AI Compliance Addendum

Effective: 2026-05-26 Version: 2026-05-26.v2

This AI Compliance Addendum (the "Addendum") supplements the Acceptable Use Policy and Terms of Service between you and Lead Friendly LLC. It applies whenever you use, configure, deploy, or operate any AI voice agent, AI calling capability, AI messaging capability, or AI auto-attendant on the Lead Friendly LLC platform (collectively, "AI Voice Features"). To the extent of any conflict, the more restrictive provision governs.

Background

The U.S. Federal Communications Commission, in its Declaratory Ruling of February 8, 2024 (FCC 24-17), confirmed that AI-generated voices used in calls qualify as "artificial voice" under the Telephone Consumer Protection Act, 47 U.S.C. § 227, and 47 CFR § 64.1200. Marketing calls and texts placed using artificial or prerecorded voice (including AI voices) to wireless numbers require Prior Express Written Consent ("PEWC") meeting the technical requirements of 47 CFR § 64.1200(f)(9). The FCC's Notice of Proposed Rulemaking of September 2024 proposes mandatory upfront disclosure on every AI-generated call. Recent class-action complaints, including Mortgage One Funding (E.D. Mich. Feb. 2026), confirm that failing to disclose AI usage and failing to maintain PEWC are direct vectors for class-action liability.

Lead Friendly LLC does not assume your TCPA, FCC, or state-law obligations as a calling party. Those obligations remain yours. This Addendum sets the platform-side requirements that we enforce to protect our underlying carrier reputation and to give you a defensible posture.

1. Disclosure on First Turn

• You acknowledge that the platform automatically prepends a non-removable AI-disclosure preamble to every AI agent system prompt, requiring the AI to identify itself as an AI assistant on the first turn of every call.
• You will not configure, prompt, or instruct any AI agent to: (a) deny or evade the AI disclosure; (b) paraphrase, shorten, or delay the disclosure; (c) deny being AI if asked; (d) impersonate a specific human individual; or (e) suppress or override the recording disclosure.
• The disclosure script identifies the agent by the configured agent name, identifies your business as the calling party (using your organization name as it appears in the platform), and discloses recording in jurisdictions where two-party consent applies.

2. Prior Express Written Consent (PEWC)

• For every AI marketing call to a U.S. wireless number, you represent and warrant that you have obtained valid PEWC from the called party that meets the requirements of 47 CFR § 64.1200(f)(9), including: (a) a clear and conspicuous disclosure that the consent is to receive calls or texts using an automatic telephone dialing system, artificial voice, or prerecorded voice; (b) the consent is not a condition of purchase; (c) the consent is signed (electronically or otherwise); and (d) the called party is identified by name and the seller(s) authorized to call are identified by name.
• You will store evidence of consent for each contact, including the consent text, the source URL, the IP address and user-agent at time of capture, and the timestamp. The platform provides the customer_consent_records ledger for this purpose; you may use it or maintain equivalent records under audit.
• The platform will block any AI marketing call to a contact lacking an active PEWC record. You will not attempt to bypass that block.

3. Revocation of Consent

• Per 47 CFR § 64.1200(a)(10) (effective April 11, 2025), revocation of consent must be honored by any reasonable means, with respect to all calls and texts to that number, within ten business days of receipt of the request.
• Common revocation phrases including "stop", "cancel", "end", "quit", "unsubscribe", "remove", "take me off", "do not call", and "opt out" must be honored regardless of channel.
• The AI agent must, upon hearing such language, immediately acknowledge the revocation, mark the contact as opted-out, and end the call. The AI must not argue, negotiate, transfer, or otherwise attempt to overcome the objection.
• One auto-confirmation message within five minutes is permitted; any further outbound contact for the revoked purpose is prohibited.

4. Time-of-Day Window

• AI calls are restricted to a window narrower than the federal 8 AM – 9 PM TCPA window. The default platform window for AI outbound calls is 10 AM – 6 PM in the contact's local timezone.
• State mini-TCPA windows that are narrower than the platform default (e.g., Florida, Oklahoma, Washington) take precedence and are enforced by the platform when the contact's state is identified.
• You may not configure, instruct, or attempt to place AI calls outside the applicable window.

5. Velocity Caps

• The platform enforces per-destination velocity caps on AI calls: by default, no more than one (1) call per destination phone number per 24-hour period and no more than four (4) calls per destination phone number per 14-day period.
• These caps may be tightened (but not relaxed) for specific accounts based on traffic risk, vertical, or carrier feedback.
• You will not attempt to circumvent these caps by rotating destination representations (formatting, prefixes, sub-account hops).

6. Number Reputation, Number Pools, and Snowshoeing

• The platform may rotate originating phone numbers within a number pool to balance carrier reputation. You will not engage in "snowshoeing" — the practice of distributing similar traffic across many numbers to evade per-number spam thresholds — outside of authorized rotation provided by the platform.
• You will register your brand and campaigns with The Campaign Registry through the platform before sending A2P 10DLC traffic.
• You will not use any phone number on the platform to call or message contacts that lack an active consent record for the relevant channel and use case.

7. Answering-Machine Detection (AMD) and Voicemail

• AMD-positive calls (calls answered by a voicemail or answering machine) must be terminated by the AI agent without leaving a prerecorded message, except for transactional calls where the called party has explicitly opted in to receive such messages and the call falls within an established business relationship exception.
• You will not configure the AI agent to leave marketing voicemails on AMD-positive calls.

8. Do Not Call Lists and Reassigned Numbers

• You are responsible for maintaining and scrubbing against the National Do Not Call Registry, applicable state DNC lists, and your internal Do Not Call list.
• The platform maintains an internal DNC list per organization that auto-includes contacts who have requested opt-out via any channel.
• Where required by law (currently Maine, with other states likely to follow), you will scrub against the FCC Reassigned Numbers Database before placing any AI marketing call to a number more than 30 days old in your records.
• The platform will provide tooling to integrate these scrubs; you remain legally responsible for completing them.

9. Recording

• All AI calls are recorded for compliance, dispute resolution, training, and quality purposes.
• The platform's first-turn disclosure includes a recording disclosure for contacts in two-party-consent jurisdictions. You may not disable that disclosure.
• Recordings are stored encrypted and retained per the data retention period of your subscription tier. You may export and delete recordings via the standard data-export and data-deletion mechanisms.

10. State Mini-TCPA, Industry-Specific, and Foreign Laws

• You acknowledge state-level "mini-TCPA" statutes (Florida Telephone Solicitation Act, Oklahoma Telephone Solicitation Act, Washington Commercial Electronic Mail Act and related, Maryland Telephone Consumer Protection Act, New York General Business Law § 399-z, and others) may impose stricter requirements than federal law and apply to your traffic into those states.
• You acknowledge industry-specific rules apply (e.g., financial services under the Gramm-Leach-Bliley Act and Regulation B, healthcare under HIPAA, debt collection under the FDCPA and Regulation F).
• For calls to contacts outside the United States, additional laws apply (e.g., Canadian Anti-Spam Legislation, the EU GDPR, the UK Privacy and Electronic Communications Regulations). You are solely responsible for compliance.

11. Quarantine and Remediation

• If your account or any phone number is flagged by an underlying carrier, an analytics partner (e.g., Hiya, TNS Call Guardian, First Orion), the FCC traceback consortium, or the platform's internal anomaly detector, the platform may automatically quarantine the affected resource.
• You will receive notice and a 48-hour window to respond with a written remediation plan that includes: (a) the consent records for the recent traffic to the destinations in question; (b) the scrub records (DNC SAN, RND query log, internal DNC export) for the past 30 days; (c) the AI agent prompt and disclosure script; and (d) a corrective-action plan.
• Failure to respond, or a response that we determine in our sole discretion is inadequate, will result in termination.

12. Audit Rights

• We may audit your consent-capture website, opt-in records, AI agent prompts, and other compliance records on 24 hours' notice.
• We may pull and review call detail records, AI transcripts, and analytics data at any time without notice.

13. Indemnification (TCPA-Specific)

In addition to and not in limitation of the indemnification in the Terms of Service and AUP, you specifically indemnify Lead Friendly LLC for any claim, demand, action, judgment, or settlement arising out of or related to: (a) any TCPA claim concerning your AI calls or messages; (b) any state mini-TCPA claim concerning your AI calls or messages; (c) any FCC or state-attorney-general inquiry concerning your AI calls or messages; (d) any class action concerning AI-voice marketing calls; or (e) your failure to obtain or maintain PEWC for any contact called or messaged through the AI Voice Features. This obligation survives termination.

14. Acknowledgment

By accepting this Addendum you confirm that you understand AI voice calls are subject to TCPA and FCC artificial-voice rules, that PEWC is required for AI marketing calls to wireless numbers, that the platform's disclosure preamble cannot be removed, and that the velocity caps and time-of-day windows above will be enforced by the platform.

Lead Friendly LLC privacy@leadfriendly.com