# Zing — AI Disclosure and Recording Consent Policy

**Effective Date:** June 16, 2026
**Last Updated:** June 16, 2026

**Open item PA-01:** The all-party consent state list and disclosure scripts below are based on our research as of this date. This policy **must be reviewed by qualified legal counsel** before production launch. State laws change frequently and carrier/regulator interpretations vary.

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## 1. AI Phone Agent Disclosure

When you call a phone number powered by Zing:

**You are speaking with an AI.** The Zing voice agent is an automated artificial intelligence system, not a human. The agent is powered by:
- Large Language Model (LLM) for conversation
- Automated Speech Recognition (ASR) for understanding your voice
- Text-to-Speech (TTS) for generating the agent's voice

### Disclosure at Call Start

The AI agent identifies itself as automated at the start of every call:

**English:**
> "Hi, this is Zing, an AI assistant for [Business Name]. I'm an automated system. How can I help you today?"

**Spanish:**
> "Hola, soy Zing, un asistente de IA de [Nombre del negocio]. Soy un sistema automatizado. ¿En qué puedo ayudarte?"

This disclosure satisfies:
- California AB 302 (Chatbot Disclosure Act): AI must identify itself as automated before the conversation continues.
- Federal Trade Commission guidance on AI/chatbot transparency.
- Similar state-level requirements.

### Human Transfer

If you request to speak with a human, the AI agent will:
1. Acknowledge your request
2. Offer to log a callback request (name + phone number)
3. Close the call professionally

The agent does NOT falsely claim to be human at any point.

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## 2. Call Recording

### 2.1 General Policy

Calls to Zing-powered phone numbers may be recorded for:
- Quality assurance and agent improvement
- Dispute resolution
- Legal compliance

### 2.2 One-Party vs. All-Party Consent States

The United States has different laws regarding call recording consent:

**One-party consent states:** One party to the conversation (Zing, as the platform operator) may record without explicit consent from all parties. Calls are recorded by default in these states.

**All-party consent states (also called two-party consent states):** Recording requires the explicit consent of all parties to the conversation.

#### All-Party Consent States (current as of June 2026)

| State | Statute |
|-------|---------|
| California | Penal Code §632 |
| Connecticut | C.G.S. §52-570d |
| Florida | F.S. §934.03 |
| Illinois | 720 ILCS 5/14-2 |
| Maryland | Md. Code, Cts. & Jud. Proc. §10-402 |
| Massachusetts | M.G.L. c. 272 §99 |
| Michigan | M.C.L. §750.539c |
| Montana | M.C.A. §45-8-213 |
| Nevada | N.R.S. §200.620 |
| New Hampshire | N.H.R.S.A. §570-A:2 |
| Oregon | O.R.S. §165.540 |
| Pennsylvania | 18 Pa. C.S.A. §5703 |
| Washington | R.C.W. §9.73.030 |

**PA-01 NOTE:** This list reflects our current research. It must be verified by legal counsel. Some states have nuanced interpretations (e.g., business vs. personal calls, federal preemption arguments). Do not treat this as legal advice.

### 2.3 Recording Consent Script (All-Party States)

When a call originates from an all-party consent state (detected by caller's area code or SIP metadata):

> "This call may be recorded for quality assurance. By continuing, you consent to being recorded. If you do not consent, please say 'no recording' and I'll note your preference."

If the caller says "no recording":
- Recording is disabled for this session
- `recording_consent: false` is logged in `voice_sessions`
- The call continues normally without recording

### 2.4 Recording Consent Logging

Every voice session records:
- `recording_consent_state` — the detection method used
- `recording_consent` — whether consent was obtained
- `disclosure_type` — the disclosure variant played

This audit trail supports compliance documentation.

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## 3. SMS Consent

### 3.1 Transactional SMS (No Separate Opt-in Required)

By providing your phone number and placing an order, you consent to receive transactional SMS:
- Order confirmation
- Order status updates
- Receipt of purchase

CTIA and TCPA guidelines allow transactional SMS without explicit marketing opt-in.

### 3.2 Marketing SMS Opt-In

Marketing SMS requires affirmative opt-in. The Zing checkout page includes:

> [ ] Text me order updates and occasional specials from [Business Name]. Message & data rates may apply. Reply STOP to opt out.

**This checkbox is NOT pre-checked.** Pre-checking would violate TCPA requirements.

Consent is logged with:
- Timestamp (`sms_opt_in_at`)
- IP address
- Session reference
- Consent text shown at time of opt-in (version-controlled)

### 3.3 Verbal Opt-In (Phone Agent)

During phone orders, the AI agent may ask:
> "Would you like to receive a text confirmation for your order?"

If the customer confirms verbally:
- `sms_opt_in: true` is recorded
- Consent type is set to `verbal`
- Voice session ID is logged as consent reference

### 3.4 Opt-Out Handling

**STOP keyword:** Twilio processes all inbound STOP/UNSUBSCRIBE/CANCEL/QUIT/END keywords automatically and sets `sms_opt_in: false`. Zing also processes a webhook to sync opt-out to the customer record in the database. Opt-out is permanent until the customer re-opts-in.

**HELP keyword:** Returns: "Zing: Reply STOP to unsubscribe. For help: support@zing.app"

### 3.5 10DLC Campaign Registration

Before sending SMS to US numbers on major carriers (AT&T, Verizon, T-Mobile), Zing registers:
- Brand registration with The Campaign Registry (TCR)
- Campaign use case: Transactional + Marketing
- Opt-in documentation: Web checkbox + verbal consent script

**This registration must be completed before pilot launch (T9.3).**

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## 4. Open Items (Pre-Launch Blockers)

| Flag | Description | Owner | Resolution |
|------|-------------|-------|-----------|
| PA-01 | All-party consent state list needs legal review | Legal Counsel | Verify state list + obtain opinion letter |
| PA-02 | TTS voice IDs not finalized (Cartesia sonic-english voice selection) | Product | Select from Cartesia catalog + test |
| PA-03 | 10DLC registration not yet submitted | Operations | Register brand + campaigns pre-launch |
| PA-04 | Recording consent state detection: area code heuristic may misfire (VoIP numbers) | Engineering | Implement more robust detection; consider consent-by-default |

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*This document was prepared by Zing for internal compliance reference. Consult qualified legal counsel before production launch.*