Why Do You Need Specific Privacy Policy and Terms of Service?
During Toll-Free Verification, carriers check more than your website's opt-in flow. They also review your Privacy Policy and Terms of Service (ToS). If these legal texts are missing required compliance statements, your verification request will be rejected.
This article lists what carriers look for, provides ready-to-use templates, and ends with a pre-submission checklist. You can adapt the wording to your business, but keep the mandatory clauses exactly as written.
Note: Links to your Privacy Policy and ToS must be clearly visible and clickable on your opt-in page, close to the call-to-action. Hiding them in pop-ups or dropdowns, or placing them far from the phone number field, is not permitted. Broken links or wrong targets will get your verification rejected.
Privacy Policy Requirements
Your Privacy Policy must meet all three requirements below:
- Publicly accessible: The URL must be live and open without login, and the page must be clearly labeled "Privacy Policy".
- Accurate and up to date: It must truthfully describe how your messaging program collects, uses, and handles user data.
- Data sharing clause: If the policy mentions data sharing in any form, it must include the clause below, word for word.
Verbatim clause (copy exactly):
"No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties."
Tip: Place this clause near the sections on user consent or marketing communications, and make sure the Privacy Policy is linked next to the opt-in checkbox.
Terms of Service (SMS Program Disclosure) Requirements
Your ToS page must be an embedded standalone page, not a pop-up, and must include all of the following:
- Business or program name: State the exact company or brand responsible for sending the messages, such as "ABC Inc.", not just "our team".
- Message frequency: State how often users receive messages, for example "Message frequency varies" or "Up to 4 messages per month". This item is not required for single-message transactional programs.
- Message content: Describe the types of messages you send, such as account notifications, marketing offers, or delivery notifications.
- Customer care contact: Provide a working support channel, such as a support email address or phone number.
- Opt-out instructions: Tell users how to unsubscribe, for example "Reply STOP to opt out".
- Rate disclaimer: Include this exact sentence: "Message and data rates may apply". In automated SMS replies with strict character limits, the abbreviation "Msg & data rates may apply" is accepted.
- Carrier liability: State that wireless carriers are not liable for delayed or undelivered messages.
- Link placement: Label the links "Terms of Service" and "Privacy Policy" and place them close to the opt-in call-to-action.
Opt-in Consent Language Template
Carriers also review the consent language displayed next to your phone number field. Adapt this template for your opt-in flow:
"By checking this box and submitting this form, you consent to receive [message type or purpose] text messages from [Business Name] at the mobile number provided. Message frequency varies. Message and data rates may apply. Reply HELP for help or STOP to opt out. Read our full [Terms of Service link] and [Privacy Policy link]."
Replace the bracketed fields with your own details, and link both legal pages directly in this text.
Quick Checklist
Before submitting your Toll-Free Verification request, confirm every item:
| Checklist Item | Status |
|---|---|
| Privacy Policy URL is live, public (no login), and labeled "Privacy Policy" | ☐ |
| Privacy Policy accurately describes the messaging program's data collection and use | ☐ |
| Privacy Policy contains the verbatim data-sharing clause (if data sharing is mentioned) | ☐ |
| ToS is an embedded standalone page (not a pop-up) | ☐ |
| ToS states business name, message frequency, and message types | ☐ |
| ToS includes support contact, STOP opt-out, "Message and data rates may apply", and the carrier liability statement | ☐ |
| ToS and Privacy Policy links sit close to the opt-in call-to-action | ☐ |
| All links work and point to the correct pages | ☐ |
Legal texts ready? The next step is writing your message samples: Message Sample Writing Guide.
Frequently Asked Questions
For the full verification process, see the Toll-Free Verification guide. For opt-in page requirements, see the opt-in page article. For help with your application, contact Textr Team support.