SHOTPRO TECHNOLOGIES

SMS & Messaging Policy

1. Introduction & Purpose

ShotPro Technologies, Inc. ("ShotPro," "we," "us," or "our") 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 our Dealer partners (shooting ranges and firearms retailers).

As a provider of services to the firearms industry, we recognize the unique regulatory requirements that apply to our messaging activities. This Policy ensures compliance with:

• Telephone Consumer Protection Act (TCPA)
• Cellular Telecommunications Industry Association (CTIA) Messaging Principles and Best Practices
• SHAFT Compliance Requirements (Sex, Hate, Alcohol, Firearms, Tobacco)
• CAN-SPAM Act (for email communications)
• State-specific privacy laws (CCPA, state TCPA equivalents)
• Carrier-specific requirements for A2P 10DLC messaging

2. SHAFT Compliance for Firearms Industry

SHAFT is an acronym used by mobile carriers and regulators to identify content categories requiring special handling: Sex, Hate, Alcohol, Firearms, and Tobacco. As a firearms industry service provider, ShotPro implements the following safeguards:

2.1 Age Verification (21+ Requirement)

All SMS recipients must be verified as 21 years of age or older before receiving any firearms-related messaging. Our age verification process includes:

• Birth Date Collection: During opt-in, we require date of birth via a secure form field.
• Automated Validation: Our system automatically validates that the subscriber is at least 21 years old.
• Third-Party Verification: Where required, we may use third-party age verification services.
• Opt-In Denial: If a subscriber is under 21, their opt-in is denied and no messages will be sent.
• Ongoing Compliance: We periodically review subscriber data to maintain age-appropriate messaging lists.

2.2 Content Restrictions

All SMS content sent through the ShotPro Platform must:

• Be appropriate for audiences 21 years of age and older
• Not contain explicit, hateful, discriminatory, or violent content
• Comply with all federal, state, and local firearms advertising regulations
• Not promote illegal sales or transfers of firearms
• Include required legal disclaimers where applicable

2.3 Dealer Compliance Obligations

Dealers using the ShotPro Platform for SMS communications must certify compliance with all firearms laws, maintain current FFL licensing, and ensure all messaging content complies with ATF regulations and state-specific requirements.

3. Consent & Opt-In Requirements

3.1 Prior Express Written Consent

We collect phone numbers only with prior express written consent as required by the TCPA. Consent is obtained through:

• Website sign-up forms with clear disclosure and checkbox acknowledgment
• In-store kiosks with digital consent capture
• Point-of-sale enrollment during checkout with written acknowledgment
• Paper forms with signature capture (digitized and stored)

3.2 Opt-In Disclosure Requirements

At the point of opt-in, subscribers are clearly informed of:

• The identity of the message sender (ShotPro and/or specific Dealer)
• The types of messages they will receive (promotional, transactional, alerts)
• Expected message frequency (e.g., "up to 5 messages per month")
• "Message and data rates may apply"
• How to opt out (reply STOP)
• How to get help (reply HELP)
• Link to this SMS Policy and Privacy Policy

3.3 Consent Confirmation

Upon opt-in, subscribers receive a confirmation text message that:

• Confirms successful enrollment
• Reiterates message frequency and data rate disclosures
• Provides opt-out instructions (reply STOP to unsubscribe)
• Provides help instructions (reply HELP for assistance)

3.4 Consent Record Retention

We maintain detailed records of all consent obtained, including:

• Phone number enrolled
• Date and time of consent
• Method of consent (web form, kiosk, paper, etc.)
• IP address (for web-based consent)
• Exact language of consent disclosure shown
• Age verification confirmation

Consent records are retained for a minimum of 5 years from the date of last communication or opt-out, whichever is later.

4. Opt-Out Process

Subscribers may opt out of receiving SMS messages at any time through the following methods:

4.1 STOP Keyword

Reply STOP to any message received from us. The subscriber will receive a confirmation message and no further messages will be sent. We also honor STOP, UNSUBSCRIBE, CANCEL, END, and QUIT.

4.2 Alternative Methods

• Email: [email protected] with subject line "SMS Opt-Out"
• Phone: 888-555-1234 during business hours
• Account Settings: Update preferences in your account portal

4.3 Opt-Out Processing

• Opt-out requests are processed immediately upon receipt
• Confirmation message sent within 24 hours
• Marketing messages stop immediately; transactional messages (order confirmations, safety alerts) may continue unless separately opted out
• Subscribers may re-opt in at any time using the original enrollment methods

5. Message Types & Frequency

5.1 Promotional Messages

Marketing and promotional communications including:

• Special offers and discounts
• New class or event announcements
• Membership promotions
• Product availability alerts

Frequency: Up to 5 promotional messages per month (unless otherwise specified at opt-in)

5.2 Transactional Messages

Service-related communications including:

• Booking confirmations and reminders
• Order and payment confirmations
• Class schedule changes
• Membership renewal notices
• Waiver and document reminders

Frequency: As needed based on subscriber activity and transactions

5.3 Safety & Emergency Alerts

Critical communications including:

• Range closure notifications
• Safety recalls or alerts
• Weather-related closures
• Emergency notifications

6. Data Privacy & Security

• Phone numbers are collected solely for the purposes described in this Policy
• We do not sell, rent, or share phone numbers with third parties for their marketing purposes
• Phone numbers may be shared with service providers who assist in delivering messages (under strict confidentiality agreements)
• All data is encrypted in transit and at rest
• Access to subscriber data is restricted to authorized personnel
• Full privacy practices are detailed in our Privacy Policy at shotpronetwork.com/privacy-policy

7. HELP Response

Subscribers who reply HELP to any message will receive:

8. Carrier Compliance & 10DLC Registration

ShotPro maintains compliant A2P 10DLC campaign registration with major carriers. Our messaging campaigns are:

• Registered with The Campaign Registry (TCR)
• Vetted for SHAFT compliance as a firearms industry sender
• Subject to carrier throughput limits and filtering
• Monitored for spam complaints and delivery issues

9. Compliance Audits

ShotPro conducts periodic audits of SMS campaigns to ensure compliance with this Policy, including:

• Quarterly review of consent records and opt-in flows
• Monthly review of message content for SHAFT compliance
• Annual third-party compliance assessment
• Ongoing monitoring of opt-out processing and complaint rates

10. Contact Information

For questions about this SMS & Messaging Policy:

11. Policy Updates

We may update this Policy from time to time. Material changes will be communicated via:

• SMS notification to enrolled subscribers
• Email notification to registered users
• Posted notice on our website

Continued use of our messaging services after Policy updates constitutes acceptance of the revised terms.

12. Related Documents

Master Services Agreement	shotpronetwork.com/master-services-agreement
Data Processing Agreement	shotpronetwork.com/data-processing-agreement
Privacy Policy	shotpronetwork.com/privacy-policy
Terms & Conditions	shotpronetwork.com/terms-and-conditions