Pursuant to 47 CFR § 64.6305, all voice service providers must file certifications to the Federal Communications Commission’s Robocall Mitigation Database providing detailed information regarding their implementation of the STIR/SHAKEN caller ID authentication framework and/or a robocall mitigation program.  Accordingly, Zultys has implemented this robocall mitigation program (the “Robocall Mitigation Program”).

1. Robocall Mitigation Program Applicability

All calls originated by customers are subject to the Robocall Mitigation Program. By accepting Zultys’ Terms and Conditions, you agree to participate in the Robocall Mitigation Program, provide required information about your business entity, commit to responding to requests to trace suspect calls and cooperate in investigating and stopping illegal robocallers.

• Vetting Customer Entity and Identity
  • All new and renewing customers are subject to a vetting process that involves verifying the customer’s information as is provided in the signed Zultys Services Agreement.
• Telephone Number Authorization/Validation
  • Your system should be provisioned to originate calls from valid phone numbers only. A phone number is considered valid if it is legally owned by you or assigned to you by any entity that owns the phone number. Zultys reserves the right to block phone calls originating from phone numbers that fail validation. Zultys can request proof of ownership for phone numbers used as a Caller ID. Phone numbers allocated by Zultys or ported to Zultys are considered authorized and do not require additional validation.

2. Measures to Prevent or Avoid the Origination of Illegal Robocalls 

• Monitoring
  • Zultys utilizes analytics technologies to monitor traffic on the network to identify potentially unlawful call origination activity. Illegal call originators are being recognized by examining call detail records to identify such activity as intermittent bursts of high activity, suspiciously low call completion rates/short call times, and evidence of systematic calling, or “war dialing.”
• Investigation of Suspicious Activity
  • Zultys will investigate potentially unlawful call origination activity and decide what action to take for remediation. This action may include immediate call blocking and notification to you to stop the illegal calling, or Zultys may directly contact the party sending Zultys the calls (i.e., Zultys’ carrier/provider customer) to investigate and determine whether the calls are unlawful and eliminate the source of the calling if appropriate. You agree to respond within two (2) business days of Zultys’ requests to provide information (the “Notice Period”) regarding the unlawful activity and traceback requests Zultys may receive from the upstream carriers.
• Call Blocking and Service Cancellation
  • If you do not respond to Zultys during the Notice Period or refuse to cooperate to remediate the unlawful call activity, your non-compliance shall be considered a material breach of the Terms and Conditions, and Zultys shall be entitled to exercise its right to disconnect and cancel the Services in accordance with Terms and Conditions.