Call Recording Policy

1. What is recorded

1.1 Every billable call routed through the Platform is recorded — a billable call is one capable of accruing a Publisher Payout or an Agent charge. Recording starts the moment the call is answered by (or connected to) the agent, until hang-up, and is performed by the Platform's telephony provider (Twilio) at the routing layer — not by the agent's device. The Platform does not route billable calls without call recording active.

1.2 Recordings may be transcribed (Twilio Voice Intelligence). Transcripts serve the same purposes as recordings.

1.3 There is no per-call opt-out switch in the product: a billable Platform call is a recorded call, by construction — the Platform does not route billable calls without recording active. See Section 5 for what that means when a consumer objects.

2. Why we record

• Qualification verdicts under the published criteria, and the Qualified-or-Credited Guarantee (the recording is the evidence).
• Billing dispute resolution (agent charge reviews; publisher payout clawbacks).
• Compliance: telemarketing-law defense, fraud detection, audit trails, lawful production to regulators.
• Quality and training.

3. Consent framework

3.1 Legal baseline. Call-recording consent law is state-by-state. One-party-consent states require the consent of one participant; all-party-consent states require everyone on the call.

3.2 All-party states (2026 operating list). We treat the following as all-party: California, Connecticut, Delaware, Florida, Illinois, Maryland, Massachusetts, Michigan, Montana, Nevada, New Hampshire, Oregon, Pennsylvania, Washington. Notes: Nevada is treated as all-party for phone calls per its case law; Michigan is legally ambiguous and treated as all-party out of prudence.

3.3 Doctrine: universal disclosure. Because calls route across states and the caller's location cannot be guaranteed, the Platform's doctrine is a universal disclosure at the start of every call ("This call may be recorded"), regardless of state. Disclosure at the start plus the consumer's decision to continue the call constitutes implied consent under the all-party statutes as commonly applied.

3.4 Consumer-initiated context. All Platform calls are dialed by the consumer from an approved advertisement. This affects telemarketing analysis, not recording law: recording consent rules apply regardless of who dialed.

4. Publisher and agent obligations

4.1 Publishers consent to Platform recording as a condition of delivering calls, must keep their ads, landing pages, and any IVR consistent with this policy, and must not represent calls as unrecorded.

4.2 Agents consent to Platform recording as a condition of taking calls, must deliver the verbal disclosure per Section 3.3, and must never deny that a call is recorded.

5. If the consumer objects to recording

5.1 The product cannot stop recording for a single live call. Doctrine, aligned to that reality: if a consumer refuses recording after the disclosure, the agent must politely end the call. Do not continue the conversation "off the record" — there is no off the record.

5.2 A consumer's post-call request to delete a recording is handled as a privacy-rights request under the Privacy Policy (§7).

6. Access, storage, retention

6.1 Access is role-scoped, as built: agents can play recordings of their own calls (call log and call detail); Platform administrators access recordings for operations, audit, and disputes; publishers do not get audio — the publisher portal shows the verdict, reason, and limited quality data for their own calls only. Transcript access follows the same scoping.

6.2 Recordings are stored with the telephony provider (Twilio); transcripts and call metadata in the Platform database. Access is authenticated and logged.

6.3 Retention: 5 years, then deletion, subject to legal hold.

7. Transcription note

Transcription is a platform feature tied to recording (it only runs on recorded calls). Transcripts inherit every rule in this policy: same consent framework, same access scoping, same retention. AI processing of transcripts beyond verdict/quality purposes (e.g., automated call scoring) is a potential future feature and would be re-reviewed before launch.

8. Versioning

This policy is published in the Platform and versioned like the contracts that reference it. Material changes are notified to account holders; the version in effect at the time of a call governs that call.