Acceptable Use Policy (AUP)

- Telecommunications Services

1. Purpose and scope

This Acceptable Use Policy ("AUP") establishes the rules governing the lawful and responsible use of telecommunications and related digital services provided by SkyTel OÜ ("SkyTel", "Company", "we", "us" or "our").

The purpose of this Policy is to protect customers, telecommunications networks, service providers and the general public against fraud, unsolicited communications, identity misrepresentation, network abuse and other forms of misuse.

This Policy applies to all customers using SkyTel services, including business customers, individual customers, wholesale telecommunications partners, resellers and authorised users.

It covers all applicable services, including:

• VoIP and SIP trunking;
• Wholesale voice origination and termination;
• Cloud PBX and related voice services;
• Virtual telephone numbers (DID/DDI);
• SMS and messaging services;
• eSIM and mobile connectivity;
• Customer portals, APIs and related telecommunications infrastructure.

This Policy forms part of the contractual framework governing the use of SkyTel services.

Customers must ensure that persons authorised to use their accounts or services comply with this Policy.

2. General principles of acceptable use

SkyTel services may be used only for lawful purposes and in accordance with applicable telecommunications regulations, consumer protection laws, privacy requirements and the contractual conditions governing the relevant Service.

Customers must not use or permit the use of SkyTel services for activities that:

• Violate applicable laws or regulations;
• Facilitate fraud, deception or other criminal activity;
• Infringe the rights of third parties;
• Interfere with the security or integrity of telecommunications networks;
• Misrepresent the identity or authority of a caller or message sender;
• Generate unlawful or abusive telecommunications traffic;
• Circumvent applicable regulatory, contractual or technical restrictions.

Customers are responsible for ensuring that their intended use of the Services is lawful in the jurisdictions where communications originate, transit or terminate.

3. Fraud and prohibited telecommunications activities

The following activities are prohibited:

3.1 Financial fraud and impersonation

Using the Services to conduct or facilitate financial fraud, payment scams, identity theft, impersonation of financial institutions, government agencies or other organisations, or fraudulent requests for personal or financial information.

3.2. Phishing and social engineering

Using voice calls, SMS or other communications to obtain passwords, verification codes, payment card details, account credentials or other sensitive information through deception.

3.3. Wangiri and callback fraud

Generating missed calls or other communications intended to induce recipients to call premium-rate, revenue-sharing or other chargeable destinations under false or misleading circumstances.

3.4. Artificial traffic generation

Generating or facilitating artificial, manipulated or fraudulent telecommunications traffic, including traffic pumping, international revenue share fraud (IRSF) and other arrangements intended to generate improper financial benefits.

3.5. Unauthorised use of telecommunications services

Using compromised SIP credentials, PBX systems, customer accounts or other telecommunications resources without authorisation.

3.6. Traffic origin concealment

Deliberately misrepresenting or concealing the true origin, identity or nature of telecommunications traffic in order to evade applicable legal requirements, technical controls, carrier restrictions or fraud prevention mechanisms.

4. Caller ID and telephone number integrity

Customers must ensure that all outbound Caller ID information is accurate, authorised and compliant with applicable law.

Customers may present only telephone numbers that they own, have been assigned or are otherwise expressly authorised to use.

The customer must be able to provide reasonable evidence of the right to use a presented telephone number upon request.

The following activities are prohibited:

• Presenting telephone numbers without the necessary ownership, assignment or authorisation;
• Impersonating another individual, company, financial institution, government agency or emergency service;
• Manipulating Caller ID information to mislead recipients regarding the identity or origin of a call;
• Using invalid, unallocated or fictitious telephone numbers as Caller ID, except where expressly permitted by applicable law and the relevant service configuration;
• Manipulating SIP signalling information to conceal fraudulent or unauthorised traffic;
• Using telephone numbers in a manner intended to circumvent applicable anti-spoofing controls or regulatory requirements.

Where technically and legally applicable, telephone numbers must be transmitted in an appropriate international format, including E.164.

Customers must ensure that a presented telephone number is correctly assigned, authorised for the intended use and capable of reaching the legitimate subscriber or organisation where applicable.

Legitimate caller identification presentation restrictions, including lawful withholding of Caller ID, are not prohibited by this Policy.

SkyTel may request documentation establishing the customer's right to use specific telephone numbers and may restrict the presentation of numbers that cannot be verified or are associated with suspected misuse, subject to applicable law.

5. Spam, robocalling and automated communications

Customers must not use SkyTel services to conduct unlawful unsolicited calling campaigns, spam or automated communications.

The use of automated dialling systems, predictive diallers, prerecorded messages, artificial intelligence voice systems or other automated calling technologies is permitted only where the intended use complies with applicable law and the relevant service conditions.

Customers conducting outbound calling campaigns are responsible for:

• Establishing and documenting an appropriate legal basis for contacting recipients;
• Obtaining consent where required by applicable law;
• Complying with applicable telemarketing, consumer protection and privacy requirements;
• Observing applicable calling hours, contact restrictions and national or sector-specific opt-out requirements;
• Honouring valid requests not to receive further communications;
• Ensuring that recipients are not deliberately misled regarding the identity of the caller or the purpose of the communication;
• Complying with applicable requirements governing automated calls, prerecorded messages and AI-generated communications.

Customers must not use automated calling systems to generate repeated nuisance calls, harass recipients or evade applicable blocking mechanisms.

SkyTel may request information regarding the intended use of automated calling services, the customer's business activities and the compliance measures applied to outbound calling campaigns.

6. Wholesale voice traffic and resellers

Wholesale telecommunications customers and resellers must ensure that traffic submitted to the SkyTel network complies with this Policy and all applicable regulatory requirements.

Wholesale customers must take reasonable measures to verify the legitimacy of their traffic sources and prevent the transmission of fraudulent or abusive communications.

Customers must not knowingly route traffic originating from unauthorised, fraudulent or otherwise prohibited sources.

Where required for an investigation, customers must provide available information reasonably necessary to identify the source of suspicious traffic, establish the legitimacy of the relevant communication and address the suspected violation.

Customers must cooperate with reasonable requests to investigate traffic that may involve fraud, unlawful robocalling, Caller ID spoofing or other forms of telecommunications abuse.

Customers remain responsible for implementing appropriate controls within their own networks and contractual relationships with downstream users.

The use of downstream carriers, agents or subcontractors does not relieve customers of their obligations under this Policy.

7. Virtual telephone numbers

Virtual telephone numbers may be used only in accordance with applicable national numbering regulations and the conditions governing the relevant number type.

Customers must not:

• Obtain telephone numbers using false or misleading registration information;
• Provide fictitious or unauthorised address or identity documentation;
• Use telephone numbers to impersonate third parties;
• Use virtual numbers for fraudulent communications, phishing or other unlawful activities;
• Transfer, resell or assign numbers in violation of applicable contractual or regulatory restrictions.

Customers must comply with applicable geographical eligibility requirements, number registration obligations and restrictions on local or national number usage.

Where required, customers must provide valid proof of identity, address, business registration or other documentation necessary for the allocation and continued use of telephone numbers.

SkyTel may request updated documentation where required by applicable law, numbering authorities or underlying operators.

8. SMS and messaging services

Customers may use SkyTel SMS and messaging services only for lawful and authorised communications.

The following activities are prohibited:

• Sending unlawful unsolicited commercial messages;
• Distributing phishing messages, fraudulent payment requests or malicious links;
• Misrepresenting the identity of a message sender;
• Using sender IDs without the necessary authorisation;
• Sending messages containing unlawful, threatening or fraudulent content;
• Circumventing applicable sender registration, consent or message filtering requirements;
• Using messaging services to facilitate identity theft, financial fraud or other unlawful activities.

Customers are responsible for obtaining consent where required, maintaining appropriate recipient records and providing legally required mechanisms for recipients to withdraw consent or opt out of further communications.

Customers must comply with applicable electronic marketing, privacy, consumer protection and messaging regulations in the relevant jurisdictions.

9. eSIM and mobile connectivity

Customers must use eSIM and mobile connectivity services in accordance with the applicable service package, device requirements, mobile network conditions and local regulations.

The following activities are prohibited:

• Using eSIM services to facilitate fraud or other unlawful activities;
• Unauthorised duplication, cloning or manipulation of subscriber identity information;
• Using network access credentials or eSIM profiles without authorisation;
• Deliberately circumventing applicable geographical, technical or service restrictions;
• Using mobile connectivity to conduct attacks against networks, systems or other users;
• Reselling, distributing or transferring eSIM profiles contrary to the applicable service conditions.

Customers must comply with any applicable restrictions established by the underlying mobile network operator.

10. Network security and account protection

Customers must take reasonable measures to prevent unauthorised access to their accounts, telecommunications equipment and network connections.

Such measures include, where applicable:

• Protecting customer portal credentials, SIP passwords and API keys;
• Maintaining secure configurations of PBX and SIP equipment;
• Restricting access to telecommunications systems to authorised persons;
• Keeping customer-controlled equipment and software appropriately updated;
• Preventing unauthorised third parties from using assigned telecommunications resources;
• Promptly investigating and reporting suspected account compromise or unauthorised traffic.

Customers must not deliberately interfere with SkyTel's infrastructure or the networks of its telecommunications partners.

Activities such as denial-of-service attacks, unauthorised network scanning, exploitation of security vulnerabilities and intentional network disruption are prohibited.

Customers must comply with applicable technical limitations, including authorised IP addresses, concurrent call limits and calls-per-second limits.

Customers must not deliberately circumvent these limitations or use the Services in a manner that materially interferes with the operation of the network or the provision of services to other users.

11. Monitoring and detection of abuse

SkyTel may implement appropriate technical and organisational measures to detect, investigate and prevent suspected telecommunications fraud, spam, unauthorised access, network attacks and other forms of misuse.

Such measures may include, where appropriate and legally permitted:

• Customer identification and verification;
• Verification of telephone number assignment and Caller ID authorisation;
• Monitoring of relevant telecommunications traffic characteristics and usage patterns;
• Detection of unusual traffic volumes, abnormal calling patterns and other potential indicators of fraud;
• Application of technical traffic limits and access restrictions;
• Investigation of complaints received from telecommunications operators, customers, recipients of communications and competent authorities;
• Blocking or restricting traffic associated with identified security or fraud risks.

The implementation of these measures does not constitute a guarantee that all fraudulent or abusive activity will be detected or prevented.

Monitoring and related data processing shall be carried out in accordance with applicable telecommunications confidentiality, privacy and data protection requirements.

12. Investigation of suspected violations

Where SkyTel identifies a potential violation of this Policy, it may initiate an investigation appropriate to the nature and seriousness of the suspected activity.

SkyTel may request relevant information from the customer, including:

• An explanation of the traffic source and intended use;
• Evidence of the right to use presented telephone numbers;
• Information concerning the customer's telecommunications equipment or service configuration;
• Relevant call records, signalling information or other technical evidence;
• Information concerning consent or other legal authorisation for communications, where applicable;
• Details of corrective measures taken to prevent further misuse.

Customers must cooperate with reasonable and lawful requests related to the investigation of suspected service misuse.

Information obtained during investigations shall be processed and disclosed in accordance with applicable law.

13. Measures in response to violations

Where a violation of this Policy has been established, or where reasonable grounds exist to suspect an immediate and material security, fraud or network integrity risk, SkyTel may take proportionate measures permitted by applicable law and the relevant service agreement.

Depending on the circumstances, such measures may include:

• Requesting clarification or additional documentation;
• Requiring the customer to implement corrective measures;
• Restricting specific telephone numbers, traffic destinations, routes or technical functions;
• Applying additional access controls or traffic limits;
• Temporarily suspending affected services;
• Terminating the relevant service agreement where the legal and contractual requirements for termination are satisfied;
• Referring relevant information to competent authorities or telecommunications partners where legally required or permitted.

Where required by applicable law, SkyTel shall inform the customer of the reasons for a service restriction and the applicable conditions for restoring service.

Immediate protective action may be taken where authorised by applicable law and necessary to address an urgent threat.

The treatment of prepaid balances, outstanding service charges and any other financial consequences shall be governed by the applicable service agreement and mandatory law.

14. Cooperation with telecommunications operators and authorities

SkyTel may cooperate with telecommunications operators, numbering authorities, regulatory bodies, law enforcement agencies and other competent organisations to investigate and prevent telecommunications abuse.

Such cooperation may include the lawful exchange of relevant technical information, investigation of reported incidents and implementation of appropriate corrective measures.

Customer information and telecommunications data shall be disclosed only where a valid legal basis exists.

15. Changes to this Policy

SkyTel may update this Policy to reflect changes in applicable law, telecommunications standards, security requirements, service functionality or fraud prevention practices.

Customers shall be notified of changes in accordance with the applicable contractual framework and mandatory law.

The current version of this Policy shall be made available on the SkyTel website.

16. Contact and abuse reporting

Suspected misuse of SkyTel telecommunications services, including fraudulent calls, Caller ID spoofing, phishing, spam and unauthorised access, may be reported using the contact details below.

Reports should include relevant information reasonably available to the reporting party, such as the affected telephone number, date and time of the incident, description of the suspected activity and any supporting technical information.

SkyTel OÜ

Registration number: 12926323

Registered address: Lasnamäe 18, 11416 Tallinn, Estonia

Email: info@skytel24.com

Telephone: +372 333 55 10

Website: https://skytel24.com