Anti-Spam Policy

Effective Date: May 25, 2026

Legal Entity: Callsy AI OÜ (a private limited company incorporated under the laws of the Republic of Estonia) and its sister company Callsy UAB (a private limited company incorporated under the laws of the Republic of Lithuania). Together referred to in this Policy as "Callsy," "we," "us," or "our."

This Anti-Spam Policy is incorporated by reference into the Terms of Service available at www.callsy.ai (the "Terms"), and more generally into the agreement between Callsy and the customer (the "Customer," "you," or "your") governing the use of our services (the "Services"). All capitalized terms used but not otherwise defined here have the meanings given to them in the Terms.

Basic overview

The Customer may not use the Services to directly or indirectly originate, send, transmit, handle, distribute, or deliver: (a) Spam (as defined below); (b) communications to any recipient obtained via internet harvesting methods or any other impermissible electronic collection of contact information; or (c) communications to any recipient record that is incomplete, inaccurate, or not updated for all applicable opt-out notifications.

"Spam" means any commercial communication — including voice calls placed by AI voice agents, SMS messages, WhatsApp messages, emails (where applicable), or other messaging — that is transmitted without the prior, demonstrable permission of the intended recipient, or otherwise in violation of applicable law (including the TCPA, CAN-SPAM Act, GDPR, the ePrivacy Directive, the EU AI Act, and equivalent local rules).

Obtaining permission

To contact anyone using the Services — whether by AI-powered voice call, SMS, WhatsApp, email, or another channel — you must have obtained their express, prior consent to receive promotional, marketing, or transactional communications of the type you intend to send. Consent must be properly documented and auditable. Permissible methods include, for example:

A subscribe or sign-up form on your website that clearly describes the communications the user will receive (including AI voice calls, if applicable). - An opt-in checkbox that is not pre-checked. The person completing the form must willingly select the checkbox to indicate they want to hear from you. - A signed contract, order form, or other written agreement that explicitly authorizes such communications. - A clearly worded verbal opt-in captured and stored as part of an existing customer relationship, where permitted by law. - A phone number provided at checkout for the purpose of order-related contact, where the call falls within the scope of that legitimate-interest purpose under GDPR Article 6(1)(f).

You are solely responsible for ensuring you have a valid legal basis (such as consent or another lawful basis under applicable data protection law) for each contact you upload or process through the Services.

Inappropriate recipients

In connection with your use of the Services, you agree not to:

Harvest or scrape recipient data (names, phone numbers, email addresses, etc.) from third-party websites or directories. - Purchase, rent, or otherwise use any recipient list (whether described as opt-in or not) for which you did not obtain permission yourself. - Include a pre-checked field on any subscription, sign-up, or consent form. - Use a subscription form that enrolls users into a list, channel, or use case unrelated to what was disclosed at the point of collection. - Send unrelated offers or content to your recipient list. - Add a recipient to a list, calling campaign, or messaging workflow without that recipient's permission. - Contact any recipient who has requested to be removed from your list, asked not to be called, or otherwise withdrawn consent. - Place AI voice calls to numbers listed on any applicable Do-Not-Call (DNC) registry without a valid exemption. - Use a contact list older than 12 months without reconfirming the recipients' consent to receive communications. - Configure an AI voice agent to fail to disclose its non-human nature at the start of a call. This disclosure is built into the platform by default and may not be disabled.

Opt-out policy

Every communication you send or place using the Services must include, where applicable to the channel:

A valid recipient identifier (email address, phone number, or other contact data) that was lawfully obtained. - True and accurate header, sender, subject, and routing information (e.g. "From," "To," "Reply-To," caller ID), which is not misleading in any way. - Clear identification that the message or call is an advertisement or marketing communication, where required by law. - The name and physical address of the sender, plus the current and accurate full legal entity name, in channels where required by law. If you are sending communications on behalf of your own client, you must include that client's details instead. - A clear notice that the recipient may unsubscribe, opt out, or otherwise demand that use of their email address, phone number, or other identifier cease with respect to any or all communication purposes. - Information on one or more methods by which the recipient may notify the Customer of their election to unsubscribe, opt out, or otherwise stop further communications. For voice channels, this includes a clearly disclosed way to opt out during or after the call (e.g. spoken command, return SMS keyword such as STOP, or reply email). - A single-click unsubscribe link (for email) or a single-step opt-out mechanism (e.g. replying STOP to an SMS, saying "stop calling me" during a voice call) that immediately removes the subscriber from the relevant list, in channels where required by law. No input from the recipient, other than confirmation, should be required. Once a recipient opts out, the Customer may never again contact them through that channel for marketing purposes, other than sending a final confirmation of unsubscription or strictly necessary order-related communications.

The Customer warrants that it will comply promptly with all opt-out, unsubscribe, "do not call," and "do not send" requests. The Services will automatically suppress recipients whose contacts are consistently returned as undeliverable, invalid, or who have opted out through the Callsy platform — across all channels, instantly.

Verification procedures

Callsy uses multiple layers of approval and monitoring to help ensure compliance with this Anti-Spam Policy:

The Services are integrated with third-party spam, abuse, and complaint-reporting systems used by major SMS, voice, and email providers. If a recipient marks a message as spam, files a carrier complaint, or reports a call as unwanted, we will be notified. If your account exceeds any of the following thresholds, you will receive a warning email requesting an explanation and providing guidance: spam-complaint rate greater than 0.1% of all delivered communications (10 complaints per 10,000 recipients); bounce or failed-delivery rate greater than 4%; email unsubscribe rate greater than 2%; SMS opt-out rate greater than 3%; voice-call "do not call again" or negative-sentiment rate greater than 5%. Higher levels of complaints, bounces, or opt-outs will result in accounts being flagged as spamming, throttled, locked, or terminated. Receiving two or more warning emails within a 3-month period will result in your account being locked or terminated and any promotional discounts or extra features being revoked. - Our team may review or audit contact lists, call scripts, AI voice-agent prompts, or recipient files imported into the Services. - Callsy monitors carrier blacklists, ISP feedback loops, and our internal abuse warning system on an ongoing basis. We can readily pinpoint customers causing delivery problems or generating complaints. - If Callsy detects that your contact list contains one or more spam traps, known seeded numbers, or honeypot addresses, you will be required to clean your list. If you fail to do so within the period we specify, your account will be locked or terminated. A "spam trap" is an address or number used to identify illegitimate senders who add recipients to their lists without permission, or marketers with poor permission and list-management practices. Callsy will assist with list cleaning through written instructions and guidance from our support team, and in some cases through paid list-cleaning services.

If we discover that the Customer is sending Spam, placing unsolicited AI voice calls, or otherwise breaching any rule of this Policy, we reserve the right to suspend or terminate the Customer's Callsy account immediately and without prior notice.

Contacts

If you have any questions about this Anti-Spam Policy, or if you want to report spamming, unsolicited calling, or other abusive activity by one of our customers, please contact us:

Callsy AI OÜ (trading as Callsy)

Attn. Legal Department

Republic of Estonia

Email: support@callsy.ai

We respond to all abuse reports within 2 business days and typically within hours during European working time. Material reports may be escalated to the recipient's carrier or to data-protection regulators where required.