Communications Compliance Addendum

1. Purpose and core principle

This Communications Compliance Addendum ("Addendum") is part of the agreement between Closelio AI LLC, a {{ENTITY_STATE}} limited liability company ("Closelio," "we," "us"), and the Customer ("you") under our Terms of Service. It applies to every text message, phone call, voicemail and email sent or made through the Service, whether by you, your Users, the Power Dialer, an automated sequence, or an AI agent you configure.

The core principle is simple. You are the sender of every message and the caller on every call. For legal purposes you are the party that initiates the communication and, where the communication promotes insurance products, the seller or the agent acting for the seller. You decide whom to contact, when, how often, with what content, and on what basis. You are solely responsible for making sure each communication complies with every law, regulation, carrier rule and industry standard that applies to it.

Closelio is a technology provider. We supply software that you use to communicate. We do not choose your Contacts, write your scripts, decide when you call, or verify your consent, and we do not act as your lawyer or compliance officer. Nothing in the Service, our documentation, our support conversations or this Addendum is legal advice. You should get your own legal advice about your communications program.

This Addendum adds to our Acceptable Use Policy and SMS Terms. If you belong to an agency workspace, our Agency Addendum also applies.

2. Laws that apply to you

Your communications may be governed by many laws. They include the Telephone Consumer Protection Act (TCPA, 47 U.S.C. § 227) and the Federal Communications Commission's rules under it; the Telemarketing Sales Rule (TSR) enforced by the Federal Trade Commission; the CAN-SPAM Act for commercial email; the Truth in Caller ID Act; state telemarketing, "mini-TCPA," do-not-call, and call recording laws; state insurance laws and insurance department rules; Medicare marketing rules where they apply; and US privacy laws. Carriers and industry bodies also impose their own rules on messaging and calling.

These rules change often, and courts and regulators interpret them differently over time. It is your job to keep up with them and to adjust how you use the Service.

3. Consent

You must have the consent the law requires before you text or call any Contact. In particular:

• Autodialed, artificial voice and prerecorded calls and texts. Under the TCPA, certain calls and texts to mobile phones, and artificial or prerecorded voice calls, need the called party's prior express consent. When those communications are for marketing purposes, they generally need prior express written consent. Assume that the Power Dialer, automated sequences, and AI voice agents may be treated as the kinds of technology these rules cover, and get consent that meets the strictest standard that may apply.
• Marketing texts. Marketing text messages generally need prior express written consent, and many state laws and carrier rules add further requirements.
• Consent for the right seller. Where the law requires consent to be given to a specific seller, the consent must clearly cover you, or the business you represent, by name. A general consent to be contacted by unnamed "partners" or a long list of companies may not be enough. Follow the consent rules in effect at the time of each call or text.
• Scope. The consent must cover the type of communication (for example, texts, calls, artificial voice calls), the phone number you are contacting, and the subject matter of what you are offering.

You must document consent and be able to produce it. For each Contact, you must keep a record that shows who gave consent, when, how, to whom, the exact language they agreed to, and the phone number it covers. You must be able to produce that record promptly if a Contact, carrier, regulator, court or Closelio asks for it.

Leads you buy are your responsibility. If you buy or receive leads from a lead vendor, aggregator or other third party, you must verify that each lead's consent is valid for you, for the communications you plan to send, and under the laws of the Contact's state. A vendor's promise that its leads are "TCPA compliant" does not shift your responsibility. Closelio does not review or vouch for any lead source.

Consent attestations. The Service asks you to confirm consent when you upload Contacts and when you start a campaign. Each time you do, you are making a representation to us that it is true. These attestations do not reduce your obligations.

Revocation. A Contact may revoke consent at any time and by any reasonable means, including by replying to a text, telling a caller or an AI agent, or contacting you another way. You must honor revocations promptly and within any deadline the law sets. The Service processes common text opt-out keywords, such as STOP, automatically. You are responsible for recording other forms of revocation, such as a verbal request on a call or a written reply that does not use a keyword.

4. AI voice agents

The FCC has stated that calls using AI-generated voices are calls using an "artificial or prerecorded voice" under the TCPA. You must treat every call made or answered by a Closelio AI voice agent that way. That means:

• you must have the consent required for artificial or prerecorded voice calls before an AI voice agent calls anyone;
• at the start of the call, the AI agent must identify the business it is calling for, and you must not configure an AI agent to claim to be a human or to deny that it is automated;
• you must provide any further disclosures, opt-out mechanisms, or other requirements that federal or state law sets for artificial voice calls;
• you are responsible for the AI agent's instructions and for what it says, including any statement about an insurance product, price or benefit.

AI output can be wrong or unexpected. You must review your AI agents' configuration, monitor their conversations, and correct problems promptly.

5. Calling hours

Federal rules generally limit telephone solicitations to between 8:00 a.m. and 9:00 p.m. in the called party's local time. Many states set narrower hours, bar calls on certain days or holidays, or limit how many times you can call the same person in a period. You must follow the strictest rule that applies to each Contact.

The Service lets you set quiet hours and calling windows. Platform default settings are a convenience, not a statement of what the law requires, and they are not a guarantee. You are responsible for configuring these settings correctly. The Service determines a Contact's local time from the information available to it, such as area code or address, which may not match where the Contact actually is.

6. Do-not-call rules

You must comply with all do-not-call requirements, including:

• National Do Not Call Registry. You must not make telephone solicitations to numbers on the National Do Not Call Registry unless an exemption applies, such as a valid established business relationship or the person's written permission. You are responsible for any registry access you are required to have and for scrubbing your lists as often as the law requires.
• State do-not-call lists. Several states keep their own do-not-call lists. You must comply with the ones that apply to you.
• Internal (company-specific) do-not-call list. You must keep a list of people who asked you not to contact them, honor those requests promptly and within any deadline the law sets, and keep a written do-not-call policy if the law requires one.

The Service includes an internal do-not-call list and automatic text opt-out handling. It does not check numbers against the National Do Not Call Registry or state do-not-call lists for you. These tools help but do not guarantee compliance. Data sources can be incomplete or out of date, a number can be reassigned to a new person, and opt-outs received outside the Service will not be captured unless you record them.

7. State telemarketing laws

Many states have their own telemarketing and "mini-TCPA" laws. Florida and Oklahoma are examples. These laws may define autodialers more broadly than federal law, require different consent, limit the number and timing of calls and texts, require registration or bonding, or give consumers the right to sue. You must know and follow the laws of each state where your Contacts are located.

8. Call recording

The Service can record calls, and call recording is a workspace-level setting that can be turned on for all calls. Some states allow recording when one party to the call consents. Other states require every party to consent. Calls between people in different states may be subject to the stricter rule.

If you turn on recording, you are responsible for giving any notice and getting any consent that the law requires, before recording begins. The Service includes a recording disclosure setting. You are responsible for turning it on where needed and for making sure the disclosure says what the law requires. Calls handled by AI voice agents are transcribed so the agent can work, and you should disclose this where required.

9. Caller ID and identification

Caller ID. You must transmit accurate caller ID information, and you may only use phone numbers you are authorized to use. You must not alter caller ID to mislead, defraud or cause harm. The Service offers a local-presence caller ID option. If you use it, you must use it in a way that is lawful and not misleading, and you must make sure people who call those numbers back can reach you or opt out.

Identification. At the start of each call, and in your texts as the law and carrier rules require, you must clearly identify yourself or your agent by name, the business on whose behalf the communication is made, and its purpose. You must provide a way to opt out. You must not misrepresent who you are, whom you represent, or what you are offering.

10. Insurance marketing rules

You are responsible for complying with insurance laws and the rules of each state insurance department that applies to you, including licensing and appointment requirements, rules on advertising and solicitation, and rules on what you may say about products, premiums and benefits.

If you market Medicare products, you are also responsible for following the marketing rules of the Centers for Medicare & Medicaid Services (CMS) and the requirements of the carriers you represent, including rules on consent, timing, scope of appointment, required disclaimers, and call recording, where they apply. The same applies to any other government program, carrier or field marketing organization rules that govern your business.

Closelio does not review your scripts, templates, AI instructions or product statements for compliance with insurance rules.

11. A2P 10DLC and carrier rules

To send text messages from standard US local numbers, carriers require brand and campaign registration (known as A2P 10DLC). When you ask us to, we file your registration with carriers through our telephony provider, using the information you give us. You must:

• give complete, truthful and current information, and tell us promptly if it changes;
• send messages only within the use case, sample messages and opt-in process you registered;
• follow carrier and industry messaging rules, including rules on content, opt-in, opt-out and help keywords.

Carriers decide whether to approve your registration and how long it takes. We do not control the outcome or the timing. Carriers may filter, block, delay or charge extra for messages at any time, including after approval. Until your registration is approved, each seat is limited to 300 outbound dials per day, and texts may be limited or blocked by carriers. Registration fees are passed through as described in our Included-Usage Terms.

12. Compliance tools are aids, not a safe harbor

The Service includes features meant to help you run a compliant program. These include consent records for each Contact, consent attestations at upload and per campaign, the internal do-not-call list and automatic text opt-out handling, quiet hours and calling windows, per-seat daily dial caps before A2P approval, and the recording disclosure setting.

These tools are aids only. They are not a safe harbor, not legal advice, and not a guarantee that any communication complies with the law. They depend on the data and settings you provide, they may not reflect every federal, state or carrier rule, and they may contain errors or fail. Using them does not move any of your responsibility to Closelio. You must have your own compliance program, policies, training and legal review.

We may change, add or remove compliance features over time.

13. Records

You must keep records of consent, revocations and opt-outs, do-not-call requests, and the calls and texts you send, for at least {{TODO: years, e.g. 5}} years, or longer if the law or a pending claim requires it. Do not rely on the Service as your only copy. Export your records before your account ends.

We may keep platform logs of messages, calls, consent records and opt-outs as described in our Privacy Policy and Data Processing Addendum, including to respond to complaints, carrier inquiries, legal claims and regulatory requests.

14. Complaints, claims and inquiries

You must notify us at legal@closelio.ai within {{TODO: days}} days after you receive any complaint, demand letter, lawsuit, arbitration, carrier notice, or regulatory or law enforcement inquiry that relates to communications sent or made through the Service. Your notice should include a copy of what you received and the related Contact, phone numbers and dates.

You must cooperate with us in good faith. That includes promptly providing consent records and other information we reasonably request so that we can respond to carriers, regulators and anyone who makes a claim against us.

If we receive a complaint, subpoena, carrier notice or other inquiry about your communications, we may respond to it, and we may share relevant information about your account and communications with the person making it to the extent we believe is reasonably required, consistent with our Privacy Policy and the law.

15. Our rights

To protect Contacts, carriers, other customers and the Service, we may, with or without prior notice, take any of these steps:

• throttle, pause or block messages or calls from your account, numbers or campaigns;
• suspend features such as the Power Dialer, automated sequences or AI voice agents;
• suspend or terminate your account under the Terms.

We may take these steps if we receive complaints about your communications, receive a carrier notice or regulatory inquiry, see high opt-out, complaint, block or failure rates, have reason to believe you lack required consent or are violating this Addendum or the law, or if a carrier or telephony provider requires it. We have no obligation to monitor your communications, and our decision not to act is not approval of your practices.

16. Indemnity

Your obligation to defend and indemnify Closelio under the Terms of Service includes claims, fines, penalties, carrier fees and costs arising from communications sent or made through your account, your breach of this Addendum, or your violation of any communications, telemarketing, privacy or insurance law.

17. Changes

We may update this Addendum as laws, carrier rules and the Service change. If we make a material change, we will notify you by email, in the app, or both, and continued use of the Service will require you to accept the updated Addendum in the app.

Questions about this Addendum can be sent to legal@closelio.ai.