Regulatory Compliance

1. Our BYOC Position & Regulatory Classification

Ascent24 Technologies LLP is classified as a software application provider, not a telecommunications carrier. Under this model:

• You connect your own Twilio account — ReachTo App connects to your Twilio account over Twilio's Voice API
• All telephony routes, phone numbers, SIP trunks, and carrier interconnects are managed entirely by Twilio Inc. under their own carrier agreements and FCC/Ofcom/regulatory filings
• ReachTo App does not own, lease, or sublease any telephone numbers, PSTN access, or spectrum capacity
• We do not process, switch, or route any call audio — all voice traffic flows directly through Twilio's media servers
• ReachTo App does not file or hold any carrier licenses (CLEC, IXC, VoIP provider registrations) with the FCC, Ofcom, TRAI, or equivalent bodies

Accordingly, the primary regulatory obligations associated with telecommunications — including number registration, lawful intercept capability, E911 compliance, and carrier reporting — are fulfilled by your upstream carrier (Twilio), not by Ascent24 Technologies LLP.

2. TCPA & US Telemarketing Law

The Telephone Consumer Protection Act (TCPA) and FCC regulations govern how businesses and individuals may contact consumers by phone in the United States. As a ReachTo App user, you are responsible for ensuring your calling activity complies with TCPA and related rules:

• Prior Express Consent: You must obtain appropriate prior express written consent before making any autodialed, prerecorded, or artificial-voice calls to mobile phones or residential lines for marketing purposes
• Do-Not-Call Registry: You must honor the National Do-Not-Call Registry and any company-specific opt-out requests. ReachTo App does not automatically scrub your contact lists against DNC registries — this is your responsibility
• Caller ID: You may only display a caller ID that is a valid phone number you are authorized to use. Caller ID spoofing for deceptive purposes violates the Truth in Caller ID Act
• Call Recording: If you enable call recording through Twilio, you must comply with all applicable one-party and two-party consent recording laws for the jurisdiction of the parties on the call
• TRACED Act: ReachTo App supports STIR/SHAKEN caller authentication through Twilio's certified gateway, consistent with FCC TRACED Act mandates

ReachTo App reserves the right to suspend accounts where TCPA violations are reported or detected. We cooperate with FCC enforcement inquiries when legally required.

3. GDPR & EU/UK Data Protection Rules

The General Data Protection Regulation (GDPR) and UK GDPR apply to the processing of personal data of individuals located in the EU and UK. ReachTo App's obligations and your obligations under GDPR are separate:

• ReachTo as Data Processor: When you use ReachTo App to make calls, we may process personal data (call logs, contact phone numbers, timestamps) on your behalf. In this capacity, we act as a data processor under GDPR Article 28
• You as Data Controller: As the ReachTo App account holder, you are the data controller responsible for determining the lawful basis under which you contact individuals, managing consent, and honoring data subject rights
• Data Processing Agreement: Our Privacy Policy serves as the core data processing agreement. Enterprise customers requiring a formal DPA should contact our team
• Data Transfers: Your data may be processed in the United States where our servers and Twilio's infrastructure are located. We rely on Standard Contractual Clauses (SCCs) as the lawful transfer mechanism for EU data flows
• ePrivacy / PECR: Calls made to EU/UK individuals for direct marketing purposes are subject to ePrivacy Directive and UK PECR rules. You must ensure you hold appropriate consent before making such calls

For all GDPR-related inquiries, contact our team. We respond to data subject access requests and erasure requests within 30 days.

4. STIR/SHAKEN & Caller Authentication

STIR (Secure Telephony Identity Revisited) / SHAKEN (Signature-based Handling of Asserted information using toKENs) is the framework mandated by the FCC TRACED Act for authenticating caller ID on VoIP and telephony networks.

• ReachTo App routes all calls through Twilio's PSTN gateway, which is a registered STIR/SHAKEN-compliant originating service provider
• Twilio digitally signs outbound calls with an attestation level (A, B, or C) based on the relationship between the caller and the number being presented as caller ID
• Attestation A (Full): Applies when you use a Twilio number that is directly registered to your Twilio account
• Attestation B (Partial): Applies when you use a number that Twilio has verified you are authorized to use but does not own
• Attestation C (Gateway): May apply in international or BYOC trunk scenarios where full chain-of-trust cannot be established
• ReachTo App does not independently handle STIR/SHAKEN signing — this is performed entirely at the Twilio carrier layer

To maximize attestation level and avoid call-blocking by receiving carriers, we recommend using Twilio-provisioned numbers as your primary caller ID within ReachTo App.

5. Emergency Calling (E911 / 999 / 112)

Important Notice: ReachTo App is NOT a certified emergency calling service and must NOT be used as the sole or primary means of placing emergency calls.

ReachTo App is a BYOC business telephony client. It does not have access to your physical location data and does not integrate with E911 (Enhanced 911) positioning systems in the United States, 999 emergency services in the UK, or 112 in the EU.

• Do not rely on ReachTo App to place calls to emergency services (911, 999, 112, or any local equivalent)
• If you attempt to dial an emergency number through ReachTo App, the call may be routed via Twilio's VoIP infrastructure, which may not deliver your location information to the PSAP (Public Safety Answering Point)
• Always use a traditional cellular network, landline, or FCC-compliant VoIP service with registered E911 to contact emergency services
• If Twilio's BYOC services include E911 registration for a specific number, that registration is between you and Twilio — ReachTo App is not involved in that process

By using ReachTo App, you acknowledge and accept these emergency calling limitations.

6. Carrier-Level Regulatory Obligations

The following regulatory obligations belong to your upstream carrier (Twilio) and not to Ascent24 Technologies LLP. You should refer to Twilio's compliance documentation for details on each:

• CPNI (Customer Proprietary Network Information): Twilio is responsible for CPNI protection requirements under 47 U.S.C. § 222. ReachTo App does not hold CPNI independently
• CALEA (Communications Assistance for Law Enforcement Act): Lawful intercept obligations under CALEA are fulfilled by Twilio as a covered telecommunications carrier. ReachTo App is not a CALEA-covered entity
• Number Portability: Number porting (LNP) is administered by Twilio. ReachTo App has no role in porting processes
• USF Contributions: Universal Service Fund (USF) fees applicable to interstate VoIP calls are assessed and remitted by Twilio. ReachTo App subscription fees do not include USF surcharges separately
• TRAI / Indian Telecom Regulations: Users operating in India must ensure their Twilio account is configured to comply with TRAI DLT (Distributed Ledger Technology) regulations for commercial communications. ReachTo App does not manage TRAI DLT headers or consent templates
• Ofcom Registration (UK): VoIP services in the UK may require Ofcom notification. Twilio holds the relevant Ofcom registration for its VoIP services used by ReachTo App

7. International Telecom Compliance

ReachTo App is available globally. Users in certain jurisdictions are subject to additional local regulations. You are responsible for ensuring your use of the platform complies with local laws in your country of operation:

• India (TRAI): Commercial calls in India require prior DLT registration of sender IDs, call templates, and telemarketer registration. Non-compliance with TRAI regulations can result in number blocking by Indian carriers
• Australia (ACMA): The Australian Communications and Media Authority (ACMA) enforces the Do Not Call Register Act and Spam Act. Users calling Australian numbers for marketing must comply with these regulations
• Canada (CRTC): Canada's Anti-Spam Legislation (CASL) and CRTC rules on unsolicited telecommunications apply. You must maintain consent records for all marketing calls to Canadian numbers
• Germany / EU: Germany's UWG (Act Against Unfair Competition) and EU ePrivacy rules place strict limits on cold-calling for B2C marketing. Ensure you have a lawful basis before calling EU consumers
• Singapore (PDPA): Singapore's Personal Data Protection Act and Do Not Call registry apply to marketing calls. You must check the DNC registry before calling Singapore numbers for marketing

ReachTo App does not verify compliance with local regulations on your behalf. It is your responsibility to understand and comply with the telecom laws applicable to your target calling regions.

8. User Regulatory Responsibilities & Compliance

By using ReachTo App, you represent, warrant, and agree that you will:

• Compliance with Country Rules: Strictly adhere to the local laws, regulations, and telecommunications rules of your country. If any violation of local or national rules occurs, the company (Ascent24 Technologies LLP) is not responsible or liable under any circumstances
• Only use the platform for lawful calling activity permitted in your jurisdiction and in the jurisdictions of parties you are calling
• Maintain all required registrations, licenses, and consents required by applicable telecom law before initiating calls through the platform
• Not use ReachTo App to conduct robocalling campaigns, autodial consumers without prior written consent, or otherwise violate TCPA, PECR, or equivalent laws
• Not spoof caller ID information in any deceptive, misleading, or unlawful manner
• Ensure that any call recordings made using Twilio's recording features comply with all applicable consent and disclosure laws for the recording jurisdiction
• Immediately stop using the platform for any activity upon being made aware that such activity violates applicable law
• Cooperate with ReachTo App and Twilio in good faith if either party receives a complaint or regulatory inquiry relating to your calling activity

Violation of these responsibilities may result in immediate account suspension and/or reporting to relevant regulatory authorities. ReachTo App reserves the right to determine, in its sole discretion, whether a violation has occurred.

9. Regulatory Contact

For questions about our regulatory compliance position, to request compliance documentation, or to submit a regulatory inquiry, please contact us: