What does SHAFT stand for?
SHAFT stands for Sex, Hate, Alcohol, Firearms, and Tobacco, specifically retailers who sell products within any of those categories and market to their customers via SMS.
In addition to following standard CTIA, TCPA, FCC, and carrier-specific guidelines, SHAFT clients must adhere to additional rules and regulations to get properly provisioned and remain in good standing.
What is required to provision SHAFT programs?
A robust age gate is a requirement and critical for anyone that falls within SHAFT
Carriers must be able to see and test a program’s age gate experience for approval.
The standard provisioning process should be followed for SHAFT clients, including providing all the standard materials.
Carriers have the discretionary right to approve or deny any program, including if programs don’t align with their codes of conduct and content policies.
Onsite content should be reviewed to ensure nothing illegal or encouraging illegal activity is promoted, and Mobile Terms & Conditions should be updated to include expectations of the program.
What is a ‘robust age gate'?
An age gate collects a contact’s birthdate to confirm their age before subscription, and is set at the acquisition campaign level in Listrak.
These are in place to protect unintended audiences from receiving content they shouldn’t be consuming, per FCC and TCPA guidelines.
Age gates additionally provide “written” consent from the end user that they intend to opt-in and receive content.
The actual age requirement is determined by state and federal law, under the advisement of the client’s legal counsel (most commonly 18 or 21).
Firearms and Alcohol programs must be set to a 21+ age gate.
Birthdate should be collected in MM/DD/YYY format, and the contact will not be subscribed if they are not old enough (and receive a Denied Entry Message).
An age gate cannot be a yes or no question.
Does TMobile still have separate requirements for firearms?
Yes, TMobile continues to apply specific policy terms to the firearms vertical that prohibits the marketing via text of any firearm or part that is not legal in all 50 states, including automatic weapons and parts.
TMobile treats programs that send any marketing campaign referencing AR products as ‘Severity 0’ and will stop all traffic until changes are reviewed and approved.
Text messages cannot include direct promotion of these products and cannot include links that send users to pages that directly promote the sale of these products.
URLs can still be included in text messages if they do not point to the sale of any firearm or part that is not legal in all 50 states.
What about cannabis?
Cannabis, CBD, hemp, etc. is now considered a controlled substance, but can still fall under illegal drugs depending on the product and state.
Marijuana is currently a Schedule 1 substance under the Controlled Substances Act.
Clients that sell products that fall within this category should avoid sending texts with links that would otherwise direct back to related content promoting the use or sale of cannabis products.
⚠️ Any related content is strictly prohibited from marketing via text.
What SHAFT content is allowed?
Text messages around promotions, sales, events, or anything that doesn’t reference a specific product directly can be sent by SHAFT clients without issue.
Content on safety, product care, and customer service can be sent as well.
All standard compliance rules must be followed, including program name with each text and HELP and STOP instructions monthly.
Message Examples that MEET requirements:
[BRAND]: Come check out our new stock, now 10% off just for you! https://www.brand.com HELP for help, STOP to stop
[BRAND]: Gear just reduced and moving quickly – Grab what you need before it’s gone. https://www.brand/com
What SHAFT content is prohibited?
Additional prohibited message content includes:
Sexually explicit content, solicitation of sex, promotion of sexual conduct, simulation or actual sex act, or solicitation of minors, etc.
💡 Lingerie and related products can be promoted, but brands should avoid sending MMS that shares explicit imagery
Profanity and hate speech, hateful language that encourages or solicits hat and makes threats, etc.
Encouraging the use or consumption of alcohol, encouraging minors to use alcohol, etc.
Use of a firearm to harm an individual, organization or group, and promoting illegal use/ purchase of a firearm
Promoting consumption of tobacco, vape, and cannabis products, encouraging minors, etc.
Any gambling-related content
Any Sweepstakes
Message Examples that DO NOT MEET requirements:
[BRAND]: Come check out our pistols, now 10% off just for you! https://www.brand.com/pistol123 HELP for help, STOP to stop
[BRAND]: These ARs are on sale moving quickly – Grab yours before it’s gone. https://www.brand/com/arsale
Is Transactional Messaging impacted by SHAFT?
Listrak recommends setting up different paths in Journey Hub for Transactional messaging, to look for carrier and products purchased.
Campaigns should first split based on TMobile or non-TMobile carrier, to send TMobile contacts down a specific path.
From there, a second split can be based SKUs in the last order placed.
Messages can be more generic than specific, eliminating the need for carrier or product-based segmentation, for example:
[PROGRAM]: Your order has shipped! Click here to track it: https://www.program.com/order STOP to stop
For segmentation to be most effective, client data must be clean with consistent naming conventions.
Program approval is always up to the discretion of the carriers; be ready to make changes as needed.
Transactional Messaging for cannabis is allowed, but the products purchased CANNOT be mentioned in the texts, and messages CANNOT link directly to the cannabis order or other content.
Transactional Messaging for cannabis is limited to:
Order Confirmation
Shipping Confirmation
Delivery Confirmation
FAQs
Q: Does it cost anything extra to run a SHAFT client program?
A: Not necessarily, unless amendments or changes are required as the results of carrier audits or litigation.
Q: Can Listrak give legal advice to SHAFT clients on their website and content?
A: No, we cannot give legal advice beyond standard mobile compliance-related information. Please review all materials related to the program with your own legal counsel.
Q: Can SHAFT clients choose to not use an age gate?
A: You can choose to follow Listrak's recommendations and rules as they see fit. But at the same time, the carriers have their discretionary right to approve or deny programs. We cannot guarantee any program will be approved without issue.
Q: Do any of the other carriers have their own policy updates?
A: As of right now, only TMobile has implemented policies specific to firearms dealers.