A2P Messaging Privacy Policy

Purpose:

This Policy establishes the standards for the collection, use, protection, and management of personal information associated with Application-to-Person (A2P) messaging. It ensures compliance with applicable laws, carrier requirements, and industry best practices governing SMS and MMS communications.

Applicability

This policy applies to Fairlead Integrated, Fairlead Boatworks, and their subsidiaries.

Effectivity

The policy is effective upon issuance, superseding all prior intercompany policies and procedures related to messaging and communication privacy.

Discussion:

Fairlead utilizes A2P messaging (SMS/MMS) to communicate with employees, customers, and authorized stakeholders for business-related purposes. These communications may include transactional notifications, operational updates, multi-factor authentication (MFA), and, where explicitly authorized, limited informational or marketing messages.

Participation in A2P messaging requires prior consent from the recipient. Consent may be obtained through written, electronic, or verbal mechanisms, including web forms, paper forms, or keyword-based opt-in processes. All opt-in methods must clearly disclose message frequency, applicable carrier charges, and opt-out instructions.

Fairlead does not sell, rent, or share mobile phone numbers or messaging data with third parties for marketing purposes. Information collected through A2P messaging is limited to what is necessary to support communication delivery, compliance requirements, and operational effectiveness.

Messaging data may include phone numbers, consent records (including timestamp and source), message delivery status, and recipient responses such as opt-out or help requests. This data is retained only as long as required to meet legal, regulatory, and business requirements.

All A2P messaging activities are conducted in compliance with applicable regulations and standards, including the Telephone Consumer Protection Act (TCPA), CTIA Messaging Principles and Best Practices, and carrier-specific requirements such as 10DLC registration.

Procedures:

Consent and Opt-In

Recipients must provide explicit consent prior to receiving A2P messages. Approved opt-in methods include:

• Web-based forms with disclosure language

• Paper-based authorization forms

• Verbal consent, where recorded and documented

• Keyword opt-in (e.g., texting “JOIN”)

• Choosing a “Push to SMS” or similar option for multifactor authentication options

All opt-in disclosures must include:

• Statement of consent to receive messages

• Message frequency disclosure (“message frequency may vary”)

• Notice that message and data rates may apply

• Instructions for opting out (STOP) and requesting assistance (HELP)

Opt-Out and User Controls

Recipients may revoke consent at any time by:

• Replying STOP to unsubscribe

• Replying HELP to receive assistance

Upon Opt-Out, Fairlead will send a confirmation message and cease further messaging unless the recipient re-subscribes.

Note: for standard company communications (e.g., disaster, late start, MFA, etc.), Opt Out is not authorized or available.

Data Usage and Sharing

Collected information is used exclusively for:

• Delivering authorized messages

• Supporting operational communications (e.g., MFA, alerts)

• Maintaining compliance records

• Providing customer or employee support

Data may be shared only with authorized service providers (e.g., SMS gateways, telecommunications carriers) for the purpose of message delivery. All such providers are required to maintain appropriate data protection controls.

Data Retention

Messaging records, including consent and delivery data, are retained in accordance with:

• Legal and regulatory requirements

• Audit and compliance needs

• Operational support requirements

Data is not retained longer than necessary for these purposes.

Compliance

All A2P messaging must adhere to:

• TCPA requirements for consent and communication practices

• CTIA Messaging Principles and Best Practices

• Carrier-specific A2P and 10DLC requirements

Prohibited content categories (e.g., SHAFT: Sex, Hate, Alcohol, Firearms, Tobacco) will not be transmitted.

Standard Disclosure Requirement

All A2P opt-in points must include the following disclosure:

“By providing your phone number, you agree to receive SMS messages from Fairlead. Message frequency may vary. Message and data rates may apply. Reply STOP to opt out, HELP for help. See our Privacy Policy for details.”

Contact Information

Questions regarding this policy or messaging practices should be directed to: Fairlead Human Resources.