SmartAlex Synthetic Media and AI Voice Disclosure Policy
1. Purpose and scope
This Synthetic Media and AI Voice Disclosure Policy (this "Policy") explains how THERCSGROUP PTE. LTD., trading as SmartAlex ("SmartAlex", "we", "us", or "our"), uses synthetic voices and other AI-generated media, and what customers must do when they configure and operate AI voice agents, in connection with the SmartAlex platform, websites, applications, and APIs (the "Services").
This Policy covers two things: the synthetic text-to-speech voices that power AI voice agents on the Services, and other AI-generated audio or media produced through the Services. It sets out how those voices are created, what disclosure is expected of the people who deploy them, and the uses that are prohibited. It does not repeat the data-protection or recording detail owned by our other documents; it points to them instead.
This Policy supplements our AI Usage Policy, our Acceptable Use Policy, our Telephony and Call Recording Notice, our EU AI Act Transparency Notice, and our Privacy Policy. Where those documents govern a topic in more detail, they control on that topic.
This Policy is a statement of how SmartAlex approaches synthetic media and AI voice disclosure. It is not legal advice, and it does not vary any negotiated agreement between SmartAlex and a customer. Where there is a conflict between this Policy and such an agreement, that agreement prevails as between SmartAlex and the customer. In this Policy, "Customer" means the business that holds a SmartAlex account and configures and operates the Services, and "End User" means a person the Customer interacts with through the Services, such as the person at the other end of a call.
2. Our use of synthetic voices
AI voice agents on the Services speak using pre-built synthetic text-to-speech voices. These are ready-made voices generated by our text-to-speech provider. They are selected by the Customer from the options we make available; they are not modelled on, and are not intended to reproduce, the voice of any specific identifiable person.
SmartAlex does not offer a feature that lets a Customer upload a recording of a person in order to clone or recreate that specific real person's voice. There is no customer-facing voice-cloning capability on the Services. A Customer cannot supply a voice sample to the Services and have an agent speak in the cloned voice of a named individual.
The synthetic voices are produced by our text-to-speech provider, and the surrounding speech recognition and language processing are provided by our speech and language AI providers. We engage these providers as subprocessors. The current list of subprocessors is published at our Subprocessor List. We do not publish the underlying vendor names in this Policy; the Subprocessor List is the source of truth for who those providers are at any time.
3. AI disclosure
Where disclosure is required by applicable law, or is expected as a matter of good practice, End Users should be informed that they are interacting with an AI system and that the voice they hear is a synthetic voice, not a recording of a live human agent. The Services are designed so that a Customer can present this disclosure at or near the start of an interaction.
Disclosure obligations differ by jurisdiction and by use case. The Customer is responsible for determining what disclosure is required in each jurisdiction in which it operates, and for configuring the Services so that the appropriate disclosure is given to its End Users. SmartAlex provides the tooling to make disclosure; the Customer decides on and configures the wording and timing to fit its own legal position.
For the transparency obligations that can apply to AI systems that interact with natural persons, and for the specific expectations around informing callers, see our EU AI Act Transparency Notice and our Telephony and Call Recording Notice.
4. Prohibited uses
The Customer must not use, and must not permit any person to use, synthetic voices or AI-generated media produced through the Services to do any of the following:
- impersonate a specific, identifiable real person without that person's documented and verifiable consent;
- deceive any person about the artificial nature of the voice or the agent in any situation where disclosure of that artificial nature is required by law or is reasonably expected;
- create political deception, or produce or distribute deepfakes intended to mislead about the words or conduct of a real person, candidate, official, or organisation;
- generate non-consensual intimate, sexual, or sexualised synthetic content depicting any person;
- commit or facilitate fraud or a scam, or circumvent, defeat, or attempt to defeat identity verification, authentication, or know-your-customer controls;
- engage in any use that is unlawful, harassing, abusive, threatening, or that otherwise breaches our Acceptable Use Policy.
These prohibitions are in addition to, and do not narrow, the restrictions in our Acceptable Use Policy and our AI Usage Policy.
5. Customer responsibilities
The Customer is responsible for the lawful and disclosed use of synthetic voices and AI-generated media in its own campaigns and interactions. In particular, the Customer is responsible for:
- obtaining any consent that is needed for the way it uses synthetic voices or AI-generated media, including any consent required before impersonating or referencing a specific person;
- configuring the disclosures its End Users receive, so that people are told they are interacting with an AI system and a synthetic voice where that is required or expected;
- complying with the synthetic-media, AI-disclosure, consumer-protection, and telemarketing laws of every jurisdiction in which it operates;
- ensuring that it does not use the Services in any way prohibited by Section 4 of this Policy or by our other policies.
The Customer decides who is contacted, what its agents say, and what content its campaigns carry. As between SmartAlex and the Customer, the Customer is responsible for its own campaigns and content.
6. Provenance and marking
Some jurisdictions require AI-generated audio or media to be marked, labelled, or otherwise disclosed as artificial, whether through an audible statement, a written label, or an embedded machine-readable marker. Where applicable law imposes such a requirement on a Customer's use of the Services, the Customer must ensure that the required marking or disclosure is provided to its End Users.
SmartAlex will support disclosure and, where we make provenance or marking features available, will make them available through the Services; the responsibility for determining what marking the law requires, and for ensuring it is applied, rests with the Customer. For the related transparency expectations, see our EU AI Act Transparency Notice.
7. Enforcement
We may investigate suspected breaches of this Policy. Where we reasonably believe that a Customer, or a person acting through a Customer's account, has breached this Policy or our Acceptable Use Policy, we may suspend, restrict, or limit access to the Services or to specific features, in whole or in part, and may take further action in accordance with the applicable agreement between us. We will act proportionately and, where practicable, will give notice, but we may act without prior notice where there is a risk of harm, unlawful conduct, or continuing abuse.
8. Relationship to other terms
This Policy supplements, and should be read together with, our AI Usage Policy, our Acceptable Use Policy, our Telephony and Call Recording Notice, and our EU AI Act Transparency Notice. It does not replace any of them. Nothing in this Policy limits or excludes any right that cannot be limited or excluded under the law that applies to you.
9. Updates and contact
We may update this Policy from time to time to reflect changes in the Services, in the synthetic-media and AI-disclosure landscape, or in applicable law. When we make a material change, we will update the version and effective date below.
For questions about the Services or about configuring disclosures, contact support@getsmartalex.com. For questions about this Policy, contact legal@getsmartalex.com. For questions about how we handle personal data, contact privacy@getsmartalex.com.
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.
10. Version and effective date
This Synthetic Media and AI Voice Disclosure Policy is version 1.0 and is effective from 8 July 2026.