My business uses conversational SMS — always initiated by the consumer, and never used for advertising nor any automated API. TCR documentation states implied consent is sufficient in this case, but it seems that my campaign would be rejected if I were to just rely on that?

Is it sufficient to add a clause to our terms and conditions on the business’ website stating that consent to receive conversational SMS to communicate with the business is implied, and then for opting out to have both (1) a paper form available in-office for customers to fill out AND (2) customers can text “opt out” to the business’ number and we will mark their files as do-not-text?