TCPA COMPLIANCE POLICY & COMMUNICATIONS DISCLOSURES

Rivvia Sales, LLC

Effective Date: January 1, 2025
Last Updated: December 21, 2025

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Rivvia Sales, LLC (“Rivvia,” “we,” “our,” or “us”) is committed to full and ongoing compliance with the Telephone Consumer Protection Act (47 U.S.C. § 227), all applicable Federal Communications Commission (“FCC”) regulations, relevant state telemarketing, consumer protection, and privacy laws, and mobile carrier requirements, including Application-to-Person (“A2P”) messaging standards.

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This TCPA Compliance Policy establishes Rivvia’s standards, controls, and procedures governing telephone calls, text messages (SMS/MMS), prerecorded or artificial voice messages, automated dialing technologies, ringless voicemail where permitted, and AI-assisted or automated communication systems that are initiated by or on behalf of Rivvia.

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This Policy applies to both inbound and outbound communications, regardless of whether such communications are initiated manually, through automated systems, or with the assistance of artificial intelligence or algorithmic tools.

This Policy is intentionally designed to operate in coordination with, and is incorporated by reference into, Rivvia’s:

• SMS/Text Messaging Policy

• Privacy Policy

• Terms of Use

• Recruiting disclosures and compliance acknowledgments

 

Where communications involve SMS, MMS, automated dialing, prerecorded content, or AI-assisted systems, this TCPA Compliance Policy should be read together with those policies. In the event of a conflict, the policy most specific to the communication method and legal requirement shall govern.

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Commitment to Consent-Based Communications

Rivvia’s communications are consent-driven and purpose-limited. Rivvia does not engage in unsolicited mass messaging, deceptive outreach, or high-risk telemarketing practices. All communications are initiated only where Rivvia reasonably believes that a lawful basis exists under applicable law and that the communication aligns with the expectations created at the time consent was obtained.

Rivvia does not sell, rent, license, or transfer consumer consent, telephone numbers, or text messaging opt-in data to third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent records are treated as restricted compliance data and are shared only as necessary to deliver communications or comply with legal obligations.

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Use of Automated and AI-Assisted Technologies

Rivvia may use automated systems, software platforms, or AI-assisted tools to support communications, including message delivery, inquiry routing, scheduling, and standardized informational responses. The use of such technologies does not diminish Rivvia’s responsibility to comply with the TCPA or other applicable laws.

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AI-assisted systems are implemented with defined limitations and human oversight and are not used to circumvent consent requirements, opt-out mechanisms, calling restrictions, or carrier safeguards. These systems function solely as operational tools and do not independently determine legal eligibility, employment status, compensation, or contractual rights.

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No Emergency or Time-Sensitive Reliance

Communications sent by or on behalf of Rivvia are not emergency communications. Individuals should not rely on phone calls, text messages, or other communications from Rivvia for urgent medical, legal, safety, or time-critical matters.

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Acknowledgment and Acceptance

By providing a telephone number to Rivvia, initiating contact, submitting an application, opting in to communications, or otherwise engaging with Rivvia through any communication channel, individuals acknowledge that they have reviewed and understand this TCPA Compliance Policy and agree to the communication practices described herein, to the extent permitted by applicable law.

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1. Purpose of This Policy

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The purpose of this TCPA Compliance Policy is to establish clear, enforceable standards governing how Rivvia Sales, LLC conducts telephone calls, text messaging, and other electronic communications in compliance with the Telephone Consumer Protection Act (TCPA), applicable FCC regulations, relevant state telemarketing and consumer protection laws, and mobile carrier requirements.

This Policy is designed to ensure that all communications initiated by or on behalf of Rivvia are lawful, consent-based, transparent, and respectful of individual preferences. It explains how Rivvia:

• Obtains, documents, and verifies legally sufficient consent

• Limits communications to permitted purposes and channels

• Honors opt-out, revocation, and do-not-contact requests

• Enforces calling-hour, frequency, and content restrictions

• Applies oversight to automated and AI-assisted communication systems

• Maintains records necessary to demonstrate compliance and respond to audits, inquiries, or disputes

 

This Policy applies to all communications, whether conducted manually, through automated systems, or with the assistance of artificial intelligence or algorithmic tools, and regardless of whether such communications are initiated directly by Rivvia or by authorized third-party service providers acting on Rivvia’s behalf.

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Protection of Mobile Information and Consent Data

Rivvia places heightened importance on the protection of mobile information and consent records. No mobile telephone numbers, text messaging data, or related opt-in information are sold, rented, licensed, shared, or transferred to third parties or affiliates for marketing, promotional, or unrelated purposes.

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Text messaging originator opt-in data and consent records are treated as restricted compliance data and are used solely to:

• Deliver authorized communications

• Enforce opt-out and suppression requests

• Demonstrate compliance with TCPA, FCC, and carrier requirements

• Respond to regulatory, carrier, or legal inquiries

 

All other categories of data processed by Rivvia expressly exclude text messaging originator opt-in data and consent records, except where disclosure is strictly necessary to facilitate message delivery through authorized service providers or to comply with applicable law.

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Commitment to Responsible Communications

This Policy reflects Rivvia’s commitment to responsible communications practices. Rivvia does not engage in unsolicited mass outreach, deceptive or misleading communications, consent trafficking, or practices designed to circumvent legal, regulatory, or carrier safeguards.

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All individuals involved in communications on Rivvia’s behalf—including employees, independent contractors, and service providers—are required to adhere to this Policy and applicable laws at all times.

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2. Scope

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This TCPA Compliance Policy applies to all inbound and outbound communications initiated by or on behalf of Rivvia Sales, LLC, regardless of whether such communications are conducted manually, through automated systems, or with the assistance of artificial intelligence or algorithmic tools.

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Covered communication channels include, without limitation:

• Voice calls, whether dialed manually or through automated dialing systems

• SMS and MMS text messages

• Prerecorded or artificial voice messages

• Ringless voicemail technologies, where permitted by applicable law

• Communications delivered through third-party platforms, aggregators, carriers, or service providers acting on Rivvia’s behalf

 

This Policy applies to communications with:

• Job applicants and recruits

• Independent contractor prospects, contractors, and representatives

• Individuals requesting information or assistance

• Existing business or operational contacts

This Policy applies regardless of device, carrier, platform, or geographic location within the United States.

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3. Consent Requirements, Lead Sources & Referral Limitations

Rivvia Sales, LLC initiates telephone calls, text messages (SMS/MMS), prerecorded or artificial voice messages, and other electronic communications only where legally permissible consent exists in accordance with the Telephone Consumer Protection Act (TCPA), FCC regulations, applicable state telemarketing and consumer protection laws, and mobile carrier requirements.

Consent requirements vary based on the type of communication, technology used, purpose of the message, and source of the lead, and Rivvia applies the highest applicable consent standard where required.

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3.1 Types of Consent

Depending on the nature of the communication, Rivvia may require:

• Prior Express Consent, where permitted for informational, operational, or non-marketing communications

• Prior Express Written Consent, where required for automated, prerecorded, artificial voice, or marketing communications

Rivvia does not rely on implied consent, inferred consent, proximity-based assumptions, referrals alone, or improperly expanded “established business relationship” theories.

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3.2 Lawful Methods of Obtaining Consent

Consent may be obtained only through lawful, affirmative methods, including:

• Website, digital, or mobile application forms containing:

  • Clear and conspicuous disclosures

  • Unchecked opt-in mechanisms or equivalent affirmative actions

  • Disclosure of message purpose, frequency, opt-out rights, and carrier charges

• Text-to-join or keyword-based SMS opt-ins, where the individual initiates contact

• Verbal consent, where legally permitted, provided such consent is:

  • Clearly requested

  • Properly disclosed

  • Reasonably documented

• User-initiated inquiries, requests, or responses that reasonably require follow-up communications to fulfill the request

Consent must be voluntary, informed, unambiguous, and specific to the disclosed purpose.

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3.3 Referrals, Lead Sources & “Live Fiber Area” Information (Not Consent)

Rivvia may receive lead information or referrals from multiple sources, including but not limited to:

• Fiber internet service providers or brand partners identifying “live,” “lit,” or service-available areas

• Independent contractors conducting door-to-door outreach

• Neighbor-to-neighbor referrals, word-of-mouth introductions, community recommendations, or customer suggestions

A referral or lead source does not constitute consent.

Referral information is treated solely as a lead indicator, not authorization to initiate calls, texts, or automated communications. A referral does not create:

• Implied consent

• Prior express consent

• Prior express written consent

• An established business relationship for TCPA purposes

Rivvia initiates communications to referred individuals only where lawful consent is independently obtained or where the individual initiates contact in a manner that reasonably requires follow-up under applicable law.

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3.4 Scope, Purpose & Limitations of Consent

Consent obtained by Rivvia:

• Is limited strictly to the specific purpose(s) disclosed at the time consent is obtained

• Does not extend to unrelated marketing, mass outreach, or third-party campaigns

• Does not transfer to Fiber Brand Partners, independent contractors, or other third parties for independent marketing use

• Does not override opt-out, revocation, or do-not-contact requests

Consent for one channel (e.g., SMS) does not automatically authorize communications via other channels unless clearly disclosed.

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3.5 Independent Contractors, Door-to-Door Activity & Consent Boundaries

Independent contractors affiliated with Rivvia:

• May identify potential leads or referrals through in-person, door-to-door interactions

• Are not authorized to represent that a referral constitutes consent

• Are not authorized to imply that communications are mandatory

• May not collect, enter, upload, or represent consent unless obtained in compliance with Rivvia disclosures and applicable law

• May not imply that Rivvia, a Fiber Brand Partner, or a neighbor has authorized future calls or texts

Any consent collected outside Rivvia-approved systems or disclosures is deemed unauthorized, invalid, and outside the scope of Rivvia’s authorization.

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3.6 No Condition of Purchase, Service, or Participation

Consent to receive calls or text messages:

• Is not a condition of purchasing goods or services

• Is not required to receive fiber availability information

• Is not required to apply for an opportunity or engage with Rivvia

• May be refused or revoked at any time without penalty

 

3.7 Documentation, Defense & Serial-Litigator Protection

Rivvia maintains reasonable records relating to consent—including method, timestamp, source, and disclosure language—where captured through Rivvia-approved systems, for compliance verification and defense purposes.

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Rivvia expressly reserves all rights to challenge claims alleging implied consent, referral-based authorization, improper EBR reliance, or misuse of TCPA statutes, including claims asserted by serial or professional litigants.

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4. Automated & AI-Assisted Communications

Rivvia Sales, LLC may utilize automated systems, software platforms, algorithmic processes, and artificial intelligence (“AI”)-assisted tools to support lawful communications and operational efficiency. Such tools may be used for purposes including, but not limited to, message delivery, inbound inquiry handling, routing and triage of requests, scheduling, appointment or installation confirmations, status notifications, reminders, standardized informational responses, and compliance-related messaging.

All automated and AI-assisted communications are deployed as supporting communication mechanisms only and are governed by Rivvia’s TCPA Compliance Policy, SMS/Text Messaging Policy, Privacy Policy, and applicable law.

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4.1 Nature & Purpose of AI-Assisted Communications

AI-assisted communications used by Rivvia are designed to:

• Facilitate timely and consistent delivery of approved communications

• Provide standardized, non-discretionary informational responses

• Support operational workflows such as confirmations, scheduling, and routing

• Improve response efficiency without expanding the scope or frequency of communications

AI systems are not autonomous decision-makers and do not initiate communications absent lawful authorization and system controls.

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4.2 Consent, Opt-Out & Suppression Controls

All automated and AI-assisted communications:

• Operate only where legally permissible consent exists

• Are subject to the same consent requirements as human-initiated communications

• Are technically and procedurally constrained by opt-out, revocation, suppression, and do-not-contact controls

• Do not bypass, override, delay, or reinterpret STOP requests, do-not-call designations, or suppression lists

If consent is revoked or a number is suppressed, AI-assisted systems are designed to cease further communications consistent with applicable law.

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4.3 Defined Rules, Safeguards & Human Oversight

AI-assisted tools operate under predefined rules, constraints, and system logic, which may include:

• Approved message templates and response boundaries

• Restricted communication purposes and use cases

• Logging and auditing of system-generated interactions

• Human-initiated configuration, review, and adjustment

Human oversight exists at the policy, configuration, and system-design level, not as real-time supervision of each interaction. The existence of AI systems does not imply continuous monitoring or direct control over independent contractor conduct.

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4.4 Limitations on AI Authority & Decision-Making

AI-assisted systems used by Rivvia:

• Do not independently determine legal rights, eligibility, employment status, compensation, pricing, service approval, creditworthiness, or contractual terms

• Do not make hiring, firing, onboarding, or disciplinary decisions

• Do not negotiate contracts, bind Rivvia, or modify agreements

• Do not exercise discretion beyond predefined informational or routing functions

All material decisions remain subject to human determination or third-party authority, as applicable.

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4.5 Independent Contractors & AI Tools

Independent contractors may interact with Rivvia systems that incorporate AI-assisted functionality. Such interaction:

• Does not create supervision, direction, or control over the contractor’s activities

• Does not convert independent contractor status into employment

• Does not authorize contractors to rely on AI outputs as legal guidance or consent validation

• Does not shift responsibility for compliance from the contractor to Rivvia

Independent contractors remain solely responsible for their own conduct and compliance with applicable law.

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4.6 No Expansion of Consent, Purpose, or Scope

The use of automated or AI-assisted systems:

• Does not expand the scope, duration, or purpose of any consent obtained

• Does not authorize additional message frequency or marketing content

• Does not convert informational communications into marketing communications

• Does not create an established business relationship where none otherwise exists

AI is used to execute approved communications, not to redefine or broaden them.

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4.7 Accuracy, Limitations & Reliance Disclaimer

AI-assisted communications rely on system inputs, available data, and predefined logic and may be subject to limitations, errors, or incomplete information.

Recipients should not rely on AI-generated communications for:

• Legal advice

• Contractual interpretation

• Binding representations

• Emergency, medical, or safety-critical decisions

Rivvia reserves the right to correct, supplement, or withdraw AI-generated communications where appropriate.

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4.8 Recordkeeping & Litigation Defense

Communications generated or supported by AI-assisted systems may be logged, aggregated, or retained consistent with Rivvia’s recordkeeping practices.

The use of AI systems:

• Does not create an obligation to preserve algorithmic logic, training data, or proprietary system designs

• Does not waive privileges or defenses

• Does not constitute an admission of liability or control

Rivvia expressly reserves all defenses related to consent, revocation timing, wrong-party communications, independent contractor conduct, and misuse of TCPA statutes by serial litigants.

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4.9 Compliance Obligation Unaffected

The use of automated or AI-assisted communications does not reduce, modify, or waive Rivvia’s compliance obligations under TCPA, FCC rules, carrier requirements, or applicable law.

AI systems are treated strictly as communication tools, not decision-makers, and are subject to the same legal standards as human-initiated communications.

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5. Prohibited Communications

Rivvia Sales, LLC strictly prohibits any communication practice that violates applicable law, carrier requirements, or this Policy. The following practices are expressly forbidden when conducted by or on behalf of Rivvia, including by independent contractors, representatives, or third parties using Rivvia systems.

Any communication activity inconsistent with this Policy is deemed unauthorized, outside the scope of Rivvia’s approval, and prohibited.

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5.1 Communications Without Required Consent

The following are strictly prohibited:

• Initiating calls, texts, or automated communications without the legally required level of consent

• Initiating communications based solely on:

  • Referrals

  • Neighbor recommendations

  • Proximity to a service area

  • Door-to-door conversations

  • Prior interactions that do not meet TCPA consent standards

• Relying on implied consent, inferred consent, or improperly expanded “established business relationship” theories

Consent must exist before communication is initiated and must be valid, documented, and within scope.

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5.2 Do Not Call (DNC) & Suppression Violations

It is prohibited to:

• Contact numbers listed on the National Do Not Call Registry where prohibited by law

• Contact individuals who have:

  • Requested not to be contacted

  • Replied STOP to SMS

  • Been placed on internal suppression lists

• Delay, ignore, override, or attempt to reinterpret opt-out or revocation requests

Once a number is suppressed, no further prohibited communications may be sent, regardless of lead source.

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5.3 Deceptive, Misleading, or Coercive Content

The following practices are strictly prohibited:

• False, misleading, or deceptive representations regarding:

  • Rivvia’s role or authority

  • Fiber service availability, pricing, or guarantees

  • Relationship with Fiber Brand Partners

  • Consent requirements or opt-out rights

• Implying that:

  • Consent is mandatory

  • Communications are required to receive service

  • The recipient has already agreed to be contacted

• Using urgency, pressure, threats, or fear-based tactics to elicit responses

All communications must be truthful, accurate, and non-coercive.

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5.4 Unauthorized Robocalls, Automated, or AI-Driven Messages

It is prohibited to:

• Send robocalls, prerecorded messages, or automated communications where not expressly permitted by law

• Use automated or AI-assisted tools to:

  • Initiate outreach without consent

  • Increase frequency beyond permitted levels

  • Mask or disguise the origin of a message

• Deploy automation to evade human accountability or legal requirements

Automation and AI may never be used to bypass TCPA, FCC, or carrier safeguards.

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5.5 Excessive, Harassing, or Abusive Communications

Rivvia strictly prohibits:

• Excessive or repetitive contact attempts

• Communications intended to harass, intimidate, or annoy

• Contact patterns inconsistent with reasonable consumer expectations

• Repeated contact following non-response or expressed disinterest

Frequency must remain reasonable, proportional, and consistent with disclosed purposes.

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5.6 Circumvention of Carrier, Platform, or Regulatory Safeguards

It is strictly prohibited to:

• Attempt to bypass carrier spam filtering, throttling, or blocking

• Rotate numbers, sender IDs, or platforms to evade detection

• Use shadow systems, personal devices, or unapproved tools

• Manipulate opt-out keywords, message formatting, or routing logic

• Engage in practices designed to defeat compliance controls

Any attempt to circumvent safeguards constitutes a material violation of this Policy.

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5.7 Independent Contractor-Specific Prohibitions

Independent contractors and representatives are expressly prohibited from:

• Conducting mass texting, bulk messaging, or robocalling outside Rivvia-approved systems

• Using personal phone numbers or third-party tools to communicate on Rivvia’s behalf

• Uploading or using unlawfully obtained contact lists

• Representing themselves as employees or agents of Rivvia

• Suggesting Rivvia authorizes non-compliant outreach

Such conduct is deemed outside the scope of authorization and undertaken solely at the contractor’s own risk.

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5.8 Unauthorized Third-Party Communications

Rivvia prohibits:

• Third-party marketing conducted using Rivvia’s name, brand, or systems without authorization

• Use of Rivvia data, leads, or referrals for unrelated campaigns

• Sharing consent data for independent marketing use

Unauthorized third-party communications are not approved, ratified, or endorsed by Rivvia.

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5.9 Consequences of Prohibited Communications

Any prohibited communication practice may result in:

• Immediate suspension or termination of system access

• Termination of contractor or representative relationships

• Forfeiture or withholding of commissions where legally permitted

• Reporting to carriers, platforms, partners, or regulators

• Indemnification obligations and legal action

Prohibited communications are deemed outside the scope of Rivvia’s authorization, and responsibility rests solely with the individual or entity engaging in such conduct.

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6. Time-of-Day Restrictions

Rivvia complies with all applicable federal and state calling-hour restrictions. Communications are generally limited to 8:00 a.m. to 9:00 p.m. local time for the recipient, unless:

• The recipient initiates the communication, or

• The recipient expressly requests communication outside those hours

Rivvia also applies reasonable controls to avoid excessive frequency or disruption.

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7. Do Not Call (DNC), Do Not Text & Suppression Compliance

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Rivvia Sales, LLC maintains and enforces reasonable, commercially appropriate procedures designed to honor individual communication preferences and comply with the National Do Not Call Registry, applicable state do-not-call laws, carrier requirements, and internal suppression standards.

DNC and suppression compliance applies to all communications initiated through Rivvia-approved systems and is a core component of Rivvia’s TCPA compliance framework.

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7.1 National Do Not Call Registry Compliance

Rivvia maintains procedures to prevent prohibited outbound telephone solicitations to residential and mobile numbers listed on the National Do Not Call Registry, except where otherwise permitted by applicable law.

Rivvia does not rely on improper or overbroad interpretations of “established business relationship” exceptions to bypass DNC protections.

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7.2 Company-Specific Do Not Call / Do Not Text Requests

In addition to national and state registries, Rivvia maintains company-specific do-not-contact lists, which may include:

• Do-not-call requests

• Do-not-text requests

• Internal suppression lists

• Campaign-specific or system-level exclusions

Any request by an individual to stop receiving calls or text messages—regardless of the phrasing used—is treated as a valid revocation of consent and honored in accordance with applicable law.

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7.3 Methods of Submitting DNC or Opt-Out Requests

Individuals may request placement on Rivvia’s do-not-contact lists through reasonable means, including but not limited to:

• Replying STOP (or similar recognized keywords) to SMS messages

• Verbally requesting no further calls during a live interaction

• Submitting a request through Rivvia’s support or contact channels

• Any other clear expression of a desire not to receive further communications

No specific wording is required to exercise opt-out or DNC rights.

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7.4 Prompt Processing & System Enforcement

Upon receipt of a do-not-call or do-not-text request:

• The request is processed promptly and without charge

• The individual’s number is added to appropriate suppression lists

• Rivvia systems are configured to prevent further prohibited communications

• Suppression applies across campaigns and communication channels where required by law

Rivvia does not delay, override, reinterpret, or condition suppression on additional actions by the individual.

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7.5 Independent Contractors & DNC Compliance Boundaries

Independent contractors affiliated with Rivvia:

• Are not authorized to ignore, delay, override, or dispute DNC or opt-out requests

• Are not authorized to represent that suppression applies only to certain campaigns or periods

• Must not attempt to re-contact suppressed individuals through alternate numbers, devices, or platforms

Any attempt by an independent contractor to bypass or disregard DNC or suppression controls is deemed unauthorized and outside the scope of Rivvia’s authorization.

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7.6 Scope & Limitations of Suppression Lists

Rivvia’s suppression lists:

• Apply to communications initiated through Rivvia-approved systems

• Do not capture or control unauthorized communications conducted outside Rivvia systems

• Are maintained for compliance and defensive purposes

• Do not constitute admissions of liability or wrongdoing

Rivvia expressly disclaims responsibility for communications initiated independently by third parties or independent contractors outside Rivvia-approved systems.

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7.7 Recordkeeping & Defense

Rivvia maintains reasonable records of DNC and opt-out requests—including method and timestamp—where captured through Rivvia-approved systems, for compliance verification and defense purposes.

Rivvia reserves all rights to challenge claims alleging failure to honor DNC requests, including challenges based on:

• Timing of the request

• Scope of the suppression requested

• Wrong-party or reassigned number defenses

• Unauthorized conduct by independent contractors

 

7.8 No Waiver of Rights or Defenses

Nothing in this Section shall be construed as:

• Creating a private right of action beyond those provided by law

• Waiving Rivvia’s statutory, procedural, or contractual defenses

• Establishing control, supervision, or agency over independent contractor conduct

All rights, remedies, and defenses are expressly reserved.

 

8. Opt-Out, Revocation of Consent & Suppression Enforcement

Rivvia Sales, LLC recognizes and enforces the right of any individual to revoke consent or opt out of communications at any time using reasonable means, in accordance with the Telephone Consumer Protection Act (TCPA), FCC regulations, applicable state law, and carrier requirements.

Revocation of consent applies regardless of the original source of the lead, referral, relationship, or prior interaction.

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8.1 Methods of Opt-Out or Revocation

Recipients may revoke consent or request cessation of communications through any reasonable means, including but not limited to:

• Replying STOP, UNSUBSCRIBE, CANCEL, QUIT, or similar recognized keywords to SMS or MMS messages

• Verbally requesting no further calls during a live interaction

• Submitting a request through Rivvia’s published support, contact, or compliance channels

• Any other clear expression of a desire not to receive further communications

No specific wording, form, or procedure is required to exercise opt-out rights.

8.2 Scope & Effect of Revocation

Upon receipt of an opt-out or revocation request:

• The revocation is treated as effective immediately for purposes of compliance

• The individual’s number is added to appropriate suppression and do-not-contact lists

• Further prohibited communications cease in accordance with applicable law

• Revocation applies across campaigns, use cases, and communication channels where legally required

Revocation of consent supersedes any prior consent, referral, business relationship, or lead source.

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8.3 Prompt Processing & System Enforcement

Opt-out and revocation requests are processed promptly, without charge, and enforced through Rivvia’s approved systems using commercially reasonable technical and procedural controls.

Rivvia does not delay, condition, reinterpret, or require confirmation of opt-out requests in order to honor revocation.

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8.4 Independent Contractors & Opt-Out Boundaries

Independent contractors affiliated with Rivvia:

• Are not authorized to dispute, override, delay, or reinterpret opt-out requests

• Are not authorized to suggest that opt-out applies only to certain messages, campaigns, or time periods

• Must not attempt to re-contact individuals who have opted out using alternate numbers, devices, or platforms

Any attempt to bypass or disregard opt-out or revocation requests is deemed unauthorized, outside the scope of Rivvia’s authorization, and a material violation of this Policy.

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8.5 Re-Consent After Opt-Out

Once consent has been revoked:

• Rivvia will not resume prohibited communications unless and until new, valid consent is independently obtained in compliance with applicable law

• Re-consent must be affirmative, voluntary, and properly documented

• Silence, non-response, referrals, or prior relationships do not constitute re-consent

 

8.6 Recordkeeping & Defense

Rivvia maintains reasonable records of opt-out and revocation requests—including method and timestamp—where captured through Rivvia-approved systems, for compliance verification and litigation defense purposes.

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Rivvia expressly reserves all rights to challenge claims alleging failure to honor opt-out requests, including challenges related to:

• Timing of the request

• Scope of revocation

• Wrong-party or reassigned number issues

• Unauthorized conduct by independent contractors or third parties

 

8.7 No Waiver of Rights or Defenses

The honoring of opt-out or revocation requests:

• Does not constitute an admission of liability or wrongdoing

• Does not waive Rivvia’s statutory, procedural, or contractual defenses

• Does not establish agency, control, or ratification of independent contractor conduct

All rights and defenses are expressly reserved.

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​9. Reassigned Numbers & Wrong-Party Protections

Rivvia maintains procedures designed to reduce communications to reassigned, recycled, or incorrect numbers, including:

• Honoring wrong-party notifications immediately

• Suppressing numbers identified as invalid or reassigned

• Monitoring delivery failures, carrier feedback, and complaints

When Rivvia becomes aware that a number does not belong to the intended recipient, communications to that number cease.

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10. Recordkeeping, Documentation, Preservation & Litigation Defense

Rivvia Sales, LLC maintains reasonable, commercially appropriate records in the ordinary course of business for purposes of operational continuity, compliance verification, and defense against complaints, audits, regulatory inquiries, arbitration demands, or litigation, including claims brought by repeat, professional, or serial TCPA litigants.

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Rivvia’s recordkeeping practices are designed to demonstrate good-faith compliance, not to provide comprehensive surveillance, real-time monitoring, or guaranteed evidentiary reconstruction of every communication event.

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Nothing in this Policy creates an obligation to maintain records beyond what is required by applicable law or reasonably maintained in the normal course of business.

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10.1 Categories of Records Maintained

Where applicable and available, Rivvia may maintain the following categories of records:

• Consent records, including:

  • Method of consent (web form, keyword opt-in, verbal acknowledgment, user-initiated inquiry)

  • Date and time consent was captured

  • Source or campaign identifier

  • Disclosure language presented at the time of consent

• Opt-out, revocation, and suppression records, including:

  • Timestamp and method of revocation

  • Suppression list status

  • System enforcement logs

• Communication logs generated by Rivvia-approved systems, including:

  • Call or message timestamps

  • Direction (inbound/outbound)

  • Routing data and system identifiers

• Delivery and carrier metadata, such as:

  • Message delivery status

  • Error codes or carrier feedback

  • Throttling or filtering notices

• Policy artifacts, including:

  • TCPA, SMS, and Privacy Policy versions in effect at the time of communication

  • Compliance guides or informational resources made available to independent contractors

  • Acknowledgments or click-through acceptances where applicable

• Limited internal notes or audit artifacts, created only where necessary to address complaints, investigations, or disputes

Records may exist in electronic, aggregated, system-generated, or third-party platform formats, and Rivvia may rely on records maintained by service providers or carriers acting on its behalf.

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10.2 System-Limited Scope of Records

Rivvia’s records:

• Reflect only communications initiated, routed, or logged through Rivvia-approved systems

• Do not capture, track, or document:

  • Unauthorized communications

  • Communications conducted using personal devices, third-party tools, or unapproved platforms

  • In-person, door-to-door conversations

• Do not evidence control, supervision, or direction over independent contractor conduct

• Do not constitute admissions of liability, wrongdoing, or ratification of any conduct

Rivvia expressly disclaims responsibility for maintaining or producing records related to communications conducted outside Rivvia systems or without authorization.

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10.3 Record Accuracy & Availability Disclaimer

Rivvia does not warrant or represent that:

• Records are complete, exhaustive, or error-free

• All historical records remain available indefinitely

• Records will exist in any specific format requested by a claimant

• Absence of a record implies absence of consent or non-compliance

Records reflect system activity as logged and preserved in the ordinary course and may be affected by platform limitations, retention schedules, carrier behavior, or lawful deletion.

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10.4 Retention & Preservation Periods

Records are retained for periods Rivvia determines are reasonably necessary to:

• Demonstrate compliance with TCPA, FCC rules, and carrier requirements

• Respond to complaints, regulatory inquiries, or carrier audits

• Defend against claims, arbitration demands, or litigation

• Preserve defenses related to consent, opt-out timing, wrong-party notice, or reassigned numbers

Retention periods vary by record type, risk profile, and operational need and may extend beyond termination of any relationship where reasonably necessary for compliance or litigation defense.

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10.5 No Private Right to Records or Discovery Expansion

Nothing in this Policy creates:

• A private right for any individual to access, inspect, or demand Rivvia’s internal records

• An obligation to produce records absent valid legal process

• A duty to reconstruct, recreate, or supplement records not maintained in the ordinary course

• A presumption that missing, incomplete, or unavailable records establish TCPA violations

Rivvia will respond to lawful subpoenas, court orders, or regulatory requests in accordance with applicable law and procedural protections.

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10.6 Serial Litigator, Bad-Faith & Abuse Defense

Rivvia acknowledges that TCPA statutes are frequently exploited by serial litigants and professional plaintiffs seeking statutory damages disconnected from actual harm.

Accordingly, Rivvia’s recordkeeping and compliance practices are designed to preserve and assert all available defenses, including but not limited to:

• Valid prior express consent

• Timing and scope of consent revocation

• Wrong-party or reassigned number defenses

• Lack of authorization or agency

• Independent contractor misconduct outside scope of authorization

• Consent misuse or manipulation by claimants

• Standing, credibility, and good-faith challenges

Rivvia expressly reserves the right to pursue dismissal, sanctions, fee-shifting, or other remedies in response to abusive or bad-faith claims.

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10.7 No Waiver of Rights, Privileges, or Defenses

The creation, maintenance, production, or disclosure of records:

• Does not waive attorney-client privilege, work-product protection, or other privileges

• Does not constitute an admission of liability or wrongdoing

• Does not establish control, agency, or ratification of independent contractor conduct

• Does not limit Rivvia’s right to assert arbitration provisions, class-action waivers, statute-of-limitations defenses, or statutory exemptions

All rights, remedies, and defenses are expressly reserved.

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11. Third-Party Vendors, Platforms, Fiber Brand Partners, Lead Sources & Line-of-Sight Business Relationships

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Rivvia Sales, LLC operates as a sales facilitation, recruiting, and operational support organization that coordinates with multiple third parties, including technology vendors, communications platforms, and fiber internet service providers (“Fiber Brand Partners”). These relationships are structured to enable lawful outreach, operational efficiency, and customer introductions while maintaining clear separation of roles, responsibilities, and legal obligations.

Nothing in this Policy shall be construed as creating a partnership, joint venture, franchise, fiduciary, or agency relationship unless expressly set forth in a separate written agreement.

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11.1 Communications Platforms, Aggregators & Carriers

Rivvia may utilize third-party platforms, aggregators, carriers, or vendors to support communications and operational functions, including but not limited to:

• SMS, MMS, and voice communication platforms

• Application-to-Person (“A2P”) messaging aggregators

• Mobile network carriers and routing providers

• CRM, lead-management, mapping, and territory tools

• Cloud infrastructure, analytics, logging, and security providers

All vendors engaged by Rivvia for communications are contractually required to:

• Comply with the TCPA, FCC rules, and applicable state laws

• Adhere to carrier policies, messaging guidelines, and A2P 10DLC requirements

• Implement reasonable administrative, technical, and physical data-security safeguards

• Process data only for authorized purposes and in accordance with Rivvia’s instructions

Rivvia does not control carrier-level delivery decisions and is not responsible for delays, filtering, throttling, blocking, or delivery failures caused by carriers, aggregators, spam-mitigation systems, or network conditions beyond Rivvia’s direct control.

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11.2 Fiber Brand Partners & “Live Fiber Area” Information

Rivvia may receive service availability information, market activation notifications, build-completion updates, or geographic indicators from Fiber Brand Partners identifying areas where fiber internet service has recently become available or is designated as “live,” “lit,” or serviceable (“Live Fiber Areas”).

Such information may include high-level geographic indicators (e.g., neighborhoods, streets, or zones) and is used solely to:

• Identify areas where fiber service may be available

• Support door-to-door, in-person outreach conducted independently by contractors

• Facilitate lawful introductions between consumers and Fiber Brand Partners

• Support internal operational tracking, attribution, and reporting

Rivvia does not control, own, operate, or manage the underlying fiber networks, infrastructure, installation processes, billing systems, pricing structures, promotions, or service eligibility determinations of any Fiber Brand Partner.

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11.3 Line-of-Sight Business Relationship Clarification

In connection with Fiber Brand Partners, Rivvia may operate within a line-of-sight business relationship for sales and referral purposes. Under this model:

• Rivvia may promote awareness of fiber availability in designated areas

• Independent contractors may represent the existence of available fiber service, subject to approved disclosures

• Prospective customers are introduced or referred to the Fiber Brand Partner

• Customers ultimately enter into a direct contractual relationship with the Fiber Brand Partner, not Rivvia

• All payments, billing, service provisioning, installation approvals, and ongoing service obligations are handled exclusively by the Fiber Brand Partner

Rivvia does not collect customer payments for fiber service and does not act as the merchant of record.

Nothing in this Policy creates an “established business relationship” between Rivvia and a consumer for purposes of TCPA marketing exceptions unless independently created through lawful consent.

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11.4 Independent Contractor Sales Activity, Accounts & Attribution

Independent contractors affiliated with Rivvia may be associated with specific territories, leads, or sales activity for operational attribution purposes only. Such attribution:

• Is used to track activity, performance, and compensation eligibility

• Does not constitute ownership of customer accounts

• Does not create a direct contractual relationship between the contractor and the Fiber Brand Partner unless separately agreed

• Does not authorize the contractor to modify pricing, service terms, installation timelines, or eligibility requirements

Independent contractors are not authorized to accept payments, guarantees, deposits, or contractual commitments on behalf of Rivvia or any Fiber Brand Partner.

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11.5 Communications, Consent & Brand Representation Boundaries

Any communications conducted through Rivvia-approved systems in connection with Fiber Brand Partner offerings:

• Must comply with this TCPA Compliance Policy, Rivvia’s SMS/Text Messaging Policy, and Privacy Policy

• Must be supported by valid consent where required by law

• Must not imply that Rivvia controls, guarantees, or provides the fiber service itself

• Must clearly distinguish Rivvia’s role from that of the Fiber Brand Partner

Rivvia does not sell, rent, license, or transfer SMS opt-in data, consent records, or messaging permissions to Fiber Brand Partners for independent marketing or outreach purposes.

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11.6 Separation of Liability & Responsibility

Rivvia is not responsible for:

• Communications initiated independently by Fiber Brand Partners

• Communications initiated by independent contractors outside Rivvia-approved systems

• Representations made by contractors beyond approved materials

• Carrier-level filtering, throttling, blocking, or delivery failures

• Acts or omissions of third-party vendors beyond contractual scope

Each Fiber Brand Partner, vendor, and independent contractor remains independently responsible for its own compliance with applicable laws, regulations, and carrier requirements.

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11.7 No Agency, Joint Venture, or Ratification

The existence of referrals, lead indicators, territory data, Live Fiber Area information, branding materials, or compensation arrangements does not:

• Create an agency or joint-venture relationship

• Establish joint control over communications

• Constitute ratification of unauthorized conduct

• Transfer TCPA liability between parties

All parties operate independently within their respective roles.

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12. Independent Contractors, Door-to-Door Activity, Limited System Access & Indemnification

Rivvia Sales, LLC engages independent contractors (“ICs”) who may conduct in-person, door-to-door outreach as part of their independent business activities. These individuals are not employees, agents, partners, or joint venturers of Rivvia, and Rivvia does not control the manner, means, timing, location, or substance of their in-person interactions with members of the public.

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Independent contractors may be provided limited, conditional access to certain Rivvia tools or applications (the “Rivvia App”) for purposes such as territory awareness, lead tracking, documentation, or operational support. Access to Rivvia tools does not constitute control, supervision, or direction of in-person conduct, and does not create an agency, employment, or fiduciary relationship.

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12.1 No Control Over Door-to-Door Conduct

Rivvia does not control, supervise, or direct:

• Which doors an independent contractor chooses to knock

• The timing, duration, or frequency of in-person visits

• The language used in face-to-face conversations

• The contractor’s compliance with local solicitation, permitting, or trespass laws

All door-to-door activity is conducted independently and at the contractor’s sole discretion and risk.

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12.2 Limited & Conditional Use of Rivvia Systems

Independent contractors may use Rivvia-provided systems, including the Rivvia App, only for authorized purposes and only within the scope expressly permitted by Rivvia.

Rivvia systems may include safeguards, logging, or restrictions designed to support compliance; however:

• Rivvia does not monitor or control real-time in-person behavior

• System access does not guarantee compliance by the contractor

• Contractors remain solely responsible for their actions, representations, and communications

Use of Rivvia systems is a revocable privilege, not a right.

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12.3 Prohibited Conduct Using Rivvia Systems

Independent contractors are strictly prohibited from:

• Using Rivvia systems to initiate calls or texts without valid consent

• Uploading, entering, or using contact information obtained unlawfully or deceptively

• Using personal phone numbers, devices, or messaging accounts to communicate on Rivvia’s behalf

• Sending unapproved scripts, content, or representations through Rivvia systems

• Attempting to bypass opt-out, suppression, or compliance controls

• Representing themselves as employees or agents of Rivvia

 

12.4 Consent Collection Limitations

In-person door-to-door interactions do not automatically authorize future electronic communications.

Independent contractors are not authorized to:

• Represent that consent to receive calls or texts is required

• Collect consent without required disclosures

• Enter or upload consent into Rivvia systems unless obtained lawfully

• Misstate Rivvia’s authority, pricing, availability, or guarantees

Any consent collected must comply with Rivvia’s disclosure standards and applicable law.

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12.5 Independent Contractor Responsibility

Independent contractors are solely responsible for:

• Their compliance with TCPA, state telemarketing laws, and local solicitation laws

• Their in-person conduct, statements, and representations

• Any communications initiated outside Rivvia-approved systems

• Any misuse of Rivvia tools or data

Rivvia expressly disclaims responsibility for unauthorized or improper acts by independent contractors.

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12.6 Indemnification by Independent Contractors

To the maximum extent permitted by law, each independent contractor agrees to defend, indemnify, and hold harmless Rivvia Sales, LLC, its members, managers, officers, employees, partners, and affiliates from and against any and all claims, demands, damages, penalties, fines, liabilities, costs, or expenses (including attorneys’ fees) arising out of or related to:

• The contractor’s door-to-door activities

• Violations of TCPA, FCC rules, state telemarketing laws, or local solicitation laws

• Unauthorized communications or misuse of Rivvia systems

• False, misleading, or unauthorized representations

• Failure to obtain or properly document consent

• Acts or omissions outside Rivvia’s approved systems

This indemnification obligation survives termination of access or contractual relationship.

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12.7 Enforcement & Revocation of Access

Rivvia reserves the right, but does not assume an obligation, to:

• Audit system usage

• Investigate suspected violations

• Suspend or revoke access to Rivvia systems

• Terminate contractual relationships

Such actions do not constitute supervision, control, or acceptance of liability for independent contractor conduct.

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12.8 No Assumption of Agency or Vicarious Liability

Nothing in this Policy, nor the provision of tools, training, or systems, shall be construed to create agency, employment, or vicarious liability. Independent contractors act solely on their own behalf, and Rivvia does not ratify unauthorized conduct.

 

13. General Compliance Guides, Resources & Independent Contractor Responsibility

Rivvia Sales, LLC may make available general compliance guides, informational materials, written policies, or reference resources related to TCPA requirements, communications laws, and best practices (collectively, “Compliance Guides”). These Compliance Guides are provided solely for informational and reference purposes and are intended to support general awareness of applicable legal standards.

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The provision of Compliance Guides:

• Does not constitute mandatory training

• Does not create supervision, direction, or control

• Does not establish an employment, agency, or fiduciary relationship

• Does not guarantee compliance by any individual

Independent contractors are not required to review, complete, certify, or follow any Compliance Guide as a condition of their independent contractor status, unless expressly agreed to in a separate written agreement.
 

13.1 Independent Contractor Responsibility

Independent contractors remain solely and independently responsible for:

• Understanding and complying with all applicable federal, state, and local laws

• Ensuring their own communications, representations, and conduct comply with TCPA, FCC rules, state telemarketing laws, and local solicitation requirements

• Determining how, when, and whether to apply any information contained in Compliance Guides

Rivvia does not monitor, evaluate, or enforce how independent contractors interpret or apply Compliance Guides in their independent activities.
 

13.2 No Oversight or Control

Rivvia does not:

• Supervise or direct independent contractor communications or conduct

• Audit or certify compliance with Compliance Guides

• Require reporting, testing, or completion of compliance materials

• Assume responsibility for independent contractor compliance decisions

The availability of Compliance Guides does not create a duty of oversight, inspection, or enforcement by Rivvia.
 

13.3 No Reliance or Legal Advice Disclaimer

Compliance Guides are not legal advice and should not be relied upon as a substitute for independent legal counsel. Independent contractors are encouraged to consult their own advisors regarding applicable laws and requirements.

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14. Enforcement, Violations, Corrective Actions & Independent Contractor Liability

Rivvia Sales, LLC reserves the right, but does not assume an obligation, to take corrective or protective action in response to suspected, alleged, or confirmed violations of this TCPA Compliance Policy, related communications policies, or applicable law.

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Nothing in this Section shall be construed as creating a duty to monitor, supervise, direct, or enforce compliance with respect to independent contractor activities, nor shall any enforcement or corrective action be interpreted as evidence of control, agency, or employment.

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14.1 Corrective Actions

Where Rivvia becomes aware of conduct that may violate this Policy, Rivvia may, in its sole discretion and to the extent permitted by law, take one or more of the following actions:

• Suspension, limitation, or termination of access to Rivvia systems, platforms, applications, or tools

• Temporary or permanent revocation of calling, messaging, or application privileges

• Termination of contractor, representative, or referral relationships

• Forfeiture, withholding, chargeback, or nonpayment of commissions or compensation, where legally permitted

• Referral or reporting to partners, carriers, aggregators, platforms, or regulatory authorities where required or deemed appropriate

Corrective action may be taken with or without prior notice, depending on the nature, severity, or risk associated with the conduct.

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14.2 No Obligation to Enforce; No Waiver

Rivvia’s decision to take, or not take, corrective or enforcement action:

• Does not waive Rivvia’s rights under this Policy or any other agreement

• Does not create a precedent or expectation of future enforcement

• Does not constitute acceptance, approval, or ratification of any conduct

• Does not create an obligation to investigate, audit, monitor, or supervise independent contractor activities

Failure to enforce any provision at any time shall not be deemed a waiver of Rivvia’s right to enforce such provision at a later time.

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14.3 Independent Contractor Responsibility

Independent contractors and representatives remain solely and independently responsible for their own conduct, communications, representations, and compliance with applicable federal, state, and local laws.

Any corrective action taken by Rivvia is remedial and protective in nature only and does not shift responsibility, liability, or legal exposure from the independent contractor to Rivvia.

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14.4 No Responsibility for Unauthorized or Unlawful Mass Messaging

Rivvia Sales, LLC is not responsible for, and expressly disclaims liability for, any unauthorized, unlawful, or non-compliant communications initiated by independent contractors or representatives, including but not limited to mass texting, bulk messaging, robocalls, automated outreach, or similar activity conducted:

• Outside Rivvia-approved systems

• Without valid, documented consent

• In violation of this Policy, TCPA, FCC regulations, carrier rules, or applicable state law

 

Independent contractors are not authorized to engage in mass texting or bulk messaging on Rivvia’s behalf except through Rivvia-approved systems and only where all legal consent requirements are satisfied. Any such activity conducted using personal devices, third-party tools, unapproved platforms, or unlawfully obtained contact lists is undertaken solely at the independent contractor’s own direction and risk.

Rivvia does not direct, control, approve, benefit from, or ratify unauthorized mass messaging activities. Such conduct shall be deemed outside the scope of any authorization granted by Rivvia and may constitute a material breach of applicable agreements.

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To the maximum extent permitted by law:

• Responsibility for TCPA violations, fines, penalties, damages, and claims arising from such conduct rests solely with the independent contractor

• Rivvia disclaims any joint, vicarious, or derivative liability for such actions

 

14.5 Cooperation With Investigations

Where required by law, regulation, carrier rules, or contractual obligation, Rivvia may cooperate with investigations or inquiries conducted by regulators, carriers, platforms, or partners. Such cooperation does not constitute an admission of wrongdoing or acceptance of liability.

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15. State Law Compliance

Rivvia complies with all applicable state telemarketing, calling, and consent laws. Where state law imposes stricter requirements than federal law, the stricter standard applies.

 

16. No Emergency Communications

Communications from Rivvia are not emergency communications. Individuals should not rely on calls or texts from Rivvia for urgent medical, legal, safety, or time-sensitive matters.

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17. Policy Updates & Legal Supremacy

Rivvia reserves the right to modify this TCPA Compliance Policy to reflect changes in law, regulatory guidance, or carrier rules.

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If any provision of this Policy conflicts with applicable law, the law shall govern to the minimum extent required, and the remaining provisions shall remain enforceable.

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19. Contact Information

Questions regarding this TCPA Compliance Policy or Rivvia’s communication practices may be directed to:

Rivvia Sales – Compliance Support
Email: support@rivviasales.com
Website: https://www.rivviasales.com