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TCPA Consent Policy & Procedures

1. Overview

AgoryLeads LLC ("Company," "we," "us," or "our") is committed to full compliance with the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, and related federal and state telecommunications regulations. This policy outlines our consent requirements, procedures, and consumer rights regarding telephone communications.

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Our Commitment: All leads generated by AgoryLeads include documented, verifiable consent from consumers to be contacted by insurance professionals using the phone numbers provided.

2. TCPA Consent Requirements

Express Written Consent

For all leads involving potential automated calls, text messages, or calls to wireless numbers, we obtain express written consent that includes:

Required Elements:

  • Clear disclosure that consent is being provided for insurance marketing calls

  • Specific phone number(s) to which consent applies

  • Understanding that automated dialing systems may be used

  • Agreement that consent is not required as a condition of purchase

  • Instructions for how to revoke consent

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Sample Consent Language: "I understand and agree that by providing my phone number and clicking 'Get My Quote' or similar button, I am giving my express written consent for AgoryLeads, its partners, and the insurance professionals in their network to contact me at the phone number(s) provided using automated dialing systems, prerecorded messages, and/or text messages, even if my phone number is on a Do Not Call list. I understand this consent is not required to make a purchase."

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Express Oral Consent

For leads generated through telephone interactions:

  • Clear verbal consent is obtained and recorded

  • Consumers are informed they're providing consent for insurance marketing calls

  • Date, time, and phone number are documented

  • Audio recordings are retained for compliance purposes

3. Consent Documentation

Record Keeping Requirements

We maintain comprehensive records of all consent for a minimum of 4 years, including:

  • Date and time of consent

  • Phone number(s) for which consent was provided

  • Method of consent (written, oral, electronic)

  • Source of the lead (website, phone call, partner)

  • Complete consent script or language used

  • Consumer's name and contact information

  • IP address (for online consents)

  • Audio recording (for phone-based consents)

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Consent Verification Process

  • All consent records are timestamped and stored in secure systems

  • Regular audits ensure consent documentation completeness

  • Consent records are made available to insurance professionals upon request

  • Compliance team conducts monthly consent quality reviews

4. Global Call Center Operations

International Partner Compliance

AgoryLeads works with call centers located internationally to generate leads. All international partners must:

  • Follow equivalent TCPA consent standards

  • Use approved consent scripts in appropriate languages

  • Maintain documented proof of consent for each lead

  • Undergo regular compliance training and auditing

  • Report consent acquisition data in real-time to US-based systems

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Consent Standardization

  • All global partners use standardized consent language approved by our legal team

  • Consent scripts are translated by certified translators where needed

  • Regular quality monitoring ensures consistent consent procedures

  • Monthly compliance reports from all international locations

5. Consumer Rights & Opt-Out Procedures

Opt-Out Processing

  • All opt-out requests are processed within 10 business days

  • Consumers receive confirmation of opt-out status

  • Numbers are added to internal Do Not Call suppression lists

  • All call center partners receive immediate updates

  • Global suppression across all systems and partners

Do Not Call Registry Compliance

  • All phone numbers are scrubbed against National Do Not Call Registry before contact

  • State-specific Do Not Call registries are checked where applicable

  • Monthly updates ensure current DNC status for all numbers

  • Established business relationship exemptions are properly documented

6. Lead Delivery & Consent Transfer

We implement comprehensive security measures to protect personal information:

Technical Safeguards:

  • Encryption of data in transit and at rest

  • Secure servers located in the United States

  • Access controls and authentication requirements

  • Regular security audits and vulnerability assessments

Administrative Safeguards:

  • Employee privacy and security training

  • Incident response procedures

  • Vendor management and oversight programs

  • Regular policy reviews and updates

Physical Safeguards:

  • Secure facility access controls

  • Environmental protections for servers and equipment

  • Secure disposal of physical documents and media

7. Automated Systems & Technology

Autodialer and Prerecorded Message Consent

For leads that may receive automated calls:

  • Specific consent for automated dialing systems is obtained

  • Consent includes permission for prerecorded messages where applicable

  • Technology limitations and capabilities are clearly disclosed

  • Consent covers reasonable frequency of contact attempts

Text Message Consent

For leads that may receive text messages:

  • Separate consent is obtained for SMS communications

  • Message frequency expectations are disclosed

  • Standard message and data rates apply disclaimers are provided

  • Clear opt-out instructions ("Reply STOP") are included

8. Compliance Monitoring & Quality Assurance

Internal Compliance Program

  • Dedicated compliance team monitors TCPA adherence

  • Regular training for all staff and international partners

  • Monthly compliance audits and reporting

  • Incident response procedures for potential violations

Quality Assurance Procedures

  • Random sampling of consent documentation

  • Call monitoring and recording review

  • Consumer complaint tracking and resolution

  • Regular legal and regulatory update training

9. Consumer Complaint Resolution

  • Complaint Process

  • Consumers with TCPA-related concerns may:

  • Contact our compliance department at tcpa@agoryleads.com

  • Call our dedicated compliance line: (415) XXX-XXXX

  • Submit written complaints to our San Francisco office

  • Request immediate removal from all calling lists

  • Resolution Procedures

  • All complaints are investigated within 5 business days

  • Consumers receive written response regarding findings and actions taken

  • Immediate suppression of phone numbers pending investigation

  • Corrective actions implemented to prevent future issues

10. Regulatory Updates & Changes

Staying Current

  • Regular monitoring of FCC rulings and TCPA updates

  • Participation in industry associations and compliance organizations

  • Legal counsel review of regulatory changes

  • Prompt implementation of required procedure updates

Policy Updates

This policy may be updated to reflect:

  • Changes in TCPA regulations or interpretations

  • New FCC rulings or enforcement actions

  • Industry best practice developments

  • Internal procedure improvements

11. Training & Education

Staff Training Requirements

  • All employees receive initial TCPA compliance training

  • Annual refresher training and testing

  • Updates provided when regulations change

  • Role-specific training for different job functions

Partner Training Program

  • Comprehensive TCPA training for all global call center partners

  • Regular compliance webinars and updates

  • Performance monitoring and feedback

  • Certification requirements for international operations

12. Legal Compliance & Defense

  • Litigation Preparedness

  • We maintain comprehensive documentation to defend TCPA compliance:

  • Complete consent records for all leads generated

  • Call center training and procedure documentation

  • Compliance monitoring and audit reports

  • Expert witness capabilities for consent verification

  • Indemnification Support

  • AgoryLeads provides reasonable support to insurance professionals facing TCPA claims related to our leads:

  • Consent documentation and records

  • Expert testimony regarding consent procedures

  • Cooperation with legal defense efforts

  • Documentation of compliance program implementation

13. Contact Information

Privacy Questions or Requests:

  • Email: privacy@agoryleads.com

  • Phone: +1 551 358 9881

  • Mail: AgoryLeads LLC, ATTN: Privacy Officer, 5562 Arcadia Cir. Discovery Bay CA 94505, 

General Business Inquiries:

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Legal Disclaimer:

This TCPA Consent Policy is designed to comply with current TCPA regulations and industry best practices. Given the complex and evolving nature of TCPA law, we strongly recommend having this policy reviewed by qualified telecommunications counsel before implementation to ensure full compliance with your specific business operations and the most current regulatory requirements.

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