Smileline

US Communications Compliance Addendum

Who is responsible for consent when Smileline calls, texts or emails a patient in the United States — accepted by the practice owner during onboarding.

Version 2026-08-30 · Last updated 30 August 2026

This US Communications Compliance Addendum (the "Addendum") supplements the Terms of Service between Smileline Technologies Ltd, company number 17408336, registered in England and Wales with its registered office at 1 Lyric Square, London, England, W6 0NB ("Smileline"), and a practice in the United States (the "Practice").

US calling, texting and email law puts the duty to hold consent on the Practice, but puts the damages within reach of the platform that placed the call. This Addendum says plainly who is responsible for what, and what the Practice must have in place before it uses these features.

1. What the Practice is responsible for

The Practice decides who to contact, on what basis, and what to say. Smileline supplies the tools. The Practice is responsible for complying with, and warrants that it complies with:

  • the Telephone Consumer Protection Act (47 USC 227) and the FCC's rules at 47 CFR 64.1200, including the requirement for prior express written consent before an autodialled or artificial- or prerecorded-voice call, and before a marketing text, to a wireless number;
  • the National Do Not Call Registry and applicable state do-not-call registries, and the requirement to maintain an internal do-not-call list and a written do-not-call policy;
  • the rule that telephone solicitations may only be made between 8am and 9pm in the called party's local time;
  • applicable call-recording consent law. Federal law permits one-party consent, but roughly a dozen states — California (Penal Code §632, which carries a private right of action), Washington, Illinois, Pennsylvania, Florida, Massachusetts, Maryland, Montana, Nevada, New Hampshire, Connecticut, Michigan and Oregon among them — require the consent of all parties, on the law of the called party's location as well as the Practice's own;
  • the CAN-SPAM Act for commercial email, including accurate headers, a functioning opt-out honoured within ten business days, and a valid physical postal address in every message;
  • state mini-TCPA statutes, and any telephone-solicitor registration its state requires.

The Practice warrants that it holds the consent each contact requires before it uses the Service to make it, that it can evidence that consent, and that it will honour a revocation promptly and through any reasonable means the recipient uses.

2. What Smileline provides

  • A recording notice. Recorded calls carry a spoken notice at the start. It is not removable. It is a notice, not consent: in an all-party-consent state the Practice must still satisfy itself that consent has been obtained.
  • AI disclosure. The AI voice agent identifies itself as an AI assistant, and does not claim to be a person.
  • A do-not-contact record. When someone tells the AI agent to stop calling, or a member of staff records the same, Smileline writes a suppression against the patient that every outbound lane consults — the AI agent, the Power Dialer and messaging alike.
  • Records. Call logs, message logs and consent records are retained and exportable, so the Practice can evidence what happened and when.

3. What Smileline does not provide, today

Stated plainly so the Practice does not assume otherwise:

  • Smileline does not scrub the National Do Not Call Registry or state registries. The Practice must do this before loading contacts.
  • Smileline does not verify that prior express written consent exists before placing a call. It honours a recorded refusal; it cannot confirm a consent it never saw.
  • Calling windows follow the Practice's configured hours, not the called party's local time zone. A Practice calling across time zones must set its window accordingly.
  • Smileline cannot be used to reach emergency services. See clause 15 of the Terms of Service.

4. Indemnity

The Practice will indemnify Smileline against all losses, damages, fines, penalties, statutory damages, settlements, costs and reasonable legal fees arising from any claim, demand, regulatory action or class action brought by or on behalf of a person contacted through the Service, to the extent it arises from the Practice's breach of section 1. This indemnity is one of the matters that sits outside the liability cap in clause 9 of the Terms of Service, and the procedure in clause 14 applies to it.

5. Suspension

Smileline may suspend the Practice's outbound calling or messaging immediately, without notice, where it reasonably believes those features are being used without the consent this Addendum requires, or where a carrier, regulator or platform requires it. We will tell the Practice why and what would let us restore the feature.

6. Contact

Smileline Technologies Ltd · Company 17408336 · 1 Lyric Square, London, England, W6 0NB · support@smileline.io