SMS & Messaging Policy

Section 1 — Introduction and Purpose

ShotPro Technologies, Inc. ("ShotPro") is committed to responsible, compliant, and transparent text messaging practices. This SMS & Messaging Policy ("Policy") governs all SMS, MMS, and other electronic messaging communications sent through the ShotPro Platform on behalf of Dealer partners (shooting ranges and firearms retailers).

As a provider of software services to the firearms industry, ShotPro and its Dealers operate under a unique set of carrier, regulatory, and industry-specific requirements. This Policy ensures compliance with:

• Telephone Consumer Protection Act (TCPA)
• CTIA Messaging Principles and Best Practices
• SHAFT Compliance Requirements (Sex, Hate, Alcohol, Firearms, Tobacco)
• CAN-SPAM Act (for email communications)
• State-specific privacy laws including CCPA
• Carrier-specific A2P 10DLC messaging requirements
• The Campaign Registry (TCR) Firearms Vertical standards

Section 2 — SHAFT Compliance Framework

SHAFT is the carrier and regulatory acronym for five content categories requiring special handling: Sex, Hate, Alcohol, Firearms, and Tobacco. For ShotPro and its Dealers, the Firearms category is the primary compliance surface — though all five apply.

2.1 Age Verification — 21+ Requirement

All SMS subscribers must be verified as 21 years of age or older before receiving any firearms-related messaging. This applies to all ShotPro Platform messaging regardless of content — because the business context itself (a shooting range) classifies the program under the Firearms SHAFT category.

• Date of birth collected at opt-in via secure form field
• System automatically validates subscriber is 21+ before enrollment is confirmed
• Opt-in denied for any subscriber under 21 — no confirmation message sent
• Age verification records retained with all other consent records for minimum 5 years
• Third-party age verification services used where required by carrier or state law

2.2 10DLC Campaign Registration

ShotPro maintains A2P 10DLC campaign registration with The Campaign Registry (TCR) in the Firearms & Weapons vertical. All Dealer messaging sent through the Platform is covered under ShotPro's registered campaigns. Dealers may not send firearms-related messaging through unapproved channels or use ShotPro's infrastructure for campaigns outside the registered use cases.

Section 3 — Prohibited Words, Phrases, and Content

3.1 Absolutely Prohibited — Will Trigger Carrier Block

The following words and phrases are prohibited in all SMS messages — promotional or transactional — sent through the ShotPro Platform.

3.2 Restricted — Use With Caution / Requires Review

The following words are not automatically blocked but may trigger carrier filtering depending on context, frequency, or campaign type. They require careful use and are subject to ShotPro's content review process prior to campaign activation.

3.3 Approved Substitute Language

The following substitutions are recommended to maintain compliance while preserving marketing effectiveness:

Section 4 — Consent and Opt-In Requirements

4.1 Prior Express Written Consent

All SMS marketing messages require prior express written consent under TCPA. ShotPro collects consent through the Platform at kiosk check-in, web waiver signing, and POS enrollment. Dealers must not add subscribers to messaging lists without documented opt-in through ShotPro's consent capture tools.

4.2 Required Opt-In Disclosure Language

The following language, or a substantially equivalent approved alternative, must appear at every opt-in point. Dealers may not modify this language without ShotPro's prior written approval:

4.3 Opt-In Confirmation Message

Upon successful opt-in, the following confirmation message is sent automatically by the Platform:

4.4 HELP Response

4.5 Opt-Out — STOP Keywords Honored

ShotPro honors the following opt-out keywords on all messaging programs: STOP, UNSUBSCRIBE, CANCEL, END, QUIT. Opt-outs are processed immediately. Confirmation message sent within 24 hours. Transactional messages (booking confirmations, payment receipts, safety alerts) may continue unless separately opted out.

4.6 Consent Record Retention

All consent records are retained for a minimum of five (5) years from the date of last communication or opt-out, whichever is later. Records include: phone number, date/time of consent, method of consent, IP address (web opt-ins), exact disclosure language presented, and age verification confirmation.

Section 5 — Message Types and Frequency Limits

Section 6 — Dealer Compliance Obligations and Liability

Dealers using the ShotPro Platform for SMS communications are jointly responsible for compliance. Specifically, each Dealer must:

• Certify compliance with all applicable federal and state firearms laws prior to activating SMS features
• Ensure all marketing content submitted for SMS delivery complies with Section 3 of this Policy
• Not submit message content containing Absolutely Prohibited words from Section 3.1
• Submit campaigns containing Restricted words from Section 3.2 for ShotPro review before activation
• Not use the ShotPro Platform to send messages on behalf of non-FFL third parties
• Not collect phone numbers outside of ShotPro's approved opt-in flows and add them to Platform lists
• Maintain current FFL licensing and notify ShotPro immediately upon any license suspension or revocation

Section 7 — Carrier Compliance and 10DLC Registration

ShotPro maintains A2P 10DLC campaign registration with The Campaign Registry (TCR) under the Firearms & Weapons vertical. All messaging through the Platform is subject to carrier throughput limits and real-time content filtering by AT&T, T-Mobile, and Verizon. ShotPro's campaigns are:

• Registered and vetted for SHAFT compliance under the Firearms vertical
• Subject to carrier throughput limits — high-volume campaigns require advance notice to ShotPro
• Monitored for spam complaints, opt-out rates, and delivery issues on a continuous basis
• Subject to suspension by carriers without advance notice if content violations are detected

ShotPro's 10DLC registration covers Dealers operating as part of the ShotPro network. Dealers who wish to register independent campaigns must do so through ShotPro's platform configuration and cannot use personal or business accounts outside the Platform for ShotPro-managed data.

Section 8 — Governing Documents and Policy Updates

ShotPro may update this Policy to reflect changes in carrier requirements, CTIA guidelines, or applicable law. Material changes will be communicated to active Dealers via email at least 30 days before the effective date. Continued use of Platform messaging features after the effective date constitutes acceptance.

Section 9 — Contact Information

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