Document Version: 1.0
Last Updated: November 6, 2025
Prepared for: Twilio Toll-Free Verification

1. About Xprenz
2. SMS Use Cases
3. Opt-In Process
4. Consent Language
5. Opt-Out Process
6. Message Frequency
7. Data Collection & Storage
8. User Support
9. Compliance Measures

Business Name: Xprenz
Industry: Financial Technology (FinTech) / Social Messaging Platform
Business Type: Mobile Application

Description:
Xprenz is a comprehensive mobile communication and financial platform that combines messaging, group chat, and integrated payment features. The app enables users to:

• Send and receive messages (individual and group chats)
• Manage group finances and shared expenses
• Send and receive money domestically and internationally
• Split bills and track group contributions
• Conduct peer-to-peer financial transactions

SMS Messaging Purpose:
Xprenz uses SMS to deliver critical transactional notifications, security alerts, and account activity updates to ensure users stay informed about their financial transactions and account security, especially when they don't have immediate access to the mobile application.

Xprenz sends SMS messages for the following purposes:

Financial Transactions:

• Payment received confirmations
• Money sent confirmations
• Payment request notifications
• Currency exchange notifications
• Transaction failure alerts
• Refund notifications
• Group contribution reminders
• Bill split notifications

Account Security:

• Login verification codes (2FA/OTP)
• Suspicious activity alerts
• Password reset confirmations
• Device verification codes
• Account lockout notifications
• Security setting changes

Account Notifications:

• New message alerts (when push notification fails)
• Group chat invitations
• Payment link sharing
• Account verification status
• KYC (Know Your Customer) status updates
• Account limit notifications

• App update reminders
• Scheduled maintenance notifications
• Service disruption alerts
• Terms of service updates (critical)

• Promotional offers (only if separately opted-in)
• New feature announcements
• Referral program invitations
• Special discount notifications

Note: Marketing messages are completely optional and require separate explicit consent from transactional messages.

Xprenz collects explicit, affirmative consent from users before sending any SMS messages. Users must actively opt-in; we do not use pre-checked boxes or implicit consent.

Location: Mobile App - Phone Verification Screen

Process:

1. User downloads Xprenz mobile application
2. User begins account creation process
3. User enters their mobile phone number
4. User is presented with SMS consent screen containing:

• Unchecked checkbox for transactional SMS consent (required)
• Unchecked checkbox for marketing SMS consent (optional)
• Full disclosure of message types and frequency
• Clear explanation of message and data rates
• Opt-out instructions (STOP keyword)
• Help instructions (HELP keyword)
• Links to Terms of Service and Privacy Policy
• Support contact information

1. User must actively check the transactional SMS consent box to proceed
2. User may optionally check the marketing SMS consent box
3. User taps "Continue" or "Verify Phone Number" button
4. System records:

• Timestamp of consent
• IP address
• Device information (model, OS version)
• Consent version
• Opt-in location (app screen identifier)
• User ID

1. Verification code is sent via SMS
2. User enters verification code to confirm phone number ownership
3. Account creation is completed

Consent is Required: Users cannot proceed with account creation without providing transactional SMS consent, as SMS is used for critical security notifications (2FA codes, fraud alerts).

Location: Mobile App - Settings → Notifications → SMS Preferences

Process:

1. User navigates to app settings
2. User selects "Notifications" or "SMS Preferences"
3. User sees toggle switches for:
   • Transactional SMS (if previously opted out)
   • Marketing SMS (optional)

1. User enables desired SMS types
2. System displays consent confirmation dialog with full disclosure
3. User confirms consent
4. System records opt-in with timestamp and metadata

Use Cases:

• User previously opted out and wants to re-enable SMS
• User wants to add marketing SMS consent
• User wants to update SMS preferences

Location: Various app screens when SMS-related features are accessed

Process:

1. User attempts to use a feature that benefits from SMS notifications (e.g., sending money)
2. System checks if user has SMS consent
3. If no consent, app displays opt-in prompt explaining:
   • Why SMS is recommended for this feature
   • What types of messages will be sent
   • How to opt-out later
   • Full disclosure information

1. User can choose "Enable SMS" or "Not Now"
2. If enabled, system records consent with metadata

Example Scenarios:

• First time sending money: "Get SMS confirmations for all transactions"
• Setting up 2FA: "SMS verification codes for secure login"  
• Joining a group finance: "Get SMS reminders for group contributions"

Location: https://www.xprenz.com/sms-notifications

Process:

1. User visits Xprenz website
2. User navigates to SMS notification signup page
3. User fills out form with:
   • Phone number
   • Email address (for confirmation)
   • Name

1. User reads full SMS terms and conditions on page
2. User checks consent checkboxes (not pre-checked)
3. User submits form
4. System sends confirmation SMS with instructions to reply YES
5. User replies YES to confirm (double opt-in)
6. System sends welcome message and records consent

• Explicit Consent Request: All opt-in screens display the heading "SMS Notifications" followed immediately by the consent statement "I agree to receive account updates and notifications via text messages from Xprenz" so the intent of the checkbox is unmistakable and aligned with the informational use case.
• Separated Agreements: SMS consent checkboxes are listed independently from acknowledgments for the privacy policy, terms of service, or other agreements. Users must accept those agreements separately, preventing bundled consent.
• Prominent Placement: The consent language, checkbox, and supporting disclosures are positioned directly above the primary action button on the screen, with 14px minimum font size and standard brand contrast so the language is never hidden or minimized.
• Message Type Disclosure: The consent copy summarizes the categories of SMS traffic (transactional alerts, account security, group finance updates, account notifications, and optional promotions) so users understand exactly what they are opting into before submitting the form.
• Clarity & Accessibility: All disclosures, including message frequency and carrier rate notices, are written in plain language at an eighth-grade reading level and are available in the app's supported languages.

Exact Language Displayed to Users:

SMS Notifications

By checking this box, I agree to receive account updates, transactional alerts, and security notifications via SMS text messages from Xprenz to the mobile number provided above. These messages include:

• Payment confirmations and receipts
• Money transfer notifications
• Security alerts and verification codes (2FA/OTP)
• Account activity notifications
• Group finance updates and reminders
• Important service announcements

Message Frequency: Message frequency varies based on your account activity. You may receive multiple messages per day during active use.

Cost: Message and data rates may apply. Standard messaging rates from your mobile carrier will apply to all SMS messages sent and received.

Opt-Out: You can opt out of SMS notifications at any time by:

• Texting STOP to any message from Xprenz
• Disabling SMS in your app Settings
• Contacting customer support

Help: Text HELP to any message for assistance, or contact support@xprenz.com

Support: For questions or assistance:

• Email: support@xprenz.com
• Phone: (855) 773-5415 
• In-app: Settings → Help & Support

By providing your mobile number and checking this box, you agree to receive SMS messages from Xprenz and confirm that you are the account holder or have authorization to use this number. You also agree to our [Terms of Service] and [Privacy Policy].

Exact Language Displayed to Users:

Promotional SMS (Optional)

☐ I agree to receive marketing messages and special offers from Xprenz via text message, including:

• Special offers and discounts
• New feature announcements
• Referral rewards
• Exclusive promotions for Xprenz users

Message Frequency: Up to 4 promotional messages per month. Frequency may vary based on special events and promotions.

Opt-Out: You can opt out of promotional messages at any time without affecting your transactional notifications by:

• Texting STOP PROMO to any promotional message
• Disabling marketing SMS in Settings → Notifications
• Contacting customer support

This is completely optional. You will still receive important transactional and security messages even if you don't opt in to promotional messages.

Sent immediately after phone verification:

Welcome to Xprenz! Your account is now set up. You'll receive SMS notifications for transactions, security alerts, and account updates. Message frequency varies. Msg & data rates may apply. Reply STOP to opt out, HELP for support. Terms: xprenz.com/terms

Xprenz provides multiple, easily accessible methods for users to opt out of SMS notifications at any time. All opt-out requests are processed immediately and automatically.

Process:

1. User replies "STOP" to any SMS from Xprenz
2. System automatically:
   • Marks user as opted-out in database
   • Records opt-out timestamp
   • Updates user notification preferences
   • Stops all SMS messages immediately

1. System sends final confirmation SMS:

"You have been unsubscribed from Xprenz SMS notifications. You will no longer receive text messages from us. To resubscribe, reply START or update your preferences in the app. For support: support@xprenz.com"

Accepted Keywords: STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, QUIT

Processing Time: Immediate (within seconds)

Important Note: Critical security messages (e.g., fraud alerts, account compromise) may still be sent even after opt-out to protect the user's account, as required by financial services regulations.

Location: Mobile App - Settings → Notifications → SMS Preferences

Process:

1. User opens Xprenz app
2. User navigates to Settings → Notifications
3. User sees SMS toggle switches:
   • Transactional SMS: ON/OFF
   • Marketing SMS: ON/OFF

1. User toggles OFF for desired category
2. System displays confirmation dialog: "Are you sure you want to disable SMS notifications? You'll miss important updates about your transactions."
3. User confirms opt-out
4. System immediately:
   • Updates user preferences
   • Records opt-out with timestamp
   • Displays success message

1. User receives confirmation SMS (final message)

Granular Control:

• Users can opt out of marketing SMS while keeping transactional SMS
• Users can completely opt out of all SMS
• Users can easily re-enable SMS at any time

Contact Methods:

• Email: support@xprenz.com
• Phone: (855) 773-5415
• In-app chat: Settings → Help & Support → Contact Us 

Process:

1. User contacts support via any channel
2. User requests SMS opt-out
3. Support agent:
   • Verifies user identity
   • Processes opt-out request immediately
   • Confirms opt-out to user
   • Provides reference number

1. System records opt-out with support ticket ID
2. User receives confirmation email

Response Time: Within 24 hours (usually immediate during business hours)

Location: https://www.xprenz.com/account/notifications

Process:

1. User logs into Xprenz web portal
2. User navigates to Account → Notification Preferences
3. User unchecks SMS notification checkboxes
4. User saves changes
5. System processes opt-out immediately
6. User sees confirmation message on screen
7. User receives confirmation email

Process:

1. User replies "START" to previous Xprenz messages
2. System automatically:
   • Re-enables SMS notifications
   • Records opt-in timestamp
   • Updates user preferences

1. System sends confirmation SMS:

"Welcome back! You have been resubscribed to Xprenz SMS notifications. You'll receive messages about transactions, security, and account updates. Reply STOP to opt out anytime."

Accepted Keywords: START, UNSTOP, YES

Users can re-enable SMS at any time through app Settings following the same process as initial opt-in (Method 2 above).

Frequency: Varies based on user activity

Typical Usage Patterns:

• Active Users (3-5 transactions/day): 5-15 messages per day
• Transaction confirmations
• Group chat notifications
• Payment requests
• Security verifications
• Moderate Users (1-2 transactions/day): 2-5 messages per day
• Transaction confirmations
• Occasional group updates
• Light Users (< 1 transaction/day): 1-3 messages per week
• Occasional transactions
• Security alerts as needed
• Inactive Users: 0-1 messages per month
• Security alerts only
• Critical account notifications

Peak Times:

• Higher volume during: weekdays, end of month (bill splitting), holidays (money transfers)
• Lower volume during: weekends, early morning hours

Time-of-Day Sending Policy:

• Transactional messages: Sent immediately when event occurs (24/7)
• Marketing messages: Only sent between 8 AM - 9 PM user's local timezone
• Security alerts: Sent immediately regardless of time (critical)

Frequency: Maximum 4 messages per month (up to 1 per week)

Typical Pattern:

• Weekly feature highlights: 1 per week
• Special promotions: 1-2 per month
• Seasonal offers: During major holidays/events

Sending Times: Only between 9 AM - 8 PM user's local timezone, never on major holidays

For every opt-in, Xprenz collects and stores the following information:

Required Data:

• Phone number (E.164 format)
• User ID (unique identifier)
• Opt-in timestamp (UTC)
• Consent type (transactional, marketing, or both)
• Consent version (terms version number)
• Opt-in method (app_registration, settings, contextual, website)
• Opt-in location (specific screen/page identifier)

Metadata for Verification:

• IP address (IPv4 or IPv6)
• Device information (manufacturer, model, OS version)
• App version
• User agent (for web opt-ins)
• Geographic location (country/region)

Audit Trail:

• All consent changes (opt-in, opt-out, preference updates)
• Timestamps for each change
• Method of change
• Reason for change (if applicable)

Database: PostgreSQL (encrypted at rest)

Retention Period: Minimum 4 years after opt-out or account closure (compliance requirement)

Security Measures:

• Encrypted database connections (TLS 1.3)
• Access restricted to authorized personnel only
• Regular security audits
• GDPR and CCPA compliant data handling
• Automated backups (daily)

Export Capability:

• Consent records can be exported to CSV format
• Available for regulatory audits
• User can request their consent history via support

Who Can Access Consent Data:

• Authorized Xprenz compliance team
• Customer support (limited view for user assistance)
• Legal team (for regulatory requests)
• Regulatory authorities (with proper legal documentation)

Who Cannot Access:

• Marketing team (cannot send messages to opted-out users)
• Third-party vendors (no sharing of consent data)
• External parties (except as required by law)

Before sending any SMS, Xprenz system automatically:

1. Checks Consent Status

• Queries database for current opt-in status
• Verifies consent type (transactional vs marketing)
• Confirms consent is active (not expired or revoked)

1. Validates Phone Number

• Confirms number is verified
• Checks for invalid/disconnected numbers
• Respects carrier opt-out lists

1. Applies Business Rules

• Respects time-of-day restrictions (marketing only)
• Applies rate limiting (prevent spam)
• Checks message frequency caps

1. Logs Message

• Records message type
• Stores message content
• Tracks delivery status
• Links to consent record

Every SMS sent is logged with:

• Message ID (Twilio SID)
• Recipient phone number
• Message type (transactional, marketing, security)
• Message content
• Send timestamp
• Delivery status (sent, delivered, failed, bounced)
• Consent verification (confirmed user had active consent)
• Cost (for accounting)

Delivery Status Monitoring:

• Track delivery success/failure rates
• Monitor bounce rates
• Identify problematic numbers
• Automatic retry logic for failed messages (transactional only)

Primary Support Channels:

1. Email Support

• Address: support@xprenz.com
• Response Time: Within 24 hours
• Available: 24/7 (automated responses after hours)

1. Phone Support

• Number: (855) 773-5415 
• Hours: Monday-Friday, 9 AM - 6 PM EST
• Available: Voice support during business hours

1. In-App Support

• Location: Settings → Help & Support
• Features: Live chat, FAQ, Contact form
• Response Time: Within 2 hours (business hours)

1. SMS Keywords

• HELP: Sends automated response with support information
• STOP: Immediate opt-out
• START: Re-opt-in

When user texts "HELP" to Xprenz:

Xprenz SMS Help: You're receiving notifications about transactions, security alerts, and account updates. Msg frequency varies. Msg & data rates apply. Reply STOP to unsubscribe. Support: support@xprenz.com or (855) 773-5415. Terms: xprenz.com/terms

SMS-Related Issues:

• Not receiving verification codes
• Want to change phone number
• Receiving too many messages
• Want to opt-out/opt-in
• Reporting spam or phishing attempts
• Billing questions about message charges

Support Resolution:

• Verify consent status
• Check phone number validity
• Resend verification codes
• Process opt-out/opt-in requests
• Update user preferences
• Escalate technical issues

United States:

• TCPA (Telephone Consumer Protection Act): Full compliance
• Prior express consent for all messages
• Easy opt-out mechanism
• Respect Do Not Call registries
• No autodialing without consent
• CAN-SPAM Act: Applicable to marketing messages
• Clear identification of sender
• Accurate subject lines (for MMS)
• Physical address in marketing messages
• Honor opt-outs within 10 days
• CTIA Guidelines: Mobile messaging best practices
• Proper opt-in procedures
• Clear terms and conditions
• Message frequency disclosure
• Cost disclosure
• STOP, HELP, START keyword support

International:

• GDPR (Europe): User consent and data protection
• Privacy Laws: Compliance with applicable regional laws

Prohibited Content:

• No SHAFT content (Sex, Hate, Alcohol, Firearms, Tobacco)
• No phishing or deceptive content
• No malware or suspicious links
• No harassment or abusive messages
• No unauthorized account sharing

Quality Assurance:

• All message templates reviewed by compliance team
• Regular audits of sent messages
• Monitoring of user complaints
• Carrier feedback monitoring
• Deliverability rate tracking

Staff Training:

• All customer support staff trained on SMS compliance
• Developers trained on consent verification requirements
• Regular compliance updates and training
• Documentation of training activities

Twilio Toll-Free Compliance:

• Completed toll-free verification
• Submitted use case documentation
• Provided opt-in/opt-out workflows
• Submitted sample messages
• Provided business documentation

Ongoing Monitoring:

• Track spam complaint rates (maintain < 0.1%)
• Monitor carrier filtering/blocking
• Respond to carrier inquiries promptly
• Maintain good sending reputation

Monthly Reviews:

• Consent opt-in/opt-out rates
• Message volume by type
• Delivery success rates
• User complaints and resolutions
• Compliance violations (if any)

Quarterly Reviews:

• Full consent database audit
• Message content compliance review
• Support ticket analysis (SMS-related)
• Carrier feedback review
• Policy updates (if needed)

Available for Regulatory Review:

• Complete consent records (anonymized if required)
• Message sending logs
• Opt-out processing records
• User complaint logs
• Support interaction records
• Compliance documentation

Export Formats:

• CSV (consent records, message logs)
• PDF (policies, procedures, training records)
• JSON (API data for automated systems)

Payment Sent:

You sent $50.00 to John Smith via Xprenz. Transaction ID: TXN12345. Balance: $150.00. Questions? support@xprenz.com

Payment Received:

You received $25.00 from Jane Doe via Xprenz. Transaction ID: TXN12346. Balance: $175.00. View details in app.

2FA Verification:

Your Xprenz verification code is: 123456. Valid for 10 minutes. Don't share this code. Didn't request this? Contact support immediately.

Security Alert:

SECURITY ALERT: New device login detected on your Xprenz account from New York, NY. If this wasn't you, secure your account now: xprenz.com/secure

Group Contribution Reminder:

Reminder: Your contribution of $30.00 for "Vacation Fund" group is due in 2 days. Pay now in the Xprenz app. Reply STOP to opt out.

Payment Request:

Sarah Johnson requested $15.00 from you via Xprenz for "Dinner Split". Accept or decline in the app. Msg & data rates apply.

Feature Announcement:

NEW on Xprenz: Send money internationally to 50+ countries! Get started today with zero fees on your first transfer. T&Cs apply. Reply STOP to opt out.

Promotional Offer:

Limited time: Refer a friend to Xprenz and you both get $10! Share your referral link in the app. Offer ends 12/31. Reply STOP PROMO to opt out.

Welcome Message (Initial):

Welcome to Xprenz! Your account is set up. You'll receive SMS for transactions & security alerts. Msg frequency varies. Msg & data rates apply. Reply STOP to opt out, HELP for support.

Opt-Out Confirmation:

You've unsubscribed from Xprenz SMS. You won't receive text messages from us. To resubscribe, reply START or update in app. Support: support@xprenz.com

Re-Opt-In Confirmation:

Welcome back! You're resubscribed to Xprenz SMS. You'll receive transaction & security messages. Reply STOP anytime to opt out.

Policy Updates:

• This document is reviewed quarterly
• Updates made to reflect:
  • Regulatory changes
  • Feature additions
  • User feedback
  • Carrier requirements

User Notification of Changes:

• Material changes: Users notified via email and in-app notification
• Minor updates: Updated on website with change log
• Consent re-verification: Required if messaging use case significantly changes

Version Control:

• Each policy version is dated and numbered
• Previous versions archived for audit purposes
• Users can request historical policy versions

Xprenz
Business Address: [Insert physical business address]
Email: support@xprenz.com
Phone: (855) 773-5415
Website: https://www.xprenz.com

For Regulatory Inquiries:
Email: compliance@xprenz.com
Phone: [Insert compliance team direct line]

For Twilio/Technical Issues:
Email: tech@xprenz.com
Phone: [Insert technical team contact]

Note: Actual screenshots of the opt-in process are available upon request and will be uploaded during the Twilio toll-free verification submission process.

Screenshots Include:

1. Account registration screen with SMS consent checkboxes
2. Full consent language displayed to users
3. SMS preferences in app settings
4. Opt-out confirmation dialog
5. Terms of Service (relevant SMS sections)
6. Privacy Policy (relevant SMS sections)