Acceptable Usage Policy

1. Introduction

This Acceptable Usage Policy was adopted by Backchat Proprietary Limited (Registration Number: 2023/735133/07) ("Backchat", "we", "us", or "our") with effect from 28 February 2026.

This Policy prescribes the standards, restrictions and prohibitions attached to the use of the Chatterbox Platform and corresponding Services by all Chatterbox Users. It applies to any and all persons and entities who have access to and/or may utilise the Chatterbox voice and SMS broadcast platform, the web portal, and any associated Services.

The full details of Backchat can be accessed in our Terms of Service, and a consolidated glossary of the capitalised terminology adopted throughout this Policy can be accessed in our Glossary.

2. General

The Chatterbox Platform and corresponding Services may only be utilised for legitimate, lawful and bona fide purposes in strict compliance with all Applicable Laws and Regulations.

These bona fide purposes may include but are not necessarily limited to:

• Appointment reminders
• Payment notifications
• Service-related updates
• General business notifications
• Regulated Activities (subject to strict compliance with all Applicable Laws and Regulations)

Notwithstanding the purpose for which any Chatterbox User may utilise the Platform and/or any of the Services, all Chatterbox Users shall retain the responsibility and continuing obligation to:

• Obtain all of the necessary consents and authorisations to process Personal Information on the Chatterbox Platform
• Maintain accurate records of these consents and authorisations
• Give effect to any applicable third party rights, including the rights of Target Recipients
• Exercise good faith in its Platform-related activity in a manner which is consistent with the principle of fair dealing
• Cooperate with Backchat's compliance-related processes and procedures

3. Content Standards

All Content produced, generated and/or transmitted as part of any Campaign generated by any Chatterbox User on the Platform shall be subject to the standards and limitations established by any Applicable Law or Regulation.

3.1 General Standards

The Content generated and/or transmitted on the Platform must:

• Be accurate, truthful and not misleading (or contain unsubstantiated claims or promises)
• Not violate any third-party rights, including those of any Target Recipient
• Be compliant with all Applicable Laws and Regulations
• Be reviewed and approved by the initiating User prior to being transmitted
• Contain all appropriate disclosures and disclaimers (where required or appropriate)

3.2 Content Elements

The Content generated and/or transmitted on the Platform must contain the following core elements:

• A clear identification of the initiating Chatterbox User (or principal of the Campaign, as the case may be)
• The purpose of the Content
• Opt-out instructions
• Contact information for inquiries and complaints
• Legal disclaimers (where required by any Applicable Law or Regulation)

3.3 Language and Tone

The language and tone adopted by Content generated and/or transmitted on the Platform must:

• Be professional, respectful and courteous
• Be free from profanity, vulgarity or offensive language
• Be consistent with a legitimate purpose

3.4 Prohibited Content

No Content generated on the Platform may:

• Constitute "high pressure tactics" or engender any artificial urgency
• Exploit any Target Recipient's fears, vulnerabilities or lay knowledge
• Target minors for any reason whatsoever

4. Prohibited Activities

All Chatterbox Users are strictly prohibited from utilising the Chatterbox Platform and any of the corresponding Services (including the generation or transmission of any Content as part of any Campaign) which is prohibited by any Applicable Law or Regulation, the Terms of Service, this Policy and/or any other Policy adopted by Backchat from time to time.

4.1 Illegal Activities

Examples of illegal activities include (non-exhaustive):

• Fraud, scams and pyramid schemes
• Money laundering and the financing of terrorism
• The violation of any third party rights, including the rights of Target Recipients
• The infringement of any intellectual property rights, including those Intellectual Property rights of Backchat
• The contravention of any Applicable Law or Regulation

4.2 Abusive Content

Examples of abusive Content include (non-exhaustive):

• Hate speech
• Discrimination on the basis of race, ethnicity, nationality, religion, gender, sexual orientation (or any other ground enshrined in the Constitution of RSA, 1996)
• Harassment and intimidation
• The promotion of or incitement of violence
• Any other Content designed or intended to cause emotional distress or psychological harm

4.3 Privacy Violations

Examples of privacy violations include (non-exhaustive):

• The unlawful disclosure, dissemination and/or publication of Personal Information, confidential or otherwise sensitive information (such as allegations of infidelity or financial difficulties)
• The circumvention or violation of any aspect of Backchat's Privacy Policy

4.4 Deceptive Practices

Examples of deceptive practices include (non-exhaustive):

• The misrepresentation, impersonation or passing off as a third party person, business, association or other entity
• "Spoofing"
• Any other false and/or misleading statements

4.5 Cybercrime

Examples of cybercrime include (non-exhaustive):

• The transmission of any viruses, malware or malicious code
• Interference with the Platform or other User access to the Platform
• The circumvention of any of the security safeguards and measures imposed by Backchat from time to time

4.6 Spam

Examples of spam include (non-exhaustive):

• Bulk and unsolicited Content
• The continued transmission of Content in circumstances where the Target Recipient has expressly "opted-out"

5. Fair Usage

5.1 Free Trial and Paid Services

Backchat offers a limited free trial and paid services. The following usage parameters apply:

• Free Trial: A limited number of free voice calls and SMS messages per verified phone number for evaluation purposes
• Wallet Balance: A positive wallet balance is required to launch campaigns beyond the trial allowance
• Campaign Concurrency: Outbound calls are limited to a maximum number of simultaneous connections per campaign execution
• Calling Hours: Campaigns are restricted to system-enforced South African legal calling hours (see Section 5.3)

5.2 Paid Services

Paid services operate on a prepaid wallet credit system. Users top up their wallet via PayFast and funds are reserved at campaign launch. Voice calls are billed at the applicable per-call rate only when the message is successfully played to the recipient. SMS messages are billed at the applicable per-message rate upon sending. Non-billable outcomes (voicemail, unanswered, failed calls) result in reserved funds being released back to your wallet. Current rates are displayed on the platform.

5.3 Calling Hours Enforcement

The platform enforces South African legal calling hours. Campaigns cannot execute outside the following windows:

• Monday to Friday: 08:00 - 20:00 SAST
• Saturday: 08:00 - 13:00 SAST
• Sundays: No calls or SMS permitted
• South African public holidays: No calls or SMS permitted

Active campaigns are automatically paused at the end of each calling window and resumed when the next valid window begins. This enforcement is automatic and cannot be bypassed by users.

5.4 Campaign Channels and Features

The platform supports the following channels and features:

• Voice Campaigns: Automated phone calls delivering your recorded or text-to-speech message to recipients
• SMS Campaigns: Text messages delivered to recipient mobile phones
• Auto-Rerun: Campaigns can be configured to automatically retry unsuccessful recipients within calling hours
• SMS Fallback: After the final auto-rerun attempt, SMS can optionally be sent to recipients who could not be reached by voice
• Message Verification: Messages must pass AI verification (grammar, tone, cultural compliance) before translation services are made available

6. Data Privacy

Backchat is committed to ensuring the confidentiality, integrity, and availability of all data processed through our solutions. Users must:

• Comply with the Protection of Personal Information Act 4 of 2013 (POPIA)
• Use secure and encrypted networks when accessing our services
• Protect any account credentials from unauthorised disclosure
• Obtain proper consent from data subjects before processing their information through our platform
• Report any suspected data breaches to Backchat immediately

For full details on how we handle your data, please refer to our Privacy Policy.

7. Regulated Activities

The following activities shall constitute Regulated Activities for the purposes of this Policy:

• Debt Collection, as regulated by, inter alia, the National Credit Act 34 of 2005
• Direct Marketing, as regulated by, inter alia, the Consumer Protection Act 68 of 2008
• Health communications, as regulated by, inter alia, the National Health Act 61 of 2003
• Financial communications, as regulated by, inter alia, the Financial Advisory and Intermediary Services Act 37 of 2002

An overview of the restrictions applicable to Debt Collection and Direct Marketing Activities are respectively outlined in Appendix A and Appendix B to this Policy. These appendices should be construed as only an overview of the applicable restrictions and do not purport to be an exhaustive recordal or substitute of any Applicable Laws and Regulations.

8. Guidance and Compliance Tools

Backchat provides in-platform guidance to help users understand responsible use of our services, including:

• An interactive step-by-step guide for creating and managing campaigns
• AI-powered message verification with actionable suggestions for improving message quality
• System-enforced compliance guardrails, including calling hour restrictions and content verification requirements

Users are encouraged to stay informed about updates to our policies and South African telecommunications regulations.

9. Compliance and Enforcement

9.1 Monitoring

Backchat reserves the right to monitor usage of our solutions to ensure compliance with this Policy, the Terms of Service, and all Applicable Laws and Regulations.

9.2 Violations

Suspected violations of this Policy will be investigated. Consequences may include:

• Warnings and corrective action requests
• Temporary suspension of services
• Permanent termination of access
• Reporting to relevant authorities where required by law
• Civil liability and/or criminal prosecution

9.3 Reporting Concerns

If you suspect a violation of this Policy or have concerns about misuse of our services, please contact us at compliance@backchat.co.za.

10. Mandatory Policy Revisions

This Policy shall, in the sole and unfettered discretion of Backchat, be subject to all such amendments reasonably necessary to ensure its continued effectiveness, relevance, and compliance with evolving business needs, industry standards and legal or regulatory requirements.

Chatterbox Users will be notified of any updated versions of this Policy on the Platform. Any revised version of this Policy will only take effect on at least 30 (Thirty) calendar days' notice.

11. Contact

Any queries or recommendations in connection with this Policy must be directed to:

• Email: compliance@backchat.co.za
• Website: www.backchat.co.za

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Appendix A: Debt Collection Activities

This appendix should be construed as only an overview of the restrictions applicable to Debt Collection activities in the context of the Chatterbox Platform and the corresponding Services. For the avoidance of doubt, this appendix does not purport to be an exhaustive recordal or substitute of any Applicable Laws and Regulations.

A.1 Applicable Legislation

The legislative framework regulating Debt Collection activities in RSA comprises, inter alia:

• The National Credit Act 34 of 2005
• The Debt Collectors Act 114 of 1998
• The Protection of Personal Information Act 4 of 2013
• The Consumer Protection Act 68 of 2008
• The Harassment Act 17 of 2011

Any Chatterbox User utilising the Platform for Debt Collection purposes shall be obliged to adhere to this legislative framework at all times.

A.2 Registration Requirements

Any Chatterbox User utilising the Platform for Debt Collection purposes must:

• Be registered with the NCR as a debt collector (if acting on behalf of third parties)
• Furnish proof of its NCR registration to Backchat
• Immediately notify Backchat if his/her/its status with the NCR is suspended or revoked

In the event of any Chatterbox User utilising the Platform for Debt Collection purposes on behalf of a credit provider, the User must:

• Be possessed of written authorisation from the credit provider concerned
• Be satisfied that the credit provider concerned is registered with the NCR as such
• Furnish proof of authorisation to Backchat upon request

A.3 Prohibited Practices

In addition to any of the prohibited practices prohibited elsewhere in this Acceptable Usage Policy, any Chatterbox User utilising the Platform for Debt Collection purposes must not engage in any activity amounting to:

• Harassment or abuse in respect of the nature or frequency of the Content
• A deceptive practice in respect of the Content
• An unfair practice in respect of any purported debt
• A privacy violation in respect of any Target Recipient

A.4 Content Requirements

In addition to any of the Content standards prescribed elsewhere in this Acceptable Usage Policy, all Debt Collection-related Content must incorporate:

• Any mandatory disclosures including the details and NCR registration number of the User (and/or Campaign principal) acting as a debt collector, the details of the relevant credit provider (if applicable) and the Target Recipient's rights
• Clear language, absent any legal jargon or confusing terminology

A.5 Target Recipient Rights

Any Chatterbox User utilising the Platform for Debt Collection purposes must uphold the rights of Target Recipient debtors to, inter alia:

• Dispute and verify any purported debt
• Defer to a debt counsellor or application for debt review
• "Opt-out" from the Content

Any Chatterbox User utilising the Platform for Debt Collection purposes must:

• Act in good faith when discussing payment arrangements with Target Recipient debtors
• Take special care in respect of the Content (and all applicable standards) when dealing with Target Recipient debtors who are elderly, have mental or physical disabilities or who are in financial distress

A.6 Record Keeping

Any Chatterbox User utilising the Platform for Debt Collection purposes must maintain detailed records of:

• All Debt Collection-related Content
• Target Recipient debtor requests and complaints
• Payment arrangements and agreements reached with Target Recipient debtors
• "Opt-out" requests made by Target Recipient debtors
• All relevant debt verification information
• NCR registration documentation

All of the abovementioned records must be retained by Chatterbox Users acting as debt collectors for at least 5 (Five) years or such alternative period of time as may be required by the NCR.

A.7 Compliance

Backchat shall at all times retain the following rights:

• To monitor Debt Collection Campaigns for compliance with this appendix
• To request proof of any Chatterbox User's NCR registration
• To suspend Campaigns that violate this appendix and/or any Applicable Law or Regulation
• To refer complaints to the NCR

Any Chatterbox User utilising the Platform for Debt Collection purposes must:

• Promptly respond to Backchat's compliance inquiries
• Furnish Backchat with evidence of consent upon request
• Report material complaints or regulatory inquiries
• Immediately implement corrective measures where necessary

A.8 Non-Compliance

Any violation of this appendix (and/or any Applicable Law or Regulation) by any Chatterbox User may result in:

• The suspension or termination of the User's Chatterbox profile
• A report to the NCR or any other appropriate authority
• Civil liability
• Criminal prosecution and the imposition of administrative penalties

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Appendix B: Direct Marketing Activities

This appendix should be construed as only an overview of the restrictions applicable to Direct Marketing activities in the context of the Chatterbox Platform and the corresponding Services. For the avoidance of doubt, this appendix does not purport to be an exhaustive recordal or substitute of any Applicable Laws and Regulations.

B.1 Applicable Legislation

The legislative framework regulating Direct Marketing activities in RSA comprises, inter alia:

• The Protection of Personal Information Act 4 of 2013, particularly sections 11, 69, and Part B of Chapter 4
• The Consumer Protection Act 68 of 2008, particularly sections 11-12
• The Electronic Communications and Transactions Act 25 of 2002, particularly section 45

The Direct Marketing of financial products must also comply with, inter alia:

• The Financial Advisory and Intermediary Services Act 37 of 2002
• The National Credit Act 34 of 2005
• The Financial Sector Conduct Authority

The Direct Marketing of health-related products or services must comply with, inter alia:

• The Medicines and Related Substances Act 101 of 1965
• The Advertising Standards Authority

Any Chatterbox User utilising the Platform for Direct Marketing purposes shall be obliged to adhere to this legislative framework at all times.

B.2 Consent Requirements

Any Chatterbox User utilising the Platform for Direct Marketing purposes must obtain prior, express consent before conducting any Direct Marketing activities to any Target Recipient.

Any such consent by a Target Recipient must:

• Be made freely and voluntarily in the absence of coercion or consequences for refusal
• Be specific as to a purpose and/or product/service category
• Be reasonably informed
• Be express and unambiguous

The requisite consent for Direct Marketing activities may be obtained verbally, in writing, electronically or through clear and positive conduct by the Target Recipient.

Any Chatterbox User utilising the Platform for Direct Marketing purposes must:

• Maintain documented proof of consent for each Target Recipient
• Record the date, method, and scope of the obtained consent
• Demonstrate consent on request

For the avoidance of doubt, the consent of any given Target Recipient is not required if:

• The Target Recipient is an existing customer of the marketed products or services
• The Target Recipient's details were obtained in the context of a sale and the Direct Marketing is for similar products or services
• The Target Recipient has been given a reasonable opportunity to opt-out

B.3 Opt-Out Requirements

All Content deployed for Direct Marketing purposes must include unambiguous "opt-out" options and instructions.

Any Chatterbox User utilising the Platform for Direct Marketing purposes must acknowledge and give effect to "opt-out" requests within no more than 24 (Twenty Four) hours and maintain a suppression list of the "opted-out" Target Recipients.

Unless specified otherwise by the Target Recipient, their "opt-out" applies to all and any Direct Marketing Content from the Chatterbox User concerned.

Any Chatterbox User utilising the Platform for Direct Marketing purposes must:

• Screen their Campaigns against their suppression list of "opted-out" Target Recipients
• Share their suppression lists across their divisions and affiliates (where applicable)
• Not sell, rent, or distribute their suppression lists with any third parties

B.4 Content Requirements

In addition to any of the Content standards prescribed elsewhere in this Acceptable Usage Policy, all Direct Marketing-related Content must incorporate:

• Any mandatory disclosures including the identity of the User (and/or Campaign principal), the details of the product or service being marketed and clear "opt-out" instructions
• Accurate information concerning the relevant products or services, including any material terms and conditions
• Any other information required by any applicable advertising standard or regulation

B.5 Special Categories of Recipients

Any Chatterbox User utilising the Platform for Direct Marketing purposes must cross-check the National Consumer Commission's Do-Not-Call registry (as may be required in the context) and update his/her/its suppression list accordingly.

Any Chatterbox User utilising the Platform for Direct Marketing purposes must adhere to all and any of the special protections applicable to vulnerable consumers, including minors, elderly individuals, individuals with limited literacy, or persons with mental or physical disabilities.

B.6 Best Practices

Any Chatterbox User utilising the Platform for Direct Marketing purposes should, in the interests of best practice:

• Implement preference centres enabling Target Recipients to customise their marketing preferences
• Adopt double "opt-in" procedures
• Implement clear and prominent "opt-out" options
• Segment marketing lists
• Monitor and respond to Target Recipient feedback
• Regularly audit marketing practices
• Train their staff on marketing compliance requirements
• Maintain transparent privacy policies

B.7 Record Keeping

Any Chatterbox User utilising the Platform for Direct Marketing purposes must maintain detailed records of:

• All Direct Marketing-related Content
• The consent obtained from each Target Recipient
• "Opt-out" requests made by Target Recipients
• Complaints received from Target Recipients

All of the abovementioned records must be retained by Chatterbox Users for at least 5 (Five) years or such alternative period of time as may be required by any Applicable Law or Regulation.

B.8 Compliance

Backchat shall at all times retain the following rights:

• To monitor Direct Marketing Campaigns for compliance with this appendix
• To suspend Campaigns that violate this appendix and/or any Applicable Law or Regulation
• To refer complaints to any appropriate authority

Any Chatterbox User utilising the Platform for Direct Marketing purposes must:

• Promptly respond to Backchat's compliance inquiries
• Furnish Backchat with evidence of consent upon request
• Report material complaints or regulatory inquiries
• Immediately implement corrective measures where necessary

B.9 Non-Compliance

Any violation of this appendix (and/or any Applicable Law or Regulation) by any Chatterbox User may result in:

• The suspension or termination of the User's Chatterbox profile
• A report to any appropriate authority
• Civil liability
• Criminal prosecution and the imposition of administrative penalties

By using Chatterbox, you acknowledge that you have read, understood, and agree to be bound by this Acceptable Usage Policy.