Passteam Corp.

This Messaging & Acceptable Use Policy (“Policy”) governs Customer’s use of Passteam’s messaging, notification, and communication features, including SMS, push notifications, and related engagement tools (collectively, the “Messaging Services”).

This Policy forms part of the Passteam Master Subscription Agreement (“Agreement”) and is incorporated by reference. Capitalized terms not defined in this Policy have the meanings set forth in the Agreement.

1. CUSTOMER RESPONSIBILITY FOR COMPLIANCE

Customer is solely responsible for complying with all applicable laws, regulations, and industry standards governing messaging, marketing, privacy, and consumer protection, including but not limited to:

• SMS and telecommunications laws;
• marketing and advertising regulations;
• data protection and privacy laws;
• consumer consent and opt-out requirements.

Passteam does not provide legal, regulatory, or compliance advice.

2. CONSENT AND PERMISSIONS

Customer is solely responsible for:

• obtaining valid, informed, and documented consent from end users prior to sending messages;
• ensuring consent language is accurate, clear, and legally sufficient;
• maintaining records of consent;
• honoring unsubscribe, opt-out, and preference management requests without delay.

Customer must ensure that messages are sent only to recipients who have provided the required consent under applicable law.

3. MESSAGE CONTENT AND RECIPIENT CONTROL

Customer retains full control over and responsibility for:

• message content;
• recipient selection;
• timing and frequency of messages;
• segmentation, targeting, and triggering logic.

Passteam does not:

• determine when messages are sent;
• select message recipients;
• approve, edit, or review message content.

4. PROHIBITED USES AND CONTENT

Customer shall not use the Messaging Services to send, transmit, or facilitate content that is:

• unlawful, deceptive, misleading, or fraudulent;
• unsolicited, spam-like, or sent without required consent;
• harassing, abusive, threatening, or obscene;
• infringing on intellectual property, privacy, or publicity rights;
• promoting illegal activities, violence, or discrimination;
• containing malware, malicious code, or harmful links.

Passteam reserves the right to restrict or suspend Messaging Services where necessary to prevent harm, abuse, or legal exposure.

5. TELECOMMUNICATIONS AND THIRD-PARTY DEPENDENCIES

Messaging Services may rely on third-party networks, platforms, and providers, including mobile carriers, SMS aggregators, and push notification platforms.

Customer acknowledges that:

• message delivery is not guaranteed;
• delivery timing, filtering, blocking, or throttling may occur outside Passteam’s control;
• third-party providers may impose their own policies or restrictions.

Passteam is not responsible for third-party delivery failures or carrier-level filtering.

6. INFRASTRUCTURE-ONLY ROLE OF PASSTEAM

Passteam acts solely as a technical infrastructure provider.

Passteam does not:

• act as the sender of record;
• determine the purpose or legality of messages;
• assume responsibility for Customer’s messaging campaigns or practices.

Customer is the sole sender and initiator of all messages sent using the Messaging Services.

7. SUSPENSION AND ENFORCEMENT

Passteam may suspend, limit, or terminate access to the Messaging Services, in whole or in part, if Passteam reasonably determines that Customer’s use:

• violates this Policy or the Agreement;
• creates legal, regulatory, or reputational risk;
• threatens system stability, security, or third-party relationships;
• is required to comply with applicable law or government requests.

Where practicable, Passteam will provide notice prior to suspension.

8. NO LIABILITY FOR MESSAGE CONTENT

Customer acknowledges and agrees that Passteam bears no responsibility or liability for:

• message content;
• recipient lists;
• consent collection or management;
• compliance with messaging laws.

Customer agrees to indemnify Passteam as set forth in the Agreement for claims arising from Customer’s messaging practices.

9. MODIFICATIONS TO THIS POLICY

Passteam may update this Policy from time to time. Updates will apply prospectively and will not materially reduce Customer’s rights during an active subscription term.

10. ORDER OF PRECEDENCE

In the event of a conflict:

1. The Master Subscription Agreement
2. This Messaging & Acceptable Use Policy

‍