TCPA Compliance Policy

This policy applies to all voice calls and SMS messages placed using the Dorazo platform, including:

• AI-answered inbound calls placed by callers to a Customer's business number (caller-initiated)
• Return calls and message notifications sent at a Customer's direction
• SMS message notifications delivered to a Customer's staff
• After-hours AI call answering for a Customer's business line

This policy covers calls placed within the United States. International calling requirements vary by jurisdiction and are the Customer's sole responsibility.

The TCPA (47 U.S.C. § 227) restricts autodialed calls, pre-recorded voice messages, and text messages to wireless phone numbers without prior express consent. Key requirements include:

• Prior express written consent is required before placing autodialed or pre-recorded calls to wireless numbers, even for B2B calls
• Calls to residential landlines for non-commercial purposes require prior express consent
• The FCC's 2024 and 2025 rulings extend TCPA requirements to AI-generated voice calls — all AI voice calls to wireless numbers require prior express written consent, regardless of B2B status
• Violations carry statutory damages of $500–$1,500 per call and can result in class action exposure

Dorazo is an inbound call answering service. Dorazo does not place AI-generated outbound marketing or telemarketing calls, and does not place AI-generated marketing SMS.

• Inbound only: The AI receptionist speaks only with callers who have themselves dialed a Customer's business number. The caller initiates every conversation.
• AI identification: The AI receptionist identifies itself as an AI when asked, and never claims to be human.
• Callbacks: Where a Customer configures a return call, that call is placed by or on behalf of the Customer, and the Customer is responsible for having a lawful basis to call that number.

Where a Customer uses Dorazo to send message notifications or to return a caller's call, the Customer is the party responsible for TCPA compliance with respect to those communications. Dorazo provides the technology; the Customer controls who is contacted and why.

• Obtain prior express written consent before sending any autodialed or pre-recorded call or text to a wireless number. This consent must be documented and retained.
• Maintain a do-not-call list for any recipients who opt out, and configure the platform to exclude those numbers.
• Scrub against the National DNC Registry for any consumer-facing outbound calls.
• Limit calling hours to 8:00 AM – 9:00 PM in the recipient's local time.
• Provide call-recording notice where required. Several states require all-party consent to record a call.

The Customer indemnifies Dorazo against all claims, fines, and penalties arising from the Customer's failure to comply with TCPA or any other applicable telemarketing or call-recording law in connection with communications sent using the Dorazo platform.

Customers are strongly advised to document consent as follows:

• Employment agreements: Include a clause in staff employment agreements authorizing automated calls and SMS to the employee's work phone number in the course of their employment duties.
• Written consent forms: For contractors and customers, obtain a signed consent form stating that they consent to receive automated calls and texts at the provided number.
• Digital opt-in: On any intake or booking form, include a clearly worded consent checkbox: “I consent to receive automated calls and text messages from [Business Name] at this number. Message and data rates may apply. Reply STOP to opt out.”
• Record retention: Retain consent records for at least 5 years or as required by applicable law.

These are recommended practices, not legal advice. Consult a TCPA attorney to design a consent program appropriate to your specific situation.

SMS messages sent through the Dorazo platform comply with the following requirements:

• Every initial SMS to a new number includes identification of the sender and the nature of the messages
• Every SMS campaign includes opt-out instructions (e.g., “Reply STOP to unsubscribe”)
• STOP replies are processed automatically and the number is removed from SMS sends within one business day
• HELP replies receive a response with contact information
• SMS is sent only during permitted hours (8:00 AM – 9:00 PM recipient local time)
• Dorazo maintains all required Twilio A2P 10DLC registrations for its messaging campaigns

To submit a do-not-call request for any Dorazo-originated communication:

• During a call: Say “do not call,” “remove me,” or “stop calling” at any time
• By SMS: Reply STOP to any Dorazo SMS
• By email: Send your phone number and name to hello@dorazoai.com with subject line “Do Not Call Request”

Dorazo will process DNC requests within one business day and will not contact the number for sales purposes thereafter.

For calls placed on behalf of a Customer business, the Customer is responsible for honoring DNC requests. Contact that business directly, or contact Dorazo at the email above and we will forward the request to the relevant Customer.

Dorazo maintains records of all outbound calls and SMS messages, including timestamp, phone number called, AI script used, call duration, and opt-out events. These records are retained for a minimum of 5 years.

Customers should maintain their own consent records. Dorazo can provide call logs for Customer accounts upon request to support compliance documentation.