Code of Conduct

Scope: All Dealsby Platforms  |  Issuer: Virely LLC, Atlanta, GA

Virely LLC — Master Code of Conduct

Section I — Purpose & Scope

This Code of Conduct establishes the binding guidelines, standards, and expectations that all businesses must adhere to when accessing and utilizing Virely LLC's suite of smart marketing technologies. This policy applies universally across the Dealsby platform ecosystem, including Dealsby Referrals, Dealsby Appointments, and Dealsby Reservations.

Virely LLC reserves the unilateral right to vet, monitor, suspend, or permanently remove any business account that fails to meet the standards outlined herein. The mission of this policy is to maintain a trusted, high-quality ecosystem that protects consumers, business partners, and the integrity of the Dealsby brand.

Each platform carries a supplemental addendum to this Code of Conduct that addresses platform-specific rules. Businesses are bound by both this master document and the applicable platform addendum(s).

Section II — Business Eligibility Requirements

To be approved for access to any Dealsby platform, a business must satisfy the following baseline requirements:

• Legal Entity Status: Must be a legally registered business entity (LLC, Corporation, Sole Proprietorship, Partnership, or equivalent) in its operating jurisdiction.
• Tax Identification: Must provide a valid Employer Identification Number (EIN) or equivalent tax identification, or a valid SSN for sole proprietors.
• Verifiable Address: Must maintain a verifiable physical or virtual business address.
• Lawful Operation: Must operate in a lawful industry that does not conflict with Virely LLC's Prohibited Industries list (Section III).
• Account Administrator: Must designate at least one authorized account administrator with a verifiable business email address and direct phone number.
• Policy Agreement: Must agree to and digitally sign the Virely LLC Terms of Service, this Code of Conduct, and all applicable platform addenda.

Section III — Prohibited Industries & Use Cases

Virely LLC does not extend platform access to businesses operating in the following categories. This list is non-exhaustive and subject to update at Virely LLC's sole discretion:

• Illegal or federally prohibited goods and services, including unlicensed cannabis operations.
• Adult entertainment, escort services, or sexually explicit content businesses.
• Weapons, ammunition, or explosives manufacturing and retail (excluding licensed sporting goods retailers).
• Pyramid schemes, multi-level marketing organizations with deceptive practices, or fraudulent business models.
• Unlicensed financial services, payday lending with predatory terms, or cryptocurrency mixing/tumbling services.
• Businesses engaged in promotion of harassment, hate speech, discrimination, or violence.
• Counterfeit goods distribution, intellectual property infringement operations, or grey-market resellers.
• Any business under active federal, state, or local investigation for fraud, embezzlement, or consumer harm.
• Unlicensed pharmaceutical sales, telehealth operations without proper medical licensing, or unapproved health product distributors.

Section IV — Standards of Conduct

All businesses utilizing Virely Smart Marketing Technologies must uphold the following standards at all times:

• Honest Representation: Business profiles, descriptions, services, pricing, and promotional materials must be truthful, current, and not misleading to consumers.
• Consumer Communication Compliance: All customer-facing communications sent through Dealsby platforms (SMS, email, push notifications) must comply with CAN-SPAM, TCPA, and all applicable federal, state, and local consumer protection regulations.
• Data Integrity: Businesses must not upload fraudulent customer data, fabricate referrals, inflate appointment activity, manipulate reservation data, or tamper with platform analytics through artificial means.
• Platform Security: Businesses must not reverse-engineer, scrape, exploit vulnerabilities, perform unauthorized API access, or otherwise misuse any Dealsby platform technology.
• Payment Compliance: Subscription fees and add-on charges must be paid on time. Accounts with balances exceeding 15 days past due are subject to feature restrictions; accounts exceeding 30 days are subject to suspension.
• Responsive Communication: Businesses must maintain an active, monitored account and respond to compliance inquiries from Virely LLC within 5 business days of notification.
• Anti-Spam Policy: Bulk unsolicited messaging, use of purchased or scraped contact lists, or any form of communication abuse through the platform is strictly prohibited.
• Consumer Privacy: Businesses must handle all customer data collected through Dealsby platforms in accordance with applicable privacy laws and must not sell, share, or misuse consumer data obtained via platform tools.

Section V — Vetting & Onboarding Process

All new business accounts undergo a structured vetting process before gaining full platform access:

• Application Submission: Business submits registration with required documentation including business license, EIN/tax ID, owner identification, and business address verification.
• Identity Verification: Virely LLC verifies the identity of the primary account holder and confirms the legitimacy of the business entity through third-party verification services.
• Industry Screening: The business's industry, services, and public reputation are reviewed against the Prohibited Industries list and general quality standards.
• Provisional Access (30 Days): Upon initial approval, businesses receive a 30-day provisional access period during which activity is actively monitored for compliance with this Code of Conduct.
• Full Activation: After successful completion of the provisional period with no violations, the account is granted full platform access with all features enabled for the subscribed tier.

Section VI — Enforcement Framework

Violations of this Code of Conduct are categorized into three tiers based on severity. Virely LLC applies enforcement actions proportionally, though reserves the right to escalate directly to Tier 3 for egregious conduct.

Tier 1 — Warning (Low Severity): Minor or first-time infractions that do not directly harm consumers or compromise platform integrity. Written warning via email, 7-day corrective action window, compliance note added to account, no feature restrictions.

Tier 2 — Suspension (Moderate Severity): Repeated violations, failure to correct Tier 1 issues, or conduct that risks consumer harm or platform abuse. Temporary account suspension (14–90 days), SMS/email sending privileges revoked, mandatory corrective action plan, reinstatement requires written review.

Tier 3 — Removal (High Severity): Egregious, illegal, or willfully harmful conduct; repeated Tier 2 violations; or failure to complete corrective action. Permanent account termination, removal from all Dealsby platforms, forfeiture of prepaid subscription fees, potential referral to legal authorities.

Section VII — Suspension Procedures

When a business account is suspended under Tier 2 enforcement, the following procedures apply:

• Notification: The primary account administrator will receive written notification via email and in-platform alert specifying the violation, the enforcement tier, and the suspension duration.
• Access Restrictions: During suspension, the business loses access to all active platform features including customer-facing tools, messaging capabilities, analytics dashboards, and API endpoints.
• Data Preservation: Business data is preserved during suspension for the duration of the suspension period plus 30 days. Virely LLC is not obligated to preserve data beyond this window.
• Corrective Action Plan: Suspended businesses must submit a written corrective action plan addressing the root cause of the violation before reinstatement will be considered.
• Reinstatement Review: Reinstatement requires approval from the Virely LLC compliance team. Reinstated accounts enter a 60-day heightened monitoring period.

Section VIII — Permanent Removal Procedures

• Immediate Termination: All platform access is revoked immediately upon issuance of the removal notice.
• Data Export Window: The business has 14 calendar days from the removal date to request an export of their non-proprietary business data. After 14 days, all account data is permanently deleted.
• Financial Settlement: Outstanding invoices remain due and payable. Prepaid subscription fees for the current billing cycle are forfeited and non-refundable.
• Blacklist: Removed businesses, including their ownership principals and associated entities, are permanently barred from creating new accounts on any Dealsby platform.
• Legal Referral: In cases involving suspected illegal activity, Virely LLC will cooperate with and may proactively refer the matter to applicable law enforcement agencies.

Section IX — Ongoing Monitoring & Compliance

• Automated Monitoring: Platform activity is continuously monitored via automated systems for anomalous behavior including unusual messaging volume, complaint spikes, and payment irregularities.
• Periodic Review: Business accounts are subject to periodic compliance reviews at Virely LLC's discretion, including re-verification of business status and licensing.
• Consumer Complaints: Consumer complaints filed against a business through any Dealsby platform are investigated. Patterns of unresolved complaints may trigger enforcement action.
• Self-Reporting: Businesses are expected to proactively report material changes to their business status, licensing, ownership, or operations that may affect their eligibility.

Section X — Amendments & Governing Authority

Virely LLC reserves the right to amend this Code of Conduct at any time. Businesses will be notified of material changes via email and in-platform notification at least 30 days prior to the effective date of any amendment. Continued use of any Dealsby platform after the effective date constitutes acceptance of the amended terms.

This Code of Conduct is governed by the laws of the State of Georgia, United States. Any disputes arising from this policy shall be resolved through binding arbitration in Atlanta, Georgia, in accordance with the rules of the American Arbitration Association.

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Dealsby Reservations — Code of Conduct Addendum

Parent Policy: Virely LLC Code of Conduct

Section RV-I — Scope of This Addendum

This addendum supplements the Virely LLC Master Code of Conduct with rules specific to the Dealsby Reservations platform. All provisions of the master policy apply in addition to the platform-specific rules below. In the event of a conflict, the more restrictive provision governs.

Dealsby Reservations is a booking management platform designed for restaurants, hospitality venues, salons, medical offices, and other service-based businesses requiring reservation capabilities. The platform supports multi-location enterprise operations, floor plan management, waitlist management, and customer communications. Businesses are responsible for the accurate, professional, and ethical management of their reservation operations.

Section RV-II — Reservation Integrity & Accuracy

• Accurate Availability: Businesses must keep their reservation availability, seating capacity, table configurations, and floor plans current and accurate. Publishing false availability that results in overbooking, consumer confusion, or denied service upon arrival is a violation.
• Honest Capacity Representation: Businesses must not misrepresent their venue capacity, seating arrangements, or service capabilities.
• No Phantom Reservations: Businesses must not create fake bookings, fabricated guest entries, or placeholder reservations to manipulate capacity appearance, inflate booking metrics, or block availability for non-business purposes.
• Service Delivery: Businesses must honor confirmed reservations at the designated date, time, and party size. Chronic failure to seat confirmed reservations within a reasonable window (15 minutes for restaurants) may trigger a compliance review.
• Waitlist Integrity: Guests must be managed on a fair, first-come-first-served basis unless transparent priority policies are disclosed to all guests at the time of joining the waitlist.

Section RV-III — Multi-Location & Enterprise Standards

• Per-Location Accuracy: Each location must maintain independently accurate availability, floor plans, and operating hours.
• Role-Based Access Responsibility: Businesses utilizing role-based access control are responsible for properly configuring staff permissions. Granting excessive access privileges to unauthorized staff is a security violation.
• Location Verification: Each location registered on the platform must correspond to a real, operating business location. Registering fictitious locations to obtain higher-tier benefits or additional SMS/email allocations is fraud and will result in immediate removal.
• Consistent Consumer Experience: All locations operating under a single brand must maintain consistent reservation policies, cancellation terms, and communication standards.

Section RV-IV — Consumer Communication Standards

• Reservation Confirmations: Businesses must send confirmations promptly after a reservation is made, including date, time, party size, location, and any special instructions or policies.
• Reminder Limits: Automated reminders are limited to a maximum of two (2) per reservation: one 24–48 hours prior and one same-day.
• Transactional Integrity: Businesses must not embed promotional content, upsells, or unrelated marketing within transactional reservation communications unless the guest has explicitly opted in to marketing.
• Post-Visit Follow-Up: Businesses may send one (1) post-visit follow-up message per completed reservation. Follow-ups must include an opt-out mechanism and must be sent within 7 days of the visit.
• Opt-Out Compliance: All non-transactional communications must honor opt-out requests within 24 hours.

Section RV-V — No-Show, Cancellation & Deposit Policies

• Full Disclosure at Booking: All financial policies must be clearly presented to the guest before the reservation is confirmed. Hidden or post-booking fee disclosures are strictly prohibited.
• Reasonable & Proportional Fees: Per-person charges exceeding $50 or flat fees exceeding $200 for standard reservations require prominent disclosure.
• Cancellation Window: Policies requiring more than 24 hours advance notice for standard restaurant reservations, or more than 48 hours for large party/event reservations, must be prominently disclosed at booking.
• Deposit Handling: Deposits collected through the platform must be applied to the guest's bill or refunded according to the disclosed terms.
• Dispute Process: Disputes must be acknowledged within 3 business days and resolved within 14 business days.

Section RV-VI — Floor Plan & Venue Data Accuracy

• Accurate Floor Plans: Digital floor plans must reasonably reflect the actual venue layout, including table positions, seating capacity per table, and accessible seating options.
• Capacity Compliance: Total capacity represented in the reservation system must not exceed the venue's legal occupancy limit.
• Accessibility: If a venue offers accessible seating, the floor plan must accurately identify accessible tables and options.
• Timely Updates: Businesses must update floor plans within 7 days of any material change to venue layout, capacity, or accessibility features.

Section RV-VII — Industry-Specific Standards

• Restaurants & Hospitality: Must comply with all applicable health department regulations, food safety standards, and liquor licensing requirements.
• Salons & Personal Care: Must maintain all required cosmetology, barbering, or esthetics licenses.
• Medical & Dental Offices: Must maintain all required medical licenses and facility certifications. Patient data must be handled in compliance with HIPAA and all applicable healthcare privacy regulations.
• Event Venues: Must accurately represent venue capacity, amenities, and any restrictions. Deposit and cancellation terms must be clearly documented prior to confirmation.

Section RV-VIII — SMS & Email Usage Compliance

• Plan Limits: Starter ($59/mo): 1,000 SMS, 5,000 email, 1 location. Growth ($99/mo): 2,000 SMS, 10,000 email, 3 locations. Enterprise ($399/mo): 8,000 SMS, 40,000 email, 8 locations. Overages billed per applicable add-on or pay-as-you-go rates ($0.01/SMS, $0.001/email).
• Reservation-Related Use: Messaging credits are intended for reservation-related communications. Using platform messaging for unrelated purposes constitutes misuse.
• Multi-Location Allocation: For Growth and Enterprise plans, messaging allowances are shared across all registered locations.
• Carrier & Regulatory Compliance: All SMS must comply with TCPA, carrier 10DLC requirements, and A2P messaging standards.

Section RV-IX — Platform-Specific Enforcement

Tier 1 — Warning: Outdated floor plans not updated within 30 days; first instance of reminder frequency overage; minor disclosure omissions corrected within 14 days; inaccurate operating hours. Action: Written warning, 7-day corrective window, compliance note on account.

Tier 2 — Suspension: Repeated overbooking causing denied service; embedding marketing in transactional messages after warning; undisclosed fees generating 3+ consumer complaints in 60 days; failure to honor confirmed reservations; two or more Tier 1 violations in 90 days. Action: 14–90 day suspension, messaging privileges revoked, corrective action plan required, 60-day monitoring upon reinstatement.

Tier 3 — Removal: Reservation fraud or phantom bookings; registering fictitious locations; operating without required industry licenses; HIPAA violations; systematic deposit fraud; customer data misuse; repeated Tier 2 violations. Action: Immediate permanent removal from all Dealsby platforms, 14-day data export window, potential referral to regulatory or law enforcement authorities.

Section RV-X — Data Retention & Guest Privacy

• Minimum Necessary Data: Businesses should collect only the guest information necessary for the reservation and service delivery.
• Retention Limits: Virely LLC recommends retaining guest data no longer than 24 months from the last interaction unless required by law or regulation.
• No Unauthorized Sharing: Guest data collected through Dealsby Reservations must not be sold, shared with third parties for marketing purposes, or used in any manner not disclosed to the guest.
• Guest Data Requests: Businesses must honor guest requests to access, correct, or delete their personal data in accordance with applicable privacy laws (CCPA, GDPR where applicable).

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© 2026 Virely LLC (dba Dealsby). All rights reserved. Atlanta, Georgia. This document constitutes a binding agreement between the subscribing business and Virely LLC.