9.2 How to Use Resolution Data Responsibly

Resolution data is powerful. It also comes with real obligations. The following practices are not optional suggestions — they are the baseline for responsible use.

Check DNC flags before calling or texting.
Every resolution record includes a Landline DNC and Mobile DNC field. These flags indicate whether a number appears on the National Do Not Call Registry. Before making any outreach calls or sending SMS messages, check these fields. Contacting a number that is flagged as DNC exposes you to serious legal and financial risk.

See Section 4.2 for where DNC fields appear in a resolution record.

Do not treat a site visit as consent.
A visitor landing on your website — even repeatedly — does not constitute consent to receive marketing communications. Do not interpret resolution data as an opt-in list. If your outreach channel requires consent, you need to obtain it through your own means.

Know your channel’s rules.
Different outreach channels carry different legal requirements:

• Email — CAN-SPAM applies at minimum. B2B email to business addresses operates under different rules than consumer email. Know the difference before sending.

• Phone calls — TCPA applies to automated or prerecorded calls. Manual calls carry separate rules. DNC compliance is required.

• SMS / text messages — TCPA applies strictly to text messages. Do not send texts to resolution data without understanding your TCPA obligations.

• Direct mail — Generally lower regulatory burden, but address accuracy and suppression lists still apply.

• Digital ads — Using resolution data in Custom Audiences on Facebook or other platforms is governed by those platforms’ terms of service in addition to applicable law.

Honor your own suppression lists.
If a contact has previously asked not to be contacted by you — through any channel — that request applies to resolution data too. Cross-reference new resolution records against your existing suppression and opt-out lists before any outreach.

Keep your outreach proportionate.
Resolution data tells you someone visited your website. That is a behavioral signal, not an invitation. Outreach that is immediate, aggressive, or clearly surveillance-like damages trust and can generate complaints. Use the signal appropriately.