Call Recording & Consent

Effective date: October 14, 2026

This Call Recording and Consent Policy (the "Policy") explains how Paywall Inc., a Delaware corporation ("Company", "we", "us", or "our"), records, transcribes, and screens telephone calls processed through the CallPayWall product and service ("CallPayWall"). It applies to account owners who use CallPayWall to handle their inbound calls ("Account Owners"), to callers who reach those Account Owners ("Callers"), and to anyone whose voice is captured on a call processed by CallPayWall. This Policy is incorporated into the CallPayWall Terms of Service and should be read together with the CallPayWall Privacy Policy.

1. Overview of Recording and AI Screening

1.1 CallPayWall is an AI phone gatekeeper and virtual receptionist. When a call is routed through CallPayWall, an automated AI assistant named Paige answers the call, interacts with the Caller, screens the Caller live, and classifies the Caller's intent before the call may be connected to the Account Owner.

1.2 To provide these features, calls processed through CallPayWall are, by default:

• transcribed into text; and
• screened and analyzed by AI to classify intent, detect commercial or sales callers, support fee collection where applicable, generate notifications and summaries, capture information the Caller provides, and improve the quality and accuracy of the Service.

1.3 Not every call is recorded as audio. Business and sales calls may be recorded, but only after the Caller hears the spoken disclosure described in Section 2. Personal calls are never recorded. When an Account Owner takes over a call and speaks with the Caller, that conversation is not recorded by default. Voicemail and pitch messages that a Caller chooses to leave are recorded so the Account Owner can hear them.

1.4 Recordings, transcripts, and derived data are processed and stored as described in Section 6 and in the Privacy Policy.

2. Spoken Disclosure to Callers

2.1 At or near the beginning of a call, Callers receive an automated spoken disclosure substantially similar to:

"This call may be recorded and screened by an automated assistant."

2.2 The exact wording may vary and may be supplemented by additional disclosures (for example, identifying that the Caller is speaking with an automated assistant or that a fee may apply to reach the Account Owner). The disclosure is intended to inform Callers that the call is recorded and handled by an automated system before any substantive conversation occurs.

2.3 Where required, the disclosure, the Caller's continued participation after the disclosure, and/or an explicit affirmative response are used to evidence consent to recording.

3. Recording Laws Vary

3.1 Laws governing the recording of telephone calls and conversations differ by jurisdiction and change over time. In the United States, some states follow a "one-party consent" rule, meaning that recording is permitted if at least one party to the conversation consents. Other states follow a "two-party" or "all-party" consent rule, meaning that all parties to the conversation must consent to the recording.

3.2 When a call involves parties in different jurisdictions, the stricter rule may apply, and additional or different consent may be required. Outside the United States, many countries impose their own recording, notice, and data-protection requirements, which may be more restrictive than U.S. law.

3.3 Because of these differences, the spoken disclosure described in Section 2 is designed to provide notice to Callers, but compliance with all-party-consent and other legal requirements depends on the specific circumstances of each call.

4. Account Owner Responsibilities

4.1 The Account Owner is responsible for ensuring that the recording, transcription, and AI screening of calls on the Account Owner's account is lawful in the Account Owner's jurisdiction and in the jurisdictions of the Callers the Account Owner expects to receive calls from.

4.2 By enabling call recording and screening features, the Account Owner represents and warrants that the Account Owner has the legal right to record and process such calls, has obtained or will obtain any consents required by applicable law beyond the standard spoken disclosure, and will comply with all applicable recording, wiretapping, privacy, telemarketing, and data-protection laws.

4.3 The Account Owner must honor reasonable requests from Callers regarding recording, including requests to decline recording or to have a recording or transcript deleted to the extent required by law, and must not use CallPayWall to record or capture conversations in violation of any person's rights.

4.4 The Account Owner is responsible for any additional disclosures or consents that may be required for calls involving minors, sensitive information, or jurisdictions with heightened requirements.

4.5 The Company provides tools and standard disclosures to support compliance but does not provide legal advice and does not warrant that any particular configuration satisfies the requirements of every jurisdiction. The Account Owner agrees to indemnify the Company for claims arising from the Account Owner's unlawful recording or use of calls, as further described in the Terms of Service.

5. Caller Choices

5.1 A Caller who does not wish to be recorded or screened may decline to proceed. After hearing the spoken disclosure, a Caller may:

• end the call by hanging up before continuing the conversation; and/or
• decline to provide information to the automated assistant.

5.2 Ending the call or declining to continue means the Caller will not be connected through CallPayWall, and the features that depend on recording and screening will not be available for that call. A Caller may also contact the Account Owner through other means the Account Owner makes available, if any.

5.3 If a Caller has questions about recording on a specific account, the Caller should contact the Account Owner. General questions about CallPayWall may be directed to support@callpaywall.com (support@callpaywall.com).

6. Retention, Access, and Security

6.1 Recordings, transcripts, AI-generated classifications and summaries, and related metadata are retained for the periods and purposes described in the CallPayWall Privacy Policy, which may include providing and improving the Service, security and fraud prevention, billing and dispute resolution, post-call review and quality assurance, and legal compliance.

6.2 Access to recordings and transcripts is limited to the relevant Account Owner (for calls on their account), authorized Company personnel and service providers acting on our behalf under appropriate confidentiality and security obligations, and others as permitted or required by law.

6.3 Service providers. Call audio, recordings, and transcripts are processed by third-party service providers that act on our behalf and under our instructions:

• telephony and call-recording providers carry calls, stream live call audio, and store call recordings and voicemail and pitch recordings;
• speech recognition (transcription) providers turn call audio, voicemail and pitch messages, and recordings used in quality review into text;
• voice synthesis (text-to-speech) providers turn the text of Paige's replies into Paige's voice; and
• AI and language-model providers power Paige's real-time screening voice and conversation, classify caller intent, produce call summaries, and perform post-call quality review of recordings and transcripts.

These providers may use the data only to provide their services to us, and not for their own purposes. Analytics and content delivery providers may also process limited technical data (such as IP address and device information) under their own terms, as described in our Cookie Policy. After a recorded call ends, the recording may be sent to our AI and speech-recognition providers for an automated quality review of how Paige handled the call. We use these reviews to improve the Service. More detail is on our Subprocessors page at callpaywall.com/subprocessors.

6.4 We maintain administrative, technical, and physical safeguards designed to protect recordings and transcripts, consistent with the Privacy Policy. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security.

6.5 For details on how to request access to, correction of, or deletion of recordings or transcripts associated with you, and on the choices available to you, see the Privacy Policy.

7. Law-Enforcement and Legal Requests

7.1 We may access, preserve, and disclose recordings, transcripts, and related data when we believe in good faith that doing so is necessary to comply with applicable law, legal process (such as a subpoena, court order, or other valid request from public authorities), or governmental request; to enforce our agreements; to detect, prevent, or address fraud, security, or technical issues; or to protect the rights, property, or safety of the Company, our users, or the public.

7.2 Where permitted by law and appropriate under the circumstances, we may notify the affected Account Owner of a legal request relating to their account.

8. Changes to This Policy

8.1 We may update this Policy from time to time. Changes are effective when posted. Your continued use of CallPayWall, and continued participation in calls processed through CallPayWall, after changes take effect constitutes acceptance of the updated Policy.

9. Contact

Questions about this Policy may be directed to support@callpaywall.com (support@callpaywall.com) or legal@callpaywall.com (legal@callpaywall.com), or by mail to 16192 Coastal Highway, Lewes, DE 19958.