SmartAlex Outbound Calling and Telemarketing Policy

Version 1.0 · Effective July 8, 2026 · THERCSGROUP PTE. LTD. (trading as SmartAlex, Singapore Reg. No. 202543608D)

1. Purpose and scope

This Outbound Calling and Telemarketing Policy (this "Policy") explains the rules that apply when customers use THERCSGROUP PTE. LTD., trading as SmartAlex ("SmartAlex", "we", "us", or "our"), and the SmartAlex platform, websites, applications, and APIs (the "Services"), to place outbound calls.

SmartAlex provides an artificial intelligence voice agent platform. Customers use the Services to design, configure, and place outbound telephone calls using AI voice agents. This Policy sets out the rules that a customer must follow when it uses the Services for outbound calling or telemarketing.

We provide the platform. The Customer designs and runs its own calling campaigns and is responsible for those campaigns and for its own legal compliance. This Policy applies to every Customer, user, and campaign that places outbound calls through the Services, and it applies alongside the Acceptable Use Policy and the other documents cross-referenced below.

1.1 Not legal advice

This Policy is a description of platform rules and general compliance expectations. It is not legal advice and does not tell the Customer what the law requires of it in any particular case. Telemarketing, consent, and do-not-call rules vary by country, state, and industry and change over time. The Customer is responsible for determining which laws apply to its campaigns and for obtaining its own advice where needed.

2. Customer responsibility and lawful basis

The Customer decides who to call, what to say, and when to call. The Customer is the party that determines the purpose and means of each campaign, and it is responsible for the calls it places through the Services.

2.1 Lawful basis and permission

Before placing outbound calls, the Customer must have a valid lawful basis to contact each recipient and must hold any consent or permission that applicable law requires for the type of call being made. Depending on the jurisdiction and the nature of the call, this may include:

1. a lawful basis to process the recipient's personal information for the purpose of the call;
2. any consent or opt-in that applicable direct marketing or telemarketing law requires;
3. compliance with restrictions on automated dialling and pre-recorded or artificial voice calls; and
4. compliance with registration, licensing, or disclosure obligations that apply to the Customer's industry or calling activity.

The Customer must not upload, target, or call numbers that it does not have a lawful basis to contact.

3. Consent and prior express consent

Where applicable law requires consent before a call may be placed, the Customer must obtain that consent before using the Services to call the recipient. Some laws require a heightened form of consent for certain calls. For example, in the United States the Telephone Consumer Protection Act ("TCPA") generally requires prior express consent, and prior express written consent for certain marketing calls, before autodialled or pre-recorded or artificial voice calls may be placed to particular numbers.

3.1 Obtaining and recording consent

Where consent is required, the Customer must:

1. obtain the consent in the form and manner that applicable law requires before the call is placed;
2. keep accurate records of the consent, including who consented, what they consented to, and when and how the consent was given;
3. be able to produce those records if a recipient, a regulator, or SmartAlex asks the Customer to substantiate consent; and
4. stop calling a recipient who withdraws consent.

SmartAlex does not obtain consent on the Customer's behalf and does not verify the Customer's consent records. Responsibility for consent rests with the Customer.

4. Do-not-call and suppression

The Customer must honour applicable do-not-call requirements. In the United States this includes screening against and honouring the National Do Not Call Registry where it applies to the call, in addition to any state registries. Across all jurisdictions, the Customer must maintain and honour its own internal do-not-call and opt-out lists.

4.1 Processing opt-outs and maintaining suppression

1. The Customer must offer recipients a clear way to opt out of further calls where applicable law requires it.
2. The Customer must process opt-out and do-not-call requests promptly and within any timeframe that applicable law sets.
3. The Customer must maintain a suppression list of numbers that have opted out or that must not be called, and must screen campaigns against that list before dialling.
4. The Customer must not attempt to defeat, remove, or work around suppression in order to reach a recipient who has opted out.

5. Calling times and identification

The Customer must place calls only within the hours permitted by applicable law for the recipient's location, and must respect any curfew or time-of-day restrictions that apply to telemarketing in that jurisdiction.

5.1 Caller identification

1. The Customer must identify the caller and, where required, the purpose of the call, and must provide the name of the business on whose behalf the call is made.
2. The Customer must transmit accurate caller identification and must not spoof, falsify, or misrepresent the calling number or the identity of the caller.
3. The Customer must not disguise, alter, or obscure caller identity information in a way that misleads the recipient or that breaches applicable caller identification law.

6. AI voice disclosure

Calls placed through the Services use an AI voice agent with a synthetic voice. Where applicable law requires it, the Customer must disclose to the recipient that the call uses an artificial intelligence system and a synthetic or artificial voice, and must do so in the manner and at the time that the law requires.

SmartAlex provides disclosure controls and guidance to support this. The Customer's obligations for synthetic voice and AI disclosure are set out in the Synthetic Media and AI Voice Disclosure Policy, and identification and recording matters are addressed in the Telephony and Call Recording Notice. The Customer is responsible for configuring and delivering the disclosures that apply to its campaigns.

7. Recording and monitoring

Where a call is recorded or monitored, the consent and notice requirements that apply to recording are governed by the Telephony and Call Recording Notice. The Customer must comply with that Notice and with the recording, consent, and notification laws of each jurisdiction involved in the call, including any requirement to obtain the consent of one or all parties before recording.

7.1 South Africa

For calls involving South Africa, the position on interception and monitoring of communications is addressed in the South African Electronic Communications Notice. The Customer must comply with that Notice in addition to this Policy.

8. Jurisdiction summary

The table below is a high-level summary of some key rules a Customer may need to follow in certain jurisdictions. It is not exhaustive, it is not legal advice, and it does not replace the Customer's own assessment of the laws that apply to its campaigns. The interpretation of some rules is developing and the Customer remains responsible for determining its own obligations.

9. Prohibited campaigns

The Customer must not use the Services to place calls that are unlawful, deceptive, fraudulent, harassing, or otherwise abusive. Prohibited activity includes, without limitation:

1. calls that impersonate a person, business, or authority, or that make false or misleading claims;
2. calls made for fraud, scams, phishing, or the deceptive collection of money or personal information;
3. harassing, threatening, or repeated unwanted calls to a recipient; and
4. high-volume or abusive calling patterns, including calling designed to overwhelm, disrupt, or evade suppression and consent controls.

These restrictions apply in addition to the prohibitions in the Acceptable Use Policy.

10. Enforcement

If a Customer breaches this Policy, or if we reasonably believe that a campaign is unlawful, abusive, or creates a risk to recipients, to third parties, to the Services, or to SmartAlex, we may take action to protect the Services and others. This may include limiting, suspending, throttling, or terminating outbound calling, a campaign, or access to the Services, with or without notice depending on the circumstances. We may also take the steps described in the Acceptable Use Policy and the Customer's agreement with us.

11. Relationship to other documents

This Policy should be read together with the following documents, which govern the matters they describe:

1. the Acceptable Use Policy, for prohibited uses of the Services;
2. the Telephony and Call Recording Notice, for call recording consent and notice;
3. the South African Electronic Communications Notice, for the South African interception position;
4. the South African Consumer Protection Act Notice, for South African consumer protection matters;
5. the Synthetic Media and AI Voice Disclosure Policy, for synthetic voice and AI disclosure;
6. the Privacy Policy, for how personal information is handled; and
7. the Subprocessor List, for the providers that support the Services.

If there is a conflict between this Policy and the Customer's signed agreement with us, that agreement governs to the extent of the conflict.

12. Updates and contact

We may update this Policy from time to time to reflect changes in the Services, in law, or in regulatory guidance. When we make material changes, we will update the version and effective date below. The Customer's continued use of the Services after an update takes effect means the Customer accepts the updated Policy.

For questions about this Policy, contact us at support@getsmartalex.com for general support, or legal@getsmartalex.com for legal and compliance matters.

This Policy is issued by THERCSGROUP PTE. LTD. (UEN 202543608D), 160 Robinson Road, #14-04 Singapore Business Federation Center, Singapore 068914, and is governed by the laws of the Republic of Singapore.

13. Version and effective date

This Outbound Calling and Telemarketing Policy is version 1.0 and is effective from 8 July 2026.