Cold SMS Outreach

Understand the rules, regulations, and best practices for conducting cold SMS outreach with WhatSnap while staying compliant and avoiding carrier blocks.

Can I Use WhatSnap for Cold SMS Outreach?

Technically: Yes. WhatSnap's P2P SMS system can be configured for cold outreach.

Legally and Practically: It Depends on your country's regulations, your consent practices, and how you execute the campaign.

Legal Compliance Required: SMS messaging is heavily regulated in most countries. You are responsible for following all applicable laws and regulations, including TCPA (US), GDPR (EU), CASL (Canada), and local SMS marketing laws. Review our Terms of Service and consult with legal counsel before conducting any cold outreach.

Carrier Risk: Cold SMS outreach carries significantly higher risk of carrier blocks compared to warm, conversational messaging. Even if legally compliant, carriers may flag or block your number for spam-like behavior.

Understanding "Cold" SMS Outreach

What is Cold SMS?

Cold SMS means messaging people who:

  • Have not previously engaged with your business

  • May not expect a message from you

  • Have not explicitly opted in to receive SMS from you (or opted in at some point but haven't engaged recently)

  • Are being contacted for the first time or after a long dormancy

Types of SMS Outreach

🔴 Truly Cold (Highest Risk):

  • Purchased contact lists

  • Scraped data from websites/social media

  • No prior relationship or opt-in

  • ⚠️ Illegal in many jurisdictions

  • ⚠️ High carrier block risk

  • ⚠️ Not recommended

🟡 Lukewarm (Moderate Risk):

  • Old leads who opted in but never engaged

  • Past customers (2+ years dormant)

  • Trade show contacts from months/years ago

  • Referrals without explicit opt-in

  • ✅ May be legal with proper disclosures

  • ⚠️ Moderate carrier block risk

  • ✅ Use with caution and compliance measures

🟢 Warm (Low Risk):

  • Recent leads who opted in

  • Active customers

  • Recent inquiries

  • Ongoing conversations

  • ✅ Generally legal with prior opt-in

  • ✅ Low carrier block risk

  • ✅ Recommended

Legal Requirements by Region

United States (TCPA)

Telephone Consumer Protection Act (TCPA):

Required:

  • ✅ Prior express written consent before sending marketing SMS

  • ✅ Consent must be clear, conspicuous, and unambiguous

  • ✅ Provide opt-out mechanism in every message (or make it easy to opt-out)

  • ✅ Honor opt-outs within 24 hours

  • ✅ Identify your business clearly

  • ✅ Maintain records of consent

Prohibited:

  • ❌ Messaging without consent

  • ❌ Using auto-dialers for marketing without consent

  • ❌ Ignoring opt-out requests

  • ❌ Messaging numbers on Do Not Call Registry (without exemption)

Penalties:

  • $500-$1,500 per violation (per message)

  • Class action lawsuits common

  • FCC enforcement actions

Resources:

European Union (GDPR)

General Data Protection Regulation:

Required:

  • ✅ Explicit opt-in (pre-checked boxes don't count)

  • ✅ Clear privacy policy

  • ✅ Right to access, rectify, and erase data

  • ✅ Legitimate interest or consent as legal basis

  • ✅ Detailed record-keeping of consent

Prohibited:

  • ❌ Sending without lawful basis

  • ❌ Purchasing data without proper consent transfer

  • ❌ Ignoring data subject rights

Penalties:

  • Up to €20 million or 4% of global revenue (whichever is higher)

Canada (CASL)

Canada's Anti-Spam Legislation:

Required:

  • ✅ Express or implied consent

  • ✅ Clear identification of sender

  • ✅ Easy unsubscribe mechanism

  • ✅ Honor unsubscribes immediately

Penalties:

  • Up to $10 million CAD for businesses

Australia (Spam Act 2003)

Required:

  • ✅ Consent (express or inferred)

  • ✅ Identify sender

  • ✅ Unsubscribe mechanism

  • ✅ Australian-based sender or relevance to Australia

Penalties:

  • Up to $2.5 million AUD

Other Countries

Always check local regulations:

  • Many countries have strict SMS marketing laws

  • Some require registration or licensing

  • Penalties vary widely

  • Consult local legal counsel

WhatSnap's Position on Cold Outreach

From WhatSnap Terms of Service:

WhatSnap provides the technology platform, but you are responsible for:

  • ✅ Ensuring compliance with all applicable laws

  • ✅ Obtaining proper consent from recipients

  • ✅ Following carrier terms of service

  • ✅ Maintaining opt-out mechanisms

  • ✅ Handling all legal liability

WhatSnap does not:

  • ❌ Provide legal advice

  • ❌ Guarantee deliverability for any campaign

  • ❌ Take responsibility for your compliance

  • ❌ Prevent carrier blocks (we provide tools; you must use them correctly)

Review Terms: Always review WhatSnap Terms of Service and ensure your use case complies with our acceptable use policy.

Best Practices for Compliant Cold Outreach

1. Obtain Proper Consent

How to Get Consent:

  • ✅ Checkbox on web forms: "I agree to receive SMS messages"

  • ✅ Separate from other consents (not bundled)

  • ✅ Clear language about what they'll receive

  • ✅ Provide frequency and opt-out info upfront

Example Consent Language:

☑️ I agree to receive promotional text messages from [Business Name] 
at the number provided. Message frequency varies. Reply STOP to opt out. 
Message & data rates may apply.

Record Keeping:

  • Keep records of when and how consent was obtained

  • Store consent with contact record

  • Be able to prove consent if challenged

2. Use WhatSnap's Outreach Module

Built-In Safety Features: WhatSnap's Outreach module includes throttling and automatic opt-out handling to help you stay compliant.

Outreach Module Benefits:

  • ✅ Automated drip campaigns with safe sending rates

  • ✅ Automatic handling of STOP requests

  • ✅ Built-in opt-out to DND (Do Not Disturb)

  • ✅ Schedule messages during appropriate hours

  • ✅ Track engagement and responses

See: Outreach Module Documentation

Do NOT Use GHL Native SMS Broadcast Drip: The native GoHighLevel SMS broadcast drip feature does not allow proper control of delivery timing. Messages queue and can send in bulk bursts, which will trigger carrier spam filters. Always use WhatSnap's outreach features or carefully configured workflows.

3. Follow Drip Best Practices

Safe Sending Rates:

  • Maximum: 1 message per minute (sustained)

  • New SIM: Start at 1 message every 5-10 minutes

  • After warm-up: Gradually increase to 1/minute

Daily Caps:

  • Start: 10-20 messages/day (Week 1)

  • Gradual increase: 50-100 messages/day (Week 2)

  • Maximum: 100-250 messages/day (after full warm-up)

Use WhatSnap's Drip Mode:

Workflow Example:
Trigger: Contact added to campaign
↓
Wait: Random delay 1-60 minutes
↓
Send SMS: Initial message
↓
Wait: 2-3 days OR response received
↓
If no response: Send follow-up
↓
If STOP received: Auto-add to DND

See: Database Reactivations - Drip Campaigns

4. Honor Opt-Outs Immediately

Required by Law:

  • Honor opt-out requests within 24 hours (US TCPA)

  • Many jurisdictions require immediate compliance

  • Accept standard keywords: STOP, UNSUBSCRIBE, CANCEL, END, QUIT

WhatSnap Auto-DND: WhatSnap includes automatic Do Not Disturb handling:

  • Contact replies "STOP" → Automatically added to DND

  • All future messages blocked across WhatSnap accounts

  • No manual intervention needed

Workflow Enhancement:

Trigger: SMS received contains "STOP"
↓
Action: Add to DND (redundant but safe)
Action: Add tag "Opted-Out"
Action: Remove all campaign tags
Action: Send confirmation: "You've been unsubscribed. Reply START to resubscribe."
Action: Notify admin (optional)

5. Message Content Requirements

Must Include:

  • ✅ Clear identification of your business

  • ✅ Reason for contact (if not obvious)

  • ✅ Easy way to opt-out (or mention "Reply STOP")

  • ✅ Provide contact info if requested

Avoid:

  • ❌ Misleading or deceptive content

  • ❌ Excessive ALL CAPS

  • ❌ Too many exclamation marks!!!

  • ❌ Spam trigger words (FREE, LIMITED TIME, ACT NOW)

  • ❌ Links in initial messages (major spam trigger)

Good Example:

Hi {{first_name}}, this is [Your Name] from [Business Name]. 
I saw you inquired about [service] last month. Wanted to check 
if you're still interested? Reply STOP to opt out anytime.

Bad Example:

🚨 LIMITED TIME OFFER!!! Click here NOW: [link]
FREE MONEY WAITING FOR YOU!!!
Text STOP to unsubscribe

6. Respect Quiet Hours

Recommended Sending Hours:

  • Weekdays: 9 AM - 7 PM (recipient's local timezone)

  • Weekends: 10 AM - 6 PM (or avoid weekends)

  • Never: Late night (9 PM+) or early morning (before 8 AM)

GHL Workflow Time Restrictions: Configure workflows to only send during appropriate hours:

Send SMS Action → Settings → Time Window
Set: 9 AM - 7 PM, Monday-Friday

Carrier Compliance and Block Prevention

Carrier Fair Use Policies

Carriers monitor for:

  • ⚠️ High volume from new numbers

  • ⚠️ Identical messages to many recipients

  • ⚠️ Spam keywords and links

  • ⚠️ High opt-out rates

  • ⚠️ Recipients marking as spam

  • ⚠️ Sending patterns inconsistent with personal use

Stay Under the Radar:

  • ✅ Warm up SIM cards properly (2-3 weeks)

  • ✅ Personalize every message (vary content)

  • ✅ Start slow, increase gradually

  • ✅ Monitor delivery rates and response rates

  • ✅ Stop immediately if you see issues

See: Database Reactivations - Avoiding Carrier Blocks

Android Phone Limitations

Built-in SMS Limits:

  • Android phones may warn if you exceed 30 SMS in 30 minutes

  • You can override the warning, but it's a red flag

  • Exceeding this frequently may trigger carrier attention

Override if Needed:

  1. Warning appears: "App is sending large amount of SMS"

  2. Tap "Allow" to continue

  3. Messages will queue until you approve

Better Approach:

  • Stay below 1 message per minute to avoid triggering warning

  • Use multiple SIMs/devices to distribute volume

Country-Specific Limits

Example: France

  • Legal limit on SMS per month via SIM card

  • Violating limit = carrier block or legal issues

Example: UAE

  • Carrier limits: 500 SMS/day (Virgin Mobile UAE)

  • Very strict enforcement

Always check:

  • Carrier fair use policy

  • Country SMS regulations

  • Carrier-specific restrictions

See: SIM Plan Recommendations

When to Use WhatSnap P2P vs. Twilio A2P

WhatSnap P2P SMS (Peer-to-Peer)

Best For:

  • ✅ Warm leads and existing customers

  • ✅ Database reactivation (old leads with prior opt-in)

  • ✅ Conversational, relationship-based messaging

  • ✅ Local presence (your real phone number)

  • ✅ Cost-effective for moderate volume (100-500/day)

Not Ideal For:

  • ❌ Truly cold lists (no prior relationship)

  • ❌ Ultra-high volume (1,000+ messages/day per number)

  • ❌ Highly regulated industries requiring A2P compliance

  • ❌ International messaging at scale

Twilio A2P SMS (Application-to-Person)

Best For:

  • ✅ High volume transactional messages

  • ✅ Truly cold outreach (if you have proper opt-ins)

  • ✅ Compliance with carrier registration requirements

  • ✅ 10DLC or toll-free number campaigns

  • ✅ Predictable, reliable delivery at scale

Not Ideal For:

  • ❌ Budget-conscious small businesses

  • ❌ Personal touch (comes from short code or 10DLC)

  • ❌ Conversational, relationship-based messaging

Hybrid Strategy:

  • Use Twilio for cold outreach (with A2P registration)

  • Use WhatSnap for warm conversations after initial contact

  • Best of both worlds: Compliance + personal touch

Risk Assessment: Should You Do Cold SMS?

Low Risk (Go Ahead)

✅ You have:

  • Clear opt-in from recipients

  • Relationship with contacts (past customers, leads)

  • Proper warm-up plan

  • Compliance with local laws

  • Good message quality (personalized, relevant)

✅ Result: Likely success with proper execution

Moderate Risk (Proceed with Caution)

⚠️ You have:

  • Old opt-ins (1-2+ years ago)

  • Lukewarm leads

  • Purchased lists (with opt-in claims)

  • Unclear consent documentation

  • Limited personalization

⚠️ Result: Higher block risk, legal gray area. Proceed carefully with extra compliance measures.

High Risk (Reconsider)

🛑 You have:

  • No opt-in or consent

  • Scraped/purchased lists without clear consent

  • Truly cold contacts

  • No prior relationship

  • High-volume plans from day 1

🛑 Result: Very high risk of blocks, legal issues, and account suspension. Not recommended.

Better approach:

  • Build opt-in lists through legitimate means

  • Use Twilio with A2P for cold outreach

  • Focus on warm, conversational use cases for WhatSnap P2P

Summary

Can You Do Cold SMS with WhatSnap?

Technically: Yes Legally: Depends on your compliance Practically: Risky without proper consent and execution

Key Takeaways

  1. Consent is King: Always obtain proper opt-in before messaging

  2. Follow the Law: Research and comply with local regulations (TCPA, GDPR, etc.)

  3. Use Safety Features: Leverage WhatSnap's outreach module with throttling and auto opt-out

  4. Warm Up Properly: Never send high volume from new SIMs

  5. Personalize Content: Avoid spam-like messages and links

  6. Honor Opt-Outs: Immediately stop messaging anyone who requests it

  7. Monitor Performance: Watch for deliverability issues and adjust

Our Recommendation

Best Practice:

  • ✅ Use WhatSnap for warm, conversational messaging with prior opt-in

  • ✅ Reserve truly cold outreach for Twilio A2P (with proper registration)

  • ✅ Focus on database reactivation of old leads (who opted in previously)

  • ✅ Prioritize quality over quantity in message content

  • ✅ Always stay compliant with regulations and carrier policies

Smart Strategy: Use WhatSnap's strengths—personal touch, local presence, cost-effectiveness—for relationship-based messaging. For large-scale cold outreach, invest in Twilio's A2P infrastructure.

Related Resources

Need Compliance Guidance? WhatSnap support cannot provide legal advice. Consult with a legal professional specializing in telecommunications law for your jurisdiction. For technical questions about WhatSnap features, contact support@whatsnap.ai.

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