TCPA Compliance & Outbound Communications Policy.

Convert Health, LLC ("Convert Health") provides patient engagement, lead development, appointment scheduling, and Voice AI services to private medical practices. In delivering these services, Convert Health and its clients use outbound voice calls, prerecorded messages, AI-generated voice calls, and SMS/text messages to contact patients and prospective patients on behalf of healthcare providers.

This policy governs the obligations of Convert Health and its clients under the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, applicable FCC regulations, state telemarketing and consumer protection laws, and the DNC (Do Not Call) Registry rules.

Important: Client assumes full responsibility for ensuring that all contacts provided to Convert Health have given valid prior express written consent as required by applicable law. Convert Health is not the party responsible for obtaining or verifying patient consent — that obligation rests entirely with the Client.

1. Authorization to Act as Authorized Representative

By executing a service agreement with Convert Health, Client authorizes Convert Health to act as its Authorized Representative for purposes of outbound communications. This includes, without limitation, authorization to:

Register and manage Client's telephone numbers and messaging campaigns on platforms including Twilio, Telnyx, FirstOrion, FreeCallerRegistry, and similar carriers

Submit and manage 10DLC (10-digit long code) campaign registrations, brand registrations, and associated compliance filings

Configure and manage STIR/SHAKEN attestation settings on behalf of Client

Make and receive calls, send and receive SMS messages, and operate Voice AI systems on Client's behalf

Convert Health will act within the scope of this authorization, comply with all applicable regulations, and maintain the confidentiality and integrity of Client's information.

2. Client Consent Obligations

Client represents, warrants, and covenants, on a continuing basis throughout the term of any service agreement, that:

(a) Prior Express Written Consent

All contacts provided to Convert Health for outbound calling or texting have provided prior express written consent, as defined under 47 C.F.R. § 64.1200, specifically authorizing: (i) autodialed calls; (ii) prerecorded or artificial voice messages; (iii) AI-generated voice calls; and (iv) text messages to their mobile telephone numbers.

(b) Consent Documentation

Client has obtained, documented, and retained records of each individual's consent in a form sufficient to demonstrate compliance with applicable law. Client will make consent documentation available to Convert Health upon request and will cooperate in the defense of any TCPA claim.

(c) Non-Revocation

No individual whose contact information has been provided to Convert Health has revoked consent prior to the time of any outbound communication. Client will promptly notify Convert Health of any revocations or opt-out requests received, and in no case later than 24 hours of receipt.

(d) DNC Compliance

Client has scrubbed all contact lists against the National Do Not Call Registry, state DNC registries, and its own internal DNC list prior to submitting lists to Convert Health. Client will update DNC scrubs at least every 30 days, or more frequently as required by applicable law.

(e) Contact Data Accuracy

All contact information provided to Convert Health is accurate, up-to-date, and lawfully obtained. Client will promptly notify Convert Health of any changes to contact information that may affect the validity of consent or the appropriateness of outbound contact.

3. Applicable Laws and Regulations

Client agrees to comply, and warrants ongoing compliance, with all applicable laws and regulations governing outbound communications, including without limitation:

The Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, and FCC regulations thereunder

The FTC's Telemarketing Sales Rule (TSR), 16 C.F.R. Part 310

The CAN-SPAM Act, 15 U.S.C. § 7701 et seq.

State telemarketing, unfair business practices, and consumer protection statutes

State mini-TCPA statutes (including, where applicable, Florida, Oklahoma, and Washington)

HIPAA and applicable state health information privacy laws, to the extent communications involve protected health information

Client understands that Convert Health is not managing regulatory compliance on Client's behalf. Convert Health is an authorized agent for communication delivery only. Legal compliance for the content, targeting, and consent basis of all communications remains Client's sole responsibility.

4. Client Indemnification

Client assumes complete responsibility for all communications sent by Convert Health on Client's behalf. Client agrees to defend, indemnify, and hold harmless Convert Health and its members, managers, officers, employees, contractors, and agents from and against any and all claims, suits, investigations, fines, penalties, costs, or expenses (including reasonable attorneys' fees) arising directly or indirectly from:

Client's use of Convert Health's services

Any actual or alleged TCPA, FCC, FTC, state law, or DNC violation arising from Client's contact lists, consent records, or communication content

Any claim based on defective, insufficient, or revoked consent

Any class action, mass arbitration, or regulatory proceeding arising from Client's communications

Any statutory damages, civil monetary penalties, or government investigation related to outbound communications made on Client's behalf

This indemnification obligation shall survive the termination or expiration of any service agreement between the parties.

5. TCPA Caller/Sender Designation

For purposes of the TCPA and applicable FCC regulations, Client acknowledges and agrees that Client — not Convert Health — is the "caller," "sender," or "initiator" of all communications made through Convert Health's services on Client's behalf. This designation is based on the fact that Client controls the consent basis, the target contact lists, and the substantive communication content, and that all communications are made at Client's direction and for Client's benefit.

This designation provides the contractual basis for the indemnification obligations set forth in Section 4 and does not diminish Convert Health's obligations to act lawfully in performing services.

6. Prohibited Uses

Client may not use Convert Health's services to contact any individual who has:

Revoked consent or requested to be placed on an internal do-not-call list

Been registered on the National DNC Registry for more than 31 days, unless a specific exemption applies

Not provided prior express written consent for AI voice calls or autodialed texts

Client may not use Convert Health's services for any unlawful or discriminatory purpose, including activities prohibited by the FTC Act, the Fair Credit Reporting Act, the Equal Credit Opportunity Act, or any other applicable federal or state law.

7. Governing Law and Venue

This policy is incorporated by reference into all service agreements between Convert Health and Client. Any dispute arising out of or related to this policy or the services described herein shall be governed by the laws of the State of Texas and resolved exclusively in a court of competent jurisdiction in Lubbock County, Texas.

In any legal action in which Convert Health substantially prevails, Client shall pay Convert Health's reasonable costs, expenses, and attorneys' fees within 30 days of a written demand.

8. Acknowledgment

By executing a service agreement with Convert Health, LLC, Client acknowledges that it has read, understood, and agrees to be bound by this TCPA Compliance and Outbound Communications Policy, including the consent obligations, indemnification provisions, and designation of Client as the responsible party for outbound communications.

9. Contact

Questions regarding this policy may be directed to:

Convert Health, LLC

3417 73rd St, Suite 53, Lubbock, TX 79423

Email: kade@converthealth.co

Support: kade@converthealth.co

Website: convert-health.com

This policy was last updated on June 9, 2026.