Last updated: July 3, 2026
Material Model, Inc., doing business as Signals (“Signals”, “we”, “us”, “our”), provides customer messaging infrastructure for ecommerce brands. This page explains how we separate customer support from marketing, how we handle consent, and how customers can stop messages.
This page is a public summary of our operating policy and general compliance posture. Brands that use Signals remain responsible for their own legal review, notices, customer-facing terms, and consent collection where required.
Signals’ core service is an iMessage customer messaging service. When iMessage is unavailable, the conversation may fall back to RCS or SMS. We also support 10DLC SMS and WhatsApp for brands and customers that prefer those channels.
The same customer thread may support order help, product questions, returns and exchanges, delivery issues, feedback, styling questions, and purchase assistance. The compliance treatment depends on why the message is sent and what channel is used.
Our primary use case is customer support and responding to user-initiated queries. A customer may ask about an order, a delivery, an item, a service, a return, an exchange, a brand policy, or a future purchase. Signals responds to that request with the relevant context from the brand’s catalog, policies, and connected systems.
When a customer asks for styling advice, product matching, restock help, or help buying an item, we treat that as customer-initiated purchase assistance. Catalog and recommendation tools stay available for those requests. When a customer message includes support intent, such as a return, exchange, refund, damaged item, missing package, fit problem, or other issue, the support need takes priority before any optional product suggestion.
Some brands use Signals solely for support and customer-initiated conversations. Unsolicited marketing is optional and can stay disabled for a brand’s program.
Signals’ main service is to send and reply to messages using our AI agent. We also support human-sent messages, such as CX escalations, and messages sent by a customer’s own AI agent through Signals MCP.
When a brand sends, initiates, or causes a message through Signals, including through our dashboard, API, or MCP connector, that brand is responsible for making sure the message content, purpose, timing, consent basis, and recipient selection comply with applicable law, carrier rules, platform rules, and the brand’s own customer-facing terms.
For certain brands, Signals can send brand-initiated messages to highly engaged customers. These can include campaign sequence steps, proactive review asks, unsolicited cross-sell suggestions, and contextual purchase follow-ups that are not a direct response to the customer’s latest request.
Those sends are treated as marketing sends. They are gated separately from ordinary support replies and user-initiated purchase help.
For SMS, 10DLC SMS, and RCS marketing sends, we require explicit written consent before sending brand-initiated marketing content.
For iMessage marketing sends, we follow FCC 19-73 and the text-message definition in 47 U.S.C. § 227(e)(8)(C)(iii), the federal statute commonly known as the Telephone Consumer Protection Act (TCPA). FCC 19-73 excludes non-SMS and non-MMS messages sent over IP-enabled messaging services such as iMessage, WhatsApp, and Skype to other users of the same service from the FCC rule definition discussed there. Section 227(e)(8)(C)(iii) similarly excludes messages sent over an IP-enabled messaging service to another user of that same service, except SMS and MMS messages. Signals still applies additional state-level protections before brand-initiated iMessage marketing is allowed.
For customers with a restricted-state signal in Connecticut, Washington, California, Virginia, Florida, Maryland, Oklahoma, or Texas, Signals requires full written consent before brand-initiated marketing over iMessage or WhatsApp too. We treat a restricted-state signal as present when we see it from a phone area code, order shipping state, or order billing state.
Brands can use Signals even when they do not collect broad marketing consent. In those cases, Signals can still provide support and respond to user-initiated conversations, but brand-initiated marketing without explicit written consent is limited to confirmed iMessage conversations with no restricted-state signal.
Signals evaluates marketing-send eligibility before non-user-initiated marketing flows. A marketing send is allowed when the customer has explicit SMS marketing consent, or, for iMessage only, when the latest provider evidence confirms iMessage service and the customer has no restricted-state signal.
If the channel is SMS, RCS, WhatsApp, or unknown, the send requires explicit marketing consent. If provider evidence is missing, we fail closed and treat the route as non-iMessage. If consent evidence says the customer is unsubscribed, the send is blocked.
Signals can read consent evidence from commerce and messaging consent systems, including Shopify and Listrak. We also maintain our own suppression records. Suppression and unsubscribe evidence wins over subscribed evidence.
Signals uses WhatsApp through the Meta Business messaging ecosystem. When a customer messages a brand on WhatsApp, the platform supports free-form service replies inside the 24-hour customer service window. Outside that window, brand-initiated messages must use approved templates where required by Meta’s rules.
For WhatsApp marketing outreach, Signals applies consent controls and the restricted-state protections described above. Where no written marketing consent is available, Signals does not use WhatsApp for brand-initiated marketing outreach. We also follow platform requirements for approved templates and customer-service-window behavior.
Customers can opt out at any time. Signals supports standard STOP-style keywords, including STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, and QUIT. These are handled immediately, case-insensitively, and without sending the request through the normal AI response path.
Signals also uses an LLM-based admission hook to detect ordinary-language stop requests, such as “please no more messages”, “stop texting me”, “don’t contact me again”, or “remove me from these texts”. When detected, we block the conversation, suppress the phone number, and cancel pending proactive follow-ups.
START, SUBSCRIBE, and UNSTOP can remove an active suppression where resubscription is allowed.
Some customer replies are preferences rather than legal STOP requests. For example, a customer may say they only want order updates, do not want campaign follow-ups, or prefer fewer reminders. Signals can store a contextual outreach preference note and re-check it before future proactive outreach.
When that stored preference conflicts with a planned proactive send, the send is skipped. Important operational or customer-requested support replies are not suppressed unless the preference clearly blocks them.
Signals records message route evidence, consent evidence, suppression state, blocked marketing decisions, and skip reasons. Marketing workflows are checked before sending, and the SMS send path includes a defense-in-depth backstop so a marketing send that bypasses an upstream gate is still blocked before provider delivery.
Campaign step decisions can record the marketing eligibility reason. Review requests, proactive cross-sell, and contextual purchase follow-ups are also gated, and blocked attempts are logged for operational review.
Brands can use Signals for support and user-initiated conversations even if they do not collect marketing consent. Before asking Signals to send marketing content on routes that require consent, brands must collect and maintain that consent. This includes clear opt-in language, required disclosures, accurate consent records, and a working privacy policy and terms where required.
When written marketing consent is not available, Signals limits brand-initiated marketing to confirmed iMessage conversations with no restricted-state signal.
Brands may not upload or use rented, sold, or shared opt-in lists with Signals. Brands must also keep connected consent systems accurate and notify us if they need stricter rules for a particular program, geography, channel, or customer segment.
For compliance questions, contact hello@returnsignals.com.
For privacy requests, contact privacy@returnsignals.com.