SECOND PHONE NUMBER APP

MESSAGING & CALLING POLICY

Effective date: July 11, 2025

This “Second Phone App Messaging & Calling Policy” (“Policy”) outlines important rules, regulations, and restrictions for all users of the Second Phone mobile application (“Second Phone App”) regarding the use of calling and messaging features.

This Policy is designed to prevent illegal, fraudulent, and abusive calling and messaging practices, including robocalls and spam, in accordance with the FCC’s Robocall Mitigation requirements and applicable messaging laws and regulations.

Please review this document carefully. Compliance with these provisions is essential for continued use of Second Phone App services. Failure to adhere to this policy may result in account suspension, including restrictions on making calls or sending messages.

ACCEPTABLE USE

Lawful Use Only. Users must use Second Phone App calling and messaging features only for lawful and personal purposes.

Prohibited Uses. It is strictly prohibited to use the Second Phone App for:

• Illegal, fraudulent, abusive, harassing, threatening, or defamatory calls or messages.

• Unsolicited commercial calls, robocalls, or mass messaging campaigns.

• Calls or messages intended to deceive, defraud, or mislead recipients.

• Spoofing caller ID or disguising the origin of calls / messages.

• Circumventing or attempting to circumvent any security or monitoring features of the service.

General limitations. Our calling and messaging service is designed to be flexible and user-friendly. However, in order to maintain platform stability, ensure fair use, and prevent abuse or fraudulent activity, technical limitations may be applied automatically in certain cases.

Please note that these technical limits are system-imposed, cannot be manually adjusted, and apply regardless of your subscription type. If you believe your activity was mistakenly flagged, feel free to contact our support team. Where technically possible, we’ll be happy to restore full access.

MONITORING AND PREVENTION MECHANISMS

Provider Collaboration. We collaborate with Telnyx LLC, our cloud communications provider, to deliver calling and messaging services. Both Municorn and Telnyx implement filtering systems designed to detect and prevent fraudulent activity, spam, abuse, and violations of applicable laws and policies.

Monitoring. All calls and messages sent through Second Phone App are subject to collection, monitoring, and review to ensure compliance.

ADDITIONAL MESSAGING RULES

Operational messages

You acknowledge and agree that you may receive text messages from us related to the status of the phone numbers acquired through the Second Phone App, credits purchased for making calls, and other aspects of the App’s operation, including warnings and notifications regarding potential account suspension.

User consent for monitoring message content

Telnyx LLC, as our cloud communications provider and data processor, may also collect and monitor your message content to detect and prevent abuse, fraud, and security incidents.

By using the Second Phone App, you provide explicit consent to us and Telnyx LLC to collect, process, store, and monitor the content of all messages sent via the Second Phone App’s phone numbers for the following purposes:

• Preventing spam, abuse, illegal, and fraudulent activity.

• Ensuring compliance with applicable messaging laws, regulations, and the Telnyx Acceptable Use Policy and CTIA Messaging Principles.

• Cooperation with lawful requests from regulatory or law enforcement authorities.

Prohibited message content

Messages sent using phone numbers obtained via the Second Phone App must comply with the following restrictions. Sending messages that fall into the categories below may result in account suspension:

• Spam: sending unsolicited or repetitive messages with similar or identical content. If we detect spam activity (at least 10 or more duplicate or near-duplicate messages sent within a 72-hour period, we’ll send you the corresponding warning about forthcoming account blocking. If you continue spamming activities, your account (including phone number) will be blocked.

• High-risk financial content: including topics such as cryptocurrency, loans, payday loans, or student loans.

• Third-party lead generation: activities such as buying, selling, or sharing consumer information.

• Debt collection/forgiveness: messaging about debt reduction, consolidation, or credit repair programs.

• “Get rich quick” schemes: promotions for deceptive investment opportunities or pyramid schemes.

• Illegal or restricted content: messaging about cannabis (including CBD), fireworks, prescription medications, gambling, or any illegal goods or services.

• Harmful or inappropriate content: content that includes profanity, violence, harassment, defamation, pornography, or other offensive material.

• S.H.A.F.T. (sex, hate, alcohol, firearms, tobacco) use cases: messaging involving sex, hate speech, firearms and vaping-related message traffic.

• Manipulative practices: attempts to bypass filters using intentional misspellings, leetspeak, or snowshoeing (sending messages via multiple numbers to avoid detection).

• Prohibited links: especially shortened URLs or links likely to trigger spam filters.

• Fraud or scams: deceptive marketing, phishing attempts, or content designed to defraud recipients.

• Repetitive and/or continuous messaging to the same destination or number if such activity could reasonably be expected to or in fact does provoke complaints.

• Other types of content that can reasonably be considered as illegal, harmful, unwanted, inappropriate, objectionable, confirmed to be criminal misinformation, or that otherwise poses threat to the public, or the origin of which is falsified or misrepresented.

This list is non-exhaustive. For additional details, refer to the Telnyx Acceptable Use Policy.

IMPORTANT: Even with recipient consent, messages containing prohibited content are subject to filtering and may lead to account suspension.

Please note that no refunds will be issued for blocked or undelivered messages resulting from violations of our Terms, Messaging Policy, or applicable laws. This monitoring and filtering are legally required to comply with various regulations.

Obtaining recipient consent

When is recipient consent required, and how should it be obtained?

By using the phone number obtained through the Second Phone App to send messages, you agree to comply with the requirements regarding recipient consent for receiving messages (including acceptable methods and scenarios for obtaining such consent), opt-out mechanisms, and sender identification obligations.

You must ensure you have obtained the recipient’s clear and explicit consent before sending any messages.

The requirements are as follows:

1. Consent for business communications:

• Maintain records of consent, such as signed documents or timestamps.

• Consent must specify the type of messages to be sent. Blanket consent for unrelated content is not permitted.

• If the recipient initiates the conversation by sending an initial message, this constitutes consent for that specific conversation only. Any additional messages require explicit further consent.

• Consent is implied for transactional communications (e.g., appointment reminders, one-time passwords, or delivery notifications) when the recipient has provided their phone number for such purposes.

1. Consent for personal communications:

• Consent may be verbal if the recipient has an established personal relationship with you and has not objected to receiving messages.

Note: Always inform recipients about the type of messages they are consenting to receive.

ADDITIONAL CALLING RULES

User consent for call data collection and monitoring

To provide and improve the calling services of the Second Phone App, we (Municorn Limited) and our telecommunications provider, Telnyx LLC, collect, process, store, and monitor certain call-related data. By using the Second Phone App, you provide explicit consent to us and Telnyx LLC to collect and process the following information related to your calls made or received via Second Phone App phone numbers:

• Call logs, including calling and called party phone numbers.

• Dates, times, and durations of calls.

• IP addresses and device identifiers used for call initiation and reception.

• Call routing and technical metadata.

• Voicemail data (if applicable).

• Any other data necessary to detect and prevent abuse, fraud, security incidents, or violations of law.

This data is collected and processed for the following purposes:

• Preventing spam, abuse, illegal, and fraudulent activity.

• Ensuring compliance with applicable telecommunications laws, regulations, and the Telnyx Acceptable Use Policy.

• Quality assurance, troubleshooting, and service improvement.

• Cooperation with lawful requests from regulatory or law enforcement authorities.

Your call data is handled in accordance with our Privacy Policy and applicable data protection laws, including the GDPR. Access to this data is restricted to authorized personnel and is retained only as long as necessary for the above purposes.

Prohibited use of calling service

Before start using calling service you must ensure you have obtained the recipient’s clear and explicit consent.

Calls using phone numbers obtained via the Second Phone App must comply with the following restrictions. Use of calling service that fall into the categories below may result in account suspension:

• Robocalls and Automated Calls. Initiating unsolicited, automated, or prerecorded calls (robocalls), including commercial advertising, informational announcements, or any mass calling campaigns, unless legally permitted and with proper recipient consent.

• Traffic Stimulation Schemes. Participating in continuous or extensive chat lines, conference calls, or using free conference calling or similar services that may result in excessive or artificially inflated call traffic or charges.

• Open Line Monitoring. Using the service as an open telephone line for monitoring, intercom, or similar purposes.

• Repetitive or Continuous Calling. Making repetitive and/or continuous calls to the same destination or number if such activity could reasonably be expected to, or does in fact, provoke complaints.

• Long Duration Calls. Placing long duration calls (defined as calls to the same number in excess of four continuous or cumulative hours within a 24-hour period) or calls made to specific numbers/destinations for the purpose of generating charges or fees for or with a third party.

• Exceeding Call Rate or Daily Call Limits. Using the service in excess of call per second (CPS) thresholds as may be set by Municorn or its providers or making calls above daily limits established for your account or service plan.

• Non-Human or Artificial Dialog. Using the service in a manner that does not consist of uninterrupted live human voice dialog between natural human beings (e.g., using the service for artificial, recorded, or non-interactive calls).

• Caller ID Misuse and Spoofing. Using Second Phone numbers as the Calling Line Identification (CLI) in any manner that constitutes fraud, deception, or spam, including spoofing or misrepresenting the origin of calls.

• Fraudulent or Deceptive Activity. Using the service for any fraudulent, deceptive, or otherwise illegal purposes, including attempts to generate charges, fees, or circumvent security and monitoring features.

• Other types of activities that can reasonably be considered as illegal, harmful, unwanted, inappropriate, objectionable, confirmed to be criminal misinformation, or that otherwise poses threat to the public, or the origin of which is falsified or misrepresented.

This list is non-exhaustive. For additional details, refer to the Telnyx Acceptable Use Policy.

IMPORTANT: Even with recipient consent, these types of calling service use may lead to account suspension.

Please note that no refunds will be issued for blocked accounts resulting from violations of our Terms, Messaging and Calling Policy, or applicable laws. This monitoring and filtering are legally required to comply with various regulations.

Call Authentication, Blocking, and Fraud Prevention

• Outgoing calls will display the assigned Second Phone number as caller ID.

• Municorn and its partners use caller ID authentication standards (e.g., STIR/SHAKEN) where feasible.

• Calls suspected of being illegal, fraudulent, or violating this policy may be blocked or filtered.

• Inbound and outbound calls may be screened for spam or robocall characteristics.

MONITORING, INVESTIGATION, AND ENFORCEMENT

• Usage patterns are monitored for suspicious or potentially abusive activity.

• If suspicious activity is detected, Municorn may:

• Issue a warning or request additional user verification.

• Temporarily suspend or permanently terminate user access.

• Cooperate with law enforcement authorities and industry traceback groups as required.

• Municorn responds promptly to official traceback or information requests regarding suspicious calls / messages.

• Users must cooperate in any investigation of suspicious or prohibited activities.

APPEALING ERRONEOUS ACCOUNT SUSPENSION

If you believe your account was suspended or your messages were filtered in error, contact us at second-phone-support@municorn.com. We will review your case to determine if an error occurred.

POLICY UPDATES

Municorn may anytime update this Policy to reflect changes in law, regulation, or service practices.

CONTACT US

If you have any questions about this Policy or Second Phone App, please contact us via email at second-phone-support@municorn.com or legal@municorn.com.