Robocall Mitigation Plan

1Provider Information

2Role in the Call Path

PinnacleVoice Networks provides cloud voice services to business customers, including contact centers, BPOs, and enterprises. In the call path we act as an originating voice service provider for traffic generated by our customers, and we interconnect with upstream and downstream carriers for termination and origination.

We sell to businesses, not to the public. There is no anonymous signup and no instant self-service origination here. Every account goes through the documented review described in Section 4 before it can place a single call.

3STIR/SHAKEN Implementation

We apply STIR/SHAKEN caller ID authentication to calls originating on our network in the IP portions of our network, in accordance with the FCC's rules.

• Calls originated by customers using telephone numbers that we assigned, and where we have a direct authenticated relationship with the customer, are signed with the highest attestation level appropriate to that relationship.
• Calls originated using numbers the customer brings to our platform are signed at the attestation level supported by the verification we hold for that number, including documented evidence of the customer's right to use it.
• We do not sign traffic at an attestation level higher than the verification we hold supports, and we do not sign traffic whose origin we cannot establish.
• Where portions of a call path are non-IP, we apply a robocall mitigation program to that traffic consistent with FCC requirements.

PinnacleVoice Networks is identified in the SHAKEN ecosystem by Operating Company Number (OCN) 645L.

4Know Your Customer (KYC)

Preventing illegal robocalls starts before the first call is placed. Every prospective customer completes a documented onboarding review before traffic is enabled. That review collects and verifies:

• Legal business name, registered address, business type, and jurisdiction of incorporation.
• Tax identification or business registration number, supported by a copy of the company registration certificate.
• Identity of an authorized representative, including a government-issued photo identification document.
• Intended use case, expected call volume, target destinations, and dialing mode.
• Regulatory posture, including whether the customer or its principals have previously had telecom service terminated for non-compliance, and whether the traffic will include telemarketing or automated outbound campaigns.
• An electronic certification that the information provided is accurate, together with acceptance of our Acceptable Use Policy.

Some applications get a closer look before anyone approves them. Prior termination for non-compliance, high-volume automated outbound campaigns, business registration we cannot independently verify, or identity documents that do not line up. Those applications are declined, or approved with limits on volume and destinations.

Onboarding records, including submitted identity and registration documents, are retained for the duration of the customer relationship and for a subsequent period consistent with our record-retention practices, so that the originator of any given call can be identified.

5Contractual Obligations

Every customer is bound by our Acceptable Use Policy, which is incorporated into the service agreement and expressly prohibits illegal robocalls, unlawful caller ID spoofing, TCPA and Do Not Call violations, traffic pumping, and related abuse.

Customers who resell our services or transmit traffic on behalf of their own clients are contractually required to:

• Perform equivalent KYC due diligence on each of their downstream customers before enabling traffic;
• Bind those customers to terms at least as restrictive as our AUP;
• Maintain records identifying the originator of any call carried on their account; and
• Identify that originator to us within 24 hours of a traceback or information request.

6Traffic Monitoring & Analytics

We watch traffic continuously for the patterns that illegal robocalling tends to produce. The indicators we review include:

Accounts that deviate materially from their approved profile are flagged for review. Where indicators suggest illegal traffic, we investigate, request supporting documentation from the customer (including consent records and campaign detail), and apply the enforcement measures in Section 9. We also maintain per-account velocity limits, spend caps, and high-risk destination blocks as standing controls.

We monitor traffic patterns and metadata; we do not routinely monitor call content, and access content only where necessary to investigate a specific violation or where required by law.

7Number Provisioning Controls

• Telephone numbers are assigned only to customers who have completed onboarding review, and only in quantities consistent with their verified use case and volume.
• Customers using numbers they bring to the platform must provide documented authorization to use those numbers; we verify that authorization before permitting origination.
• We monitor the reputation of numbers originating on our network across carrier analytics platforms, and remediate or withdraw numbers that show signs of abuse.
• We do not permit customers to originate using numbers they do not own or have documented authority to use, and we do not permit number rotation patterns designed to evade blocking or labeling.

8Traceback Response

PinnacleVoice Networks cooperates fully with traceback requests, including those from the Industry Traceback Group (ITG), the registered consortium selected by the FCC.

• We respond substantively to traceback requests within 24 hours of receipt.
• Our response identifies the customer that originated or handed off the traffic and, where we are not the originator, the upstream provider from which the traffic was received.
• We require customers to identify their own downstream originator within 24 hours, and failure to do so is treated as a material violation of the AUP.
• Traceback records are retained so that repeat patterns across a customer's traffic can be identified and acted on.

Traceback and law enforcement requests should be directed to support@pvndialer.com and are prioritized on receipt.

9Enforcement Against Customers

Where investigation indicates that a customer is originating or transmitting illegal traffic, we take action proportionate to the severity and immediacy of the risk:

Where traffic is apparently illegal or presents an immediate risk to consumers or the network, we suspend or block it without prior notice and notify the customer promptly afterwards. We do not knowingly continue to carry traffic from a customer we have determined to be originating illegal robocalls, and we terminate such customers. Where an entity is terminated for illegal traffic, we do not re-onboard it or its principals under a different name without a documented review.

10Regulatory & Law Enforcement Cooperation

We cooperate with the Federal Communications Commission, the Federal Trade Commission, state attorneys general, the Industry Traceback Group, and law enforcement agencies in investigations concerning illegal robocalls. We respond promptly to lawful requests for information and to FCC notifications identifying suspected illegal traffic on our network, including taking effective mitigation steps within any period specified by the Commission.

11Designated Contact for Robocall Mitigation

This individual is responsible for receiving and responding to traceback requests, regulatory inquiries, and reports of suspected illegal traffic, and is reachable during business hours with monitored coverage outside them.

12Review & Certification

This Plan is reviewed at least annually, and additionally whenever there is a material change to our network, our customer mix, or applicable FCC rules. Updates are published on this page with a revised review date and reflected in our Robocall Mitigation Database filing.

PinnacleVoice Networks certifies that it has adopted and implemented the practices described in this Plan, and that those practices are reasonably designed to prevent the origination, carriage, and termination of illegal robocall traffic on its network. This Plan is on file with the Federal Communications Commission in the Robocall Mitigation Database under filing ID RMD0023105.

See also our Acceptable Use Policy, TCPA compliance overview, compliance tooling, and Terms of Service.