility and authorization

• Suspend or terminate SMS communications where eligibility is unclear

• Require re-consent where circumstances change

These measures are intended to maintain ongoing compliance and protect recipient rights.

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4. Consent Standards (Express Consent)

Rivvia Sales, LLC requires express consent prior to initiating any SMS or MMS communications, except where otherwise expressly permitted by applicable law, such as when responding directly to a user-initiated inquiry that reasonably requires an SMS reply. Consent is obtained in a manner designed to be clear, informed, voluntary, and verifiable, and is documented to demonstrate compliance with the Telephone Consumer Protection Act (TCPA), Federal Communications Commission (FCC) rules, and A2P 10DLC carrier requirements.

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No SMS messages are sent without a lawful basis for contact, and consent is never implied from silence, inactivity, or the mere submission of contact information without an accompanying disclosure.

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4.1 Definition of Express Consent

For purposes of this Policy, “express consent” means a clear and affirmative action by an individual authorizing Rivvia Sales, LLC to send SMS messages to a specific mobile telephone number. Express consent must be knowingly given, must relate to the identified SMS program, and must not be obtained through deceptive or misleading practices.

Express consent may be provided in written, electronic, or verbal form, provided such consent complies with applicable legal and carrier requirements and is properly documented.

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4.2 Acceptable Methods of Obtaining Consent

Rivvia Sales, LLC may obtain express consent through one or more of the following methods:

• Website or digital application forms that include a clear, conspicuous, and unchecked opt-in checkbox accompanied by an appropriate SMS disclosure

• Electronic acknowledgments, including digital signatures, click-through agreements, or similar electronic actions

• Written consent, including signed documents or written acknowledgments

• Verbal consent, where legally permitted, provided that such consent is clearly obtained, accurately recorded, and documented

• User-initiated contact, where an individual initiates a request or inquiry and an SMS response is reasonably necessary to fulfill or respond to that request

Consent obtained through any method must be specific to SMS communications and may not be bundled with unrelated consents in a manner that obscures the nature of the authorization.

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4.3 Required Consent Disclosures

All SMS consent disclosures presented by Rivvia Sales, LLC are designed to be clear and conspicuous and to ensure that individuals understand what they are agreeing to. At a minimum, all consent disclosures include the following elements:

• The identity of the sender as Rivvia Sales, LLC

• A general description of the purpose of SMS communications (e.g., recruiting, onboarding, training, operational updates)

• A statement that message frequency may vary

• A statement that message and data rates may apply

• A clear statement that consent is not a condition of purchase, employment, application, or participation

• Instructions to reply STOP to opt out of SMS communications

• Instructions to reply HELP for assistance

Disclosures are presented in proximity to the consent mechanism and are not hidden, minimized, or obscured.

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4.4 Voluntary Nature of Consent

Consent to receive SMS messages from Rivvia Sales, LLC is entirely voluntary. Individuals are not required to consent to SMS communications in order to:

• Apply for opportunities

• Participate in recruiting or onboarding processes

• Access information or services

• Engage with Rivvia in other communication channels

Refusal or withdrawal of consent does not result in retaliation, denial of services, or adverse treatment.

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4.5 Documentation and Recordkeeping

Rivvia maintains records sufficient to demonstrate valid consent, including:

• The date and time consent was obtained

• The method of consent (e.g., web form, verbal, written)

• The mobile number to which consent applies

• The disclosure language presented at the time of consent

• System or metadata records (such as IP address or form source), where available

These records are retained in accordance with legal, contractual, and carrier requirements and are used solely for compliance and audit purposes.

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4.6 AI-Assisted Messaging and Consent Enforcement

Where AI-assisted or automated messaging systems are used, such systems are configured to enforce consent requirements by:

• Sending SMS messages only to numbers with documented express consent or lawful exception

• Respecting the scope and purpose of the consent provided

• Preventing messaging where consent is withdrawn, expired, or invalid

• Automatically honoring opt-out and suppression lists

AI-assisted systems do not override consent controls and are subject to human oversight and compliance monitoring.

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4.7 Withdrawal and Revocation of Consent

Individuals may withdraw consent at any time using the opt-out procedures described in this Policy. Revocation of consent applies prospectively and does not affect the lawfulness of SMS messages sent prior to revocation.

Once consent is withdrawn, Rivvia ceases SMS communications to the affected number unless and until valid consent is re-established.

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4.8 No Sale or Transfer of Consent

Consent obtained by Rivvia Sales, LLC is specific to Rivvia and its SMS program. Consent is not sold, transferred, shared, or assigned to third parties for their independent use.

5. Opt-Out, Revocation of Consent & Preference Management

Rivvia Sales, LLC provides clear, simple, and effective mechanisms for individuals to revoke consent and opt out of SMS and MMS communications at any time. Opt-out rights are honored promptly, without charge, and without requiring explanation or additional steps beyond those described in this Policy.

Revocation of consent applies prospectively and does not affect the lawfulness of messages sent prior to the opt-out request.

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5.1 Opt-Out Methods

Recipients may opt out of Rivvia’s SMS messaging program at any time using any of the following methods:

• Replying STOP to any SMS message

• Using other recognized opt-out keywords supported by carriers (e.g., STOPALL, UNSUBSCRIBE, CANCEL, END)

• Submitting an opt-out request through Rivvia’s website or support channels

• Contacting Rivvia directly via email or other published contact methods

Rivvia does not require recipients to provide a reason for opting out.

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5.2 Opt-Out Processing & Timing

Opt-out requests are processed promptly and in accordance with applicable law and carrier requirements. Upon receipt of an opt-out request:

• The recipient’s number is placed on Rivvia’s internal Do-Not-Text (DNT) and suppression lists

• SMS messaging to that number is terminated

• The opt-out status is enforced across all systems, platforms, and campaigns

Rivvia makes commercially reasonable efforts to process opt-outs in near real-time and no later than the timeframe required by law.

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5.3 Opt-Out Confirmation Message

After a valid opt-out request is received, Rivvia may send one (1) final confirmation message acknowledging the opt-out. This confirmation message:

• Confirms that SMS communications have been stopped

• Does not contain promotional content

• Does not attempt to persuade the recipient to re-subscribe

No further SMS messages are sent unless the recipient subsequently provides valid re-consent.

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5.4 Effect of Opt-Out

Once an opt-out request is processed:

• Rivvia ceases all non-exempt SMS communications to the affected number

• The opt-out applies to all SMS programs operated by Rivvia unless otherwise specified

• The recipient remains opted out unless and until valid express consent is re-established

Opt-out does not affect other forms of communication (e.g., email) unless separately requested.

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5.5 AI-Assisted Messaging and Opt-Out Enforcement

Where AI-assisted or automated messaging systems are used, such systems are configured to:

• Immediately honor opt-out requests

• Prevent further SMS transmissions to opted-out numbers

• Enforce suppression lists across all messaging workflows

• Prevent accidental or unauthorized re-messaging

AI systems do not override opt-out requests and are subject to human oversight and compliance monitoring.

 

5.6 Re-Consent After Opt-Out

If a recipient who has opted out later wishes to resume SMS communications, Rivvia requires new, express consent that meets the standards described in Section 4 of this Policy.

Re-consent must:

• Be affirmative and voluntary

• Include all required disclosures

• Be properly documented

Previously opted-out numbers are not reactivated without valid re-consent.

 

5.7 Error Handling & Misdelivery

If Rivvia becomes aware of SMS messages sent in error to an opted-out number due to technical failure or system error, Rivvia will:

• Immediately suspend messaging to the affected number

• Investigate and remediate the root cause

• Update systems and controls to prevent recurrence

Rivvia maintains internal processes to detect and address opt-out compliance issues.

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5.8 Preference Management

Where applicable, Rivvia may allow recipients to manage preferences related to SMS communications, such as:

• Message categories

• Frequency or timing preferences

Preference management does not override opt-out rights and does not limit a recipient’s ability to fully revoke consent.

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5.9 No Charge or Penalty for Opt-Out

Rivvia does not impose any fee, penalty, or adverse consequence for opting out of SMS communications. Opt-out is honored without discrimination or retaliation.

5.10 Recordkeeping & Audit Support

Rivvia maintains records of opt-out requests, including:

• Date and time of opt-out

• Method of opt-out

• Confirmation messaging, if sent

These records are retained to demonstrate compliance with TCPA, FCC, and carrier requirements and may be used in audits or investigations.

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6. Message Frequency, Timing & Delivery Controls

Rivvia Sales, LLC implements structured controls governing the frequency, timing, pacing, and delivery of SMS and MMS communications to ensure messages are reasonable, relevant, non-intrusive, and compliant with applicable legal and carrier requirements. These controls apply to messages sent by human representatives and AI-assisted or automated messaging systems.

6.1 Message Frequency Standards

Message frequency varies based on the recipient’s interaction with Rivvia and the stage of engagement, such as recruiting, onboarding, training, or operational support. Rivvia limits SMS communications to those reasonably necessary to fulfill legitimate business purposes.

• Some recipients may receive only one or a small number of messages

• Others may receive periodic messages during active onboarding or engagement

• Frequency may temporarily increase in response to user-initiated actions

Rivvia does not engage in excessive, repetitive, or harassing SMS messaging practices.

6.2 Contextual Relevance and Triggered Messaging

Messages are sent in response to defined events or interactions, including:

• Submission of an application or inquiry

• Request for information or assistance

• Progression through onboarding or training steps

• Scheduling or logistical needs

SMS messages are not sent arbitrarily or without a contextual basis related to the recipient’s interaction with Rivvia.

6.3 Timing and Quiet Hours Compliance

Rivvia makes commercially reasonable efforts to deliver SMS messages during appropriate hours and to comply with applicable federal and state contact-time restrictions, including quiet-hour requirements where applicable.

• Messages are generally sent during daytime or early evening hours based on the recipient’s local time zone

• Systems are configured to avoid early-morning or late-night messaging where restricted by law

• Timing controls may vary based on system configuration and recipient activity

Rivvia does not intentionally send SMS messages during prohibited time windows.

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6.4 Time Zone Management

Where available, Rivvia’s systems account for recipient time zones to ensure messages are delivered at appropriate local times. If time-zone data is unavailable, reasonable assumptions are used to minimize disruption.

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6.5 AI-Assisted Messaging and Timing Controls

AI-assisted and automated messaging systems are configured to adhere to Rivvia’s frequency and timing standards by:

• Enforcing message-rate limits

• Respecting quiet-hour restrictions

• Suppressing messages outside approved delivery windows

• Preventing rapid or duplicative messaging

AI systems do not override frequency or timing restrictions and operate under human oversight.

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6.6 Throttling, Rate Limiting & Safeguards

Rivvia employs technical safeguards to manage message volume and pacing, including:

• Rate-limiting controls to prevent message flooding

• Throttling mechanisms to manage spikes in outbound messages

• Monitoring for unusual delivery patterns

These safeguards reduce the risk of carrier filtering, consumer complaints, or system errors.

6.7 Pausing or Suspending Messaging

Rivvia reserves the right to pause or suspend SMS messaging to individual recipients or across programs in response to:

• Opt-out or revocation of consent

• Compliance concerns or legal changes

• Technical issues or carrier feedback

Suspensions are implemented promptly to maintain compliance and message integrity.

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6.8 Delivery Failures and Retries

SMS delivery is subject to carrier availability and network conditions. In the event of delivery failure:

• Messages may be retried in a reasonable manner

• Repeated failures may result in message suppression

• Failed delivery does not override opt-out or consent controls

Rivvia does not repeatedly attempt delivery in a manner that could be considered abusive.

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6.9 No Guaranteed Delivery

SMS messaging is a best-effort communication channel. Rivvia does not guarantee message delivery or receipt and is not responsible for carrier delays, blocking, or filtering.

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6.10 Monitoring, Review & Continuous Improvement

Rivvia monitors SMS messaging practices to ensure compliance with frequency and timing standards and may adjust controls as necessary based on:

• Legal or regulatory updates

• Carrier guidance or enforcement actions

• Consumer feedback or complaint trends

 

7. HELP, Customer Support & Assistance

Rivvia Sales, LLC provides accessible, transparent, and responsive support mechanisms to ensure recipients of SMS and MMS communications can obtain assistance, clarification, or additional information regarding the SMS program, their consent status, or Rivvia’s services at any time. Support is available through automated and human-assisted channels and is designed to comply with applicable legal and carrier requirements.

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7.1 HELP Keyword Functionality

Recipients may request assistance at any time by replying:

HELP

Upon receipt of a HELP request, Rivvia’s systems may generate an automated response that includes, as appropriate:

• Identification of Rivvia Sales, LLC as the sender

• A brief description of the SMS program

• Instructions on how to opt out of SMS communications

• Contact information for additional support

HELP responses are informational only and do not contain promotional or marketing content.

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7.2 Automated and AI-Assisted Support Responses

HELP responses and certain support-related SMS interactions may be generated or assisted by AI-driven or automated messaging systems operating on behalf of Rivvia Sales, LLC. Such systems are configured to:

• Provide accurate and consistent information

• Respect consent, opt-out, and suppression rules

• Avoid misleading or deceptive language

• Escalate issues where automation is insufficient

AI-assisted support is intended to provide timely assistance while maintaining compliance and transparency.

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7.3 Human Support and Escalation

Rivvia maintains human support channels for recipients who require additional assistance beyond automated responses. Where appropriate or requested, support inquiries may be reviewed or handled by a human representative.

Human escalation may occur when:

• A recipient requests clarification not addressed by automated responses

• A complaint or dispute is raised

• Technical issues or consent questions arise

• Legal or compliance-related concerns are identified

AI-assisted systems do not prevent access to human support and are designed to route complex issues appropriately.

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7.4 Available Support Channels

Recipients may contact Rivvia Sales, LLC for support through the following channels:

• SMS HELP keyword

• Email: support@rivviasales.com

• Website: https://www.rivviasales.com

Support inquiries are addressed in a commercially reasonable timeframe based on the nature and complexity of the request.

7.5 Scope of Support

Support services may include assistance with:

• Understanding the SMS program and its purpose

• Confirming consent or opt-out status

• Resolving delivery or messaging issues

• Updating contact information

• Providing guidance on alternative communication methods

Support interactions do not obligate recipients to continue SMS participation.

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7.6 Complaint Handling and Resolution

Rivvia takes consumer complaints seriously and maintains procedures to review, investigate, and resolve complaints related to SMS messaging. Complaints may be escalated internally and may result in:

• Suspension or termination of SMS communications

• System or process adjustments

• Additional compliance review

Where required, Rivvia cooperates with carriers, aggregators, or regulators in the resolution of complaints.

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7.7 Recordkeeping and Audit Support

Rivvia maintains records of HELP requests and support interactions, including:

• Date and time of request

• Method of request

• Nature of inquiry

• Resolution steps taken

Records are retained to support compliance audits, investigations, or regulatory inquiries.

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7.8 No Cost for Assistance

Rivvia does not charge fees for assistance or support related to SMS communications. Standard message and data rates imposed by wireless carriers may apply.

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8. Message & Data Rates; Costs and Charges

Rivvia Sales, LLC does not charge a fee to participate in its SMS or MMS messaging program. However, recipients acknowledge and agree that standard message and data rates may apply based on their individual wireless carrier, service plan, and device configuration.

This disclosure is provided to ensure transparency and informed consent and applies to all SMS and MMS communications sent by or on behalf of Rivvia Sales, LLC.

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8.1 Carrier-Imposed Charges

Any costs associated with receiving or sending SMS or MMS messages are determined solely by the recipient’s wireless carrier and service plan. Such charges may include, without limitation:

• Per-message fees

• Data usage charges

• Charges related to MMS messages or attachments

• Roaming or international messaging fees

Rivvia Sales, LLC does not control, set, waive, or reimburse carrier-imposed charges.

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8.2 No Purchase or Participation Fees

Rivvia does not require recipients to pay any fee to opt in to, participate in, or opt out of SMS messaging. Participation in SMS communications is voluntary and is not conditioned on any payment, purchase, or financial obligation to Rivvia.

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8.3 AI-Assisted Messaging and Cost Neutrality

The use of AI-assisted or automated messaging systems by Rivvia does not increase or alter the charges imposed by wireless carriers. Any carrier-imposed charges apply equally to messages sent by human representatives and those sent using automated or AI-assisted systems.

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8.4 Recipient Responsibility for Charges

Recipients are solely responsible for any charges incurred as a result of SMS or MMS communications, including charges related to replying to messages (such as STOP or HELP). Rivvia is not responsible for costs incurred due to the recipient’s service plan, carrier policies, or device settings.

8.5 Billing Disputes and Carrier Inquiries

Questions or disputes regarding SMS or MMS charges should be directed to the recipient’s wireless carrier. Rivvia does not have access to carrier billing systems and cannot resolve carrier billing disputes on behalf of recipients.

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8.6 Transparency in Disclosures

The disclosure that “message and data rates may apply” is included in:

• Opt-in consent language

• This SMS Policy

• Other applicable notices or disclosures

This consistent disclosure is intended to ensure recipients understand potential costs before consenting to receive SMS messages.

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8.7 No Premium Messaging

Rivvia does not operate premium-rate SMS programs and does not send messages that result in premium charges beyond standard carrier rates.

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9. Carrier Disclaimer, Delivery Limitations & Network Dependencies

SMS and MMS message delivery is subject to the technical capabilities, policies, and operational conditions of wireless carriers and mobile networks. Rivvia Sales, LLC does not control and cannot guarantee the delivery, timing, or receipt of any SMS or MMS message sent to or from a mobile device.

This section is intended to clearly disclose carrier-related limitations and allocate responsibility appropriately

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9.1 No Guarantee of Delivery or Timing

SMS and MMS messaging operates on a best-effort basis. Message delivery may be delayed, blocked, filtered, throttled, or fail entirely due to factors outside Rivvia’s control, including but not limited to:

• Carrier network congestion

• Network outages or maintenance

• Device compatibility issues

• Carrier spam-filtering or content review systems

• Message volume controls or rate limits

• Geographic or roaming restrictions

Rivvia makes no representation or warranty that any message will be delivered, received, or read within a specific timeframe or at all.

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9.2 Carrier Filtering, Blocking & Throttling

Wireless carriers may apply automated or manual filtering, blocking, or throttling to SMS messages based on their internal policies, content analysis, traffic patterns, or compliance assessments. Such actions may occur even where Rivvia has obtained valid consent and complies with applicable laws.

Rivvia is not responsible for carrier decisions to filter, block, delay, or restrict message delivery.

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9.3 No Carrier Endorsement or Liability

Wireless carriers are not liable for delayed, undelivered, misdirected, or blocked messages. Participation in Rivvia’s SMS program does not imply endorsement, sponsorship, or approval by any wireless carrier.

Carriers do not review or approve Rivvia’s message content and are not responsible for the substance of any SMS communication.

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9.4 Device, Plan & Technical Limitations

Message delivery and functionality may be affected by:

• Mobile device type, operating system, or settings

• SMS/MMS capability of the device

• Data connectivity or service interruptions

• User-configured message blocking or filtering

Recipients are responsible for ensuring their devices and service plans support SMS and MMS messaging.

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9.5 AI-Assisted Messaging & Carrier Controls

The use of AI-assisted or automated messaging systems by Rivvia does not bypass or override carrier controls. All messages—whether sent by human representatives or AI-assisted systems—are subject to the same carrier policies, filtering mechanisms, and delivery limitations.

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9.6 Retry Logic & Delivery Attempts

In the event of message delivery failure, Rivvia may attempt to retry delivery in a reasonable and compliant manner. Repeated failures may result in suppression of messaging to avoid excessive attempts or carrier penalties.

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Delivery retries do not override opt-out requests, consent revocation, or suppression lists.

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9.7 International, Roaming & Cross-Border Limitations

SMS delivery may be limited or unavailable when recipients are:

• Using international numbers

• Roaming outside their home carrier’s network

• Subject to cross-border messaging restrictions

Rivvia does not guarantee international or roaming SMS delivery.

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9.8 No Reliance on SMS for Critical Communications

SMS messaging should not be relied upon as the sole or guaranteed method for receiving time-sensitive, legally required, or critical communications. Rivvia may use alternative communication methods where appropriate.

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9.9 Cooperation With Carrier Inquiries

Rivvia cooperates with wireless carriers, aggregators, and messaging providers in connection with investigations, audits, or inquiries related to SMS delivery, compliance, or consumer complaints, consistent with applicable law.

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10. Privacy, Data Handling & Security (SMS-Specific)

Rivvia Sales, LLC is committed to protecting the privacy, integrity, and security of personal information used in connection with its SMS and MMS messaging program. This section governs Rivvia’s collection, use, storage, protection, and disclosure of data specifically associated with SMS communications and operates in conjunction with Rivvia’s broader Privacy Policy.

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10.1 Categories of Information Collected for SMS Communications

In connection with SMS messaging, Rivvia may collect and process the following categories of information:

• Mobile telephone number

• Consent and opt-in records (including date, time, method, and disclosure language)

• Message content and interaction history

• Opt-out and preference records

• Technical metadata (such as delivery status, timestamps, or platform identifiers)

• Support or HELP request information

Rivvia limits data collection to what is reasonably necessary to operate and comply with its SMS program.

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10.2 Purpose of Data Collection and Use

SMS-related data is collected and used solely for legitimate business and compliance purposes, including:

• Sending authorized SMS and MMS communications

• Verifying and enforcing consent and opt-out status

• Providing support and responding to inquiries

• Monitoring compliance with TCPA, FCC, and carrier rules

• Investigating complaints, disputes, or delivery issues

• Auditing, logging, and regulatory defense

SMS data is not used for unrelated purposes and is not exploited beyond the scope disclosed at the time of consent.

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10.3 AI-Assisted Messaging and Data Use

Where AI-assisted or automated messaging systems are used, such systems may process SMS-related data solely to:

• Generate or route authorized messages

• Respond to HELP or support requests

• Enforce consent, opt-out, and timing controls

• Improve message accuracy and operational efficiency

AI systems do not independently determine consent, override opt-out requests, or repurpose data for unauthorized uses. AI-assisted processing remains subject to Rivvia’s data-handling rules, human oversight, and compliance safeguards.

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10.4 Data Minimization and Retention

Rivvia applies data-minimization principles to SMS-related information and retains such data only for as long as reasonably necessary to:

• Operate the SMS program

• Demonstrate legal and regulatory compliance

• Defend against claims or audits

Retention periods may be extended where required by law, contractual obligation, or ongoing dispute resolution.

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10.5 Data Sharing and Disclosure Limitations

Rivvia does not sell, rent, lease, or trade SMS opt-in data or mobile telephone numbers.

SMS-related data may be shared only with:

• Authorized service providers or messaging platforms acting on Rivvia’s behalf

• Legal, regulatory, or enforcement authorities where required by law

• Advisors or auditors for compliance or risk management purposes

All third parties are contractually required to maintain appropriate confidentiality, security, and compliance controls.

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10.6 Security Measures

Rivvia implements commercially reasonable administrative, technical, and organizational safeguards designed to protect SMS-related data from unauthorized access, use, disclosure, alteration, or destruction, including:

• Access controls and role-based permissions

• Secure system configurations and vendor controls

• Monitoring for unauthorized activity

• Internal compliance reviews and audits

No system is completely secure, but Rivvia takes reasonable steps to mitigate risk and respond promptly to security concerns.

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10.7 Breach Response and Incident Management

In the event of a suspected or confirmed security incident involving SMS-related data, Rivvia will:

• Investigate and contain the incident

• Take appropriate remedial actions

• Comply with applicable notification obligations

• Cooperate with carriers, regulators, or affected parties as required

Incident response is handled in accordance with Rivvia’s internal security and compliance procedures.

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10.8 Consumer Rights and Requests

Individuals may have rights under applicable privacy laws to request access to, correction of, or deletion of certain personal information. Requests related to SMS-specific data may be submitted through Rivvia’s published contact channels.

Such requests are handled in accordance with applicable law and do not override Rivvia’s legal obligations to retain certain records for compliance or defense purposes.

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10.9 Relationship to Privacy Policy

This Section applies specifically to SMS communications. For broader information regarding Rivvia’s data practices, including non-SMS data, individuals should review Rivvia’s Privacy Policy. In the event of a conflict, this SMS-specific section governs SMS-related practices.

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10.10 No Waiver of Legal Protections

Nothing in this Policy limits Rivvia’s rights or obligations under applicable law, nor does it create additional rights beyond those provided by law.​​

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