Acceptable Use Policy

SmartCallPro is operated by:

• KF Consulting s.r.o.
• Žirovnická 3133/6, Praha 10, 106 00, Czechia
• IČO: 09021680
• Email: compliance@smartcallpro.cz
• Website: https://smartcallpro.cz

This policy applies to all clients who use SmartCallPro's Smart Call Assistant service, including all service tiers — Starter, Business, and Pro. It applies to all instructions provided to Smart Call Pro regarding the configuration, scripting, and operation of the Smart Call Assistant on the client's behalf.

Clients may use SmartCallPro's services to:

• Answer and manage inbound telephone calls to their business
• Capture caller information and enquiry details on their behalf
• Route calls and send notifications to appropriate staff or departments
• Automate follow-up communications to callers in connection with genuine business enquiries
• Provide callers with accurate information about the client's business, services, and contact details
• Book appointments and capture leads in connection with the client's legitimate business activities
• Integrate call data with the client's authorised CRM, calendar, or business management systems

Clients must not instruct or attempt to instruct SmartCallPro to use the Smart Call Assistant in any of the following ways:

4.1 Misrepresentation and deception

• Instructing the Smart Call Assistant to identify itself as a human being to callers
• Suppressing, removing, modifying, or circumventing the mandatory AI disclosure statement delivered at the start of every call
• Impersonating any individual, business, government body, or authority other than the client's own business
• Providing callers with false, misleading, or inaccurate information about the client's products, services, pricing, or identity
• Using the Smart Call Assistant to conduct fraudulent activity of any kind

4.2 Harassment and harm

• Using the Smart Call Assistant to harass, intimidate, threaten, or abuse callers
• Engaging in any conduct that could cause distress, harm, or offence to callers
• Using the Smart Call Assistant to contact individuals who have opted out of or objected to contact from the client
• Using the Smart Call Assistant for debt collection in a manner that violates applicable consumer protection law

4.3 Unlawful activity

• Using the Smart Call Assistant for any purpose that violates applicable EU, Czech, or international law
• Using the Smart Call Assistant to facilitate or enable criminal activity of any kind
• Using the Smart Call Assistant to collect personal data without a valid legal basis under the GDPR
• Using the Smart Call Assistant to process special category personal data without appropriate safeguards and explicit consent mechanisms in place
• Using the Smart Call Assistant in connection with any activity that violates the EU AI Act or any other applicable AI regulation

4.4 Spam and unsolicited communications

• Using the Smart Call Assistant to make unsolicited outbound calls to individuals who have not consented to receive them
• Using the Smart Call Assistant to send unsolicited SMS messages to individuals who have not opted in to receive them
• Using the Smart Call Assistant as part of any mass marketing or robocalling campaign without the prior written approval of SmartCallPro

4.5 Data misuse

• Instructing SmartCallPro to collect, store, or transmit personal data beyond what is necessary for the legitimate business purpose of the call
• Using call transcripts, summaries, or caller data for any purpose other than the client's own legitimate business operations
• Sharing, selling, or transferring caller data obtained through the Smart Call Assistant to any unauthorised third party
• Using caller data to build marketing lists, profiles, or databases without the explicit consent of the individuals concerned

4.6 Regulatory and compliance violations

• Using the Smart Call Assistant in any regulated sector, including financial services, healthcare, or legal services, in a manner that violates sector-specific regulatory requirements without ensuring appropriate compliance measures are in place
• Using the Smart Call Assistant to provide regulated advice, including financial, legal, or medical advice, without appropriate authorisation and disclaimers
• Instructing SmartCallPro to operate in a manner that would cause SmartCallPro to violate any applicable law, regulation, or regulatory guidance

4.7 Reputational harm

• Using the Smart Call Assistant in connection with any activity that is defamatory, discriminatory, or offensive
• Using the Smart Call Assistant in a manner that could bring SmartCallPro into disrepute or cause reputational harm to SmartCallPro or its other clients
• Using the Smart Call Assistant in connection with content or activities that promote hatred, violence, or discrimination on the basis of race, ethnicity, religion, gender, sexual orientation, disability, or any other protected characteristic

All call scripts and configuration instructions provided to SmartCallPro must:

• Be accurate and truthful in all material respects
• Comply with all applicable laws and regulations
• Not instruct the Smart Call Assistant to make false or misleading statements to callers
• Not instruct the Smart Call Assistant to collect personal data beyond what is necessary for the stated purpose
• Include an accurate description of the client's business, services, and call handling preferences
• Not instruct the Smart Call Assistant to suppress or modify the mandatory AI disclosure statement

SmartCallPro reserves the right to review, modify, or refuse to implement any script or configuration instruction that it reasonably believes violates this policy, the EU AI Act, the GDPR, or any other applicable law or regulation. SmartCallPro will notify the client of any such refusal and the reason for it.

All clients must use SmartCallPro's services in a manner consistent with Regulation (EU) 2024/1689, the EU Artificial Intelligence Act. In particular, clients must not:

• Instruct SmartCallPro to suppress the mandatory caller disclosure required under Article 50 of the EU AI Act
• Use the Smart Call Assistant for any purpose classified as prohibited or high risk under the EU AI Act without ensuring full compliance with applicable requirements
• Instruct SmartCallPro to use the Smart Call Assistant for biometric identification, emotion recognition, or real-time surveillance of callers

SmartCallPro's full EU AI Act compliance obligations are set out in the EU Transparency & AI Compliance Policy at https://smartcallpro.cz/eu-ai-compliance.

Clients must notify SmartCallPro immediately if they become aware of:

• Any use of the Smart Call Assistant that may violate this policy
• Any caller complaint or regulatory enquiry relating to the Smart Call Assistant
• Any data breach or security incident involving call data or caller personal data
• Any change in the client's business activities that may affect the permitted use of the Smart Call Assistant

Notifications should be sent to compliance@smartcallpro.cz.

SmartCallPro takes violations of this policy seriously. Where SmartCallPro reasonably believes that a client has violated or is violating this policy, SmartCallPro reserves the right to take any or all of the following actions:

• Issue a written warning requiring immediate cessation of the prohibited activity
• Suspend the Smart Call Assistant service immediately and without notice where the violation poses an immediate risk to callers, third parties, or SmartCallPro
• Terminate the Client Service Agreement in accordance with the termination provisions therein
• Report the violation to the relevant supervisory authority, including the Office for Personal Data Protection (UOOU), the European AI Office, or law enforcement agencies, where required by law or where SmartCallPro considers it appropriate in the public interest
• Pursue recovery of any losses, costs, or damages incurred by SmartCallPro as a result of the violation

Where SmartCallPro suspends or terminates the service due to a policy violation by the client, all fees accrued up to the date of suspension or termination remain payable. No refunds will be issued in respect of any period during which the service was suspended or terminated due to client violation of this policy.

SmartCallPro commits to:

• Configuring and operating the Smart Call Assistant only in accordance with the client's lawful instructions and this policy
• Refusing to implement instructions that violate this policy, the EU AI Act, the GDPR, or any other applicable law
• Notifying clients promptly where SmartCallPro becomes aware of any use of the service that may violate this policy
• Maintaining appropriate technical and organisational safeguards to prevent misuse of the Smart Call Assistant

SmartCallPro reserves the right to amend this Acceptable Use Policy at any time. Updated versions will be published at https://smartcallpro.cz with a revised effective date. Clients will be given thirty (30) days written notice of any material changes. Continued use of the service after the notice period constitutes acceptance of the updated policy.

This Acceptable Use Policy is governed by the laws of the Czech Republic. Any disputes arising from or in connection with this policy shall be subject to the exclusive jurisdiction of the competent courts of the Czech Republic.

To report a suspected violation of this policy or for any questions relating to acceptable use of SmartCallPro's services, please contact us:

• SmartCallPro — operated by KF Consulting s.r.o.
• Email: compliance@smartcallpro.cz
• Website: https://smartcallpro.cz
• Registered address: Žirovnická 3133/6, Praha 10, 106 00, Czechia
• IČO: 09021680