Policy for Branded Calling

    First Orion's Policy for Branded Calling was developed and proven based on more than a decade of experience in delivering industry-leading services that protect consumers from scam and nuisance calls and promote legitimate calls from trusted brands and deliver the best calling experience.

    Content Vetting of the names, images, and call reasons will be performed on all associated business telephone numbers to:

    • Ensure the policies are met.
    • Maintain continued trust in the Branded Calling service.

    Use of the Branded Communication services must comply with First Orion’s Acceptable Use Policy. The Policy provided in this article does not account for every scenario. First Orion, along with our carrier partners, reserve the right to deny any content we deem inappropriate for any reason.

    Content Vetting Policy

    The Call Display Name must include one of the following:
    • The Business Name or a DBA that is legally registered within the United States
    • A Brand Name that is trademarked by the Business, commonly used by the business, or that the Business has the right to use
    • A Department or an Agent Name may be added after the Business Name or Brand Name

    The Call Reason must:

    • Be valid 
    • Align with the Business’ calling use case
    • Accurately describe the reason for the call
    • Contain no more than 60 characters consistent with Enhanced CNAM defined by ATIS

    The Call Display Name and the Call Reason:

    • Should not infringe on any 3rd party’s intellectual rights (trademark, copyright)
    • Should not contain a hyperlink to navigate to a webpage
    • Should not begin drafting an email, text, or other messages
    • Should not take any separate action


    The Call Display Name and the Call Reason must NOT include:
    Identity Transparency

    Content that attempts to obfuscate the intention or identity of the Business (calling party).

    Examples include:

    • Masking the display with only a telephone number;
    • False, misleading, or deceptive displays to coax a called party into answering;
    • Blank display values
    Advertisements Content that includes advertisements or other marketing language
    Audience: Children Content targeting children under the age of 18.
    Audience: Adult Content that includes:
    • Adult, pornographic, sexually explicit, or obscene activity.
    • Any references, explicit or implied, to alcohol or firearms
    Illegal Drugs Content facilitating the distribution, use, or cultivation of illegal or questionably legal substances.
    Health Information Content that includes:
    • Protected Health Information as such term is defined in Section 160.103 of the Health Insurance Portability and Accountability Act of 1996 as codified at 45 C.F.R. Subtitle A, Subchapter C, Part 160, et seq. as amended.
    • Any reference, explicit or implied, to prescription drug names (brands or generic) as well as symptoms.
    Gambling Content with gambling or online gambling as the central theme.
    Weapons Content about firearms, automatic weapons, military-style assault weapons, or parts for these weapons.
    Hate Content that is discriminatory, hateful, offensive, defamatory, profane, or otherwise advocates, glorifies, or promotes the same.
    Illegal or Risky Behavior

    Content regarding any illegal activity including, but not limited to:

    • Beating drug tests, traffic tickets, fake IDs, or falsely obtained passwords;
    • Non-FDA approved drugs or procedures;
    • Pyramid schemes promoting terrorism or criminal activities

    Content that includes:

    • False, misleading, or deceptive claims;
    • Defamatory, libelous, harassing, unlawful or threatening content;
    • Links to internet abuse such as spyware, corrupted file viruses, or other materials that are intended to damage or render inoperable software or hardware;
    • Links that violate or infringe upon any third-party intellectual property rights or any other third-party rights
    Financial Information Content that includes:
    • Cardholder Data as such term is described in the Payment Card Industry (PCI) Data Security Standard glossary, as amended from time-to-time;
    • Nonpublic Personal Information as such term is defined by Title V of the Gramm-Leach-Bliley Act as codified at 15 U.S.C. Section 6801, et seq. as amended, and the regulations promulgated pursuant thereto
    Other Requirements:
    Rich Content Delivery of Logo and Call Intent Rich content delivery will only occur if the call is verified via in-band STIR/SHAKEN TN-Validation Passed or out-of-band Call Event API through a Call Placement Server. These call verification methods will also adhere to any overarching (or existing) analytics logic for Advice of Risk (AoR) display when displaying branded content.

    Image Right to Use The business must have the right to use the image to be associated with its telephone numbers:
    • The image must be associated to the Business on its official website;
    • The person supplying the image must be an authorized user for the Business;
    • Utilization of USPTO Trademark Electronic Search System (TESS), through a trademark and logo search after clicking on “the Basic Word Mark Search (New User)” option and cross-referencing the live results with the logo submitted by the business, should provide verification
    Image Use Case
    • The image must align with the Business’ calling use case.
    • The image must not contain any references to SHAFT (Sex, Hate, Alcohol, Firearms, Tobacco)
    • The image must not contain any explicit or implied reference to prescription drug names (brands or generics) or symptoms.
    Image Malware Check
    • The image must not contain a virus or malicious code.
    • A logo should not have a hyperlink or QR code that will take an end-user to a website or open another application (e.g., email).
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