TELEMARKETING DO NOT CALL POLICY
State and Federal law requires companies which initiate telemarketing sales calls
to institute policies and procedures for maintaining a list of telephone numbers of
consumers who do not wish to receive commercial telephone solicitations. To comply
with these requirements, GGW Direct, LLC. has established the following Do Not Call
Policy to be followed by all persons making telephone solicitations on its behalf.
1. GGW Direct, LLC. maintains a Do Not Call List that contains telephone
numbers of consumers who either: (a) request directly from GGW Direct (or persons
calling on its behalf) that they not be called again for any telephone solicitations, or (b)
have requested to be included in either the National Do Not Call Registry or a similar
state-maintained registry.
2. For requests made directly to GGW Direct, LLC., the consumer’s request is
maintained for a period of five (5) years. Consumer requests made to federal or state
registries are maintained on lists with each respective federal or state registry. Mantra
Films subscribes to these lists, receives updates as required by applicable state and
federal law, and contracts with third-party companies to ensure compliance with such
lists and requests (both internal and external). It is GGW Direct’s policy not to call
numbers maintained on the then-current lists.
3. It is GGW Direct’s policy that telemarketing agents shall not place any
solicitation call to a telephone number appearing on an internal or external list maintained
by third-party vendors and/or GGW Direct, LLC.
4. It is GGW Direct’s policy that at the beginning of every telemarketing sales
call, the agent shall clearly state (a) his or her first and last name, (b) that he/she is calling
on behalf of GGW Direct, (c) the nature of the call, as well as (d) the telephone number,
and (e) the address at which GGW Direct may be contacted.
5. When a GGW Direct telemarketing agent receives a request from a
consumer that the consumer not receive future telemarketing calls, the agent shall (a)
immediately record the request on the telephone consumer’s file in the Mantra computer,
(b) immediately record the telephone subscriber’s name, address and telephone number in
the Company database, (c) politely inform the consumer that his/her request has been
recorded and that the number will be removed from the GGW Direct’s telemarketing list
as required by law, and (d) end the call.
6. All consumer requests to be placed on GGW Direct’s internal do not call
list are processed internally and added to GGW Direct’s telephone solicitation
suppression system. All suppressed phone numbers are routed for inclusion on the Do
Not Call List. As telephone solicitations may already be in progress at the time of a
consumer’s request, it may take up to 30 days before telephone numbers are cleared
through all channels of the telephone solicitation suppression system and are completely
removed from such telephone programs.
7. A consumer may be placed on GGW Direct’s internal do not call list
through any of the following methods:
A. If the consumer receives a call from a GGW Direct sales agent, the
consumer may asked to be placed on the do not call list and provide the
telemarketing agent with the following information: name, address and
telephone number(s) (including area codes); and/or
B. The consumer may submit his/her request to be placed on GGW Direct’s do
not call list by calling the main telephone number for customer service
[800/689-3666] and asking to speak with a customer service representative.
The consumer should state that he/she wishes to be placed on Mantra
Films’ do not call list. The consumer will need to provide the
representative with the following information: name, address and
telephone number(s) (including area codes); and/or
C. The consumer may submit his/her request to be placed on GGW Direct’s do
not call list in writing, and include the consumer’s name, address and
telephone number(s), along with a statement indicating that the consumer
would like to be placed on GGW Direct’s internal do not call list. The
consumer’s written request may be sent to: GGW Video, P.O. Box 150,
Hollywood, California 90078, Attention: Do Not Call List Request; and/or
D. The consumer can provide the information listed above to GGW Direct
through email at the following: dncrequest@girlsgonewild.com.
8. If a consumer called by the Company notifies a sales agent that they have
already requested to be placed on GGW Direct’s internal do not call list or a state or
federal do not call registry, the sales agent will apologize for the intrusion, obtain relevant
information, and immediately contact a manager or supervisor to investigate. The
manager or supervisor will confirm that the telephone number is on the do not call list, and not subject to any exemption. The manager or supervisor will further take steps to
ensure that the consumer’s telephone number(s) is/are placed on the Company’s internal do not call list.
9. Upon request by any consumer, GGW Direct shall promptly forward to the
consumer a written copy of this telemarketing policy, either by mail or email. The agent
should also inform the consumer that the policy is immediately available to them online
at www.girlsgonewild.com/donotcall. All such requests shall be recorded in the
Company database. In the event any consumer requests an address to which the
consumer may make a written request for the GGW Direct Do Not Call Policy, the
telemarketing agent shall inform the consumer that all written requests should be made to
GGW Direct, LLC., P.O. Box 150, Hollywood, California 90078, Attention: Do Not Call
Request.
10. Consumers must inform GGW Direct of any change in telephone number
if they desire to place a new phone number on GGW Direct’s internal Do Not Call List.
11. In the event any consumer indicates the desire to terminate the call, the
telemarketing agent must immediately and politely comply with the request, thank the
consumer for their time, and end the call.
12. GGW Direct does not share or disclose a consumer’s do not call request
with external parties, other than third-party vendors retained to review Mantra’s
compliance with do not call requests.
13. The GGW Direct Do Not Call list and registries are used exclusively for
telephone solicitation suppression and compliance purposes.
14. Any person involved with telemarketing for GGW Direct is trained,
informed and directed to comply with applicable state and federal do not call
requirements, as well as GGW Direct’s internal Do Not Call Policy. Failure to comply
with the Do Not Call Policy is grounds for discipline, retraining or termination of
employment.
15. GGW Direct and its agents have trained call center personnel, and make
compliance with Mantra’s policies and state and federal do not call policies as an integral
part of call center training. GGW Direct stresses during training the telemarketing
agent’s obligation to follow these procedures. All persons that make calls for Mantra
Films and its agents are trained using the provisions of the Telemarketing Sales Rule
including: the identity of the seller; mandatory use of caller ID; that the purpose of the
call is to sell goods or services; the nature of the goods or services being offered; the time
at which telemarketing calls can be made; the process for adding consumers to the internal do not call list; the procedures the Company uses in obtaining call lists which
comply with state and federal do not call registries; and acceptable and unacceptable
conduct by telemarketing sales agents.
16. GGW Direct requires all of its agents to enter into a written agreement that
includes their obligation to comply with all laws and regulations, their obligation to
comply with GGW Direct Call Center policies, their obligation to maintain and respond
to requests to be added to Mantra’s Do Not Call List, periodic tests for quality control
and effectiveness, their duty to assist in any investigation relating to compliance with any
law, procedures relating to their use and contribution to GGW Direct’s internal do not call
list, and their obligation to indemnify GGW Direct for their intentional refusal or grossly
negligent failure to follow applicable laws, regulations, ordinances, and internal policies
of GGW Direct.
17. The procedures, policies and training methods in this policy are reviewed
by the compliance manager and Call Center manager quarterly.