Torklio legal.

Privacy Policy

Last updated: [DATE]. Effective: [DATE].

Plain-English summary

• Torklio is an AI receptionist that businesses use to answer their calls and chats. If you called or messaged a business that uses Torklio, that business decides why your information is collected; Torklio processes it on the business's behalf.
• We collect what's needed to answer and route calls, take messages, and book appointments — your phone number, what you say, and details you give (like your name or the reason for your call). Calls may be recorded and transcribed if the business turns that on.
• To work, Torklio sends call audio and text to a small number of trusted technology providers (telephony, speech, and AI models). We don't sell your information, and we don't use it to train our own AI.
• We keep information only as long as the business needs it, then delete it on a schedule.
• You can ask the business — or us — to access or delete your information.

1. Who we are and who this policy covers

[Torklio, LLC] ("Torklio," "we") provides an AI phone and chat receptionist service (the "Service") to businesses ("Customers"). This Privacy Policy explains how we handle personal information about:

• Callers and contacts — people who call, text, chat with, or are scheduled by a Customer's Torklio receptionist ("Callers"). For Caller information, the Customer is the controller / business (it decides the purposes) and Torklio is a processor / service provider acting on the Customer's instructions under our Terms of Service and Data Processing Addendum. The Customer's own privacy notice also applies to you.
• Customer users — business owners and staff who use the Torklio dashboard ("Users"). For User account information, Torklio is the controller.
• Website visitors — people who visit torklio.com.

If you are a Caller and have questions about how a specific business uses your information, contact that business first; we will also help you as described in Section 9.

2. Information we collect

2.1 From Callers (processed on behalf of the Customer)

• Identifiers: phone number, caller ID name, email address if you provide it, and a name if you give one.
• Call and chat content: what you say or type to the receptionist, including the reason for your call, appointment preferences, and any details you choose to share. Call audio and chat text are processed to generate responses.
• Recordings and transcripts: if the Customer enables recording, the audio of your call and a written transcript. The receptionist plays a recorded-line notice when the Customer enables it.
• Appointment and message records: appointments booked, messages taken, callbacks requested, and the business's notes about the interaction.
• Technical data: call metadata (time, duration, numbers), and for web chat, a session identifier, IP address, and browser type.
• Sensitive information: We do not intend to collect sensitive information (such as health, financial account, government ID, or precise location data). Customers are instructed not to configure the receptionist to request it. If you volunteer such information in a call, it may be captured in a recording or transcript; you can ask the business to delete it.

2.2 From Customer Users

• Account details (name, business name, email, password hash, role), login and security events, settings and configuration, knowledge-base content you add (services, FAQs, documents, website imports), calendar connection tokens you authorize, billing details (handled by our payment processor — we do not store full card numbers), support requests, and dashboard usage logs.

2.3 From website visitors

• Standard server logs (IP address, browser, pages viewed, timestamps). We do not use advertising trackers. [Confirm: analytics tool, if any.]

2.4 Cookies and similar technologies

• Dashboard: a session cookie to keep you signed in and a security (CSRF) cookie. No advertising cookies.
• Chat widget on Customer websites: a session identifier (stored in your browser) so a conversation can continue across page loads. The Customer's website may use its own cookies under its own policy.
• Voice test page: temporary tokens to connect a browser voice session. None of these are used for cross-site tracking.

3. How we use information

We use information to:

• Operate the Service — answer and route calls and chats, understand speech, generate responses, take messages, book and manage appointments, check calendar availability, send confirmations and reminders, and transfer calls to the people the Customer designates.
• Provide recordings, transcripts, summaries, and records to the Customer.
• Secure and maintain the Service — authenticate users, detect abuse, fraud, prompt-injection attempts, and toll fraud, rate-limit, debug, and keep audit logs.
• Support Customers — respond to support requests; with the Customer's authorization, a Torklio support person may temporarily access a Customer's dashboard (these sessions are logged and attributed).
• Improve the Service — using de-identified, aggregated statistics (for example, average call length). We do not use Caller or Customer content to train Torklio's own AI models, and we configure our AI providers not to use it for training where they offer that option. [Verify per provider — see Section 6.]
• Bill and communicate — process payments, send transactional emails (verification, invites, receipts, alerts), and service notices. We do not send Callers marketing on Torklio's behalf.
• Comply with law — respond to lawful requests, enforce our Terms, and protect rights and safety.

We process Caller information only on the Customer's documented instructions (its configuration and our Terms/DPA), plus as required by law.

4. AI processing and call recording — what actually happens

Because transparency about automated systems matters, here is the actual data flow for a phone call:

1. Your call reaches the Customer's Torklio number via our telephony provider.
2. Call audio is streamed in real time to a speech-and-language AI provider that transcribes it and generates the receptionist's responses; the response text is converted to speech by a text-to-speech provider. These providers process the data under contracts that restrict use to providing the service.
3. Torklio stores the transcript (and the recording, if enabled) in the Customer's isolated account, along with any appointment or message created.
4. After the call, an AI model may summarize the conversation, identify questions the receptionist couldn't answer, and score the lead — for the Customer's use only.

Automated decisions. The receptionist makes operational decisions in real time (for example, which appointment times to offer or when to transfer to a person) according to the Customer's settings. It does not make decisions with legal or similarly significant effects about you; a human at the business reviews and can change any booking or record.

Recording notice. Where the Customer has enabled recording, the receptionist states that the call may be recorded. If you do not wish to be recorded, you may end the call or ask to be contacted another way. Laws on recording vary by state; compliance with them is the Customer's responsibility.

5. How long we keep information

We keep information only as long as needed for the purposes above, according to our Data Retention Policy and the Customer's settings. Current defaults:

When a Customer closes its account, its data is available for export for [30] days and then deleted, except as law requires or in backups until they roll off.

6. Who we share information with

We do not sell personal information and do not share it for cross-context behavioral advertising. We share information only:

• With the Customer whose receptionist you interacted with — that is the purpose of the Service.
• With service providers ("subprocessors") that process data on our behalf under contracts that limit use to our instructions. Our current subprocessors, kept up to date at torklio.com/subprocessors, include providers of: telephony and SMS (Twilio); real-time speech and language models (OpenAI); text AI for chat, summaries, and lead scoring (Anthropic); text-to-speech (ElevenLabs); transactional email (Resend); calendar and sign-in integrations the Customer chooses to connect (Google, Microsoft); hosting and encrypted backups (DigitalOcean); and, when billing launches, payment processing (Stripe — card data goes directly to Stripe). [Ops: confirm each provider's retention and "no training" settings and keep the list current.]
• With people the Customer designates — for example, when the receptionist transfers your call or sends a message to a staff member.
• For legal reasons — to comply with law, subpoenas, or lawful requests; to enforce our Terms; to protect the rights, safety, or property of Torklio, our Customers, Callers, or the public.
• In a business transfer — if Torklio is involved in a merger, acquisition, financing, or sale of assets, information may be transferred subject to this policy.

7. Security

Each Customer's data is kept in an isolated environment separate from other Customers. Data is encrypted in transit. Administrative access requires multi-factor authentication and is logged. Secrets are protected and access-restricted. Public-facing endpoints are rate-limited and guarded against abuse. Backups are encrypted and stored off-site. We test and review our security regularly. No system is perfectly secure; if we confirm a breach affecting your information, we will notify affected Customers (and, where required, individuals and regulators) without undue delay.

8. Your choices

• Recording: Tell the business if you don't want to be recorded, or end the call.
• Texts: Reply STOP to any text from a Customer's Torklio number to stop receiving texts from that number; reply HELP for help. Message and data rates may apply.
• Marketing from Torklio (Users only): unsubscribe links in our emails; transactional messages will still be sent.
• Calendar and sign-in connections (Users): disconnect at any time from the dashboard; we delete the associated access tokens.
• Account deletion (Users): close your account from the dashboard or by contacting us.

9. Your privacy rights

Depending on where you live (for example, California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states, or the EU/UK), you may have rights to access, correct, delete, or obtain a copy of your personal information, to opt out of certain processing, and to not be discriminated against for exercising rights.

• Callers: because the Customer controls your information, please direct requests to the business you contacted; we will support the business in fulfilling them. If you contact us directly at [privacy@torklio.com], we will forward your request to the relevant Customer and assist as permitted.
• Users and website visitors: contact us at [privacy@torklio.com]. We will verify your identity (for example, via your account email) and respond within the time the law requires. You may authorize an agent to act for you.
• Appeals: if we decline a request, you may appeal by replying to our decision; we will respond within the legally required period.

California notice (CCPA/CPRA). We act as a service provider to our Customers for Caller information. We do not sell or "share" personal information. In the past 12 months we have collected the categories described in Section 2 for the purposes in Section 3 and disclosed them to the service providers in Section 6. [Counsel: confirm whether Torklio independently meets CCPA business thresholds and whether a "Notice at Collection" is needed for Users.]

Do Not Track / Global Privacy Control. Because we do not track visitors across sites or sell/share data, these signals do not change our processing; where required we will honor GPC as an opt-out of any applicable sale/sharing.

10. International visitors

Torklio is operated from the United States and our providers primarily process data in the U.S. If you interact with a Customer's receptionist from outside the U.S., your information is transferred to and processed in the U.S. Where the GDPR or UK GDPR applies, we rely on appropriate safeguards such as Standard Contractual Clauses, as described in our DPA. [Decision: will Torklio serve EU/UK customers at launch? If not, state the Service is intended for U.S. businesses.]

11. Children

The Service is for businesses and is not directed to children under 13 (or 16 where applicable). We do not knowingly collect information from children. Customers may not use the Service to operate services directed at children. If you believe a child's information was collected, contact us and we will delete it.

12. Changes to this policy

We may update this policy. We will post the new version with a new "Last updated" date and, for material changes affecting Users, notify them by email or in the dashboard. Customers are responsible for updating their own Caller-facing notices.

13. Contact

[Torklio, LLC] — [Street address, City, AR ZIP]

Privacy: [privacy@torklio.com] · Security: [security@torklio.com] · Support: [support@torklio.com]

Attorney review notes (remove before publishing)

1. Confirm entity, addresses, and whether Torklio meets CCPA "business" thresholds on its own.
2. Verify the "no training" statement against each provider's current API terms (OpenAI, Anthropic, ElevenLabs, Twilio) and the settings actually in use.
3. Confirm retention numbers match compliance.RETENTION_DEFAULTS and the backup rotation; fill the backup roll-off period.
4. Decide EU/UK posture (Section 10) and whether to add a GDPR-style "legal bases" table.
5. Consider a short Caller Notice template Customers can post ("This business uses an AI receptionist…").
6. Update SUBPROCESSORS.md: Microsoft (Outlook/365 calendar) is now enabled.

Terms of Service

Last updated: [DATE]. Effective: [DATE].

Plain-English summary (not a substitute for the Terms below)

• Torklio is an AI receptionist for businesses. It answers calls and chats, captures details, and can book appointments based on what you set up. It is software — not an employee, and not a substitute for you.
• It is not for emergencies. Torklio cannot call 911 or provide emergency help. Tell your customers to call 911 in an emergency.
• You are responsible for how you use it with your callers — including telling callers when they're talking to an AI where the law requires it, getting consent to record where required, and following texting laws. We give you the switches; you decide how to use them lawfully.
• AI can make mistakes. Torklio may misunderstand, mis-state, or mis-book. Review what it does. Don't rely on it for legal, medical, or financial advice.
• You own your data. We use it only to run the service for you. We don't sell it.
• Don't abuse it — no spam, robocalls, fraud, harassment, or trying to break the system. We can suspend accounts that do.
• Our liability is limited, and disputes go to individual arbitration (you can opt out within 30 days).

1. Agreement and who these Terms cover

1.1 These Terms of Service (the "Terms") are a binding agreement between [Torklio, LLC — confirm legal entity name and state] ("Torklio," "we," "us") and the business or organization that creates an account or uses the Service ("Customer," "you"). The person accepting these Terms represents that they have authority to bind the Customer.

1.2 The Service is offered to businesses only, for use in their commercial operations. You must be at least 18 and able to form a binding contract. The Service is not directed to consumers or children, and you may not use it to operate a service directed at children under 13.

1.3 These Terms incorporate the following documents, each as posted at torklio.com/legal and updated from time to time: the Acceptable Use Policy (summarized in Section 6; the standalone Acceptable Use Policy controls if more detailed), the AI & Communications Disclosure, the SMS / Messaging Terms, the Privacy Policy, the Data Processing Addendum (where applicable), and the Subprocessor List. If you sign a separate written agreement with Torklio, that agreement controls over any conflict with these Terms.

1.4 By creating an account, clicking "I agree," or using the Service, you accept these Terms. If you don't agree, don't use the Service.

2. The Service

2.1 What it is. Torklio provides a hosted, AI-powered receptionist (the "Service," and the AI persona, by whatever name you give it, the "Receptionist") that can answer phone calls and website chats, converse with callers, capture caller information, answer questions based on information you provide, schedule appointments according to rules you set, take messages, and route or transfer calls to people you designate. It also provides a dashboard, a knowledge base, calendar integrations, optional text messaging, call recordings and transcripts, and related features.

2.2 What it is not. The Receptionist is an automated software system. It is not a human, an employee, an agent with authority to bind you beyond the settings you configure, or a licensed professional of any kind. It does not provide legal, medical, financial, insurance, or other professional advice, and nothing it says should be treated as such.

2.3 NO EMERGENCY SERVICES. THE SERVICE DOES NOT SUPPORT EMERGENCY CALLS OR EMERGENCY RESPONSE. IT CANNOT PLACE OR ROUTE 911/E911 CALLS, CANNOT CONTACT EMERGENCY SERVICES, AND IS NOT MONITORED BY HUMANS IN REAL TIME. YOU MUST NOT USE, MARKET, OR CONFIGURE THE SERVICE AS A MEANS OF OBTAINING EMERGENCY HELP, AND YOU MUST MAKE THIS CLEAR TO YOUR CALLERS WHERE APPROPRIATE. [Counsel: confirm FCC/Kari's Law/RAY BAUM's applicability given the Service does not provide outbound 911 calling for end users.]

2.4 Changes. We may add, change, or remove features. We'll give reasonable notice of material reductions to paid features. Features labeled beta, preview, or early access (Section 10) may change or end at any time.

3. Accounts, users, and security

3.1 You must provide accurate account information and keep it current. You're responsible for everyone who uses the Service through your account ("Authorized Users"), for keeping credentials confidential, and for all activity under your account. Tell us immediately at [security@torklio.com] if you suspect unauthorized access.

3.2 Seats, roles, and usage allowances are as described in your plan. You may not share logins or circumvent seat or usage limits.

3.3 We may require email verification, multi-factor authentication, and other security measures. We may suspend access we reasonably believe is compromised.

4. Your responsibilities with callers (recording, AI disclosure, consent, texting)

This Section is the heart of the agreement. Laws about recording calls, disclosing AI, and sending texts vary by state and country and change often. Torklio gives you controls; you are responsible for using them lawfully.

4.1 You control the configuration. You decide the Receptionist's name, greeting, personality, knowledge, permissions (for example whether it may quote prices, book, cancel, or transfer), business hours, and whether calls are recorded and whether the Receptionist identifies itself as an AI. Torklio provides these settings and default wording; you are responsible for reviewing them and for what the Receptionist says and does as a result of your configuration and knowledge content.

4.2 Call recording, transcription, and chat logging. Recording and transcription are features you can turn on or off. Many jurisdictions (including "two-party" / "all-party" consent states such as California, Florida, Illinois, Maryland, Massachusetts, Michigan, Montana, Nevada, New Hampshire, Pennsylvania, and Washington, among others) require the consent of all parties before a call is recorded. You are solely responsible for determining whether and how you may lawfully record calls with your callers, for enabling the recorded-line notice where required, for the wording of any notice, and for honoring a caller's refusal. Torklio's default notice language is provided for convenience only and is not a representation that it satisfies any law. Website chat and browser voice sessions are logged and transcribed by design so that you have a record of the conversation; some jurisdictions treat the interception or recording of chat sessions like call recording (for example under state wiretap laws such as the California Invasion of Privacy Act). You are responsible for disclosing to your website visitors, in your own privacy notice or near the chat widget, that chat conversations are recorded and processed by a service provider on your behalf.

4.3 AI disclosure. Some jurisdictions require that people be told when they are interacting with an automated or AI system (for example under California's bot-disclosure law, Utah's and Colorado's AI laws, and others that may apply to you). You are responsible for determining whether AI disclosure is required for your callers and for enabling and wording the Receptionist's AI introduction accordingly. The "introduce as an AI" setting is on by default; if you turn it off, you do so at your own risk.

4.4 Text messaging (SMS) and outbound communications. If you enable any texting or outbound feature (including missed-call text-back, confirmations, reminders, or verification codes), you are the sender of those messages and calls. Note that under FCC rulings, calls using an AI-generated or artificial voice are treated as "artificial or prerecorded voice" calls under the TCPA and generally require prior express consent. You must (a) obtain and document any consent required by the Telephone Consumer Protection Act (TCPA), the CAN-SPAM Act, state mini-TCPA laws, and carrier rules before messaging any person; (b) honor opt-outs (STOP) immediately and not message anyone who has opted out; (c) not send messages the law or carriers prohibit; and (d) complete any carrier registration (such as A2P 10DLC) we require. Torklio may block, throttle, or disable messaging at any time to comply with law or carrier requirements or to protect the platform.

4.5 Caller privacy. You are responsible for your own privacy notices to callers, for complying with privacy laws that apply to your business (which may include state consumer privacy laws, HIPAA, GLBA, FCRA, COPPA, and others), and for not collecting or instructing the Receptionist to collect information you are not permitted to collect. Do not configure the Receptionist to solicit payment card numbers, Social Security numbers, government IDs, passwords, or full health records over the phone.

4.6 Regulated and high-risk uses. If you are in a regulated field (healthcare, legal, financial services, insurance, real estate, debt collection, and similar), you are solely responsible for compliance with the rules of that field, including any restrictions on what an automated system may say or collect. Torklio is not a HIPAA Business Associate unless we have signed a Business Associate Agreement with you in writing. [Decision: will Torklio offer a BAA? If not, state that the Service is not intended for PHI.]

4.7 Accuracy of your information. The Receptionist answers from the information you give it (your knowledge base, website imports, documents, services, hours, pricing). You are responsible for keeping that information accurate, lawful, and current, and for the consequences of inaccurate or misleading information you provide.

4.8 Your commitments to callers are yours. Appointments, quotes, prices, promises, and other statements the Receptionist makes on your behalf, within the permissions you set, are your commitments to your callers, not Torklio's. Torklio is not a party to any transaction between you and your callers.

4.9 Biometric information. The Service processes call audio to transcribe and respond to speech. The Service is not designed to create, collect, or use voiceprints or other biometric identifiers to identify individual callers, and you may not configure or use it to do so. Some states (for example Illinois under the Biometric Information Privacy Act, Texas, and Washington) regulate the collection of biometric identifiers, including voiceprints, and provide private rights of action. If any law treats audio processing you enable as the collection of biometric information from your callers, you are responsible for providing any required notice and obtaining any required consent from them. [Counsel/ops: confirm with each speech vendor, in writing, that no speaker-identification voiceprints are created or retained from Customer call audio, and reflect the answer here and in the Privacy Policy.]

5. AI limitations — no reliance

5.1 The Receptionist uses large language models and speech technology from third-party providers. AI systems can be wrong. The Receptionist may misunderstand speech, mis-state facts, misapply your rules, book or cancel incorrectly, fail to capture details, respond slowly or not at all, or produce content that is inaccurate, incomplete, or inappropriate. Torklio designs the Service to reduce these risks (for example, it is instructed not to invent prices or dates and to decline questions outside your information), but we cannot guarantee accuracy, completeness, or suitability of any output.

5.2 You must review. You are responsible for reviewing appointments, messages, leads, and other outputs, and for correcting errors with your customers. Do not rely on the Receptionist for any decision that could cause injury, financial loss, legal exposure, or other significant harm without human review.

5.3 Safety filtering is not perfect. The Service includes safeguards against misuse, prompt injection, and disclosure of confidential instructions, but no safeguard is perfect. Callers may say things to the Receptionist that are offensive, misleading, or manipulative; Torklio is not responsible for caller conduct.

5.4 No professional advice. Outputs are not legal, medical, financial, tax, insurance, engineering, or other professional advice, and you may not hold them out as such.

6. Acceptable Use Policy

You and your Authorized Users may not, and may not permit or configure the Receptionist to:

Illegal and harmful use

• (a) violate any law, regulation, court order, or third-party right, or facilitate anyone else's violation;
• (b) use the Service for emergency or life-safety purposes (see Section 2.3);
• (c) engage in fraud, deception, phishing, "vishing," social engineering, or impersonation of any person, business, government agency, or emergency service;
• (d) harass, threaten, abuse, defame, or discriminate against any person, or collect information for stalking or harassment;
• (e) use the Service in connection with illegal gambling, controlled substances where unlawful, weapons trafficking, sexual services, or content that is sexually explicit, exploits children, or promotes violence or hatred;

Telephony and messaging abuse

• (f) place or cause robocalls, autodialed or prerecorded calls, or mass/unsolicited calls or texts, or any call or message that violates the TCPA, the Telemarketing Sales Rule, Do-Not-Call rules, CAN-SPAM, or carrier rules;
• (g) spoof or falsify caller ID or sender information;
• (h) engage in or facilitate toll fraud, traffic pumping, international revenue share fraud, or calling/transferring to premium-rate, high-cost, or sanctioned destinations;
• (i) use numbers obtained through the Service for any purpose other than operating your own business's inbound communications, or resell, sublicense, or "rent" numbers or the Service;

Platform integrity

• (j) reverse engineer, decompile, scrape, crawl, probe, or attempt to extract the Service's source code, prompts, system instructions, models, or security mechanisms, or attempt to make the Receptionist reveal them;
• (k) interfere with or disrupt the Service or other customers (including excessive automated requests, load testing without written permission, or attempting to access another customer's account or data);
• (l) circumvent usage limits, seat limits, rate limits, billing, or security controls, or use automated means to create accounts;
• (m) introduce malware or harmful code, or use the Service to develop a competing product or to train AI models;
• (n) upload or import content you do not have the right to use, or content containing others' confidential information, payment card data, government IDs, or credentials;

Misrepresentation

• (o) represent that the Receptionist is a human when a reasonable caller would be misled, or disable AI disclosure where it is legally required;
• (p) use Torklio's name, marks, or the Receptionist to imply Torklio's endorsement, or to make statements on Torklio's behalf.

Fair use. Plans include usage allowances (such as call minutes, messages, numbers, and AI processing). Usage materially beyond normal business use for a plan, or patterns consistent with abuse (for example, sustained very long calls, repeated identical calls, or call volumes inconsistent with the stated business), may be throttled, billed as overage, or require a plan change.

Enforcement. We may monitor the Service for abuse, investigate suspected violations, remove content, throttle, suspend, or terminate accounts, and cooperate with carriers and law enforcement. Where practical we will notify you and give you a chance to cure, but we may act immediately to protect callers, other customers, carriers, our providers, or the platform, or where required by law.

7. Telephone numbers and telephony

7.1 Phone numbers we provision for you are licensed, not sold. You do not own them. You may not transfer, sell, or assign them except by porting as permitted by law and Section 7.4. Additional numbers are subject to plan entitlements and fees.

7.2 We may change or reclaim a number if required by a carrier, regulator, or law, if your account is suspended or terminated, or if the number is unused for an extended period; we will give notice where reasonably possible.

7.3 Using your own existing number by forwarding calls to the Service is your responsibility to configure with your carrier; Torklio is not responsible for forwarding failures or your carrier's charges.

7.4 Porting. Subject to carrier rules and any outstanding balance, you may port a number we provisioned for you to another provider, or port a number to Torklio, using the processes we make available. Number porting is handled by carriers and may take time; we do not control carrier timelines.

7.5 Carriers and networks. The Service depends on telecommunications carriers, networks, and third-party providers that we do not control. We are not responsible for their outages, call quality, delays, blocked or labeled calls ("spam likely"), or changes to their rules. Carriers may label or block calls or messages based on their own criteria.

7.6 Emergency calling. See Section 2.3. Numbers provisioned through the Service are for receiving and routing your business communications and are not provisioned for emergency (911) calling by you or anyone else.

8. Your data; our use of it

8.1 You own your data. As between you and Torklio, you own all information you provide and all information the Service captures for you — caller details, recordings, transcripts, messages, appointments, knowledge content, and settings ("Customer Data"). You grant Torklio a non-exclusive, worldwide license to host, process, transmit, display, and otherwise use Customer Data solely to provide, maintain, secure, support, and improve the Service for you, to comply with law, and as otherwise permitted by the Privacy Policy and DPA.

8.2 Third-party AI and telephony providers. To provide the Service, Customer Data (including call audio, transcripts, and knowledge content) is processed by our subprocessors — currently including providers of telephony, speech-to-text, text-to-speech, large language models, calendar integrations, email, and hosting, as listed at torklio.com/subprocessors. Torklio does not use Customer Data to train Torklio's own models, and we configure providers not to use your data to train their models where the provider offers that option. [Counsel/ops: confirm each provider's current data-use terms and reflect accurately.]

8.3 Retention and deletion. Recordings, transcripts, and other Customer Data are retained according to your settings and our Data Retention Policy. You can delete recordings and customer records from the dashboard or by request. After termination, we will make Customer Data available for export for [30] days, after which we may delete it, except as required by law or kept in routine backups for a limited period.

8.4 Security. We maintain administrative, technical, and physical safeguards designed to protect Customer Data, as described in our security documentation. No system is perfectly secure. We will notify you without undue delay of a confirmed security incident affecting your Customer Data, as required by law and the DPA.

8.5 Your callers. You are the party with the relationship with your callers. You are responsible for your own privacy notice to them and for responding to their rights requests; we will assist you as described in the DPA.

8.6 Aggregated data. We may create and use de-identified, aggregated statistics that do not identify you or any individual (for example, average call duration across customers) to operate and improve the Service.

9. Fees, billing, trials

9.1 Fees. You agree to pay the fees for your plan, any usage-based charges (such as minutes, messages, additional numbers, or AI processing beyond plan allowances), and any add-ons, at the rates shown when you subscribe or as later updated under Section 9.6. Fees are in U.S. dollars and exclude taxes; you are responsible for applicable sales, use, telecommunications, and similar taxes and regulatory fees, which we may collect.

9.2 Billing and auto-renewal. Subscriptions bill in advance on a recurring basis (monthly or annually) and automatically renew for successive periods until canceled. Usage charges bill in arrears. You authorize us and our payment processor to charge your payment method on file. [Confirm billing provider; card data is handled by the processor, not stored by Torklio.]

9.3 Late payment and suspension. If payment fails or is late, we may retry, suspend the Service (including the Receptionist's ability to answer calls), reclaim numbers, and charge interest of the lesser of 1.5% per month or the maximum allowed by law, plus reasonable collection costs. You are responsible for chargebacks you initiate without a good-faith basis.

9.4 Refunds. Except as required by law or expressly stated in an offer, fees are non-refundable, including for partial periods, unused allowances, downgrades, or early termination. We may, at our discretion, provide prorated credits.

9.4a 30-day money-back guarantee (first payment). As an express offer under Section 9.4, your first subscription payment is refundable in full if you request a refund within 30 calendar days after that payment succeeds. An approved refund cancels your subscription, ends paid access, and reclaims any assigned phone number. Later renewal payments are not automatically refundable and are reviewed case by case at our discretion.

9.5 Trials and promotions. Free trials and promotional credits are provided as-is, may be limited, and may be modified or withdrawn. A valid payment method is required to start a trial; you are not charged during the trial, and if you cancel before it ends you owe nothing. Trials are limited to one per business unless we agree otherwise, and we may decline, shorten, or end a trial for abuse (for example, repeated trials through new accounts, or usage inconsistent with evaluating the Service for your own business). Before a trial begins we will disclose the plan price, the trial length, and when billing starts; unless you cancel before the trial ends, the plan you selected begins and bills automatically. You can cancel during the trial from the dashboard at any time, in which case you owe nothing. [Ops: checkout and cancellation flows must satisfy the FTC's Negative Option Rule ("click to cancel") and state auto-renewal laws — clear pre-billing disclosure, express consent, and cancellation as easy as signup.]

9.6 Price changes. We may change fees with at least 30 days' notice (email or in-app). Changes take effect at your next renewal after the notice period. Continued use after that date is acceptance. Exception — price-locked plans. Where we have expressly offered a plan with a locked base price (for example, the Founding Partner plan's commitment that the base subscription price stays at its original amount while the subscription remains continuously active), we will not increase that plan's base subscription price for as long as the subscription remains active and in good standing; the lock ends if the subscription lapses, is terminated for breach, or the Customer changes plans. Usage-based charges, overages, add-ons, and taxes are not part of a base-price lock.

9.7 Usage disputes. Contact us within 30 days of a charge to dispute it; we will review in good faith. Our records are presumed accurate absent clear evidence otherwise.

10. Beta features

Features identified as beta, preview, early access, or similar are provided for evaluation, may be unstable, may be modified or discontinued without notice, and are excluded from any service commitments. Use them at your own discretion.

11. Intellectual property

11.1 Torklio and its licensors own the Service, including software, models and prompts, voices, designs, documentation, and trademarks. These Terms grant you a limited, non-exclusive, non-transferable, revocable right to use the Service during your subscription for your internal business purposes. No other rights are granted.

11.2 Feedback. If you give us feedback or suggestions, we may use them without restriction or compensation.

11.3 Your marks. You grant us a limited license to use your business name and logo within the Service to present the Receptionist to your callers (for example, on your booking page), and, only with your prior written consent, to identify you as a customer.

12. Term, suspension, and termination

12.1 These Terms apply from account creation until your subscription ends and your account is closed.

12.2 Your termination. You may cancel at any time from the dashboard or by written notice; cancellation takes effect at the end of the current billing period (no refund for the remainder, see Section 9.4).

12.3 Our suspension or termination. We may suspend or terminate your access, immediately and without refund, if you (a) materially breach these Terms (including the Acceptable Use Policy) and, where the breach is curable, fail to cure within 10 days of notice; (b) fail to pay; (c) pose a security, legal, reputational, or abuse risk to Torklio, callers, carriers, providers, or other customers; or (d) are subject to a legal or carrier requirement. We may also terminate for convenience with 30 days' notice and a prorated refund of prepaid, unused fees.

12.4 Effect. On termination, your right to use the Service ends, the Receptionist stops answering, numbers may be reclaimed (Section 7.2), and Section 8.3 governs your data. Sections that by their nature should survive (including 4, 5, 6 (enforcement), 8, 9 (amounts owed), 11, 12.4, 13, 14, 15, 16, and 17) survive.

13. Disclaimers

THE SERVICE, THE RECEPTIONIST, AND ALL OUTPUTS ARE PROVIDED "AS IS" AND "AS AVAILABLE." TO THE FULLEST EXTENT PERMITTED BY LAW, TORKLIO AND ITS SUPPLIERS DISCLAIM ALL WARRANTIES, EXPRESS, IMPLIED, OR STATUTORY, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, ACCURACY, AND UNINTERRUPTED OR ERROR-FREE OPERATION. TORKLIO DOES NOT WARRANT THAT THE RECEPTIONIST WILL ANSWER EVERY CALL, UNDERSTAND EVERY CALLER, BOOK CORRECTLY, OR PRODUCE ACCURATE OR APPROPRIATE OUTPUT, THAT CALLS WILL BE RECORDED OR TRANSCRIBED, OR THAT THE SERVICE WILL MEET YOUR LEGAL OR REGULATORY OBLIGATIONS. YOU ASSUME ALL RISK OF USING AI-GENERATED OUTPUT. STATEMENTS ON TORKLIO'S WEBSITE, MARKETING PAGES, COMPARISON PAGES, OR IN SALES CONVERSATIONS DESCRIBE THE SERVICE'S DESIGN AND INTENT AND ARE NOT WARRANTIES OR SERVICE COMMITMENTS UNLESS EXPRESSLY STATED IN THESE TERMS OR A SIGNED AGREEMENT. SOME JURISDICTIONS DO NOT ALLOW CERTAIN DISCLAIMERS, SO SOME MAY NOT APPLY TO YOU.

14. Limitation of liability

14.1 Exclusion of certain damages. TO THE FULLEST EXTENT PERMITTED BY LAW, TORKLIO AND ITS AFFILIATES, SUPPLIERS, AND PROVIDERS WILL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR LOST PROFITS, LOST REVENUE, LOST BUSINESS, LOST CUSTOMERS OR APPOINTMENTS, LOSS OF DATA, OR COST OF SUBSTITUTE SERVICES, ARISING OUT OF OR RELATED TO THE SERVICE OR THESE TERMS, HOWEVER CAUSED AND UNDER ANY THEORY OF LIABILITY, EVEN IF ADVISED OF THE POSSIBILITY.

14.2 Cap. TO THE FULLEST EXTENT PERMITTED BY LAW, TORKLIO'S TOTAL CUMULATIVE LIABILITY ARISING OUT OF OR RELATED TO THE SERVICE OR THESE TERMS WILL NOT EXCEED THE GREATER OF (A) THE FEES YOU PAID TO TORKLIO IN THE TWELVE (12) MONTHS BEFORE THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED U.S. DOLLARS ($100).

14.3 Specific acknowledgments. Without limiting the above, Torklio is not liable for: missed, dropped, misrouted, or unanswered calls; inaccurate, incomplete, or inappropriate AI output; incorrect bookings, cancellations, or quotes; acts or omissions of callers; carrier or provider outages or blocking; your configuration choices; or your failure to comply with recording, AI-disclosure, messaging, privacy, or industry laws.

14.4 Exceptions. These limits do not apply to liability that cannot be limited by law, to a party's gross negligence or willful misconduct, or to your payment obligations or your indemnification obligations.

14.5 Basis of the bargain. The fees reflect this allocation of risk; Torklio would not provide the Service on these terms without it.

15. Indemnification

15.1 By you. You will defend, indemnify, and hold harmless Torklio, its affiliates, and their officers, directors, employees, and agents from and against all claims, demands, investigations, fines, penalties, damages, losses, and expenses (including reasonable attorneys' fees) arising out of or related to: (a) your or your Authorized Users' use of the Service, including the Receptionist's statements or actions made within the configuration and content you provided; (b) Customer Data or other content you provide; (c) your breach of these Terms or the Acceptable Use Policy; (d) your violation of any law, including call-recording, wiretap, AI-disclosure, TCPA/telemarketing, CAN-SPAM, Do-Not-Call, privacy, or consumer-protection laws; (e) your products, services, pricing, commitments, or transactions with your callers; or (f) any claim by your callers, customers, employees, or contractors.

15.2 By Torklio. Torklio will defend you against third-party claims that the Service, as provided by Torklio and used as permitted, infringes a U.S. patent, copyright, or trademark, and pay resulting damages finally awarded or agreed in settlement, provided you promptly notify us, give us control of the defense, and cooperate. This does not apply to claims arising from Customer Data, your configuration, combinations with non-Torklio products, or use after we tell you to stop. If a claim arises, we may modify or replace the affected feature or terminate it with a prorated refund. This Section states Torklio's entire liability for infringement.

15.3 Process. The indemnified party must give prompt notice, allow the indemnifying party to control the defense and settlement (no settlement admitting fault or imposing obligations on the indemnified party without its consent), and cooperate reasonably.

16. Governing law; dispute resolution; arbitration and class-action waiver

16.1 Governing law. These Terms are governed by the laws of the State of Arkansas and applicable U.S. federal law, without regard to conflict-of-law rules. The Federal Arbitration Act governs Section 16.2. [Counsel: confirm interaction with the Arkansas Uniform Arbitration Act (Ark. Code Ann. § 16-108-201 et seq.) and any Arkansas-specific requirements for arbitration clauses in standard-form agreements.]

16.2 Binding individual arbitration. PLEASE READ CAREFULLY. Except as provided in 16.3 and 16.4, any dispute, claim, or controversy arising out of or relating to these Terms or the Service will be resolved by binding, individual arbitration administered by the American Arbitration Association under its Commercial Arbitration Rules, before a single arbitrator, in [VERIFY county — e.g., the Arkansas county of Torklio's principal place of business] County, Arkansas or by video conference. The arbitrator may award any individual relief a court could, and must apply these Terms. Judgment on the award may be entered in any court of competent jurisdiction.

16.3 Class-action and jury waiver. YOU AND TORKLIO AGREE THAT EACH MAY BRING CLAIMS ONLY IN AN INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE, CONSOLIDATED, OR REPRESENTATIVE PROCEEDING, AND BOTH WAIVE ANY RIGHT TO A JURY TRIAL. If this waiver is found unenforceable as to a particular claim, that claim will proceed in court under Section 16.5, and the remainder stays in arbitration.

16.4 Exceptions. Either party may (a) bring an individual action in small-claims court, or (b) seek injunctive or other equitable relief in court to protect intellectual property, confidential information, or the security of the Service. Collection of undisputed fees may be pursued in court.

16.5 Venue if not arbitrated. For matters not subject to arbitration, the state courts located in [VERIFY county] County, Arkansas and the United States District Court for the [VERIFY: Eastern/Western] District of Arkansas have exclusive jurisdiction, and each party consents to personal jurisdiction there.

16.6 30-day opt-out. You may opt out of Section 16.2 and 16.3 by emailing [legal@torklio.com] within 30 days of first accepting these Terms with your business name and a clear statement that you opt out of arbitration. Opting out does not affect any other provision.

16.7 Informal resolution first. Before starting arbitration or litigation, a party must send written notice of the dispute to the other and make a good-faith attempt to resolve it for at least 30 days. Notice to Torklio goes to [legal@torklio.com].

16.8 Limitations period. To the extent permitted by law, any claim must be brought within one (1) year after it arises.

17. General

17.1 Changes to these Terms. We may update these Terms. For material changes we will give at least 14 days' notice by email or in-app (30 days for fee changes, Section 9.6). Continued use after the effective date is acceptance; if you don't agree, cancel before then. The "Last updated" date shows the current version.

17.2 Notices. We may give notice by email to your account address or in the dashboard. Legal notices to Torklio must be sent to [legal@torklio.com] and [mailing address].

17.3 Assignment. You may not assign these Terms without our written consent, except to a successor in a merger or sale of substantially all assets with notice. We may assign to an affiliate or successor.

17.4 Force majeure. Neither party is liable for delay or failure caused by events beyond its reasonable control, including carrier or provider outages, internet failures, acts of government, labor disputes, natural disasters, pandemics, or attacks; payment obligations are not excused.

17.5 Independent contractors; no third-party beneficiaries. The parties are independent contractors. Except for indemnified parties in Section 15, there are no third-party beneficiaries; your callers are not beneficiaries of these Terms.

17.6 Export and sanctions. You will comply with U.S. export and sanctions laws and will not use the Service in or for embargoed countries or prohibited persons.

17.7 Government users. The Service is commercial computer software; government rights are limited as set out in FAR 12.212 and DFARS 227.7202.

17.8 Entire agreement; severability; waiver. These Terms (with the incorporated documents) are the entire agreement about the Service and supersede prior agreements. If any provision is unenforceable, it will be modified to the minimum extent necessary and the rest remains in effect. A failure to enforce is not a waiver.

17.9 Language and headings. Headings are for convenience. "Including" means "including without limitation."

18. Contact

[Torklio, LLC]

[Street address, City, AR ZIP]

[legal@torklio.com] · [support@torklio.com] · [security@torklio.com]

Attorney review notes (remove before publishing)

1. Confirm the legal entity name, formation state (expected: Arkansas LLC), and addresses.
2. Decide: BAA/HIPAA posture (4.6); export window (8.3); refund policy (9.4); arbitration county and federal district (16.2/16.5); whether to add an SLA for paid plans.

2a. 2026-08-22 change: governing law, arbitration seat, and venue moved from North Carolina to Arkansas at the founder's direction (Arkansas counsel engaged). Counsel to confirm enforceability of 16.2–16.3 and 16.8 under Arkansas law. See LAWYER_REVIEW_CHECKLIST.md.

1. Verify each subprocessor's data-use terms support the statement in 8.2 (no training on customer data).
2. Confirm the emergency-calling disclosures (2.3, 7.6) against current FCC rules for the Service's actual telephony configuration.
3. Consider state-specific AI-disclosure and recording-consent language updates at least annually.
4. Consider a separate short "Caller Notice" template customers can post for their own callers.
5. Check consumer-protection constraints on the limitations period (16.8) and the class waiver for any customers who may be treated as consumers.
6. 2026-08-31 additions (self-review pass): (a) 4.2 extended to website-chat/browser-voice logging (CIPA session-recording litigation wave); (b) new 4.9 biometrics/BIPA — confirm in writing with speech vendors that no voiceprints are created, then mirror in the Privacy Policy; (c) 4.4 notes the FCC's AI-voice-equals-artificial-voice TCPA ruling; (d) 9.5 trial anti-abuse + FTC Negative Option Rule ("click to cancel") operational note — checkout must disclose "7 days free, then $X/mo" before collecting payment info and cancellation must be as easy as signup; (e) 9.6 price-lock exception aligning the public Founding Partner "$99 stays $99" commitment with the contract; (f) Section 13 sentence that marketing statements are not warranties (the site says things like "booking fails safe" — ensure the product's failsafe behavior genuinely matches, and keep this sentence). Also: the new public comparison pages name competitors — keep vendor descriptions accurate and dated to manage Lanham Act false-advertising exposure.

Acceptable Use Policy

Last updated: [DATE]. Effective: [DATE].

1. Why this policy exists

Torklio provides an AI receptionist (the "Receptionist") that answers phone calls and website chats for businesses (each a "Customer"). The Service runs on real telephone networks, messaging carriers, and AI providers (our "Subprocessors"), and every Customer shares the reputation of the platform with every other Customer. One abusive account can get numbers blocked, messages labeled as spam, or a provider relationship terminated for everyone.

This policy sets the rules. If you use the Service, or allow anyone to use it through your account, you agree to it. Capitalized terms have the meaning given in the Terms of Service (the "Terms").

2. Illegal and harmful use

You may not use the Service, or configure the Receptionist, to:

2.1 Violate any law, regulation, court order, or third-party right, or help anyone else do so.

2.2 Obtain emergency help. The Service does not support 911 or emergency calling and is not monitored by humans in real time. You may not market, describe, or configure the Receptionist as a way to reach emergency services, a crisis line, or urgent medical, safety, or security response. Tell your Callers to dial 911 in an emergency.

2.3 Commit or facilitate fraud, phishing, "vishing," social engineering, identity theft, or impersonation of any person, business, government agency, or emergency service.

2.4 Harass, threaten, abuse, defame, stalk, or discriminate against any person, or gather information about a person for those purposes.

2.5 Promote or facilitate illegal gambling, controlled substances where unlawful, weapons trafficking, human trafficking, sexual services, sexually explicit content, child exploitation, violence, or hatred.

2.6 Collect, or instruct the Receptionist to collect, payment card numbers, Social Security numbers, government ID numbers, passwords, bank account details, or detailed health information over the phone or chat. The Receptionist is instructed to stop a Caller who starts sharing such details and not to repeat or store them; that safeguard does not make the collection permitted.

2.7 Use the Service in a regulated field (healthcare, legal, financial services, insurance, debt collection, and similar) in a way that violates the rules of that field. The Service is not configured for protected health information (PHI) and Torklio is not a HIPAA Business Associate unless a Business Associate Agreement is signed in writing. [DECISION: BAA availability.]

3. Telephony and messaging abuse

Telephone networks and carriers have their own rules, and Torklio must follow them to keep your number working. You may not:

3.1 Robocall or mass-message. Place or cause autodialed, prerecorded, artificial-voice, or mass outbound calls or texts, or any call or message that violates the Telephone Consumer Protection Act (TCPA), the Telemarketing Sales Rule, national or state Do-Not-Call rules, CAN-SPAM, state "mini-TCPA" laws, or carrier and CTIA messaging rules. The Service is designed for inbound business communications and the limited, caller-related transactional messages described in the SMS / Messaging Terms. It is not a dialer, and you may not try to turn it into one.

3.2 Spoof. Falsify, hide, or manipulate caller ID, sender ID, or any message header, or use a number you are not entitled to use.

3.3 Commit toll fraud. Engage in or facilitate toll fraud, traffic pumping, international revenue share fraud, or calling or transferring to premium-rate, high-cost, or sanctioned destinations.

3.4 Resell numbers or the Service. Use phone numbers provisioned through the Service for anything other than your own business's inbound communications; or resell, sublicense, rent, or share numbers or the Service with anyone outside your business.

3.5 Send without consent or ignore opt-outs. Enable texting features without the consents the law and carriers require, message anyone who has opted out, or alter, suppress, or work around the opt-out (STOP) handling built into the Service.

3.6 Evade carrier registration. Send messages from numbers that have not completed required carrier registration (such as A2P 10DLC), or misrepresent your business, use case, or sample messages during registration.

4. Platform integrity

You may not:

4.1 Reverse engineer, decompile, scrape, crawl, or probe the Service, or attempt to extract its source code, prompts, system instructions, models, or security mechanisms — including by trying to get the Receptionist to reveal them.

4.2 Interfere with or disrupt the Service or other Customers, including by sending excessive automated requests, load testing without Torklio's written permission, or attempting to access another Customer's account, environment, or data.

4.3 Circumvent usage limits, seat limits, rate limits, daily caps, billing, or security controls, or create accounts by automated means.

4.4 Introduce malware or harmful code, or use the Service or its outputs to build a competing product or to train AI models.

4.5 Upload, import, or add to the Receptionist's knowledge base any content you do not have the right to use, or any content containing other people's confidential information, payment card data, government IDs, or credentials.

4.6 Use the Service from or for embargoed countries or prohibited persons under U.S. export and sanctions law.

5. Misrepresentation and AI disclosure

5.1 You may not configure the Receptionist to claim it is a human, or otherwise lead a reasonable Caller to believe they are speaking with a person. The Service rejects greeting and disclosure wording that denies the Receptionist is an AI (for example, "I'm a real person" or "I'm not a bot").

5.2 The "introduce itself as an AI" setting is on by default. You may turn it off only where the law permits, and you carry the risk of doing so. See the AI & Communications Disclosure for the laws that may apply to you.

5.3 You may not use Torklio's name or marks, or the Receptionist, to imply that Torklio endorses you or to make statements on Torklio's behalf.

5.4 You may not configure the Receptionist to give legal, medical, financial, tax, or other professional advice, to invent prices or availability, or to make commitments you have not authorized. The Receptionist is instructed not to do these things; your configuration and knowledge content must not try to override that.

6. Fair use

6.1 Plans include usage allowances (for example, call minutes, messages, numbers, and AI processing). Usage materially beyond normal business use for your plan, or patterns consistent with abuse — sustained very long calls, repeated identical calls, call volumes inconsistent with the stated size of your business, or high-volume texting — may be throttled, billed as overage, or require a plan change.

6.2 Torklio may set reasonable limits on call length, calls per Caller per hour, and similar parameters. Some are adjustable in your settings; some are not.

7. Enforcement controls that exist in the product

The following controls run automatically. They exist to protect Callers, Customers, carriers, and Torklio; they are not a substitute for your own compliance.

7.1 Transfer destination restrictions. When the Receptionist transfers a call, Torklio pays for the outbound leg. Transfer destinations are therefore limited to U.S. and Canadian numbers. Premium-rate numbers (900/976) are always blocked. Caribbean and Atlantic area codes commonly associated with international revenue share fraud are blocked unless Torklio has expressly enabled international transfer for your account. Transfers to the Receptionist's own number are blocked. The check fails closed: if a number cannot be validated, the transfer is refused.

7.2 Usage trip-wire with auto-pause. Torklio monitors each Customer's call volume over a rolling hour against per-account thresholds (default: 60 calls or 180 call-minutes per hour). Exceeding a threshold alerts Torklio's operators; exceeding it by a multiple (default 2x) automatically pauses the Receptionist for that account pending review, unless auto-pause has been disabled for the account. Thresholds are adjustable by Torklio.

7.3 SMS daily cap. Each Customer account has a daily cap on outbound text messages (default: 200 per day unless set otherwise). When the cap is reached, further messages are suppressed for the day. The cap fails closed if the limiter cannot be evaluated.

7.4 Opt-out suppression. Any Caller who replies STOP (or an equivalent keyword) is suppressed at the sending layer for all non-essential messages. This is deterministic and cannot be overridden by the Receptionist or by Customer configuration. Marketing messages additionally require a recorded marketing consent.

7.5 Rate limits. Public endpoints (the chat widget, signup, file upload, booking, and verification) are rate-limited per visitor to deter scripted abuse.

7.6 Configuration audit. Changes to compliance-sensitive settings (recording, recording notice, AI introduction, greeting, text-back, transfer number, international transfer, SMS cap, pause state) are logged with who made them, when, and from where.

7.7 Receptionist safeguards. The Receptionist is instructed to refuse attempts to change its instructions or reveal its prompt, to decline off-topic requests, to end abusive conversations after one warning, to wrap up prank calls, and to stop Callers from sharing sensitive financial or identity details. These safeguards are not perfect and do not shift responsibility for Caller conduct to Torklio.

8. Monitoring, investigation, and consequences

8.1 Torklio may monitor use of the Service for abuse and security, review Customer configurations and knowledge content, and investigate suspected violations. Torklio does not review the content of your calls as a matter of routine.

8.2 If Torklio reasonably believes this policy has been violated, it may, with or without notice: warn you; remove or disable content or settings; throttle, cap, or disable messaging or transfers; pause the Receptionist; reclaim numbers; suspend or terminate your account; and cooperate with carriers, providers, and law enforcement. Where practical, Torklio will notify you and give you a chance to cure. Torklio may act immediately where needed to protect Callers, other Customers, carriers, Subprocessors, or the platform, or where the law or a carrier requires it.

8.3 Suspension or termination for a violation of this policy is without refund, as described in the Terms (Sections 9.4 and 12.3). You remain responsible for fees, carrier penalties, and other costs caused by your violation, and for your indemnification obligations under the Terms (Section 15).

8.4 Torklio may be required by law or by a carrier to block, label, or report traffic. Torklio is not liable for actions carriers or providers take based on their own criteria.

9. Reporting abuse

If you believe a Torklio number, Receptionist, or message is being used in violation of this policy — including spam texts, unwanted calls, impersonation, or fraud — contact [abuse@torklio.com]. Include the phone number or website involved, the date and time, and what happened. Callers who want to stop receiving texts from a Customer's number can reply STOP at any time; reply HELP for help. Torklio reviews reports promptly and may act under Section 8.

Security vulnerabilities should be reported to [security@torklio.com]. [DECISION: publish a safe-harbor statement for good-faith security research.]

10. Changes

Torklio may update this policy as laws, carrier rules, and the Service change. Material changes will be noticed as described in the Terms (Section 17.1). Continued use after the effective date is acceptance.

Attorney review notes (remove before publishing)

1. Confirm the enforcement controls in Section 7 against the current code before each publication (security.transfer_destination_check, security.usage_trip, notify.send_sms daily cap, compliance.can_send, chat_server.RATE_LIMITS, compliance.SENSITIVE_KEYS). Remove any item that has been changed or removed.
2. [DECISION] Whether to offer a BAA (2.7) — align with Terms §4.6 and DPA §3.3.
3. [DECISION] Abuse and security contact addresses; whether to add a security-research safe harbor.
4. Confirm that Section 8 aligns with the suspension logic actually in the product (auto-pause → operator review → manual unpause).
5. Consider whether Section 3.1 should expressly state that Torklio will not register a marketing A2P campaign on a Customer's behalf unless the Customer separately opts into marketing messaging.

AI Communications Disclosure

Last updated: [DATE]. Effective: [DATE].

1. The short version

• The Receptionist is software. By default it tells Callers it is an AI early in every conversation.
• If you turn on call recording, the Receptionist can play a recorded-line notice. You choose whether the notice is on and what it says; we supply default wording.
• Live call audio is processed by AI providers to run the conversation even when no recording is saved. Our default notice wording says so ("recorded and processed").
• You are responsible for deciding what disclosures and consents the law requires for your Callers, and for configuring the Receptionist accordingly. Torklio gives you the switches and the defaults; it does not decide the law for you.

2. How the Receptionist discloses it is an AI

2.1 Default: AI introduction ON. The "Introduce itself as an AI" setting is on for every new account. When it is on, the Receptionist is instructed to say, early in every call and chat — in the greeting or right after — that it is the business's AI receptionist, and then to reassure the Caller that it can help. Torklio's default introduction is:

2.2 Honest answers. Whether or not the introduction is on, the Receptionist is instructed never to claim to be human. If a Caller asks "Am I talking to a real person?", it says it is an AI.

2.3 No deceptive wording. Torklio rejects greeting or disclosure text that denies the Receptionist is an AI (for example, "I'm a real person," "I'm not a bot," "you're speaking with a real person"). This check runs when you save settings.

2.4 Turning it off. You may turn the AI introduction off in Voice Studio. Doing so is logged. Turn it off only if you have determined that no disclosure law applies to your Callers; you carry the risk (Terms Section 4.3). [DECISION: should Torklio make the AI introduction non-configurable, or require an acknowledgment when it is disabled?]

2.5 Chat widget. The same setting governs the website chat. The chat widget's default header and first message should identify the assistant as an AI. [VERIFY current widget copy.]

3. How the recorded-line notice works

3.1 What recording means here. Two different things happen on a call:

• Live processing. Audio is streamed in real time to a speech-and-language AI provider so the Receptionist can understand and respond. This starts when the call connects and is required for the Service to work at all. It happens whether or not a recording is saved.
• Stored recording. If "Call recording" is on, a recording file is saved to your account and kept according to your retention setting (default 90 days in our retention policy; the product's current default setting retains until you delete — [VERIFY which default is live]). A transcript is stored in either case.

Because live processing is not optional, our default notice says "recorded and processed," and it is not accurate to tell Callers that a call is "not processed" when recording is off.

3.2 Default notice wording. When the recording notice is enabled, the Receptionist weaves this into the opening greeting unless you replace it:

3.3 Settings you control. Call recording (on/off), recording notice (on/off), notice wording, retention days, and the AI introduction are separate settings. Changes to each are logged with who changed them and when.

3.4 Current default for the notice. The recording notice is currently off by default, and when on it is spoken after the greeting begins. Torklio's recommended posture, pending counsel's review, is to turn the notice on for all accounts and place it at the very start of the greeting. [DECISION: set recording_notice_enabled default to true; see RECORDING_FLOW.md.]

3.5 If a Caller objects. The Receptionist does not currently offer an in-call "press 1 to decline recording" flow. If a Caller says they do not want to be recorded, the practical options are to end the call, offer a callback from a person, or for you to operate with recording off. [DECISION: choose the recording mode (A disclose-and-continue, B affirmative consent, C no recording, D no recording + minimal transcript) that Torklio recommends as the default; counsel to advise.]

4. Caller Notice template (for Customers to post)

You can adapt this notice for your website, booking page, voicemail greeting, or front desk. Replace the bracketed items. It is a convenience, not a guarantee of compliance.

5. State-law notes for counsel [VERIFY all]

The laws below are the ones most often raised for AI receptionists. Counsel should confirm current text, thresholds, and whether each applies to a given Customer's business. Customers in other states and countries may face additional rules.

5.1 California — Bolstering Online Transparency Act (Bus. & Prof. Code § 17940 et seq.). Prohibits using a bot to communicate with a person in California online, with intent to mislead about its artificial identity, to incentivize a sale or influence a vote. Disclosure must be clear and conspicuous. Written for online interactions; applicability to voice calls should be confirmed. [VERIFY.] Keeping the AI introduction on, and the "no deceptive wording" check, are intended to address this.

5.2 Utah — Artificial Intelligence Policy Act (Utah Code § 13-2-12; amended 2025). Requires disclosure of generative AI in consumer interactions when a person asks, and proactive disclosure for certain regulated occupations (health, mental health, and other licensed services). Customers in regulated occupations in Utah may need a proactive disclosure at the start of every interaction. [VERIFY current scope after the 2025 amendments.]

5.3 Colorado — Artificial Intelligence Act (SB 24-205; effective date deferred to 2026). Requires deployers to disclose to consumers that they are interacting with an AI system, unless it would be obvious to a reasonable person, and imposes broader duties for "high-risk" AI used in consequential decisions (employment, housing, credit, healthcare, legal services, and similar). The Receptionist is not designed to make consequential decisions, but Customers in those fields should review. [VERIFY effective date and any amendments.]

5.4 Two-party / all-party consent states for call recording. Consent of every party is generally required before recording in, among others: California, Delaware, Florida, Illinois, Maryland, Massachusetts, Michigan, Montana, Nevada, New Hampshire, Oregon (in-person), Pennsylvania, and Washington. [VERIFY the list annually; treatment varies by state and by whether the Caller is out of state.] Arkansas is a one-party consent state (Ark. Code Ann. § 5-60-120), which covers Torklio's own operations but not a Customer's Callers located in an all-party state. Because an inbound Caller can be anywhere, the conservative approach is a nationwide notice on every call where recording is on.

5.5 Federal TCPA artificial-voice rules. The FCC has stated that AI-generated voices are "artificial" voices under the TCPA for outbound calls. The Receptionist answers inbound calls and places outbound calls only to transfer an active Caller to a person you designate; it does not make outbound AI-voice calls to consumers. [VERIFY that no feature initiates outbound AI-voice calls before publishing.]

5.6 FTC rules on impersonation and AI-enabled deception. The FTC's impersonation rule and Section 5 reach deceptive use of AI. Keeping the Receptionist honest about being an AI, and not configuring it to claim authority or credentials it does not have, is the baseline.

5.7 Other states to watch. Additional states have enacted or proposed chatbot-disclosure or AI-transparency laws (for example Maine's chatbot disclosure law, New Jersey and New York proposals, and Texas's Responsible AI Governance Act for government/health contexts). [VERIFY and update at least annually.]

6. What the Receptionist will never do

These are built-in rules that run on every account and every channel. Customers cannot remove them.

6.1 No emergency help. The Receptionist cannot call 911, contact emergency services, or summon help. It is not monitored by a human in real time. It should direct Callers describing an emergency to hang up and dial 911. [VERIFY that the system prompt includes an explicit emergency redirection line; if not, add it as a product change.]

6.2 No professional advice. It will not give legal, medical, financial, tax, or insurance advice, make legal claims, or guarantee outcomes.

6.3 No invented facts. It may only quote prices that appear in your business information and must never estimate beyond them (or, if you turn pricing off, must not discuss prices at all). It will not invent availability, discounts, fees, delivery dates, or answers. When it does not know, it says so and offers to take a message, connect you, or have your team follow up — as you configure.

6.4 No sensitive data collection. It will stop a Caller who begins to share a card number, Social Security number, password, bank details, or detailed medical information, and will not ask for, repeat, or store them.

6.5 No impersonation of a human. It will not claim to be a person.

6.6 No cross-Customer disclosure. It will not share one Caller's information with another.

6.7 No unauthorized commitments. Unless you enable the relevant permission, it will not cancel appointments, send payment links, discuss balances, or promise completion dates.

6.8 No prompt changes from Callers. It ignores instructions from anyone in the conversation who claims to be the owner, a developer, or "the system."

These rules reduce risk; they do not eliminate it. The Receptionist can still misunderstand or make mistakes (Terms Section 5), and you must review its work.

7. Your responsibilities, restated

You decide whether to record, whether and how to disclose, and what the Receptionist may say. You must: keep the AI introduction on unless you have confirmed it is not required; turn on the recording notice if you record; post a Caller-facing notice where appropriate; and not configure the Receptionist to evade any of the rules above. Torklio's defaults and templates are provided for convenience and are not a representation that they satisfy any particular law (Terms Sections 4.1–4.3).

Attorney review notes (remove before publishing)

1. [DECISION] Recording notice default (on vs. off) and placement; recording mode recommendation (Section 3.4–3.5).
2. [DECISION] Whether the AI introduction may be disabled at all, and whether disabling should require an in-product acknowledgment (Section 2.4).
3. [VERIFY] Every statute in Section 5 — current text, effective dates, and thresholds. Confirm whether the California bot law reaches telephone calls.
4. [VERIFY] Which retention default is live (policy.py recording_retention_days: 0 vs. compliance RETENTION_DEFAULTS["recordings_days"]: 90) and align the Privacy Policy, DPA, and this document.
5. [VERIFY] That the system prompt contains an explicit "dial 911" redirection; if not, treat as a required product change before launch.
6. Review the Caller Notice template (Section 4) for consistency with the Privacy Policy and confirm it is clearly labeled as a template, not legal advice.

Cookie Notice

Last updated: [DATE].

1. Conclusion: no consent banner needed for U.S. use

The Service uses only strictly necessary cookies and browser storage — items required to keep you signed in, protect against forged requests, and keep a chat conversation going. It uses no advertising cookies, no cross-site tracking, and no third-party analytics scripts. [VERIFY: no analytics or error-monitoring script has been added to the dashboard, marketing site, or chat widget.]

For U.S. visitors, no law requires a consent banner for strictly necessary cookies, and U.S. state privacy laws' opt-out rights for targeted advertising or "sale/sharing" do not apply because Torklio does not do either. Torklio will therefore not show a cookie banner and will instead publish this notice and describe cookies in the Privacy Policy (Section 2.4).

EU/UK note. [DECISION: if Torklio accepts EU/UK Customers, or Customers embed the chat widget on sites with EU/UK visitors, counsel should review ePrivacy/PECR requirements. Strictly necessary cookies are exempt from consent there too, but the chat widget's session identifier should be confirmed as "strictly necessary" for a service the visitor requested, and the Customer's own site banner may need to list it.]

2. What is stored, and why

None of these identify a visitor across websites, and none are shared with advertising or analytics providers.

The chat widget runs on the Customer's website. That website may set its own cookies under its own policy; Torklio does not control them.

3. Server logs

Torklio's servers keep standard request logs (IP address, browser type, page or endpoint, timestamp) for security, rate limiting, and debugging. These are not cookies, are not used for advertising, and are kept for about 12 months (metadata only).

4. Your choices

You can block or delete cookies and site data in your browser settings. If you block the session cookie, you will not be able to stay signed in to the dashboard. Clearing the chat widget's local storage ends the current chat session. Because Torklio does not track across sites or sell or share data, "Do Not Track" and Global Privacy Control signals do not change how the Service works; where the law requires, Torklio honors GPC as an opt-out of any applicable sale or sharing.

5. Short notice text (for the footer or Privacy Policy)

6. Changes

If Torklio adds analytics, error monitoring, or any non-essential cookie in the future, this notice and the Privacy Policy will be updated first, and the banner question in Section 1 will be revisited.

Attorney review notes (remove before publishing)

1. [VERIFY] Run a final check of all served HTML for third-party scripts before launch; re-check whenever the marketing site is rebuilt.
2. [DECISION] EU/UK posture (Section 1) — consistent with Privacy Policy Section 10 and DPA Section 10.
3. [VERIFY] Mission Control session lifetime and the chat widget local-storage expiry.
4. Note for Customers: if they embed the chat widget on a site with its own cookie banner, they may wish to list aura_chat_sid as a strictly necessary item. Consider adding that line to the widget setup instructions.

SMS Consent & Messaging

Last updated: [DATE]. Effective: [DATE].

Part A — SMS / Messaging Terms

1. Who is sending

1.1 Text messages sent through the Service go out from a Customer's Torklio phone number, on the Customer's behalf, to the Customer's Callers. The Customer is the sender. Torklio is the Customer's service provider and messaging platform; it does not send marketing to Callers on its own behalf.

1.2 Messaging is an optional feature. Customers who enable any texting feature accept these SMS / Messaging Terms and are responsible for the consents described below (Terms Section 4.4).

2. What messages the Service sends

The Service sends only the following message types, each triggered by a Caller's own action or an appointment the Caller made:

[VERIFY the list against the current send paths in notify.py, chat_server.py, and the reminder scheduler before publishing.]

3. Transactional vs. marketing consent

3.1 The Service keeps transactional and marketing consent separate. A Caller who phones a business, books an appointment, or asks for a verification code has started a transaction; the Service treats that as permission to send the related transactional messages above to that Caller. It is not blanket consent to marketing.

3.2 Marketing messages require a separate, recorded, affirmative opt-in from the Caller. Marketing is off by default for every Customer. Without a recorded marketing consent, the sending layer refuses marketing messages.

3.3 Customers must not relabel marketing content as "transactional" to avoid the consent requirement. Carriers and regulators look at content, not labels.

4. Opt-out, opt-in, and help keywords

4.1 Replies are processed deterministically by product code before any AI sees them. The Receptionist cannot override a keyword decision.

4.2 Opt-out keywords: STOP, STOPALL, QUIT, END, REVOKE, OPTOUT, OPT OUT, UNSUBSCRIBE, CANCEL. Matching ignores case, spacing, and punctuation. An opt-out suppresses all non-essential messages from that Customer's number to that Caller, effective immediately, and is recorded in the consent ledger and the audit log.

4.3 Opt-in keywords: START, UNSTOP, YES, OPTIN. Re-subscribes the Caller to that Customer's messages.

4.4 Help keywords: HELP, INFO. Returns a short description and the opt-out instruction.

4.5 Opted-out numbers are checked at the sending layer on every send. If the consent check cannot be evaluated, the message is not sent.

4.6 [DECISION] Whether a one-time confirmation of an opt-out (the STOP reply in Part B) should be sent after opt-out. Carriers expect a single confirmation; it is the only message the Service sends to an opted-out number.

5. Frequency, rates, and caps

5.1 Message frequency varies by activity. A typical Caller receives a handful of messages per appointment. The Service does not send recurring messages except reminders tied to a scheduled appointment.

5.2 Message and data rates may apply. Carriers may charge the Caller for messages received.

5.3 Each Customer account has a daily outbound cap (default 200 messages per day unless set otherwise). Messages beyond the cap are suppressed until the next day.

6. Carrier registration (A2P 10DLC)

6.1 U.S. carriers require business messaging from local numbers to be registered (brand and campaign) before messages are delivered. Until registration is approved, carriers reject messages even though the Service accepts them.

6.2 Customers must provide accurate business information for registration when asked and must not misrepresent their use case. Torklio registers the message types it actually sends (account notifications, 2FA, customer care). A marketing campaign is registered only for Customers who separately enable marketing messaging. [DECISION: single Torklio brand with per-Customer campaigns, or per-Customer brands? See A2P_10DLC_REGISTRATION.md.]

6.3 Carriers may filter, label, or block messages based on their own criteria. Torklio is not responsible for carrier filtering.

7. Consent records

For every consent and opt-out event, the Service records:

[DECISION] Add to the record: the exact consent wording and its version, the IP address and user agent for web consents, and the Customer's Terms version at the time. The Terms-acceptance log already captures Terms version, document hashes, IP, and user agent for Customer acceptances; extending the SMS consent ledger to the same standard is recommended for marketing consents.

Records are kept for as long as the number is in the Customer's contact list plus [VERIFY — commonly 4–5 years] to defend against TCPA claims, and opt-outs are kept indefinitely as a suppression record.

8. Customer responsibilities

Customers must: obtain and keep proof of any consent the law requires before enabling messaging; use the consent wording in Part B (or wording counsel approves) wherever a Caller opts in; honor opt-outs received through any channel (including a Caller telling the Receptionist or a staff member to stop texting) by marking the contact opted out; not message anyone who has opted out; and complete carrier registration when asked. Customers are responsible for claims arising from their messaging (Terms Sections 4.4 and 15.1).

Part B — Exact consent and reply wording

All wording below uses {business} for the Customer's business name, {name} for the Caller's first name, {service} and {when} for appointment details, and {code} for a verification code. Replace before use.

B1. Opt-in checkbox (booking page, chat widget, web forms)

The checkbox must be unchecked by default, must be separate from any Terms or privacy checkbox, and opting in must not be a condition of booking or receiving service.

Transactional (appointment texts):

Marketing (only if the Customer enables marketing):

[DECISION] Whether to show the transactional checkbox at all or rely on the booking itself as transactional consent with a disclosure line instead. Many A2P reviewers expect a visible opt-in statement even for transactional use.

B2. Verbal opt-in by phone (Receptionist)

When a Caller asks for a text confirmation or reminder during a call, the Receptionist should confirm:

Record the consent with source phone_verbal only on a clear yes. [VERIFY the Receptionist's current prompt includes this confirmation step; if not, add it as a product change.]

B3. Confirmation message after web opt-in (first message)

B4. Keyword replies (as implemented)

STOP (and equivalents):

START (and equivalents):

HELP / INFO:

[DECISION] Consider adding a support contact (phone or email) to the HELP reply; carriers often expect one. Requires a code change to compliance.process_inbound_sms.

B5. Sample transactional messages

Missed-call text-back:

[VERIFY against the tenant's configurable sms_textback_message default.]

Appointment confirmation:

Appointment reminder (24h / 2h):

Verification code:

Verification codes are single-use, expire in 5 minutes, and are never written to logs.

B6. Disclosure line for pages that collect a phone number without a checkbox

B7. Language for A2P 10DLC campaign registration

Opt-in description: "End users opt in by booking an appointment or requesting a verification code on the business's website or by phone, where they are shown or told the consent language above, or by checking an unchecked opt-in box. Consent is recorded with phone number, category, source, and timestamp. Marketing is a separate opt-in and is off by default."

Opt-out description: "STOP, STOPALL, QUIT, END, REVOKE, OPTOUT, UNSUBSCRIBE, and CANCEL are processed automatically and confirmed with a single message. Opted-out numbers are suppressed at the send layer."

Help description: "HELP and INFO return a short description with the opt-out instruction."

Attorney review notes (remove before publishing)

1. [DECISION] Whether transactional appointment texts need a visible checkbox or a disclosure line (B1 vs. B6), and whether verbal phone consent (B2) is sufficient for reminders.
2. [DECISION] Extend the SMS consent ledger to store wording/version, IP, and user agent (Section 7), and set a retention period for consent and opt-out records.
3. [DECISION] Add a support contact to the HELP reply (B4) — code change.
4. [VERIFY] Message list (Section 2) and the missed-call text-back default (B5) against the code.
5. [VERIFY] The Receptionist's prompt includes the verbal consent confirmation in B2; the quiet-hours rule (no texts before 8 a.m. or after 9 p.m. Caller local time under the TSR and several state laws) — the product does not currently enforce quiet hours for reminders. [DECISION: add a quiet-hours window.]
6. Confirm alignment with A2P_10DLC_REGISTRATION.md sample messages and with Terms Section 4.4.

Subprocessors

Status: DRAFT — ATTORNEY REVIEW REQUIRED. Verify each provider's current DPA/terms and configuration before publishing.

Torklio uses the third-party service providers ("subprocessors") below to operate the service. This list reflects providers actually integrated in the codebase. Torklio does not sell customer or end-customer data. Provider legal names, regions, and DPA URLs should be confirmed by counsel before this page is published customer-facing.

Deployed-path verification (2026-08-23)

• The live deployment runs BOT_SCRIPT=bot_realtime.py (.env:18). In that path the audio subprocessors are: OpenAI STT (gpt-4o-mini-transcribe, bot_realtime.py:548) + realtime reasoning (OpenAIRealtimeLLMService, bot_realtime.py:57-59); ElevenLabs TTS (eleven_flash_v2_5, bot_realtime.py:56,1018, engine set in settings.json:2); Anthropic for summaries/chat/extraction (carol.py:280-283).
• Deepgram and Cartesia are NOT deployed subprocessors. They exist only in the alternate bot.py relay (bot.py:50,200), which the live launcher does not run. Do not add them to this list unless a tenant is switched to BOT_SCRIPT=bot.py (add + sign DPA first). The lingering DEEPGRAM_API_KEY in .env:14 is unused.

Notes for counsel

• OpenAI receives live call audio as part of the realtime pipeline. Whether/where this occurs relative to the recording/AI disclosure is documented in RECORDING_FLOW.md. Flag whether provider processing is materially distinct from "recording" for disclosure/consent purposes.
• Confirm each provider's data-retention and (where offered) zero-retention / no-training configuration, and record the setting actually in use.
• Backups on DigitalOcean Spaces include sensitive content and are a subprocessor data location.