Do Not Call Policy and Procedure

1. How to stop calls — start here

2. Purpose

This policy sets out how Marque Group LLC, doing business as OpenPath Health Solutions, honors Do Not Call requests and complies with the federal Telephone Consumer Protection Act (TCPA), the FTC Telemarketing Sales Rule (TSR), the Florida Telephone Solicitation Act (FTSA), and comparable state telemarketing laws.

It exists so that a person who tells us to stop calling can rely on that happening, and so that everyone acting on our behalf understands that honoring the request is not optional and not subject to a retention attempt.

3. Who this applies to

This policy applies to every employee, contractor, licensed agent, vendor, and partner agency that makes or causes to be made any telephone solicitation or text message on behalf of OpenPath, or that receives consumer contact information from OpenPath.

4. Definitions

• Internal Do Not Call list — our own record of people who have asked us specifically not to contact them.
• National DNC Registry — the federal registry maintained by the FTC at donotcall.gov.
• Telephone solicitation — a call or message made to encourage the purchase of goods or services.
• Prior express written consent — a signed written agreement, including a valid electronic signature, that clearly authorizes calls or texts to a specific number using an automatic telephone dialing system or a prerecorded or artificial voice, and that states consent is not a condition of purchase.
• Established business relationship — a relationship formed by a consumer's inquiry or transaction, which is time-limited and which an internal Do Not Call request overrides.

5. Laws we follow

We maintain a written Do Not Call policy, available on request. We do not place telephone solicitations to numbers on the National DNC Registry or on any applicable state registry without prior express written consent or another lawful basis. We access and refresh registry data at least every 31 days, and we scrub calling lists against the registries and against our internal list before any campaign.

Where a state's rules are stricter than federal rules — for example Florida's — we apply the stricter standard.

6. Our internal Do Not Call list

• Any request to stop contact is recorded the moment it is received, whoever receives it and however it arrives.
• Requests take effect no later than 10 days after receipt, and are applied within one business day in practice.
• A request is honored across every channel — calls, texts, and marketing email — not only the channel used to make it.
• Requests do not expire and are not removed by the passage of time, by a later inquiry, or by any established business relationship.
• Entries are retained indefinitely. Deleting them would defeat their purpose.
• Agents may not ask a consumer to reconsider, offer an incentive to stay on the list, or route the request to anyone else before honoring it.

7. National and state registries

We maintain a subscription to the National DNC Registry for the area codes and states in which we operate, refresh that data at least every 31 days, and retain evidence of each scrub. We also honor applicable state registries and reassigned-number safeguards.

8. Consent

When consent is the basis for contacting someone, we capture and retain a record of it: the exact language the consumer agreed to, the date and time, the web page or channel where it was given, the IP address, and an independent certificate from a lead-certification provider.

• Consent is never pre-checked, bundled, or implied from inaction.
• Consent is not a condition of purchase, and our forms say so.
• Consent may be revoked at any time by any reasonable means, and revocation is honored promptly and across all channels.
• Consent is not transferred to any agency that is not listed on our partner agencies page at the time it is given.

9. Calling standards

• Calls are placed only between 8:00 a.m. and 9:00 p.m. in the consumer's local time zone, and within any narrower window a state requires.
• At the start of every call the agent states their name, that they are calling from or on behalf of OpenPath Health Solutions, the licensed agency they represent, and the purpose of the call.
• Agents provide a telephone number the consumer can call back, and a license number on request.
• We transmit accurate caller ID. We do not spoof numbers or disguise the origin of a call.
• Prerecorded or artificial-voice messages are used only with prior express written consent and include the disclosures the rules require.
• We do not abandon calls beyond the permitted rate, and abandoned calls receive the required recorded identification and opt-out message.
• For Medicare-related calls, agents deliver the required third-party marketing organization disclaimer within the first minute.

10. Text messages

Text messages are sent only with prior express written consent. Every marketing message identifies the sender and explains how to opt out. Replying STOP ends messaging immediately; replying HELP returns contact information. Message and data rates may apply, and message frequency varies.

11. Training

Everyone who contacts consumers on our behalf is trained on this policy before making their first call, and at least annually after that. Training covers how to recognize and record a Do Not Call request, calling-hour limits, required disclosures, and the rule that a request is honored without argument. Training completion is documented.

12. Records

We retain Do Not Call requests, consent records and certificates, registry scrub evidence, call detail records, call recordings where applicable, and training records for at least five years. Records are stored securely, with access limited to personnel who need them.

13. Partner agencies

Licensed agencies that receive consumer information from OpenPath are contractually required to maintain their own written Do Not Call policy, to honor requests made to either OpenPath or to them, and to pass Do Not Call requests back to us promptly so our list stays accurate.

A Do Not Call request made to OpenPath is communicated to the agencies that received your information. A request made to an agency is communicated back to us. You should not have to make the same request twice — but if you are contacted again after making one, please tell us using §14 and we will treat it as a compliance incident.

14. Complaints

If you believe you were contacted in error or after asking us to stop, contact our compliance officer at [email protected] or 888-450-5501. We acknowledge complaints within one business day and investigate them.

You may also file a complaint with the Federal Trade Commission at donotcall.gov, with the Federal Communications Commission, or with your state attorney general. We will not retaliate against anyone for filing a complaint.

15. Review and revision

This policy is reviewed at least annually, and sooner when the law changes or when a compliance incident indicates it should be. A copy of the current written policy is available free of charge on request.

16. Contact us