Acceptable Use Policy

This Acceptable Use Policy ("AUP") is incorporated into and is part of the Terms of Service. Capitalized terms have the meanings given in the Terms of Service. Squawker may update this AUP from time to time per the change procedure in the Terms.

Squawker provides an AI voice agent platform that places and receives phone calls, SMS, WhatsApp messages, and web chats. Because the Service operates in regulated communications infrastructure, Customer's use of the Service must comply with all applicable communications, consumer protection, and privacy laws. This AUP describes what is prohibited and what Squawker may do if a violation occurs.

Customer is solely responsible for ensuring that its use of the Service complies with all applicable law, including but not limited to:

• The Telephone Consumer Protection Act (TCPA, 47 U.S.C. § 227) and the FCC's implementing rules, including the February 8, 2024 declaratory ruling treating AI-generated voice as "artificial or prerecorded voice" subject to TCPA consent requirements
• The Telemarketing Sales Rule (16 C.F.R. § 310)
• The CAN-SPAM Act for SMS and email
• The National Do Not Call Registry rules
• State recording-consent laws, including the all-party-consent jurisdictions: California (CIPA), Connecticut, Delaware, Florida, Illinois, Maryland, Massachusetts, Michigan, Montana, Nevada, New Hampshire, Pennsylvania, and Washington
• Illinois Biometric Information Privacy Act (BIPA, 740 ILCS 14/) where voice recordings or voiceprints fall within its scope
• California Consumer Privacy Act and California Privacy Rights Act
• Fair Debt Collection Practices Act (FDCPA) for debt-collection use cases
• The Health Insurance Portability and Accountability Act (HIPAA), where Customer is a covered entity or business associate (the Service is not HIPAA-compliant by default; HIPAA-covered uses require a Business Associate Agreement and specific configuration)
• All applicable consumer protection, advertising, and unfair-trade-practices laws

If Customer is uncertain whether a planned use complies with applicable law, Customer must obtain qualified legal advice before using the Service.

Customer will not, and will not allow any End-User to, use the Service to:

3.1 Unauthorized communications

• Initiate calls, SMS, or WhatsApp messages without obtaining all consents required by law
• Initiate marketing calls or SMS to any number on the National Do Not Call Registry without applicable exemption
• Initiate calls to numbers Customer should reasonably know are reassigned or no longer belong to the consenting party
• Engage in robocalling, war-dialing, or sequential dialing in violation of TCPA
• Make calls before 8 a.m. or after 9 p.m. in the called party's time zone except as permitted by law
• Record calls in any state requiring all-party consent without enabling Polly's compliant disclosure
• Use the Service to call emergency services or to interfere with emergency calls

3.2 Impersonation, fraud, and deception

• Configure Polly to claim to be a human or to impersonate a specific named person, real or fictional, in a misleading way
• Use the Service to commit fraud, including phishing, vishing, smishing, or imposter schemes
• Misrepresent the identity, affiliation, or authority of the calling party
• Use Polly's voice synthesis to deceive a called party about who they are speaking with

3.3 Abuse, harassment, and harmful content

• Use the Service to harass, threaten, intimidate, or defame any person
• Use the Service to send or solicit content that is obscene, sexually explicit involving minors, or unlawfully harmful
• Use the Service to coordinate or facilitate violence, self-harm, or illegal acts
• Use the Service to discriminate on the basis of any protected class

3.4 Security and integrity

• Probe, scan, or test the vulnerability of the Service except through Squawker's responsible disclosure process
• Attempt to gain unauthorized access to the Service, other customers' data, or Squawker's infrastructure
• Interfere with or disrupt the Service, including by overloading, flooding, mailbombing, or crashing
• Send or knowingly receive malicious code, viruses, or scripts
• Conduct adversarial attacks on AI components, including prompt injection, jailbreaking, or attempts to bypass safety controls

3.5 Intellectual property and privacy

• Use the Service to infringe any third party's intellectual property, publicity, or privacy rights
• Use the Service to collect, harvest, or process personal information without the legal basis to do so
• Train or fine-tune any AI model using Service outputs in a way that competes with the Service

3.6 Commercial misuse

• Resell, sublicense, or provide the Service to third parties without Squawker's prior written authorization (white-label arrangements are governed by separate agreement)
• Use the Service in a manner that violates Squawker's published pricing or billing terms, including fraudulent generation of records to manipulate pricing exclusions

When operating in any jurisdiction requiring all-party consent for call recording, Customer must:

• Enable Polly's recording disclosure script (substantially similar to: "This call is being recorded and transcribed for training and monitoring purposes.") at the start of each call
• Verify that the disclosure is delivered before substantive conversation
• Maintain auditable records of consent capture per call
• Configure Polly's response when an End-Caller refuses consent (typically: transfer to a non-recorded line, or end the call)

Squawker provides the technical mechanisms for compliance; Customer is responsible for ensuring the mechanisms are enabled and consent is properly captured for Customer's jurisdictions.

Customer will ensure that the Service is used in a manner that complies with applicable AI-disclosure laws. The default Polly disclosure identifies Polly as an AI assistant. Customer will not modify Polly's configuration to claim that Polly is human.

Where applicable law requires additional disclosures (for example, certain pending state laws on AI consumer interactions), Customer is responsible for configuring the Service to satisfy those requirements.

Customer is the controller (under GDPR) and the business (under CCPA) of personal information of End-Callers. Customer represents that it has the legal basis and consent (where required) to process End-Caller data through the Service.

Customer must honor End-Caller requests to access, correct, delete, restrict, or object to processing of their personal information, and will use the Service's tools to fulfill these requests in a timely manner.

Reporting abuse: To report a violation of this AUP — by Customer, by an End-User, or by an End-Caller affected by a Customer's use of the Service — email legal@squawker.ai.

Investigation: Squawker may investigate suspected AUP violations. Customer agrees to cooperate with reasonable investigations.

Remedies: If Squawker determines that Customer has violated this AUP, Squawker may, at its discretion:

• Notify Customer of the violation and require correction
• Suspend or limit access to specific features
• Suspend Customer's account
• Terminate Customer's account for material violation per the Terms of Service
• Cooperate with law enforcement and regulatory authorities

For violations that present immediate harm — including suspected TCPA violations, fraud, security threats, or violations creating regulatory exposure to Squawker — Squawker may suspend immediately and without prior notice.

Customer indemnifies Squawker against any claims, damages, fines, penalties, or expenses arising from Customer's violation of this AUP, per the indemnification provisions in the Terms of Service.

Squawker may update this AUP from time to time. Material changes will be communicated to Customer per the change procedure in the Terms of Service.

To report AUP violations: legal@squawker.ai For questions about this AUP: legal@squawker.ai