Unsolicited Commercial Communication (UCC) Compliance Policy – Customer Guide

This Knowledge Base article explains:

· What constitutes UCC

      · Your compliance obligations as a customer

      · How UCC complaints are handled

      · Enforcement actions and consequences of non-compliance

FreJun follows a zero-tolerance, regulator-aligned approach to UCC violations. Compliance is mandatory and non-negotiable.

Scope of Applicability

This policy applies to:

      · All customers using FreJun’s calling, messaging, or communication services

      · All outbound communication campaigns (sales, marketing, service, follow-ups, reminders, etc.)

     · All numbers, accounts, and sub-accounts provisioned by FreJun

 

What is Unsolicited Commercial Communication (UCC)?

UCC refers to any commercial communication sent without valid recipient consent or in violation of:

      · Approved use cases

      · DLT registration requirements

      · Telecom and operator guidelines

Common Examples of UCC

      · Calls without explicit customer consent

      · Promotional use of service or transactional numbers

      · Misleading or unauthorized communication activity

      · Repeated complaints from recipients despite warnings

Customer Compliance Obligations

All FreJun customers must:

1. Obtain Valid Consent

      · Ensure consent is explicit, provable, auditable, and lawful

      · Consent must clearly cover the purpose of communication

2. Maintain Accurate CRM Records

Your CRM must be able to produce, at short notice:

      · Date and mode of consent

      · Campaign or call justification

3. Cooperate with Investigations

      · Respond promptly to regulatory queries or UCC complaints

      · Submit required documentation within prescribed timelines

Failure to meet these obligations may trigger enforcement action.

 

How UCC Complaints Are Handled

1. Receipt of Complaint

       · Every UCC complaint is treated as a regulatory event

       · FreJun is legally obligated to investigate and respond within fixed timelines

2. Mandatory CRM Evidence Submission

To contest a UCC complaint, customers must submit CRM evidence, including:

      · Proof of recipient consent

      · CRM logs, screenshots, or system records

3. Consequence of non-submission- If CRM evidence is not submitted on time, FreJun is legally required to mark the complaint as “valid”

      · FreJun has no discretion to override or delay this action

      · Once marked valid, regulatory enforcement must follow

 

Enforcement & Escalation Framework

Step 1: Warning / Notice

      · Triggered after more than three (3) valid UCC complaints

      · Formal notice issued to the customer

Step 2: Temporary Suspension

      · Account suspended for 15 days

      · No services permitted during this period

Step 3: Re-Enablement (Subject to Review)

      · Account may be re-enabled after suspension, subject to compliance review

Step 4: Permanent Discontinuation

      · Any further valid UCC complaint post-reactivation will result in:

              o Permanent termination of services

              o Customer offboarding from FreJun

 

Repetitive Offenders & Blacklisting

Customers or numbers identified as repetitive offenders may be escalated to telecom operators.

Upon confirmation, such offenders may be:

     · Blocked from accessing telecom services across all providers

     · Blacklisted for up to one (1) year, as per regulatory norms

These actions are operator or regulator-driven and are outside FreJun’s control.

 

Liability Disclaimer

      · FreJun acts solely as a regulated service provider and compliance intermediary

      · Responsibility for UCC violations rests entirely with the customer

      · Where complaints are marked valid by telecom operators or DLT authorities:

             o FreJun shall not be held liable

             o Actions taken are mandatory regulatory compliance, not discretionary business decisions

 

No Override Policy

FreJun cannot:

      · Ignore or suppress UCC complaints

      · Reclassify valid complaints without CRM evidence

      · Continue services in violation of regulatory directives

        All actions under this policy are binding and non-negotiable.

 

Customer Acknowledgement

By using FreJun services, customers:

      · Acknowledge and accept the UCC Compliance Policy

      · Agree to cooperate with investigations and enforcement actions

      · Accept that non-compliance may result in suspension or termination without further notice

 

Support & Compliance Assistance

For clarification on compliance expectations or documentation requirements, please contact:

Legal & Compliance Team 📧 legal@frejun.com