TCPA Compliance Policy

Effective Date: March 5, 2026 · Last Updated: March 5, 2026

1. Overview

LLMs At Work ("Company," "we," "us," or "our") provides AI-powered voice agent services to local businesses, including salons, auto shops, restaurants, and flower shops. Our AI agents answer inbound phone calls, book appointments, take orders, and answer frequently asked questions on behalf of our business clients.

We are committed to full compliance with the Telephone Consumer Protection Act (47 U.S.C. § 227) ("TCPA"), related FCC regulations, the Telemarketing Sales Rule ("TSR"), and applicable state telemarketing and AI-disclosure laws. This policy describes how we and our business clients protect consumers in every AI-powered phone interaction.

2. How Our Service Works

Understanding our service model is important for understanding our compliance obligations:

• Inbound call answering (primary use case): Our AI voice agents answer incoming calls placed by consumers to our business clients. Because these calls are initiated by the consumer, they are not subject to the TCPA's restrictions on outbound automated calls. The FCC has explicitly excluded inbound AI call answering from its proposed "AI-generated call" definition.
• Outbound calls (appointment reminders, follow-ups): When our AI agents make outbound calls on behalf of a business client—such as appointment confirmations, reminders, or follow-up calls—full TCPA consent and compliance requirements apply. These calls are subject to all provisions described in this policy.

3. Consent Requirements

3.1 Our Obligations to Business Clients

Before activating AI voice agent services for any business client, we require:

• A signed service agreement that includes TCPA compliance representations and warranties
• The client's acknowledgment that they are responsible for obtaining appropriate consumer consent before we make outbound calls on their behalf
• Agreement to our Acceptable Use Policy, which prohibits non-compliant use of the platform
• An indemnification clause covering TCPA claims arising from the client's failure to obtain proper consent

3.2 Business Client Obligations to Consumers

Our business clients must obtain the following consent from their customers before we make outbound AI calls on their behalf:

• Non-marketing calls (appointment reminders, order confirmations): Prior express consent from the consumer, which may be oral or written. Providing a phone number in the context of scheduling an appointment or placing an order constitutes prior express consent for related informational calls.
• Marketing or promotional calls (special offers, promotions): Prior express written consent that clearly discloses the use of automated/AI-generated calls, identifies the business on whose behalf calls will be made, and states that consent is not a condition of purchase. The written consent must bear the consumer's signature (electronic signatures that comply with the E-SIGN Act are acceptable).

We provide our business clients with compliant consent language templates and guidance materials to facilitate proper consent collection.

3.3 Consent Record-Keeping

Our business clients are required to maintain records of consumer consent. We maintain audit logs of all outbound calls made through our platform, including timestamps, phone numbers, call type, and the business client on whose behalf the call was made.

4. Do-Not-Call Compliance

4.1 National Do Not Call Registry

Before making any outbound telemarketing call, we scrub call lists against the National Do Not Call Registry maintained by the FTC. Numbers registered on the National DNC list are not called for marketing purposes unless the consumer has provided prior express written consent or has an established business relationship with our client.

4.2 Internal Do-Not-Call Lists

We maintain an internal do-not-call list for each business client. When a consumer requests not to be called—whether during a call, via email, or through any other reasonable means—we add their number to the internal DNC list and honor that request indefinitely. Opt-out requests are processed within 10 business days, as required by FCC rules.

4.3 Entity-Specific DNC

Do-not-call requests are honored on a per-business basis. If a consumer asks one of our clients to stop calling, that request applies to calls from that specific business. The consumer's relationship with other businesses on our platform is not affected.

5. Calling Hours

All outbound calls made through our platform comply with federal and state calling-time restrictions:

• Federal: Outbound telemarketing calls are placed only between 8:00 AM and 9:00 PM in the recipient's local time zone.
• State: Where state law imposes stricter calling windows, we follow the more restrictive standard.

Our platform enforces calling-time restrictions automatically based on the recipient's area code and geographic location.

6. AI Disclosure

6.1 Federal Requirements

In February 2024, the FCC confirmed that AI-generated voices are "artificial voices" under the TCPA, meaning all existing TCPA restrictions on prerecorded/artificial voice calls apply to AI voice calls. The FCC has also proposed rules (FCC 24-84) that would require clear AI disclosure at the beginning of each AI-generated outbound call.

We comply with both the current ruling and proactively implement the proposed disclosure requirements. Our AI voice agents identify themselves as AI at the beginning of each outbound call.

6.2 State Requirements

Several states have enacted their own AI disclosure laws. We comply with all applicable state requirements, including:

• Texas (SB 140): Disclosure of AI within the first 30 seconds of a call, offer to transfer to a live agent, and request for permission to continue with AI.
• California (AB 2905): Disclosure of AI involvement in phone calls.
• Other state laws as enacted and applicable.

6.3 Our Standard Practice

Regardless of whether a call is inbound or outbound, our AI voice agents:

• Identify themselves as an AI assistant at the start of each call
• Identify the business they are calling on behalf of
• Provide a callback number for the business
• Offer to transfer to a human representative when requested or when appropriate

7. Your Rights as a Consumer

If you receive a call from one of our AI voice agents, you have the following rights:

7.1 Right to Opt Out

You can opt out of receiving automated calls at any time by:

• Telling the AI agent during the call that you do not wish to receive further calls
• Using any of the following keywords: "stop," "quit," "end," "opt out," "cancel," or "unsubscribe"
• Calling the business directly and requesting to be placed on their do-not-call list
• Emailing us at hello@llmsatwork.com with the subject line "Do Not Call"

Opt-out requests are processed within 10 business days and honored indefinitely.

7.2 Right to Speak with a Human

You may request to be transferred to a human representative at any point during a call with our AI agent. If a human representative is available, the transfer will be made immediately. If no one is available, your information will be relayed so the business can return your call.

7.3 Right to Know

You have the right to know that you are speaking with an AI system. Our agents will always identify themselves as AI when asked.

8. Data Handling and Privacy

Phone call data processed through our platform is handled in accordance with our Privacy Policy. Key practices include:

• Call recordings and transcripts are stored securely and retained only as long as necessary to provide services or meet legal obligations
• Consumer phone numbers collected during calls are used solely for the purpose of providing the requested service
• We do not sell consumer phone numbers or call data to third parties
• Consent records and opt-out requests are maintained in secure, auditable systems
• Business clients may access their own call data but not the data of other businesses on the platform

9. Technical Safeguards

We implement the following technical measures to enforce compliance:

• Automated calling-time restrictions based on recipient time zone
• DNC list integration and automatic scrubbing before outbound calls
• Opt-out keyword detection during calls with automatic processing
• Call volume limits to prevent misuse
• Comprehensive audit logging of all outbound calls
• AI disclosure built into all voice agent configurations

10. Enforcement and Client Accountability

We take compliance seriously and reserve the right to:

• Suspend or terminate service for any business client that violates this policy or applicable telemarketing laws
• Audit business client usage for compliance with consent and DNC requirements
• Require additional documentation of consent collection practices
• Report suspected illegal robocalling activity to the FCC

11. Complaints and Questions

If you have a complaint about an unwanted call from one of our AI agents, or questions about this policy, please contact us:

Email: hello@llmsatwork.com

Phone: (918) 255-0379

Address: Austin, TX

You may also file a complaint with the Federal Communications Commission (FCC) or the Federal Trade Commission (FTC).

12. Policy Updates

We may update this policy as regulations evolve. Changes will be reflected in the "Last Updated" date above. We monitor FCC rulemaking, state legislation, and judicial decisions to ensure ongoing compliance.