Acceptable Use Policy

Effective date: October 14, 2026

This Acceptable Use Policy (this "Policy" or "AUP") describes activities that are prohibited when using CallPayWall, including the CallPayWall iOS application, the CallPayWall Android application, the website at callpaywall.com, the in-app AI assistant named "Paige", the telemarketer and caller portal, and all related features and services (collectively, the "Service"), operated by Paywall Inc., a Delaware corporation ("Company", "we", "us", or "our").

This Policy is incorporated into and forms part of our Terms of Service. Capitalized terms not defined here have the meanings given in the Terms of Service. By using the Service, whether as an account owner, a caller, a telemarketer, an affiliate, or any other user, you agree to comply with this Policy. We may update this Policy from time to time, and your continued use of the Service after an update constitutes acceptance of the updated Policy.

This Policy is not exhaustive. We may investigate and act against any use of the Service that we determine, in our reasonable discretion, to be harmful, abusive, unlawful, or otherwise inconsistent with the purpose of the Service, even if it is not specifically listed below.

1. Your Responsibility for Compliance

You are responsible for all activity conducted through your account and for ensuring that your use of the Service complies with all applicable laws and regulations, including telecommunications, telemarketing, consumer-protection, anti-fraud, data-protection, recording-consent, and anti-spam laws. Because the Service involves placing, screening, recording, charging for, and routing telephone calls, sending messages and emails, and capturing and handling leads, you bear particular responsibility for the lawfulness of those communications in every jurisdiction involved.

2. Prohibited Telephony and Messaging Conduct

You must not use the Service to:

• Conduct illegal telemarketing, robocalling, or autodialing. You must not use the Service to make, facilitate, or support telemarketing calls, robocalls, prerecorded or artificial-voice calls, or autodialed calls in violation of the Telephone Consumer Protection Act ("TCPA"), the Telemarketing Sales Rule, federal or state "Do Not Call" requirements, or any similar law in any jurisdiction.
• Ignore consent and do-not-call requirements. You must not contact any person who has not provided required consent, who has revoked consent, who has asked not to be contacted, or who is on an applicable do-not-call list, where the law requires honoring such requests.
• Spoof, falsify, or misrepresent caller identity. You must not transmit false or misleading caller-ID, "spoofed" numbers, or inaccurate origination information in violation of applicable law.
• Violate messaging rules. You must not send SMS, MMS, or other messages in violation of US A2P 10DLC registration requirements, carrier policies, the CAN-SPAM Act, or other anti-spam laws, including unsolicited bulk or commercial messages and messages with deceptive content or missing required identifications or opt-out mechanisms.
• Generate junk traffic. You must not generate artificial, fraudulent, or high-volume traffic intended to inflate metrics, manipulate billing or payouts, commit toll fraud, or abuse telephony resources.
• Interfere with emergency services. You must not use the Service to block, intercept, delay, charge for, or otherwise interfere with calls to 911 or other emergency services.

3. Fraud, Scams, and Deceptive Practices

You must not use the Service, including the call, email, SMS, voicemail, or lead-capture channels, to:

• Engage in fraud, phishing, social engineering, impersonation, or identity theft;
• Make deceptive, misleading, or false sales pitches, offers, or representations;
• Operate or promote scams, pyramid or Ponzi schemes, fake invoices, "tech-support" scams, or other illegitimate schemes;
• Solicit payments, credentials, or sensitive personal or financial information under false pretenses;
• Misrepresent your identity, affiliation, authority, or the nature of your communication; or
• Circumvent, manipulate, or abuse the Service's payment, screening, classification, scheduling, or refund features, including attempting to reach an account owner without paying a required fee or to evade screening.

4. Harassment, Abuse, and Harmful Content

You must not use the Service to:

• Harass, threaten, stalk, intimidate, defame, or abuse any person;
• Transmit content that is unlawful, obscene, sexually exploitative (including any content that sexually exploits or endangers minors), hateful, or that incites violence;
• Promote illegal goods or services, including illegal drugs, weapons, or other contraband;
• Distribute malware, viruses, or other malicious code; or
• Engage in any conduct that is harmful to the safety or well-being of others.

5. Misuse of Leads and Personal Data

The Service allows account owners to capture, store, and, where permitted, resell business leads. You must not:

• Capture, use, share, sell, transfer, or resell any lead or personal data in violation of applicable law, including data-protection and consumer-protection laws, or in violation of the rights or reasonable expectations of the individuals to whom the data relates;
• Resell or transfer leads without having a lawful basis and any required consents or notices;
• Use leads or contact information to send unlawful communications or to contact individuals who have opted out or who must not be contacted;
• Combine, enrich, or repurpose lead data in ways that are unlawful or deceptive; or
• Fail to honor data-subject rights, deletion requests, or opt-outs that you are legally required to honor.

You are the controller of, and responsible for, the lead and personal data you capture and handle through the Service.

6. Unlawful Recording and Monitoring

Calls handled through the Service may be recorded, transcribed, and screened. Recording-consent laws vary, and some jurisdictions require the consent of all parties. You must not:

• Record, transcribe, monitor, or intercept any call or communication without all consents and notices required by applicable law in every relevant jurisdiction;
• Use recordings or transcripts for any unlawful purpose, including blackmail, harassment, or unauthorized disclosure; or
• Disable, defeat, or fail to use required recording-notification features where the law requires notice.

7. Platform Abuse, Security, and Integrity

You must not:

• Access or attempt to access any account, system, data, or area of the Service that you are not authorized to access;
• Probe, scan, or test the vulnerability of the Service or breach or circumvent any security or authentication measures;
• Scrape, crawl, harvest, or use automated means to extract data from the Service except as expressly permitted;
• Interfere with or disrupt the integrity or performance of the Service or the infrastructure of the Company or its providers (including our cloud hosting, telephony, and payment providers), including through denial-of-service attacks or excessive load;
• Reverse-engineer, decompile, or disassemble any part of the Service, except to the limited extent expressly permitted by law;
• Resell, sublicense, or commercially exploit the Service except as expressly authorized;
• Create accounts by automated means or under false pretenses, or maintain more than one account to evade enforcement, limits, or payment; or
• Abuse, defraud, or manipulate the affiliate or referral program, including through self-referrals, fake acquisitions, or fraudulent revenue-share or per-acquisition claims.

8. Payment and Financial Misuse

You must not use the Service to launder money, finance illegal activity, evade sanctions, process payments for prohibited goods or services, or otherwise misuse the Service's payment, payout, or KYC features. You must provide accurate information for billing, payouts, and identity verification, and you must not provide false or stolen payment credentials or engage in fraudulent chargebacks.

9. Reporting Abuse

If you become aware of any violation of this Policy, or of any abuse, fraud, security issue, or unlawful conduct involving the Service, please report it promptly to us at support@callpaywall.com. Please include sufficient detail to allow us to investigate, such as relevant account identifiers, phone numbers, timestamps, and a description of the conduct.

10. Enforcement and Consequences

We may investigate suspected violations of this Policy and take any action we consider appropriate, in our reasonable discretion, including:

• Issuing a warning;
• Removing, disabling, or restricting access to content, configurations, leads, or features;
• Throttling, suspending, or limiting your access to the Service;
• Withholding, reversing, freezing, or forfeiting payments, payouts, or affiliate earnings associated with the violation;
• Terminating your account and these agreements;
• Preserving and disclosing information as permitted or required by law; and
• Reporting conduct to law-enforcement authorities, regulators, carriers, payment processors, or other appropriate parties, and cooperating with their investigations.

We may take these actions with or without prior notice, depending on the severity of the violation and the risk to the Service, other users, or third parties. Our decision not to enforce any provision of this Policy in a particular instance does not waive our right to enforce it later. You are responsible for any losses or liabilities resulting from your violation of this Policy, as further described in the indemnification provisions of the Terms of Service.

11. Contact

Paywall Inc. Email (support / abuse reports): support@callpaywall.com or support@callpaywall.com Email (legal): legal@callpaywall.com or legal@callpaywall.com Mailing address: 16192 Coastal Highway, Lewes, DE 19958