1. Introduction
   This Use Policy governs access to and use of APEX TELECO LLC (“APEX”) communications services (“Services”) by customers and their end users. APEX’s goals are legal compliance, caller ID integrity, network security, and recipient trust.
2. Compliance Requirements
   A. Laws and Rules
   • TCPA, 47 U.S.C. § 227; FCC rules at 47 CFR § 64.1200.
   • Caller ID authentication and robocall mitigation, 47 CFR § 64.6305.
   • Telemarketing Sales Rule, 16 CFR Part 310, and applicable state DNC laws.
     Carrier/Industry Standards
   • Applicable carrier requirements and reasonable analytics-based filtering expectations.

III. Prohibited Conduct
A. Illegal or Deceptive Activity
(i) Fraud, identity theft, or phishing; (ii) violations of law or regulation; (iii) misrepresentations to APEX about identity, use case, or traffic.
B. Robocalls/Telemarketing Violations
(i) Calls without required consent; (ii) failure to honor opt-out/stop requests; (iii) contacting DNC-listed numbers absent an exemption.
C. Caller ID Misrepresentation
(i) Manipulating or spoofing caller ID to deceive recipients; (ii) presenting false or unassigned numbers; (iii) evasion tactics such as snowshoeing/rotations to avoid detection.
D. Service Integrity and Security
(i) Bypassing filters or limitations; (ii) DoS or attempts to overload Services; (iii) introducing malware or automated bots; (iv) unauthorized access; (v) reverse engineering or disassembly.
E. Abusive Content and IP Infringement
(i) Harassment, threats, or hate speech; (ii) infringement of copyright, trademark, or other rights.
F. Abnormal or Harmful Traffic
(i) Artificially inflated traffic, call pumping, or revenue-share schemes; (ii) persistent short-duration anomalies; (iii) unusual or repetitive sequences inconsistent with disclosed use cases; (iv) long-duration or repetitive calls designed to generate fees.

1. Customer Duties
   A. KYC and Information Accuracy
   Provide requested identity and corporate documents; keep use-case details current.
   B. Consent and Opt-Out Controls
   Maintain proof of consent; implement and honor opt-out mechanisms promptly.
   C. Downstream Compliance
   Contractually bind downstream clients to equivalent obligations; monitor their activity.
   D. Cooperation and Traceback
   Respond in a timely manner—typically within 24 hours—to APEX inquiries, including Industry Traceback Group requests.
2. Enforcement and Remedies
   APEX may, at its discretion and consistent with law and contract:
   (a) Block calls, numbers, routes, or destinations; (b) apply rate limits; (c) suspend or terminate Services; (d) cooperate with carriers, regulators, ITG, or law enforcement; (e) recover fees, costs, or damages. Lack of immediate action does not waive APEX’s rights.
3. Policy Changes and Contacts
   APEX may modify this Policy with reasonable notice (e.g., website posting, account notice, or email).

• Abuse and violations: abuse@apexteleco.com
• Law enforcement and traceback: traceback@apexteleco.com