{
  "id": "POL-074",
  "slug": "pol-074",
  "title": "An explicit SMS opt-in carve-out belongs in the policy either way",
  "statement": "The policy must carry an explicit sentence excluding SMS opt-in data and consent from any sharing, whether or not it discloses sharing elsewhere.",
  "rationale": "Reviewers grep for this sentence, so a policy that is silent about sharing gets no credit for its silence — the absence of a bad clause is not the presence of the promise. Telnyx publishes the exact wording, which is a strong hint that what is being checked is the formulation rather than the sentiment, and paraphrases that soften it routinely fail.",
  "layer": "POLICY_PAGE",
  "layerSlug": "policy-page",
  "object": "privacy policy carve-out sentence",
  "severity": "BLOCKING",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "TERMINAL_POLICY",
  "artifact": "privacy_policy",
  "authorities": [
    "Infobip",
    "Bird",
    "Telnyx",
    "Aerialink",
    "AWS"
  ],
  "codes": [
    {
      "provider": "Bandwidth/DCA",
      "code": "852",
      "remediable": true
    }
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Paste the published carve-out sentence immediately after whatever the policy says about sharing — or, in a policy that discloses none, at the end of the data-collection section. Done when the words \"text messaging originator opt-in data and consent\" appear in the document.",
  "example": "All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.",
  "pitfalls": [
    "Placing the sentence in a section of its own, far from the sharing disclosure, weakens it: the point is that it visibly overrides the categories immediately above it."
  ],
  "notes": "Absorbs POL-075, which states the same requirement for a policy that discloses no sharing at all. The sentence to add is identical in both cases, which is why they are one obligation.",
  "catalogIds": [
    "POL-075"
  ],
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/policy-page/pol-074/",
  "markdown": "https://ekas.io/rules/10dlc/policy-page/pol-074.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}