Acceptable Use Policy

The Service is a post-transactional voice AI for e-commerce merchants. It is designed to place Calls on Customer's behalf to End-Customers who have an existing transactional relationship with Customer — typically because they have placed an order, initiated a checkout, or received a delivery from Customer's store. The AUP exists to keep the Service used as designed: lawfully, transparently, and within the boundaries of post-transactional voice automation.

This AUP applies to Customer, Customer's Authorized Users, and any third party (such as an agency) acting on Customer's behalf. Violation of this AUP is a material breach of the Terms of Service and may result in immediate suspension or termination of the Service under Terms of Service Section 17.3.

The Service is designed for, and approved for use in, the following post-transactional scenarios. Each requires that the End-Customer has an existing transactional relationship with Customer (e.g., an order placed, a checkout initiated, a refund requested, or a returning-customer relationship documented in Customer's CRM):

The Service must not be used, and Customer must not configure, attempt, or assist any third party in using the Service, for any of the following purposes. The list is illustrative and not exhaustive — the Operator may classify additional behaviour as a violation of this AUP at its reasonable discretion.

If Customer is in any doubt whether a particular use case is approved, Customer must contact the Operator at [email protected] before deploying it. The default classification of an ambiguous use case is "banned" until the Operator has confirmed otherwise in writing.

Where Customer has enabled Call recording in Customer's configuration, Customer warrants that, before any Call is recorded, Customer has obtained all consents and provided all notices required by applicable law in each market in which Calls are placed. The Service plays a configurable on-call announcement informing the End-Customer that the Call may be recorded; Customer is responsible for the wording, language, and adequacy of that announcement and for honouring End-Customer opt-outs immediately.

By way of example only and without limitation: certain U.S. states require all-party consent for recording (e.g., California Penal Code §632, Florida, Illinois, Pennsylvania, Massachusetts); the EU ePrivacy Directive 2002/58/EC and Member-State implementations require a clear notice and, in many cases, prior consent; the UK Privacy and Electronic Communications Regulations apply to the UK market; Canadian PIPEDA + CRTC rules apply in Canada. Customer is responsible for identifying the applicable rule for each Call.

Customer must promptly disable recording for any End-Customer who has opted out, and must not retain any portion of an opted-out End-Customer's recording beyond the time required to remove it from the Service. The Operator's role is purely technical; Customer is the data controller for the recording.

As required by Article 50 of the EU Artificial Intelligence Act (Regulation (EU) 2024/1689), the California Bolstering Online Transparency (B.O.T.) Act, New York City Local Law 144, the Utah AI Policy Act, and equivalent transparency laws in other markets, every AI agent operating on the Service must disclose its non-human nature to the End-Customer at the commencement of each Call (or, where applicable law so requires, throughout the Call). The Operator provides default AI-disclosure announcements in supported languages.

Customer must not:

• disable or attempt to disable the AI-disclosure announcement;
• configure the agent to deny or evade questions about its non-human nature;
• use a confusingly-similar disclosure that hides the AI nature (e.g., "I am calling from [brand]" without "AI assistant" wording);
• use the agent's voice to imply human identity in any way;
• configure the agent to impersonate a specific identifiable natural person.

Customer is responsible for reviewing the AI-disclosure announcement in each language and market and updating it promptly when applicable law changes. Disabling AI disclosure is a material breach and may result in immediate suspension under Terms of Service Section 17.3.

Customer must not use the Service to place Calls to recipients in, or to operate in, any country or region subject to comprehensive sanctions or embargoes by the United States (U.S. Treasury Office of Foreign Assets Control), the European Union, the United Kingdom, or the United Nations Security Council. As of the Effective Date this includes (without limitation) Cuba, Iran, North Korea, Syria, the Crimea / so-called Donetsk and Luhansk regions of Ukraine, and the Russian Federation (subject to applicable exceptions). The list is updated by reference to the underlying authorities; Customer is responsible for monitoring it.

Customer must not use VPN, proxy, false documentation, or straw entities to circumvent jurisdictional restrictions.

Customer must operate the Service within reasonable volume and frequency limits relative to Customer's actual order flow and existing customer base. Specifically:

• No mass-dial campaigns to numbers without an existing transactional relationship.
• Frequency capping: Customer must not place repeated Calls to the same End-Customer for the same purpose within a short time window absent a clear operational reason (e.g., delivery rescheduling). The Operator's default frequency cap is one Call per End-Customer per 24 hours per purpose; Customer may not raise this without Operator's written consent.
• Honour opt-outs immediately: when an End-Customer asks to be removed from communications (verbally during a Call, by SMS reply where applicable, by e-mail, or by any other reasonable channel), Customer must add that End-Customer to a suppression list and not place further Calls except for legally-required communications (e.g., delivery confirmation of an in-flight order).
• Time-of-day restrictions: Calls must be placed only during reasonable local hours of the End-Customer (typically 09:00–20:00 local time on weekdays, with stricter limits on weekends and holidays where required by local law).
• No volume manipulation: Customer must not artificially inflate Call volumes to consume Credits or trigger the Operator's billing systems.

Customer is responsible for the content of every script in every language. The Operator provides default scripts in supported languages as templates; Customer must review and approve each script in each language before deployment, and update it when product information, regulatory disclaimers, or applicable law change. Customer warrants that:

• each script is accurate, lawful, and not deceptive;
• each script complies with applicable consumer-protection, advertising, telemarketing, sector-specific, and privacy law in the market where Calls are placed;
• regulatory disclaimers required for Customer's vertical (e.g., medicinal-product, food-supplement, financial-services) are present in the script in the correct language and at the correct moment;
• the AI-disclosure announcement (Section 5) is not removed, weakened, or contradicted by the script.

Customer must not configure the Service to make claims that exceed Customer's actual product information, that violate consumer-protection rules against deceptive advertising, or that the Operator reasonably considers brand-unsafe. Customer must not configure the Service to:

• make false, misleading, or unsubstantiated product claims (e.g., medical claims about non-medical products, "guaranteed" results, cure claims);
• create urgency through false scarcity ("only 2 left in stock!" when not true);
• misrepresent prices, fees, taxes, delivery costs, return policies, or refund terms;
• use dark-pattern phrasing intended to manipulate End-Customer decisions (e.g., framing decline-to-upsell as "are you sure you don't want to save money?");
• generate content that infringes third-party intellectual-property rights;
• generate content that is hateful, discriminatory, sexually explicit, or otherwise unlawful in the market where the Call is placed.

Customer agrees to cooperate with the Operator on AUP-compliance matters, including:

• responding to written inquiries about specific use cases or campaigns within five (5) business days;
• providing, on reasonable request, evidence of consent, source of telephone numbers, frequency-cap configuration, opt-out lists, and AI-disclosure announcement wording;
• cooperating with regulator inquiries received by the Operator that concern Customer's use of the Service;
• passing through this AUP to any agency or third party that operates the Service on Customer's behalf.

Anyone — including End-Customers, regulators, journalists, or the public — may report a suspected AUP violation to [email protected]. Reports should include the calling number, the recipient's number (where possible), the time and date of the Call, the script content if known, and any other relevant context.

The Operator investigates each report in good faith. The Operator does not disclose the identity of the reporting party to Customer, except where required by law or court order.

• Warning — written notice describing the suspected violation and a 7-day cure period.
• Restriction — temporary limitation of Service functionality (e.g., disabling outbound Calls, capping concurrent Calls, blocking specific scripts).
• Suspension — full pause of the Service pending Customer's cure of the violation, in accordance with Terms of Service Section 17.3.
• Termination — termination of the Subscription for material breach in accordance with Terms of Service Section 17.2.
• Referral — referral of evidence to law-enforcement, regulators, payment networks, fraud-prevention databases, or other authorities, where the Operator reasonably believes a violation involves criminal conduct, fraud, large-scale consumer harm, or sanctions evasion.
• Forfeiture — forfeiture of unused Credits and Plan entitlements for the period of suspension or after termination.
• Cost recovery — recovery of reasonable investigation, remediation, and compliance costs from Customer in accordance with Terms of Service Sections 21.2 and 26.11.

The Operator is not obliged to follow the enforcement matrix in sequence and may escalate immediately to suspension, termination, or referral where the violation is severe (e.g., scams, deepfakes, sanctions evasion, evident fraud).

Where the violation results in a third-party claim, regulatory inquiry, fine, or settlement against the Operator, Customer indemnifies the Operator under Terms of Service Section 21.2 to the maximum extent permitted by applicable law.

The Operator may update this AUP from time to time to reflect changes to the Service, applicable law, or evolving threat patterns (e.g., new fraud schemes, new regulator guidance). For material changes, the Operator will give Customer at least 30 days' prior notice by e-mail and in-app notice and update the "Last Updated" date at the top. Continued use of the Service after the updated AUP takes effect constitutes acceptance.

• AUP questions / pre-deployment use-case approval: [email protected]
• Reporting suspected violations: [email protected]
• Privacy and data subject rights: [email protected]
• EU contact: [email protected] (designated EU representative — see Legal Notice)
• Phone: +1 (719) 624-4435
• Postal address: 1111B S Governors Ave STE 39750, Dover, DE 19904, USA