DNC policy

 FLAWLESS SKIN CENTER, INC. 

Internal Do-Not-Call Policy 

Maintained pursuant to the Telephone Consumer Protection Act, 47 U.S.C. § 227, and 47 C.F.R. § 64.1200(d) 

Version: 1.0        Date adopted: December 22, 2023       Next review: December 22, 2026 

Policy owner: Flawless Laser Center, Inc. 

 

1.  Purpose and Scope 

Flawless Skin Center, Inc. ("Flawless Skin Center," "the Company," "we," or "us") maintains this written Internal Do-Not-Call Policy to govern telephone calls and text messages to consumers and to comply with the Telephone Consumer Protection Act, 47 U.S.C. § 227, the Federal Communications Commission's implementing rules at 47 C.F.R. § 64.1200, and other applicable federal and California law. 

This Policy applies to every Company employee, contractor, agent, and marketing vendor, at every Company location, on every platform used to contact consumers by telephone or text message. 

This Policy applies to SMS and MMS text messages to the same extent it applies to voice calls. 

 

2.  Definitions 

  • "Internal DNC List" means the Company's own record of consumers who have asked not to receive marketing calls or text messages, maintained separately from the National Do-Not-Call Registry. 

  • "Marketing Communication" means any call or message that advertises or promotes the Company's products, services, treatments, offers, events, or pricing, or that solicits a purchase or a rebooking. Requests for reviews, ratings, or referrals are treated as Marketing Communications. 

  • "Transactional Communication" means a call or message sent for a non-marketing purpose in connection with an existing patient relationship, including appointment scheduling, confirmations, and reminders; pre-treatment and post-treatment instructions; prescription and laboratory notifications; and billing or insurance matters. 

  • "Messaging Platform" means any system used to send calls or messages on the Company's behalf, including the Company's email and SMS marketing platform and its practice management and booking platform. 

  • "Compliance Officer" means the individual designated in Section 16 as responsible for administering this Policy. 

 

3.  Written Policy Available Upon Demand 

This Policy is maintained in writing and is available upon demand, at no charge, to any person who requests it. Requests may be made to the Compliance Officer using the contact information in Section 16, or to any Company location. 

The Company will provide a copy at no charge and within a reasonable time following any request. Requests are logged, including the date received, the requesting party, and the date the Policy was provided. 

 

4.  Consent Required Before Marketing Calls or Text Messages 

The Company does not place marketing calls or send marketing text messages to any consumer who has not first given prior express written consent. 

4.1  How consent is obtained 

Consent is collected through a dedicated opt-in that requires affirmative action by the consumer. The opt-in mechanism: 

  • presents an unchecked box that the consumer must check; 

  • identifies Flawless Skin Center by name as the sender; 

  • discloses that the consumer agrees to receive promotional and marketing messages at the number provided; 

  • states that message and data rates may apply; 

  • states that consent is not a condition of purchase; 

  • discloses message frequency; 

  • provides instructions to text STOP to cancel and HELP for assistance; and 

  • links to the Company's Privacy Policy and Terms and Conditions. 

4.2  What the Company does not do 

  • The Company does not purchase, rent, license, or import consumer telephone numbers from third-party lists for marketing purposes. 

  • Telephone numbers collected for treatment, scheduling, or billing purposes are not added to any marketing text message list. A patient's number becomes eligible for marketing text messages only if that patient separately provides express written consent through the opt-in described in Section 4.1. 

  • The Company does not treat a consumer's prior purchase, appointment, or inquiry as consent to receive marketing text messages. 

  • Contact records transferred from the Company's practice management and booking platform into its marketing platform are reviewed before transfer, and telephone numbers are not enrolled in any marketing text message audience unless a qualifying consent record exists. 

4.3  Consent records 

For every consumer on a marketing list, the Company retains a record of the date and time of the opt-in, the telephone number, the specific form or landing page through which consent was given, and the consent language in effect at that time. These records are retained in accordance with Section 15. 

 

5.  Honoring Do-Not-Call Requests 

5.1  How a request may be made 

A consumer may ask to stop receiving calls or messages by any reasonable means, including: 

  • replying STOP, QUIT, END, CANCEL, UNSUBSCRIBE, REVOKE, or OPT OUT to any Company text message; 

  • telling any Company employee, by telephone or in person, at any location; 

  • sending an email to info@flawlessskincenter.com;i 

  • submitting a written request to any Company address listed in this Policy; or 

  • using any unsubscribe link in a Company email. 

No particular wording is required. Any statement that reasonably communicates a desire to stop receiving calls or messages is treated as a do-not-call request. 

5.2  Recording and processing 

The Company records each request and places the consumer's name, if provided, and telephone number on the Internal DNC List at the time the request is made. 

Requests are honored as promptly as practicable, and in every case within ten (10) business days of receipt. Opt-outs submitted by keyword through a Company messaging platform are processed automatically and take effect immediately. 

Any employee who receives a request by any other means must record it and forward it to the Compliance Officer promptly, and in any event within one business day. Employees are not permitted to ask a consumer to justify the request, to attempt to talk a consumer out of it, or to route the consumer elsewhere to make it. 

5.3  Re-subscription 

A consumer whose number is on the Internal DNC List will not be contacted for marketing purposes again unless that consumer provides new, affirmative express written consent, such as by texting START or by completing a new opt-in form. A prior opt-in does not survive a later opt-out. 

 

6.  Maintenance and Retention of the Internal DNC List 

The Company maintains a record of every do-not-call request it receives. Each request is honored for a minimum of five (5) years from the date the request was made, and the Company's practice is to honor requests indefinitely unless the consumer re-subscribes. 

Records of do-not-call requests are retained for at least five (5) years. No record relating to a do-not-call request, a consent, or a message send is deleted while any inquiry, complaint, demand, or claim relating to that consumer is pending or reasonably anticipated. 

 

7.  Application Across Locations, Platforms, and Affiliates 

A do-not-call request applies to Flawless Skin Center, Inc. and to all of its locations. It is not limited to the location, campaign, brand, or platform through which the request was received. 

The Compliance Officer is responsible for ensuring that a request received on one platform is applied to every platform the Company uses to send Marketing Communications. Marketing suppression is maintained centrally, and the Compliance Officer reconciles suppression across platforms on a schedule the Compliance Officer sets and documents. 

Consistent with 47 C.F.R. § 64.1200(d)(5), a consumer's request will not be applied to an affiliated entity unless the consumer would reasonably expect it to apply to that entity. Where there is any doubt, the Company applies the request. 

Effective January 31, 2027. Under FCC rules taking effect on that date, a consumer's revocation of consent made in response to one type of message will apply to all future marketing calls and text messages from the Company, regardless of the category of message that prompted it. The Company will apply revocations on that basis as of that date, and will implement the change earlier where operationally practicable. 

 

8.  National Do-Not-Call Registry 

Option A — no outbound telemarketing 

As of the date of adoption, the Company does not place outbound telemarketing calls. Telephone calls placed by Company staff are limited to Transactional Communications as defined in Section 2. Should the Company adopt an outbound telemarketing program in the future, it will implement the requirements set out in Option B before placing any such call. 

 

9.  Calling and Messaging Hours 

No Marketing Communication will be initiated by telephone or text message before 8:00 a.m. or after 9:00 p.m. in the local time of the recipient. Campaign send times are set to fall within this window. 

 

10.  Identification 

Consistent with 47 C.F.R. § 64.1200(d)(4), every marketing telephone call placed by or on behalf of the Company will disclose the name of the individual caller, the name of Flawless Skin Center, Inc. as the entity on whose behalf the call is being made, and a telephone number or address at which the Company may be contacted. The telephone number provided will not be a 900 number or any number for which charges exceed local or long distance transmission charges. 

Every marketing text message will identify Flawless Skin Center and include opt-out instructions. 

 

11.  Text Message Procedures 

  • The Company's SMS platform automatically processes the standard carrier opt-out keywords, including STOP, END, CANCEL, UNSUBSCRIBE, and QUIT, as well as HELP and INFO for assistance. Any other request to stop receiving messages, in any wording or by any channel, is honored and processed manually under Section 5. 

  • A consumer who opts out receives a single confirmation message acknowledging the opt-out. That message is sent promptly and consistent with FCC requirements, contains no marketing or promotional content, and is the last marketing-platform message the consumer receives. 

  • The Compliance Officer periodically verifies that opt-out keyword handling is functioning and documents the result. 

  • Message frequency is disclosed at opt-in and campaign volume is kept consistent with that disclosure. 

  • Every marketing text includes the sender identification and opt-out instructions required by Section 10. 

  • The Company follows applicable CTIA Messaging Principles and Best Practices and the requirements of its messaging provider and the wireless carriers. 

 

12.  Transactional and Healthcare Communications 

Transactional Communications, as defined in Section 2, are not Marketing Communications and are governed by this Section rather than by the consent and suppression requirements in Sections 4 through 7. Consent for these messages arises from the patient voluntarily providing a telephone number in connection with care. 

The following controls apply: 

  • No Transactional Communication may contain a promotional offer, discount, price, package, rebooking solicitation, review request, or referral request. Any message containing such content is a Marketing Communication and requires marketing consent. 

  • Each Transactional Communication identifies Flawless Skin Center, provides contact information, and includes clear instructions for opting out of that category of message. 

  • Transactional Communications are limited to the frequency reasonably necessary for the patient's scheduling and care, and are not used as a vehicle for repeated or unnecessary contact. 

  • A consumer who asks to stop receiving Transactional Communications will be honored, and the request is recorded and processed under Section 5. 

  • Message templates used by the Company's practice management and booking platform are reviewed by the Compliance Officer at least annually to confirm that none has drifted into marketing content. Review requests, rating requests, and referral requests are Marketing Communications under Section 2 and may not be sent through the transactional channel. 

 

13.  Training 

Consistent with 47 C.F.R. § 64.1200(d)(2), personnel engaged in any aspect of Marketing Communications, and personnel who may receive a do-not-call request, are informed and trained in the existence and use of the Internal DNC List. 

  • Training is provided before an employee participates in any aspect of a marketing program, and again whenever this Policy materially changes. 

  • Training covers the existence and use of the Internal DNC List, how to recognize and record a request, the ten business day deadline, and how to escalate to the Compliance Officer. 

  • The Company maintains records of who was trained and when, retained in accordance with Section 15. 

 

14.  Vendors and Marketing Partners 

Any agency, vendor, or platform that places calls or sends messages on the Company's behalf is required to comply with this Policy. The Company remains responsible for calls and messages made on its behalf. 

  • The Company requires each such vendor to honor the Internal DNC List, to process opt-outs within the timeframes in Section 5, and to send only to numbers for which valid consent records exist. These obligations are included in vendor agreements as they are entered into or renewed. 

  • Vendors must provide the Company with access to consent records, opt-out records, and message send logs on request. 

  • Vendors must notify the Company promptly of any consumer complaint, demand, or regulatory inquiry relating to Company messaging. 

  • The Compliance Officer maintains a current list of every platform authorized to contact consumers on the Company's behalf. 

 

15.  Recordkeeping 

The Company maintains, for a minimum of five (5) years: 

  • consent records, including date, time, telephone number, source form, and the consent language then in effect; 

  • do-not-call requests, including date received, method, and date processed; 

  • the Internal DNC List and platform suppression lists; 

  • message and call send logs; 

  • training records; 

  • vendor agreements; and 

  • records of requests for this Policy and the Company's responses. 

Records are preserved without alteration. Where a consumer inquiry, demand, or claim is pending or reasonably anticipated, all related records are placed on hold and preserved until the matter is resolved. 

 

16.  Contact and Administration 

The Company has designated the following individual as Compliance Officer for this Policy. The Compliance Officer administers the Internal DNC List, responds to requests for this Policy, oversees training, and coordinates suppression across platforms.  

Name: Marine Margarian 

Title:  Office Manager 

Email:  info@flawlessskincenter.com 

Telephone: (818) 848-2288 

Mail:  Flawless Skin Center, Inc., 435 N Glenoaks Blvd, Burbank, CA 91502 

A consumer may make a do-not-call request, request a copy of this Policy, or raise a complaint using any of the above. 

 

17.  Review and Updates 

This Policy is reviewed at least annually by the Compliance Officer, and additionally whenever there is a material change in applicable law, in the Company's messaging platforms, or in the Company's marketing practices. Each version is dated and prior versions are retained. 

 

18.  Status of This Policy 

This Policy is adopted for internal compliance purposes and to satisfy the written policy requirement of 47 C.F.R. § 64.1200(d)(1). It states the Company's procedures on a going-forward basis from the date of adoption. It is not intended to create, and does not create, any contractual right, third-party beneficiary right, or private cause of action, and it is not an admission regarding any past practice. 

 

19.  Adoption 

This Internal Do-Not-Call Policy is adopted by Flawless Skin Center, Inc. and is effective as of the date below. It supersedes any prior version. 

 

Signature 

Name: Marine Margarian 

Title:  Office Manager  

Date:  December 22, 2025