TCPA & Telecommunications Compliance Policy

3.1 Prior Express Written Consent (PEWC)

Before initiating any outbound voice call or automated SMS message via Intelinteract, Customer must possess the required level of consent from the recipient:

• Marketing & Promotional Calls/SMS: Customer must obtain Prior Express Written Consent that is explicit, written (or legally binding electronic signature under the E-SIGN Act), clear, and conspicuous. Consent cannot be a mandatory condition of purchasing goods or services.
• Informational & Appointment Reminders: Outbound appointment reminder calls or transactional notifications (e.g., patient appointment follow-ups, doctor schedule updates) require Prior Express Consent from the patient or recipient to be contacted at the specific phone number provided.

3.2 AI Voice and Synthetic Speech Disclosure

• Mandatory AI Disclosure: In accordance with FCC regulations and state disclosures, all outbound calls and inbound voice interactions executed by Intelinteract AI agents must disclose clearly and conspicuously at the very beginning of the call that the interaction is powered by an artificial intelligence voice assistant (e.g., "Hello, this is an automated AI assistant calling from [Practice Name] with an appointment reminder...").
• Corporate Identification: The AI agent must state the legal identity of the business or medical practice on whose behalf the call is being made.

3.3 Call Recording Disclosures

If Customer enables call recording or transcript logging within Intelinteract:

• Customer is solely responsible for ensuring compliance with federal and state wiretapping laws.
• For calls placed to or from two-party consent states (e.g., California, Florida, Massachusetts, Pennsylvania, Washington), the AI agent must state at the outset: "This call may be recorded or monitored for quality and scheduling purposes."

3.4 Do Not Call (DNC) Compliance & Opt-Out Handling

• DNC Registry Scrubbing: Customer must scrub all outbound campaign lists against the National Do Not Call Registry, applicable state DNC lists, and Customer's internal company DNC list prior to initiating calls.
• Automated Opt-Out Mechanism: Intelinteract contains automated opt-out detection. For text/SMS campaigns, standard opt-out keywords (e.g., STOP, CANCEL, UNSUBSCRIBE, END, QUIT) must immediately halt further messaging.
• Verbal Opt-Out Handling: Outbound AI voice agents must be configured to recognize verbal opt-out requests (e.g., "Do not call me again", "Take me off your list") and immediately flag the phone number in Customer's DNC database.

3.5 Time-of-Day Restrictions (Calling Curfews)

• Outbound voice calls and SMS messages may only be dispatched between 8:00 AM and 9:00 PM local time at the recipient's location.
• Customer must respect stricter state calling curfews (e.g., states prohibiting calls after 8:00 PM or on state holidays).

3.6 Caller ID and STIR/SHAKEN Compliance

• Calls dispatched via Intelinteract must display accurate, non-misleading Caller ID information (originating phone number and business name).
• Spoofing Caller ID, transmitting misleading caller information, or concealing identity is strictly prohibited under the Truth in Caller ID Act.
• Phone numbers used for outbound automation must comply with STIR/SHAKEN caller identity authentication standards.

3.7 Prohibited Call Destinations

Outbound calls or automated messages must NEVER be directed to:

• Emergency telephone lines (including 911, police, fire, or ambulance dispatch);
• Hospital patient rooms, physician offices, or emergency medical facilities (unless specifically authorized for patient care follow-up under HIPAA exceptions);
• Paging services, cellular numbers assigned to emergency services, or toll-free lines where the called party is charged for the call (without explicit consent).

4.1 Continuing Warranties

Customer represents, warrants, and covenants on a continuing basis that:

• All phone numbers provided to Core Cognitics for outbound messaging or calling campaigns have been lawfully collected with verifiable consent.
• Customer maintains a written internal Do Not Call Policy and trains its staff accordingly.
• Customer will not use Intelinteract to transmit unsolicited telemarketing or spam calls.

4.2 Consent Record Retention

Customer must retain detailed, auditable records demonstrating recipient consent (including timestamp, IP address/source form, opt-in disclosures, and phone number) for a minimum of four (4) years from the date of consent. Customer shall promptly provide proof of consent upon request by Core Cognitics or regulatory authorities.

5.1 Customer Indemnification

5.2 Suspension and Termination Rights

Core Cognitics reserves the right to immediately suspend or terminate Customer's access to the Intelinteract outbound campaign engine, voice APIs, or platform account without liability if:

• Core Cognitics receives complaints or TCPA breach notices regarding Customer's calling activities;
• Customer fails to provide verifiable proof of consent for an outbound campaign upon request; or
• Core Cognitics detects unusual call abandonment rates, spam patterns, or non-compliant dialing practices.