Service AgreementAcceptable UsePrivacyWALTER SPEAKING

PROCURE MEDIA, LLC

ACCEPTABLE USE POLICY

Effective Date: July 7, 2026 • Version 1.0

1. Overview

1.1 Purpose. This Acceptable Use Policy (the “AUP”) describes conduct that is prohibited when accessing or using the services of Procure Media, LLC (“Procure”). It is part of, and incorporated into, the Procure Media Service Agreement (the “Agreement”). Capitalized terms not defined here have the meaning given in the Agreement.

1.2 Your Responsibility. You are responsible for your own use of the Services, for your users, and for any activity under your account. Violation of this AUP is a material breach of the Agreement and may result in immediate suspension or termination for cause under Section 6 of the Agreement, without refund, in addition to any other remedy available to Procure.

1.3 Examples Only; Not Exhaustive. This AUP describes examples of prohibited conduct but is not exhaustive. Procure may determine that other conduct is prohibited if it creates legal, operational, security, reputational, or business risk. Nothing in this AUP limits Procure’s right to refuse service to, or to suspend or terminate, any customer or account that Procure determines, in its sole and absolute discretion, presents unacceptable legal, regulatory, financial, operational, security, or reputational risk.

2. Compliance With Law

You will not use the Services in any way that violates any applicable law or regulation. Without limitation, you will not use the Services to violate:

3. Consent, Contact, and Messaging Rules

3.1 Consent. Before contacting any Lead by call, text, or email, you must obtain and maintain all legally required consents. You may not rely on Procure to have obtained consent on your behalf.

3.2 Do-Not-Call and Opt-Outs. You must maintain your own internal do-not-call list, honor all opt-out and unsubscribe requests promptly, and comply with calling-time restrictions and identification requirements.

3.3 Telephony, SMS, and Carrier Compliance. If you use any Procure calling or messaging feature, you must comply with all applicable carrier requirements, messaging-provider policies (for example, Twilio, Bandwidth, and similar providers), and industry best practices (including CTIA guidelines and A2P 10DLC / toll-free registration and messaging-content rules), maintain records of consent, and not send unlawful robocalls, spam, or prohibited message content.

3.4 No Harassment. You will not use the Services to harass, threaten, defraud, deceive, or abuse any Lead, consumer, or other person.

3.5 Recordkeeping. You must maintain records reasonably sufficient to demonstrate your compliance with applicable consent, marketing, and communications laws, and provide them to Procure on reasonable request.

4. Prohibited Uses of Leads and the Services

You will not:

5. Prohibited Industries and Offerings

You will not use the Services in connection with any of the following, except with Procure’s prior written approval:

6. Platform, Security, and Technical Restrictions

You will not:

7. Data Protection and Security

7.1 Consumer Data. You will handle all personal information you receive through the Services in accordance with applicable law, keep it secure, use it only for the lawful purpose for which it was provided, and honor any access, deletion, or opt-out request you are required to fulfill.

7.2 No Enrichment for Prohibited Purposes. You will not combine, append, or enrich Lead data to build profiles for unlawful, discriminatory, or prohibited uses.

7.3 Data Retention and Destruction. You will securely destroy Lead and consumer data when it is no longer needed for the purpose for which it was provided or when required by law.

7.4 Security Incident Reporting. You will promptly notify Procure of any unauthorized access, security incident, or compromise involving Procure data or Leads.

8. Enforcement

8.1 Sole Discretion; No Duty to Monitor. Procure has the sole and absolute discretion to determine whether conduct violates this AUP, and Procure’s determination is final, subject to applicable law. Procure has no obligation to monitor use of the Services, but may do so.

8.2 Suspension and Termination. Procure may suspend, restrict, disable, or permanently terminate access, remove or disable content, throttle usage, or take any other action it deems appropriate, immediately and without prior notice, and without liability or refund, for any actual or suspected violation of this AUP or the Agreement, or where a customer’s activities expose Procure to legal, regulatory, operational, security, carrier, payment-processor, advertiser, or reputational risk. Procure may report suspected unlawful activity to law enforcement and cooperate with authorities.

8.3 Documentation and Audit. Procure may request reasonable documentation demonstrating your compliance with this AUP and applicable law, and you agree to provide it within a reasonable time.

8.4 No Refund. Suspension or termination for a violation of this AUP is a termination for cause; Fees already paid are non-refundable and the end-of-period continuation described in the Agreement does not apply.

8.5 Reporting Abuse. To report a suspected violation of this AUP, contact Procure at dan@procuremedia.com.

9. Changes to This AUP

Procure may update this AUP from time to time. Procure will post the updated AUP and revise the “Last Updated” date. Your continued use of the Services after the effective date constitutes acceptance of the updated AUP.