Do Not Call Policy

Last Updated: July 3, 2026

Table of Contents

DO NOT CALL POLICY

FINBIZ LLC

VERSION: 3.0
DATE OF LAST UPDATE: JUNE 25, 2026

1.PURPOSE AND SCOPE

This Do Not Call Policy (this “Policy”) sets forth the commitment of FinBiz LLC, a Delaware limited liability company (the “Company,” “we,” “us,” or “our”), to comply with all applicable federal and state telemarketing laws and regulations, including without limitation: the Telephone Consumer Protection Act (“TCPA”), 47 U.S.C. § 227; the Federal Trade Commission’s Telemarketing Sales Rule (“TSR”), 16 C.F.R. Part 310; the FCC’s implementing regulations at 47 C.F.R. Part 64; and applicable state do not call statutes. This Policy is adopted and maintained in good faith for the purpose of establishing, implementing, and enforcing procedures reasonably designed to prevent telephone solicitations to persons who have requested not to be called, and to qualify FinBiz LLC for all available safe harbor protections under applicable law.

This Policy applies to all outbound telephone solicitations and text message communications made by or on behalf of the Company, including communications made by employees, agents, independent contractors, and third-party vendors acting at the Company’s direction or on the Company’s behalf.

Nothing in this Policy shall be construed to expand FinBiz LLC’s obligations beyond those imposed by applicable law, to create any private right of action beyond what is expressly provided by statute, or to constitute an admission that any particular practice violates applicable law.

2.DEFINITIONS

For purposes of this Policy, the following terms shall have the meanings set forth below:

“Autodialer” or “ATDS” means equipment that has the capacity to store or produce telephone numbers using a random or sequential number generator and to dial such numbers, as defined under 47 U.S.C. § 227(a)(1) and applicable FCC orders and regulations as interpreted by courts of competent jurisdiction.

“Company DNC List” means FinBiz LLC’s internal do not call suppression list, maintained pursuant to this Policy, containing telephone numbers of individuals who have requested not to receive telephone solicitations from the Company.

“Established Business Relationship” or “EBR” means a prior or existing relationship formed by a voluntary two-way communication between a person and FinBiz LLC, on the basis of an inquiry, application, purchase, or transaction by the person, within the time frames prescribed by 47 C.F.R. § 64.1200(f)(5) and 16 C.F.R. § 310.2(n).

“Prior Express Written Consent” means a written agreement, signed (including by electronic means consistent with the E-SIGN Act, 15 U.S.C. § 7001 et seq.) by the called party, that clearly and conspicuously authorizes FinBiz LLC to deliver or cause to be delivered to the signatory advertisements or telemarketing messages using an autodialer, prerecorded voice, or artificial voice, as required under 47 C.F.R. § 64.1200(f)(9).

“Telephone Solicitation” means the initiation of a telephone call or message for the purpose of encouraging the purchase or rental of, or investment in, property, goods, or services, as defined in 47 U.S.C. § 227(a)(4) and 16 C.F.R. § 310.2(dd), subject to all statutory and regulatory exemptions.

3. SAFE HARBOR FRAMEWORK AND GOOD FAITH COMPLIANCE

FinBiz LLC maintains this Policy specifically to qualify for and preserve all available safe harbor defenses under applicable law, including without limitation:

The TCPA safe harbor under 47 C.F.R. § 64.1200(c)(2)(i), which protects a company from liability for calls to numbers on the National DNC Registry where the company has established and implemented written procedures, trained its personnel, maintained a company-specific DNC list, used a process to prevent calls to numbers on the National DNC Registry, and any violation resulted from an isolated error despite such procedures;
The TSR safe harbor under 16 C.F.R. § 310.4(b)(3), which protects a telemarketer that has subscribed to the National DNC Registry, downloaded the list within 31 days prior to the call, and called erroneously despite its procedures; and
Any analogous state law safe harbor provisions applicable to the jurisdictions in which the Company operates.

In the event of any alleged violation, FinBiz LLC expressly reserves the right to assert all available safe harbor defenses, good faith reliance defenses, bona fide error defenses, and any other defense available under applicable law. The existence of this Policy, compliance records maintained hereunder, and training records shall constitute evidence of FinBiz LLC’s good faith compliance efforts.

FinBiz LLC shall not be deemed to have committed a willful or knowing violation of any applicable statute or regulation solely by reason of an isolated, unintentional error occurring despite its implementation of and adherence to this Policy and the procedures set forth herein.

4. NATIONAL DO NOT CALL REGISTRY COMPLIANCE

FinBiz LLC shall not initiate, or cause to be initiated, any telephone solicitation to any residential telephone subscriber whose number appears on the National DNC Registry, unless one or more of the following applies:

The subscriber has provided FinBiz LLC with Prior Express Written Consent to receive such calls;
FinBiz LLC has an Established Business Relationship with the subscriber, and the subscriber has not separately requested placement on the Company DNC List; or
The call falls within another recognized exemption under the TCPA, TSR, or applicable state law.

FinBiz LLC shall access and honor the National DNC Registry no less frequently than every thirty-one (31) days. Compliance with this scrubbing schedule shall be documented and maintained as part of the Company’s compliance records. FinBiz LLC’s liability for calls to registered numbers shall be evaluated in light of the applicable 31-day safe harbor window and any documented scrubbing records.

5. COMPANY INTERNAL DO NOT CALL LIST

5.1 Establishment and Maintenance

FinBiz LLC shall maintain a written Company DNC List. Any individual who requests not to receive telephone solicitations from the Company shall have his or her telephone number(s) added to the Company DNC List within ten (10) business days of such request, and shall remain on the list indefinitely unless the individual affirmatively requests removal. The Company DNC List shall be scrubbed against all outbound call campaigns prior to any dial.

5.2 Methods of Requesting Opt-Out

Individuals may request placement on the Company DNC List through any of the following channels:

Orally during any call with a FinBiz LLC representative, at any point during the call;
In writing via the Company’s website at [Website – To Be Inserted];
By email to: compliance@finbizllc.com; or
By written mail to: FinBiz LLC, Attn: DNC Compliance, [Address – To Be Inserted], Delaware.

5.3 Scope of Opt-Out

A do not call request made to FinBiz LLC applies to FinBiz LLC and its affiliates and subsidiaries to the extent they are making calls on behalf of FinBiz LLC. FinBiz LLC shall honor the request within the ten (10) business day period prescribed by 47 C.F.R. § 64.1200(d)(3). A do not call request shall not be interpreted as applying to calls that are not telephone solicitations under applicable law (e.g., purely informational or transactional calls, subject to applicable legal requirements).

5.4 Removal from Company DNC List

A number may be removed from the Company DNC List only if the individual whose number appears thereon affirmatively requests reinstatement in writing. Removal shall be documented, including the date of request, method, and identity of the requesting party. The Company DNC List shall be retained even after removal of a number, as an archived record of all prior opt-out requests.

6.1 Prior Express Written Consent for Autodialed and Prerecorded Calls

Prior to initiating any autodialed, prerecorded, or artificial voice call or text message to a cellular number, FinBiz LLC shall obtain Prior Express Written Consent that: (a) is in writing or E-SIGN-compliant electronic form; (b) clearly discloses the nature of the communications authorized; (c) is not a condition of purchase; and (d) identifies FinBiz LLC as the authorized caller. Consent records are FinBiz LLC’s primary defense against TCPA class action claims. For each consent obtained, the Company shall retain: date, time, and method of consent; IP address or device identifier; verbatim disclosure language presented; telephone number(s) covered; and any subsequent revocation. Consent records shall be retained for a minimum of five (5) years, or longer if required by applicable law or pending litigation.

Consumers may revoke consent at any time by any reasonable means. FinBiz LLC shall honor all revocations within ten (10) business days and record them in the Company DNC List. Revocation of marketing call consent does not extend to informational or transactional communications that are not telephone solicitations, unless the consumer expressly so states.

7. CALL TIME RESTRICTIONS

FinBiz LLC shall not initiate telephone solicitations before 8:00 a.m. or after 9:00 p.m. local time at the called party’s location, as required by 47 C.F.R. § 64.1200(c)(1) and 16 C.F.R. § 310.4(c).

8. REQUIRED DISCLOSURES ON CALLS

At the outset of each telephone solicitation, the following disclosures shall be made promptly: The full name of the individual caller (if applicable); The name “FinBiz LLC” as the company on whose behalf the call is made; A telephone number or address at which FinBiz LLC can be contacted; and the purpose of the call.

For prerecorded messages, the message shall: state FinBiz LLC’s name and a toll-free contact/or the primary business number at the outset; permit the consumer to opt out of future calls via an automated interactive mechanism at any time during the message; and honor any opt-out request within ten (10) business days. These disclosures are required by 47 C.F.R. § 64.1200(b) and 16 C.F.R. § 310.4(d) and their satisfaction shall be verified through call monitoring and script review prior to campaign launch.

9. THIRD-PARTY VENDOR OBLIGATIONS AND CONTRACTUAL PROTECTIONS

9.1 Required Contractual Provisions

Any third-party vendor, lead generator, or contractor that makes telephone solicitations on behalf of FinBiz LLC shall, prior to commencing any solicitation activity, execute a written agreement with FinBiz LLC that includes, at minimum, the following provisions: An express representation and warranty that the vendor complies with all applicable federal and state telemarketing laws, including the TCPA and TSR; A covenant to scrub all call lists against the National DNC Registry (within 31 days prior to any campaign and against the Company DNC List prior to each campaign; An obligation to immediately transmit to FinBiz LLC any do not call request received from a consumer, within two (2) business days of receipt; An obligation to obtain and retain valid Prior Express Written Consent for any autodialed or prerecorded calls, and to make consent records available to FinBiz LLC upon request; An indemnification obligation in favor of FinBiz LLC for any losses, claims, penalties, damages, or expenses (including attorneys’ fees) arising from the vendor’s violation of applicable telemarketing laws or of this Policy; FinBiz LLC’s right to audit the vendor’s telemarketing records, consent documentation, and DNC suppression processes upon not less than five (5) business days’ notice; and a right of immediate termination by FinBiz LLC upon discovery of any material non-compliance.

9.2 Vendor Liability Allocation

Notwithstanding FinBiz LLC’s responsibility to maintain compliance policies, any third-party vendor that generates leads or places calls on behalf of FinBiz LLC using its own systems and lists shall bear primary liability for violations arising from that vendor’s independent conduct. FinBiz LLC shall not be deemed vicariously liable for a vendor’s violations where: (a) FinBiz LLC did not direct or control the specific conduct at issue; (b) FinBiz LLC had no actual knowledge of the violation prior to a consumer complaint or legal proceeding; and (c) FinBiz LLC has contractually required the vendor to comply with applicable law. FinBiz LLC shall assert all available defenses to vicarious liability in any proceeding alleging liability for a vendor’s conduct.

10. EMPLOYEE TRAINING AND ACKNOWLEDGMENT

All employees, agents, and contractors involved in outbound telephone solicitation activities shall complete training on this Policy and applicable telemarketing laws prior to initiating any solicitation call. Training shall cover:

The TCPA, TSR, and applicable state telemarketing laws;
Procedures for identifying and honoring do not call requests;
Required call disclosures and script compliance;
Call time restrictions and time-zone verification;
Consent requirements, documentation, and revocation procedures; and
Escalation procedures for complaints, legal demands, and regulatory inquiries.

Training shall be conducted upon hire or engagement and repeated no less than annually, and more frequently upon material changes in applicable law or this Policy. Each trained individual shall execute a written acknowledgment confirming receipt of and compliance with this Policy. Acknowledgment forms shall be retained for a minimum of three (3) years. The existence of completed training acknowledgments shall be presented as evidence of FinBiz LLC’s good faith compliance in any enforcement proceeding.

11. RECORDKEEPING AND EVIDENTIARY PRESERVATION

FinBiz LLC shall maintain the following records for a minimum of five (5) years from the date of creation, or such longer period as required by applicable law or as necessitated by pending or threatened litigation: The Company DNC List in its current and all prior versions, including the date each number was added, the source of the request, and the basis for any removal; National DNC Registry subscription records and all scrub logs, including dates of access and the lists against which calls were scrubbed; Consumer consent records as described in Section 6.2; Call logs for all outbound campaigns, including the date, time, duration, and telephone number called; Records of employee training and written acknowledgments; All consumer complaints received regarding telemarketing activities, and FinBiz LLC’s documented response to each; and all third-party vendor agreements and audit records.

Records shall be stored in a manner that permits prompt retrieval and production in response to regulatory inquiries or litigation discovery. In the event FinBiz LLC receives notice of any claim, demand, regulatory investigation, or litigation relating to its telemarketing activities, a litigation hold shall be immediately implemented to preserve all potentially relevant records, and no records shall be altered, deleted, or destroyed from that point forward without the express authorization of legal counsel.

12. LIMITATION OF LIABILITY AND GOOD FAITH DEFENSE

FinBiz LLC expressly adopts this Policy as a formal, written compliance program consistent with the requirements of 47 C.F.R. § 64.1200(c)(2)(i) and 16 C.F.R. § 310.4(b)(3) for purposes of establishing its entitlement to available statutory safe harbors and affirmative defenses. The following provisions shall govern FinBiz LLC’s liability framework:

12.1 Isolated Error Defense

An isolated, unintentional violation of applicable telemarketing law occurring despite FinBiz LLC’s maintenance of this Policy and the procedures set forth herein shall not constitute a willful or knowing violation for purposes of trebled damages under the TCPA or enhanced penalties under the TSR. FinBiz LLC shall document all good faith remediation steps taken promptly following discovery of any isolated error, which documentation shall be preserved as part of the compliance record.

12.2 No Waiver of Defenses

Nothing in this Policy shall be construed as a waiver of any defense available to FinBiz LLC under applicable law, including without limitation: the safe harbor defense; the bona fide error defense; the absence of willfulness; lack of actual authority or ratification of a vendor’s conduct; constitutional challenges to statutory damages; or any defense based on the called party’s consent, EBR, or prior business dealings with the Company.

12.3 Vendor Indemnification

To the extent any claim, penalty, damage, or expense asserted against FinBiz LLC arises from or relates to the conduct of a third-party vendor, FinBiz LLC shall seek full indemnification from such vendor pursuant to the contractual provisions required under Section 9 of this Policy. Legal counsel shall be engaged promptly to pursue indemnification and contribution claims where warranted.

12.4 No Private Right of Action Under This Policy

This Policy is an internal compliance document. It does not create any private right of action in favor of any consumer, employee, vendor, or third party beyond the rights expressly conferred by applicable statute. No provision of this Policy shall be interpreted to expand FinBiz LLC’s legal obligations beyond what is required by applicable law, or to provide any basis for a claim that FinBiz LLC has assumed obligations in excess of its statutory duties.

13. INTERNAL VIOLATIONS AND ENFORCEMENT

Violations of this Policy by employees or agents of FinBiz LLC may result in disciplinary action up to and including immediate termination of employment or engagement. Violations by third-party vendors shall result in immediate notice of default, suspension of campaign activity pending investigation, and enforcement of applicable contractual remedies including indemnification demands and contract termination.

Employees or agents who become aware of a potential violation of this Policy or applicable telemarketing law are required to report such concerns immediately to the Compliance Officer at compliance@finbizllc.com. FinBiz LLC prohibits retaliation against any individual who in good faith reports a potential compliance concern. Documented reports of compliance concerns, and the Company’s responses thereto, shall be retained as part of the compliance record and may be used to demonstrate good faith remediation in any enforcement proceeding.

14. STATE-SPECIFIC COMPLIANCE

FinBiz LLC shall comply with all applicable state telemarketing statutes in each state into which it directs solicitations. As a Delaware LLC: (a) Delaware does not maintain a separate state DNC list and adopts the National DNC Registry by reference (6 Del. C. §§ 2501A et seq.); the Delaware Attorney General may enforce violations with civil penalties up to $10,000 per violation; (b) to the extent calls relate to financial products, additional disclosure obligations under the Delaware Securities Act (6 Del. C. § 7301 et seq.) and applicable banking regulations apply and shall be reviewed by legal counsel before campaign launch; and (c) for multi-state operations, the Compliance Officer shall maintain a state-by-state compliance matrix updated at least annually, states with notably more stringent regimes include Florida (Fla. Stat. § 501.059), California (Cal. Bus. & Prof. Code § 17592), New York (Gen. Bus. Law § 399-z), and Indiana (Ind. Code § 24-4.7).

15. INCIDENT RESPONSE PROTOCOL

In the event FinBiz LLC receives a consumer complaint, demand letter, regulatory inquiry, or legal proceeding alleging violation of the TCPA, TSR, or any applicable state telemarketing law, the following protocol shall be implemented without delay:

Notify the Compliance Officer and outside legal counsel within twenty-four (24) hours of receipt.
Implement an immediate litigation hold: preserve all call logs, consent records, DNC scrub logs, training records, and vendor agreements relating to the alleged violation. No records shall be altered or destroyed.
Suspend the relevant campaign or calling activity pending a preliminary investigation, unless legal counsel advises otherwise.
Conduct a documented internal investigation to determine: (a) whether the alleged violation occurred; (b) if so, whether it constitutes an isolated error or a systemic failure; (c) the root cause; and (d) available defenses, including the safe harbor, bona fide error, and consent defenses.
Do not communicate with the complaining consumer or any regulator without the prior review and approval of legal counsel.
Document all investigative steps, findings, and remediation measures, and retain such documentation as part of the compliance record.
If a systemic deficiency is identified, implement corrective measures within thirty (30) days and document such measures as evidence of good faith remediation.

FinBiz LLC’s incident response documentation – including litigation hold notices, investigation reports, and remediation records – shall constitute material evidence of the Company’s good faith compliance posture and shall be made available to legal counsel in connection with any defense strategy.

16. PRACTICAL COMPLIANCE MEASURES – OUTBOUND CALLING OPERATIONS

Adherence to this Section is mandatory and constitutes the operational implementation of FinBiz LLC’s safe harbor compliance program.

16.1 Pre-Campaign Checklist (Required Before Every Campaign)

Scrub call list against the National DNC Registry within 31 days before launch (paid FTC subscription required).

Verify Prior Express Written Consent records for any mobile numbers where an autodialer or prerecorded voice will be used.

Approve all call scripts for required disclosures and confirm dialing systems enforce the 8:00 a.m.–9:00 p.m. local time rule. Obtain written confirmation from any third-party dialing platform that its system supports real-time DNC suppression.

16.2 During Active Calling

Representatives must identify themselves and FinBiz LLC at the outset of every call.

Any opt-out request, in any form must be logged immediately and routed to the DNC intake process. No delay or negotiation is permitted.

Representatives are prohibited from misleading, deceptive, or high-pressure tactics in violation of 16 C.F.R. § 310.3.

Call monitoring shall be conducted on a sampling basis to verify script and opt-out compliance.

16.3 Post-Campaign and Ongoing

DNC requests received during a campaign must be entered into the Company DNC List within ten (10) business days.

Re-scrub the Company DNC List against the National DNC Registry every 31 days on a rolling basis.

Archive all call logs, consent records, and scrub logs for a minimum of five (5) years.

Log and investigate all consumer complaints within five (5) business days; document all responsive actions.

16.4 Compliance Audits

Internal audit by the Compliance Officer at least annually, covering scrub logs, consent records, call logs, training records, and vendor certifications. Escalate and remediate any systemic deficiency within thirty (30) days.

External audit by independent counsel or a third-party compliance firm at least every two (2) years, or following any regulatory inquiry or class action filing.

17. POLICY REVIEW AND AMENDMENT

This Policy shall be reviewed at least annually by the Compliance Officer and legal counsel and updated to reflect changes in applicable law, regulatory guidance, or Company operations. FinBiz LLC reserves the right to amend this Policy at any time. Material amendments shall be communicated to all personnel and vendors subject to this Policy and shall take effect upon adoption.

18. CONTACT INFORMATION

All do not call requests, compliance inquiries, and consumer complaints should be directed to:

FinBiz Funding LLC
Email: legal@finbizfunding.com
Phone: +1 (346) 222-4246
Site: https://finbizfunding.com/

IMPORTANT DISCLAIMER: This Policy is an internal compliance document adopted for the benefit of FinBiz LLC. It does not constitute legal advice, does not create any private right of action in favor of any third party, and shall not be construed as an admission of liability or as an acknowledgment that any particular practice violates applicable law. FinBiz LLC expressly reserves all defenses, rights, and remedies available under applicable federal and state law. Questions regarding specific legal obligations should be directed to qualified legal counsel.