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Based on the information provided about AWS End User Messaging SMS, your use case appears to fall under transactional messaging rather than promotional messaging. Transactional messages are typically for time-sensitive information, such as password resets, one-time passwords, or in your case, reward notifications.
However, it's important to note that even for transactional messages, opt-in requirements may still apply, especially in countries with strict regulations like the United States (under TCPA) and Canada. The fact that your messages are transactional doesn't automatically exempt you from opt-in requirements.
That being said, the opt-in process for transactional messages can sometimes be less stringent than for promotional messages. For your specific use case of sending reward notifications, you might consider the following:
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Ensure that employees have agreed to receive communications about their rewards program when they sign up for or participate in the program.
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Clearly communicate that SMS might be used as a method of notification for rewards.
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Provide an easy way for recipients to opt out of SMS notifications if they wish. AWS End User Messaging SMS automatically manages opt-outs when recipients reply with keywords like STOP, CANCEL, or UNSUBSCRIBE.
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Keep records of how and when users opted in to receive these notifications.
It's also worth noting that AWS End User Messaging SMS has a sandbox environment for new accounts where you can only send messages to verified phone numbers. This allows you to test your messaging system while ensuring compliance.
Regarding your competitors seemingly "getting around" these requirements, it's possible they have implemented a robust opt-in process that's integrated into their user onboarding or reward program enrollment. Alternatively, they might be operating in a gray area that could potentially put them at risk.
Given the complexity of compliance requirements, it would be advisable to consult with a legal expert specializing in telecommunications regulations to ensure your specific implementation meets all necessary requirements.
Sources
SMS and MMS limits and restrictions - AWS End User Messaging SMS
Required AWS End User Messaging SMS opt-out list keywords - AWS End User Messaging SMS
SMS/MMS and Voice sandbox in AWS End User Messaging SMS - AWS End User Messaging SMS
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