SMS AND COMMUNICATIONS PRACTICES

Texline Inc. | Version 1.0
Effective Date: August 29, 2026 | Review: Annually

1. PURPOSE

This document sets out the requirements that apply to text messaging, voice, and voicemail communications sent or received through the Texline platform. It is incorporated by reference into the Texline Terms of Service and supplements the Acceptable Use Policy.

These requirements exist for three reasons: compliance with Canadian anti-spam and privacy law, compliance with the rules imposed by telecommunications carriers, and protection of the patients who receive these messages.

2. ROLES

Texline provides the technical means to send communications. The Customer determines their content, timing, and recipients, and is the party responsible for compliance with the requirements in this document.

3. CONSENT

3.1 Customer obligation

Customer must obtain and maintain all consents required by applicable law before sending any communication through the Service, and must be able to produce evidence of that consent on request. At minimum, Customer should record who consented, when, by what means, and to what categories of communication.

3.2 Two distinct requirements

Consent under privacy legislation and consent under anti-spam legislation are separate. Both may apply to the same message.

• Privacy consent governs the collection, use, and disclosure of the patient's personal health information, including the use of an unencrypted channel such as SMS to communicate it.
• Anti-spam consent under Canada's Anti-Spam Legislation ("CASL") governs commercial electronic messages, and requires either express consent or a form of implied consent recognized by the legislation.

3.3 Operational and promotional messages

Texline distinguishes between two categories:

• Operational messages relate directly to a patient's care or an existing appointment — reminders, confirmations, rescheduling, follow-up instructions, and responses to a patient's own inquiry.
• Promotional messages advertise services, promote products, solicit fundraising, or otherwise have a commercial purpose beyond the patient's existing care.

Promotional messages require express CASL consent and must not be sent to a patient on the strength of an appointment-booking relationship alone. Whether a given operational message falls within a CASL exemption depends on its content and context.

3.4 Informing patients about SMS

Before enrolling a patient in SMS communication, Customer should inform the patient that SMS is not a secure or encrypted channel, that messages may be visible to anyone with access to the device, what kinds of messages will be sent, and how to stop receiving them. Customer should offer an alternative channel to patients who decline.

4. MESSAGE CONTENT

4.1 Identification

Every message must make the sending practice identifiable. The first message in any conversation, and every promotional message, must identify the practice by name. Promotional messages must also include the sender identification and contact information required by CASL.

4.2 Minimum necessary information

Messages must contain no more personal health information than is necessary for their purpose. Customer should avoid including diagnoses, test results, treatment details, medication names, or the clinical reason for an appointment in SMS. A message indicating that results are available and inviting the patient to contact the practice is preferable to a message containing the results.

4.3 Prohibited content

Messages sent through the Service must not contain content prohibited by carriers or by law, including content relating to unlawful products or services, gambling, high-risk financial offers, or adult content, and must not contain deceptive or misleading claims.

5. OPT-OUT

5.1 Mechanism

Texline provides automatic opt-out handling. The Service recognizes standard opt-out keywords in English and French, including STOP, UNSUBSCRIBE, ARRÊT, and their common variants, and processes them without requiring action by the Customer.

Keywords that are ambiguous in a clinical context — such as CANCEL — are treated as ordinary replies rather than opt-outs, so that a patient cancelling an appointment is not unsubscribed from all communication. Opt-out keywords may also be actioned independently by Texline's telecommunications provider at the carrier level.

5.2 Effect

When a recipient opts out:

• The opt-out is recorded against that phone number for the Customer's organization and takes effect immediately
• A single confirmation message may be sent; no further messages are sent to that number
• The opt-out is recorded in the Customer's consent records in the platform, where it can be reviewed and filtered by status

Customer must not attempt to circumvent an opt-out by sending from a different number, re-enrolling the recipient, or treating a later interaction as fresh consent without obtaining that consent explicitly.

5.3 Statutory requirements

CASL requires that an unsubscribe mechanism remain functional for at least 60 days after a message is sent, and that an unsubscribe request be given effect without delay and in any event within 10 business days. The Service is configured to act immediately; Customer must ensure that opt-outs are also reflected in any other system it uses to contact patients.

5.4 Promotional messages

Every promotional message must include clear opt-out instructions in the message itself.

6. SENDING PRACTICES

• Timing. Messages should be sent between 8:00 a.m. and 9:00 p.m. in the recipient's local time, except where a patient has requested otherwise or the message is a response to a patient-initiated conversation.
• Frequency. Message volume should be proportionate to the patient relationship. Repeated messaging that generates complaints or opt-outs places all traffic on the platform at risk of carrier filtering.
• Accuracy of numbers. Customer is responsible for the accuracy of the numbers it holds. Numbers are reassigned; messages sent to a reassigned number disclose information to the wrong person, which is a privacy breach.
• Wrong-number handling. Where a recipient indicates they are not the intended patient, Customer must stop messaging that number and correct its records.

7. PHONE NUMBERS AND CARRIER REGISTRATION

Texline provisions telephone numbers through its telecommunications provider. Numbers are allocated to a single Customer organization and are not shared between customers.

Application-to-person messaging in Canada and the United States is subject to carrier registration requirements. Registration requires accurate information about the sending organization and its messaging use case, and Customer must provide that information promptly and accurately when requested.

Messages may be filtered or blocked by carriers notwithstanding compliance with this document. Texline does not guarantee delivery of any individual message.

8. VOICE AND VOICEMAIL

8.1 Greetings and disclosure

Where the Service answers calls or captures voicemail, the greeting must disclose that the call is being recorded or transcribed and that the recording is processed by a service provider on the practice's behalf. The greeting must also direct callers with an emergency to hang up and call 911.

8.2 Automated transcription

Voicemail audio is transcribed automatically. Transcription is imperfect, particularly for clinical terminology, accented speech, and poor-quality audio. Customer must not treat a transcript as a verbatim record, and should retain access to the original audio where accuracy matters.

8.3 Retention

Voicemail audio and transcripts are retained in accordance with the retention periods set out in the Texline Privacy Policy and the Data Processing Addendum.

9. EMERGENCIES

The Service is not monitored and must not be used for emergencies. Messages and voicemails may not be reviewed outside the practice's business hours. Customer must ensure that patients are told, in greetings and automated replies, to call 911 or attend the nearest emergency department in an emergency, and must not present the Service to patients as a channel for urgent clinical concerns.

10. RECORDS AND AUDIT

The Service maintains records of messages sent and received, opt-out events, and delivery status. Customer may export these records and should retain evidence of consent independently, since consent is ordinarily captured outside the Service.

Customer remains responsible for retaining patient communication records in accordance with its own professional and regulatory record-keeping obligations.

11. ENFORCEMENT

Failure to comply with this document is a violation of the Acceptable Use Policy and may result in suspension or termination of messaging functionality in accordance with Section 6 of that Policy. Texline may act without prior notice where continued sending would place its telecommunications provider relationships or other customers at risk.

12. CHANGES

Texline may update this document to reflect changes in law or in carrier requirements. Material changes will be communicated to Customers at least 30 days before taking effect, except where a change is required immediately by a carrier or regulator.

13. CONTACT

Texline Inc.
Email: info@texline.ai
Address: Toronto, Ontario, Canada