Join Us

Legal

TCPA & marketing compliance policy

Effective date: November 12, 2026

This policy sets the minimum compliance standards for every publisher, affiliate, and sub-publisher that sends calls or leads to LeadCallsDirect, based in Italy. It forms part of our Publisher & website terms. Publishers are solely responsible for complying with all laws that apply to their traffic; where this policy is stricter than the law, this policy applies. Violations may result in non-payment, clawback, and termination.

1. Applicable laws

Publishers must comply with all applicable laws and regulations, including the Telephone Consumer Protection Act (TCPA) and FCC rules, the FTC’s Telemarketing Sales Rule (TSR), the FTC Act, the CAN-SPAM Act, National Do Not Call Registry rules, state telemarketing, telephone solicitation, and “mini-TCPA” laws, state do-not-call lists and registration requirements, and, where applicable, Medicare, CMS, and health insurance marketing rules and attorney advertising rules.

  • Any marketing call or text message to a consumer that uses an automatic telephone dialing system, or an artificial, prerecorded, or AI-generated voice, requires the consumer’s prior express written consent as defined by FCC rules, in addition to any stricter state requirements.
  • Consent must be clear and conspicuous, identify the seller or sellers authorized to contact the consumer, cover the specific phone number, state that consent is not a condition of purchase, and be signed (an electronic signature is acceptable).
  • Consent may not be obtained through deceptive practices, pre-checked boxes, or hidden disclosures, and may not be bought, sold, or transferred except as permitted by law and approved by us.
  • Consumers may revoke consent by any reasonable means. Revocations must be honored promptly and passed on to us.

3. Consent records

For any traffic that relies on consent, publishers must keep complete records, including the exact disclosure language and page shown, the date and time, the page URL, the consumer’s IP address and phone number, and, where available, a session recording or third-party consent certificate. Records must be kept for at least five (5) years and provided to us within 48 hours of our request. Failure to provide records on time is treated as a violation, and the related calls are not payable.

4. Do Not Call compliance

Any outbound contact used to generate calls must be scrubbed against the National Do Not Call Registry, applicable state do-not-call lists, and the publisher’s internal do-not-call list, unless a valid exemption applies and is documented. Publishers must maintain an internal do-not-call list, honor opt-out requests promptly, and respect federal and state calling-hour restrictions.

5. Robocalls, prerecorded and AI voice, and spoofing

  • No robocalls, autodialed calls, ringless voicemail, or artificial, prerecorded, or AI-generated voice messages may be used to generate traffic without the consent required by law and our prior written approval.
  • Caller ID spoofing, or transmitting misleading or inaccurate caller ID information, is prohibited.
  • Outbound-generated or transferred calls must be disclosed to us in advance and approved in writing.

6. Call recording

Calls may be recorded for quality, compliance, and dispute resolution. Some U.S. states require the consent of all parties to a call before it is recorded. Publishers who operate any calling or transfer step must give a recording disclosure and obtain consent as required by applicable state law, and must not interfere with disclosures played by us or our advertisers.

7. Prohibited traffic and practices

  • Incentivized traffic (rewards, prizes, or payments for calling) unless expressly approved in writing.
  • Fake, artificially generated, or manipulated calls, including bots, call farms, and repeat calling.
  • Purchased, scraped, or otherwise non-consented lists or data.
  • Unapproved traffic sources, sub-publishers, or brand bidding.
  • Adult, hateful, illegal, or otherwise objectionable content or placements.

8. Prohibited claims and advertising

  • Impersonating or implying affiliation with any government agency or program, including Medicare, CMS, the Social Security Administration, the IRS, or HealthCare.gov.
  • Impersonating any advertiser, carrier, airline, utility, or other brand, or using any trademark without written approval.
  • False urgency, such as fake deadlines or program closures.
  • Guarantees or specific promises of savings, prices, benefits, approvals, settlements, or outcomes that have not been approved.
  • Hiding who will answer the call or why the consumer is being connected.

9. Medicare, ACA, and health insurance traffic

Where a campaign involves Medicare, ACA, or other health insurance, publishers must follow all applicable CMS marketing rules and health insurance marketing laws, including required disclaimers for third-party marketing organizations where they apply. Only creative pre-approved by us for that campaign may be used, required disclaimers must not be altered or removed, and no communication may suggest that the consumer is contacting Medicare, CMS, or a government marketplace. Additional campaign-specific rules may apply and will be provided in writing.

10. Approved creative only

All ads, landing pages, scripts, and messages must be approved by us before use for the specific campaign. Any change to approved creative requires new approval. Publishers must keep copies of all creative and the dates each version ran, and provide them on request.

11. Monitoring and audits

We monitor traffic and may review call recordings, call data, creative, landing pages, and consent records at any time. Publishers must cooperate fully with any audit or inquiry, including requests from advertisers or regulators, and provide requested information within 48 hours unless we agree otherwise.

12. Consequences of violations

If we determine in good faith that a publisher has violated this policy, we may, at our discretion and without limiting any other remedy: refuse payment for affected calls, withhold or claw back payments already made, pause or remove the publisher from any or all campaigns, terminate the publisher’s account, and seek indemnification under our Terms.

13. Reporting violations

If you become aware of a potential compliance violation, including by a sub-publisher, or receive a consumer complaint, regulatory inquiry, or legal claim related to traffic sent to LeadCallsDirect, report it immediately through our contact form. Consumers who wish to report a concern or opt out may also use the contact form.

14. Changes

We may update this policy at any time by posting a revised version with a new effective date. Updates apply to all traffic sent after they are posted.