Acceptable Use Policy

1. About this policy

This policy applies to everyone who uses any part of the Service, including Members, Hosts, Customers and their Authorised Users. It forms part of our User Agreement, whose definitions apply. Hosts and Customers must also follow the Host Agreement, which prevails if the two conflict. When you message or call people in other countries, follow their law too.

If you use the Service for an organisation, "you" includes that organisation. Do not help, encourage or allow anyone else to break this policy.

2. Reporting abuse

Report spam, scams, abuse and anything else that breaks this policy to user-compliance@panelist.com, with enough detail for us to find it, such as full email headers, the sender's number or a link.

We may pass your request to stop messages to the sender, remove content, act under Enforcement and responsibility or refer the matter to a regulator or the police. We cannot promise a response time or outcome, or that we will tell you what we did. We may give your address or number to the sender so it can stop contacting you; tell us if you would rather we did not.

You can also use the unsubscribe or opt-out in a message, or complain to the Australian Communications and Media Authority about spam and telemarketing or to Scamwatch about scams. If someone is in immediate danger, call 000.

3. Email

These rules apply to every email sent using the Service, including from a connected mailbox or by Hugo. A commercial message is a commercial electronic message under the Spam Act 2003 (Cth): broadly, one with a purpose of offering or promoting goods, services, events or business opportunities. A receipt or reminder that also promotes something is commercial.

• Consent. Before you send a commercial message with an Australian link, such as one sent from or to Australia, you need the recipient's consent. It may be express or, in limited cases, inferred from an existing relationship in which they would reasonably expect to hear from you, or from their work address being published with their agreement and without a statement refusing such messages, where your message relates to their role. Consent given to a list seller or anyone else generally does not cover you, and importing, enriching or finding a contact gives no consent.
• Records. Keep records of how and when each person consented and of every unsubscribe, and give them to us within five working days if we ask.
• Lists. Do not use address-harvesting software, or send to bought, rented, shared, guessed or harvested addresses, or to people who have unsubscribed, complained or hard bounced. Do not get around any suppression the Service applies, for example by re-importing addresses, and do not send unsolicited bulk messages, even non-commercial ones.
• Sender. Identify yourself accurately, with contact details valid for at least 30 days. Send only from domains and mailboxes you are authorised to use, with any authentication the Service asks for. Do not forge headers or sender names, use misleading subject lines, or disguise a commercial message as personal or transactional.
• Unsubscribe. Every commercial message needs a clear, free unsubscribe that works for at least 30 days and needs no login or information beyond the address. Honour each request within five working days, and send that person no more commercial messages without fresh consent. Do not remove an unsubscribe link the Service adds, and do not assume it adds one, for example to emails from a connected mailbox.
• Deliverability. Stay within mailbox providers' bulk-sender rules and terms and any limits we set, or we may throttle, pause or suspend your sending until the cause is fixed.
• Content. Do not send malware or deceptive links.

4. Text messages and calls

Text messages

• Spam Act duties. The email rules on consent, records, lists and identifying yourself apply to commercial texts. Do not market to a number collected for another purpose, such as sign-in or check-in, without consent.
• Opt-out. Every commercial text must include a functional opt-out, such as "Reply STOP to opt out". Honour opt-outs within five working days, and do not text that person for marketing again without fresh consent. This is your duty: do not assume the Service adds an opt-out, including to texts Hugo sends.
• Sender IDs. Use only a number or sender ID that accurately identifies you and that you are authorised to use, and verify it if we ask. Register any alphanumeric sender ID on the SMS Sender ID Register, or give us what we need to register it, and use it only as registered. Unregistered sender IDs may be blocked or labelled "Unverified".
• Carrier rules. Follow carrier rules, do not use link shorteners, and do not try to avoid filtering, for example by rotating numbers or varying content.

Calls

Complying with the Do Not Call Register and calling hours is your duty, not Panelist's.

• Do Not Call Register. Do not make a telemarketing call to an Australian number on the Register without consent or another exception under the Do Not Call Register Act 2006 (Cth). Unless you hold consent for each number, wash your lists against the Register first, and do not assume the Service has done it.
• Calling hours and identification. Under the Telecommunications (Telemarketing and Research Calls) Industry Standard 2017, make telemarketing calls only from 9am to 8pm on weekdays and 9am to 5pm on Saturdays, in the recipient's local time, and not on Sundays or national public holidays, unless the person has agreed to a call at another time. Say early in the call who you are and who you are calling for, give contact details if asked, keep your caller ID visible, and end the call if asked.
• AI voices and recording. Say at the start if a call uses an AI voice, including Hugo's, or a recording. Record a call only after telling everyone on it and getting their consent, as surveillance and interception laws can require.

Do not rely on the Service for emergency messages or calls. If a carrier, provider or regulator fines or charges us because of your texts or calls in breach of this policy, you must pay it, except to the extent we caused it.

5. No disruption or misuse of the Service

Do not harm the operation or security of the Service, or anyone else's systems, accounts or data. In particular, do not:

• test the security of the Service, or get around authentication, rate limits or access controls, without our written agreement;
• overload or disrupt the Service, for example with floods of requests or messages;
• use bots, scripts or automation beyond what a person could normally do, except through our APIs;
• share your sign-in details or API keys, or use someone else's Account;
• upload or link to malware, or spoof headers, IP addresses, sender numbers or caller ID;
• access data you are not authorised to see, including another Workspace's, exploit a vulnerability, or disclose one before we have had a reasonable chance to fix it;
• copy, reverse engineer or decompile the Service, except as the law permits; or
• use the Service from a sanctioned place or for a sanctioned person, as the User Agreement's export controls and sanctions terms explain.

6. Prohibited content and activities

The following are prohibited on or through the Service, and you must not help anyone else with them.

• Harassment, threats, abuse and defamation, as our Community Guidelines describe, including how to complain about defamation.
• Fraud and scams, such as phishing, fake Events or invoices, and impersonating anyone, including Panelist.
• Infringing copyright, trade marks or other rights, which our Copyright and Intellectual Property Policy explains how to report.
• Scraping and harvesting: scraping, crawling or bulk-extracting data from the Service, such as profiles or contact details, except through our features and APIs, within their limits, or as a search engine following our robots instructions. This applies whether or not you are signed in, and whether directly or through someone else, such as a scraping service, and it continues after your Account closes. It also covers harvesting contact details without the consent of the people concerned, and using enrichment to build lists to sell.
• Illegal content, including class 1 material under the Online Safety Act 2021 (Cth), such as child sexual exploitation material and material that advocates terrorist acts. Sexually explicit and other class 2 material is also prohibited. We may remove such material, close the accounts involved without notice and report it to the authorities.
• Hate speech and unlawful discrimination, such as vilifying people because of their race, religion, sex or another protected attribute.
• Doxxing: publishing, or threatening to publish, someone's personal information to intimidate or harass them, and tracking or profiling people in ways they would not reasonably expect.
• Misleading advertising, such as false claims, fake reviews or endorsements, and prices that leave out compulsory fees (Australian Consumer Law, sections 18, 29 and 48).

If you run a space where others post, you must moderate it: set rules at least as strict as this policy and our Community Guidelines, act promptly on reports, and remove content that is unlawful or breaks this policy. We may also remove content there.

7. Sensitive information

Unless a feature is designed for it and the law allows it, do not put the following into the Service or give it to Hugo:

• health information, including about disability or genetics;
• financial account details, such as card numbers or bank credentials (enter card details only in the Service's payment features);
• government identifiers, such as tax file, Medicare or passport numbers, or identity documents;
• biometric information used to identify people, such as face scans or voiceprints; or
• other sensitive information under the Privacy Act 1988 (Cth), such as racial origin, religious or political beliefs, or criminal record.

Dietary requirements and accessibility needs

Hosts may ask about dietary requirements and accessibility needs only as far as the Event needs, with consent, after explaining why and who will receive the answers, without asking for diagnoses, and only for that purpose. The answers can be health information under the Privacy Act and laws such as the Health Records and Information Privacy Act 2002 (NSW), and Hosts must comply with those laws.

Children

The Service is for people aged 18 and over. Do not use it to register children, collect their information or market to them. If people under 18 may attend your Event, handle their information outside Panelist, as our Privacy Policy explains. Tell us at user-compliance@panelist.com if a child's information is on the Service.

8. Hugo and other AI features

These rules apply to Hugo and our other AI Features, which the User Agreement describes, and to AI-generated content you use on the Service.

• Be open about AI. Disclose that content is AI-generated wherever the law requires it. Do not lead people to think they are dealing with a person where that would matter to them, and never deny being an AI to someone who sincerely asks.
• No impersonation or deceptive deepfakes. Do not use AI to impersonate a real person, imitate their voice or write or speak as them without permission, and have Hugo send in a colleague's name only with their permission. Do not create or share a realistic image, audio or video of a real person saying or doing something they did not, without their consent or in a way that could deceive.
• Human review. Do not let AI make a decision with a legal or similarly significant effect on a person, such as about employment or credit, without meaningful review by a person who can change it, and give Hugo only lawful, non-discriminatory criteria for approving meeting or roundtable requests. From 10 December 2026, Australian Privacy Principles 1.7 to 1.9 require organisations to disclose such automated decisions in their privacy policies. If you use AI Features that way, that duty is yours.
• No high-risk uses, where an error could seriously harm someone's health, safety or rights, such as medical diagnosis, biometric identification or surveillance, and no regulated advice you are not licensed to give.
• Provider rules and safeguards. AI Features run on third-party models, as our Privacy Policy describes; do not breach those providers' usage policies. Do not try to make an AI Feature ignore its safeguards, reveal its instructions or act against its user, including by planting instructions in content it may read, or get around the confirmation Hugo is designed to ask for before payments and deletions.

Messages Hugo sends

Messages Hugo sends for you are your messages, and this policy's messaging rules apply to them. Follow-up messages to people who have not replied ("chases") run automatically unless an administrator sets them to preview. Other messages Hugo writes are drafts for a person to approve, unless that person or their administrator turns on sending without approval (see the Host Agreement). Before Hugo sends without approval, including chases, make sure you have any consent the law requires. Payments Hugo chases must be genuinely owed, and reminders must not harass or coerce (Australian Consumer Law, section 50).

9. Restricted industries

Ask us at support@panelist.com before using the Service for any of the following. We may decline, or set conditions such as lower sending limits.

• list brokers, data brokers and lead sellers;
• cryptocurrency and NFTs;
• gambling, other than a lawful trade promotion such as a prize draw at an Event;
• adult and escort services;
• pharmaceuticals, therapeutic goods and supplements;
• multi-level marketing and "get rich quick" schemes;
• debt collection, debt relief and credit repair, except chasing money owed to your own organisation within the limits in the Host Agreement;
• payday lending;
• firearms, ammunition and weapons;
• selling social media engagement, such as followers or reviews; and
• political campaigning, which needs our written approval and must follow electoral laws.

If we stop serving an existing use in one of these industries, we will give you at least 30 days' notice and a pro-rata refund of any prepaid Fees, unless the use breaches the law, this policy or a provider's requirements. We may also restrict other uses our providers prohibit.

10. Panelist's trade marks

"Panelist", "Hugo", the Hugo character and our logos ("Panelist marks") are ours, whether or not they are registered. Hosts may say an Event runs on Panelist (keeping the branding the Service requires), and anyone may name Panelist in plain text to say accurately that they use it or that their product works with it. Any other use needs our written permission. You must not:

• use Panelist marks, or anything confusingly similar, in your own names, domains or social media handles, or register them;
• suggest that Panelist endorses or is connected with you or your products;
• alter Panelist marks, or use the Hugo character in your own content; or
• use Panelist marks in advertising or as search keywords.

Report misuse as our Copyright and Intellectual Property Policy explains. Do not use other organisations' names or logos to suggest a connection or endorsement that does not exist, for example by showing a Sponsor's logo before it has agreed.

11. Developers and APIs

If you use our APIs or other developer tools, the User Agreement and, for Hosts and Customers, the Host Agreement apply. Keep credentials secret, stay within rate limits, access only data you are authorised to access, never combine data across Workspaces, protect personal information and delete it when you no longer need it, make sure anything you build complies with this policy, and do not present your application as Panelist's. We may throttle, suspend or revoke access that threatens the Service or its users or breaches this policy.

12. Enforcement and responsibility

What a Customer or Host does with its Workspace is its own responsibility. Messages sent from a Workspace, including campaigns, texts, calls and messages Hugo sends under the Workspace's settings, are sent by that organisation, not by Panelist. Panelist does not monitor Customers' messages or verify their consent, and has no duty to do so.

Automated checks and limits protect the Service; they do not review your messages or your compliance with the law. We may look at messages to investigate a report or when a carrier, regulator or the law requires it, without becoming responsible for them.

If we reasonably believe this policy has been breached through your Account or Workspace, or you do not answer our request to explain a suspected breach (an abuse inquiry) within five working days, or sooner if we reasonably ask while harm continues, we may remove the content or messages concerned, pause sending, and suspend or restrict your access until the problem is fixed. We may also pause sending because of high bounce, complaint or opt-out rates, or at the request of a carrier, provider or regulator.

Our action will be proportionate. We will tell you what we did and why as soon as practical, unless the law prevents it or telling you would create a risk of harm or prejudice an investigation, and we will lift a restriction once its reason is resolved. A serious or repeated breach may lead us to close an Account or end a plan for cause. Every step follows the User Agreement, which explains how to ask for a review, and, for Hosts and Customers, the Host Agreement.

You must cooperate with us and respond promptly to any inquiry about your messages, and you are responsible for fines and penalties imposed on you because of your breaches. For Hosts and Customers, the Host Agreement's Liability and Indemnity sections set out who bears which losses.

13. Changes to this policy

We may change this policy to reflect changes to the Service, the law, industry codes or our providers' rules, and will post the new version here with a new date. Changes follow the User Agreement and, for Hosts and Customers, the Host Agreement.

14. Contact us

FCR RSC Pty Ltd (ABN 37 682 852 213), trading as Panelist, New South Wales, Australia.

• Abuse, spam, scams, security vulnerabilities and permission to use Panelist marks: user-compliance@panelist.com
• Restricted industries and general enquiries: support@panelist.com