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SMS MMS CONTENT and PRIVACY POLICY

Effective Date: 4/23/2025
Last Updated: 4/23/2025

First Citizens Bank is committed to protecting the privacy of our users and ensuring that all SMS and MMS communications sent on behalf of our organization comply with applicable industry guidelines, legal standards, and the messaging policies enforced by our communication partners.

This Privacy and Messaging Content Policy outlines the rules and practices we follow for collecting user consent, sending messages, and managing opt-outs, in compliance with SMS Guidelines, the CTIA Messaging Principles and Best Practices, and the Short Code Monitoring Handbook.

1. User Consent and Opt-In Requirements

We will not send SMS/MMS marketing messages to any recipient without first obtaining their express consent:

  • Consent must be clear, documented, and specific to the type of message being sent.

  • Implied consent (e.g., a business relationship alone) is not sufficient.

  • We do not use purchased or third-party lead lists.

  • Each opt-in must be verifiable and logged, including a record of how and when the consent was obtained.

  • A double opt-in mechanism (e.g., confirmation via SMS) is used where applicable.

2. Message Frequency and Volume Control

We adhere to strict volume limitations:

  • We send no more than 50 messages per minute per originating number using Enhanced Business SMS.

  • For higher volume messaging, we utilize High Volume SMS solutions as required.

3. Message Content Guidelines

We ensure that our SMS messages:

  • Are truthful, non-deceptive, and appropriate for the recipient audience.

  • Include our business name or brand.

  • Include a clear opt-out mechanism (e.g., “Reply STOP to unsubscribe”) in all informational, promotional, and automated messages.

  • Avoid the use of non-branded or generic link shorteners and obfuscated URLs.

4. Prohibited Campaigns and Content

We strictly prohibit sending marketing messages that:

  • Relate to loans, debt collection, credit repair, or other financial services listed in carrier prohibitions.

  • Promote work from home, sweepstakes, investment opportunities, or affiliate lead generation.

  • Reference alcohol, tobacco, firearms, controlled substances, or pharmaceuticals, regardless of legality.

  • Include violence, hate speech, harassment, or misleading/fraudulent behavior.

  • Are structured to evade detection (e.g., excessive misspellings or alternate characters).

5. Opt-Out and User Rights

We honor all opt-out requests promptly and fully. All messages:

  • Include clear instructions for opting out.

  • Recognize standard opt-out keywords like STOP and UNSUBSCRIBE.

  • Are logged, and once a user opts out, they will no longer receive SMS communications from us unless they opt-in again.

We also manage opt-outs manually when received through non-SMS channels (e.g., email, web form).

6. Automated Messaging

Automated messages sent through our platform:

  • Are only sent to users who have provided explicit written consent.

  • Include opt-out language in every message.

  • Originate only from numbers registered with a valid TCR (The Campaign Registry) automated campaign.

7. Data Privacy

We protect all user data collected for SMS communications:

  • Data collected (e.g., phone numbers, opt-in records) is stored securely and only used for the purpose the user consented to.

  • We do not share SMS opt-in data or phone numbers with any third parties.  Mobile opt-in, SMS consent, and phone numbers collected for SMS purposes will not be shared or sold to any third parties or affiliates for marketing purposes.

  • We comply with relevant privacy regulations.

8. Carrier and Platform Compliance

We work closely with telecommunications carriers to:

  • Maintain TCR registration for all campaigns.

  • Avoid violations that may result in delivery blocks, fees, or account restrictions.

  • Respond to carrier requests for opt-in proof or consent records promptly.

9. Changes to This Policy

We reserve the right to update this policy at any time to reflect legal, technological, or operational changes. Updates will be posted on this page with the effective date listed above.

If you have any questions about this policy or your data, please contact us at:
334-335-3346