Terms of Service

Trust Technical Services Limited (TTS NZ) · NZBN 9429053014481 · Effective 29 September 2026 · Contact: support@ttsnz.info

Terms of Service · Acceptable Use Policy · Data Processing Agreement · Privacy Policy

Terms of Service

1. Definitions & Acceptance

1.1. "Provider", "we", "us" and "our" means Trust Technical Services Limited, trading as TTS NZ, NZBN 9429053014481, a New Zealand company with its registered address at 20 Roslyn Farm Street, Ramarama, Drury 2579, New Zealand. Email: support@ttsnz.info.
1.2. "Platform" or "Pwoli" means the SaaS product (pwoli.ai; dashboard also at ttsnzai.tech) that provides AI receptionist, AI phone answering, CRM, SMS, email marketing, social media posting, website/booking widgets, calendar and appointment reminders, and bookkeeping tools.
1.3. "Customer", "you", "your" means the business entity ("Business") on whose behalf the Platform is registered, together with the natural person who registers. The person registering must be at least 18 years old and warrants that they have authority to bind the Business. If they do not have that authority, they are personally bound by these Terms.
1.4. "Business" means the legal entity you represent when you sign up for the Platform.
1.5. "Subscription" means the monthly paid access to the Platform described in Section 10.
1.6. "Sub‑processors" means the third‑party services we engage to operate the Platform, currently Stripe, Twilio, Telnyx, Retell AI, Resend, Amazon SES, Google (Calendar/OAuth/Maps), Meta (Facebook/Instagram), AI language‑model providers, Hostinger, and Cloudflare. We may change Sub‑processors in accordance with our Data Processing Addendum.
1.7. "Effective Date" means the date you first accept these Terms.
1.8. "Customer Data" means all content, contact lists, personal information, recordings, messages and other data you or your end users submit to, or generate through, the Platform.
1.9. Electronic acceptance. You accept these Terms by ticking the acceptance box and clicking "Sign Up", "Accept" or "Subscribe", or by using the Platform. You agree that this electronic acceptance forms a binding contract under the Contract and Commercial Law Act 2017 (NZ) Part 4, the Electronic Transactions Act 1999 (Cth) and equivalent laws (including the US E‑SIGN Act), and that no handwritten signature is required. We record the date, time and version of the Terms you accepted. If you do not accept, you must not use the Platform.
1.10. Business use only. The Platform is supplied only to businesses, for business purposes. It is not offered to consumers. By accepting, you confirm you are acquiring it in trade.

2. Platform‑Only Role

2.1. The Platform is a software tool. We configure and operate the AI features on your instructions, but we do not review or approve, in advance, the individual content, messages, calls, posts or AI conversations generated through your account, and you remain responsible for them as set out in these Terms. We are not the sender, caller, publisher or agent of that content.
2.2. You decide who is contacted, what is said, when, and on what legal basis. You configure the AI's prompts, knowledge, scripts and settings. We do not act as your adviser or representative to any third party.
2.3. We have no obligation to monitor use of the Platform, but we may do so (see Section 9).

3. Customer Sole Responsibility

3.1. As between you and us, you are solely responsible for all Customer Data and all content you place in or publish through the Platform, including text, images, audio, video, website widgets, booking pages and AI‑generated replies.
3.2. As between you and us, you are solely responsible for every phone call, SMS, email, social media post and other communication made through the Platform on your behalf (including by the AI), for reviewing them, and for their legal consequences.
3.3. You are responsible for the acts and omissions of your staff, users and anyone who accesses the Platform using your account, as if they were your own.

4. AI Output Disclaimer

4.1. AI responses are generated automatically and may be inaccurate, incomplete, out of date, inappropriate or not legally compliant, including as to prices, availability, bookings and policies. We do not guarantee the accuracy, completeness or legal compliance of any AI output.
4.2. AI output is not professional (including legal, financial, tax, accounting, medical or other regulated) advice. Bookkeeping features are record‑keeping and record‑organising aids only, not tax, GST or accounting advice; you remain responsible for your tax filings and accounts.
4.3. You must review AI‑drafted emails, SMS and social media posts before they are sent or published, and monitor AI receptionist transcripts on a regular basis. You are responsible for checking AI output before relying on it.
4.4. You must not use the Platform to make, and the Platform must not be configured to make, any decision that has a legal or similarly significant effect on an individual (for example accepting or declining a booking on grounds that affect their rights, or a credit, employment or eligibility decision) without meaningful human review of that decision. Where a law gives an individual a right to notice of, an explanation for, an objection to, or an appeal against an automated decision (including EU GDPR Article 22 and applicable US state automated‑decision‑technology rules such as under the CCPA), you are responsible for providing it.
4.5. We may change the AI models or vendors used to provide the Platform, and AI behaviour and output may change as a result.

5. AI Disclosure & Recording Consent

5.1. You are the deployer of the AI features you configure and use through the Platform, and you are responsible for AI disclosure, call‑recording consent, and calling consent in every jurisdiction where your callers or message recipients are located, including (without limitation): the EU AI Act (Article 50 transparency obligations), California Bus. & Prof. Code §17941, the Utah AI Policy Act, and Colorado SB 24‑205; all‑party recording‑consent laws (for example California Penal Code §632, and the equivalent laws of Florida, Washington, Illinois, Pennsylvania and Massachusetts, and Australian state surveillance‑devices legislation); and consent requirements for AI‑generated or artificial‑voice calls under the US TCPA.
5.2. The Platform's default greeting states that the caller or recipient is dealing with an AI and that the call may be recorded. You must not disable, shorten or otherwise alter that default greeting in a way that would breach the law of the caller's or recipient's location. The default greeting is provided as a convenience only; it is not legal advice and is not a guarantee that your use of the Platform complies with the law of every jurisdiction you contact.
5.3. You must tell callers and message recipients that they are dealing with an AI where the law requires it, and you are responsible for checking AI output before relying on it.

6. Customer Legal Compliance

6.1. You must comply with all applicable laws, regulations and industry codes in every jurisdiction where you operate or where the people you contact are located, including:
‑ anti‑spam, telemarketing and do‑not‑call laws (for example the Unsolicited Electronic Messages Act 2007 (NZ), Spam Act 2003 and Do Not Call Register Act 2006 (Cth), the US TCPA and CAN‑SPAM Act, UK PECR, EU ePrivacy rules and Canada's CASL);
‑ privacy and data‑protection laws, including consent and notice requirements for recording calls;
‑ consumer protection, advertising and fair‑trading rules;
‑ any licensing or registration requirements for your industry.
6.2. Failure to comply is a material breach of these Terms.

7. Contact Consent

7.1. You warrant that, before any contact is made through the Platform, you have obtained and kept records of all consents, notices and lawful bases required by law from every individual whose contact details you upload, message or call, including consent for phone calls, SMS, email, call recording and AI‑generated or artificial‑voice outreach under laws such as the Unsolicited Electronic Messages Act 2007 (NZ), the Spam Act 2003 (Cth), Canada's CASL, the UK PECR, and prior express (written) consent under the US TCPA for AI or artificial‑voice calls and texts, and that you will honour opt‑outs promptly.
7.2. You must give us copies of those consent records within five (5) business days if we ask, including when a regulator, carrier or Sub‑processor asks us.
7.3. Outbound AI calls. Outbound AI or artificial‑voice calling is not currently available on the Platform. If we make it available, you may use it only with the prior express consent required by law (including prior express written consent for telemarketing under 47 U.S.C. §227 and the FCC's February 2024 declaratory ruling that AI‑generated voices are "artificial" for TCPA purposes), after scrubbing all applicable do‑not‑call registers, and only within the calling hours permitted by law. We may require you to provide evidence of consent before enabling outbound AI calling for your account.

8. Acceptable Use

8.1. You must use the Platform in accordance with our Acceptable Use Policy (published at pwoli.ai/terms). Prohibited activities include illegal content, harassment, fraud, spam, impersonation, and any activity that threatens the security or integrity of the Platform or our Sub‑processor accounts.

9. Right to Remove Content / Block Messages

9.1. We may remove, block or disable any content, message, call, number or AI interaction that we reasonably believe breaches these Terms, the Acceptable Use Policy or applicable law, or that a carrier, Sub‑processor, regulator or law‑enforcement authority requires us to block. Where reasonably practicable and lawful, we will tell you what was blocked and why, promptly after doing so.
9.2. We respond to notices of alleged copyright, trademark and impersonation infringement in accordance with Section 10 of the Acceptable Use Policy, and may terminate the accounts of repeat infringers in appropriate circumstances.

10. Fees, Auto‑Renewal & Payment

10.1. Automatic renewal disclosure. Your Subscription is a continuing monthly subscription. It renews automatically every month and your saved payment method will be charged the then‑current monthly fee shown on your plan (plus taxes) at the start of each billing period, until you cancel. The price, billing date and this renewal term are shown to you before you subscribe, and we send you an email confirmation of these terms and how to cancel after you subscribe.
10.2. How to cancel. You can cancel at any time online, in one step, in Settings > Manage subscription (Stripe Customer Portal), or by emailing support@ttsnz.info. Cancellation takes effect at the end of the current paid billing period, and you will not be charged again. You keep access until that period ends.
10.3. All fees are exclusive of GST, VAT, sales tax or other applicable taxes, which will be added to your invoice. You must pay any withholding tax so that we receive the full amount invoiced.
10.4. Fees are non‑refundable for any partial billing period, except as required by law or as set out in Sections 14.2, 20.3 and 26.1.
10.5. You authorise us (through Stripe) to charge your payment method for all fees and usage charges when due.

11. Non‑Payment

11.1. If a payment fails, we will notify you by email and Stripe will retry the charge. If the payment is still unpaid seven (7) days after that notice, we may suspend your access until it is paid.
11.2. If the payment remains overdue for fourteen (14) days after that notice, we may terminate your Subscription by email notice.
11.3. After termination for non‑payment, you may export your Customer Data for thirty (30) days (see Section 15.3); after that we may delete it, unless the law requires us to keep it.
11.4. All outstanding amounts, including reasonable collection costs, remain payable. Suspension does not stop fees accruing for the current billing period.

12. Usage & Third‑Party Costs

12.1. You must pay all usage charges for your use of the Platform (for example SMS fees, phone numbers and minutes, and AI‑model usage), at the rates shown in the dashboard or on our pricing page.
12.2. We may change Subscription fees or usage rates by giving at least thirty (30) days' notice by email and in the dashboard. The new price applies from your first billing period after the notice ends. If you do not agree, you may cancel before it takes effect without penalty. Where a Sub‑processor increases its charges to us with less notice, we may pass that increase through on the same notice we received, and you may cancel immediately.

13. Third‑Party Services

13.1. The Platform relies on services provided by Stripe, Twilio, Telnyx, Retell AI, Google, Meta, Resend, Amazon SES, Hostinger, Cloudflare and others. Outages, suspensions, policy changes or other issues with these services are beyond our control and are not a breach of these Terms by us.
13.2. Your use of those services is also governed by their terms, which you agree to comply with. If a third party suspends, rejects or restricts your numbers, sender identities, pages or accounts, that is not our responsibility.
13.3. We may change, replace or stop using any third‑party service, or change features that depend on it, if the third party changes or withdraws it.

14. No Uptime Guarantee / As‑Is

14.1. To the maximum extent permitted by law, the Platform is provided "as is" and "as available". We give no warranty or guarantee of uptime, availability, performance, delivery of any message or call, or error‑free operation, and no service credits apply.
14.2. We may change, improve or remove features of the Platform. If we remove a feature that is material to your use, you may cancel and we will refund any fees prepaid for the period after cancellation.

15. Data & Backups

15.1. You are responsible for keeping your own copies of any data you consider important.
15.2. We perform routine backups but do not guarantee data recovery and, to the maximum extent permitted by law, are not liable for any loss or corruption of data.
15.3. You may export your Customer Data using the Platform's export tools at any time during your Subscription and for thirty (30) days after it ends. After that period we may permanently delete it, except where the law requires us to keep it.

16. Privacy Roles

16.1. You are the data controller (or "agency" under the Privacy Act 2020 (NZ)) of all personal information in Customer Data. We process it only on your behalf and on your instructions, as your processor.
16.2. Our Data Processing Addendum and Privacy Policy are incorporated into these Terms and govern how we handle personal data.
16.3. We may use aggregated, de‑identified data derived from use of the Platform to operate, secure and improve the Platform, provided it does not identify you or any individual.
16.4. EU AI Act. For the purposes of the EU AI Act, you are the deployer of the AI features you configure and use. You will not use the Platform for any practice prohibited by Article 5 of that Act, or for any high‑risk use listed in Annex III, without our prior written agreement.

17. Disclaimer of Warranties

17.1. You acquire the Platform for the purposes of a business. To the maximum extent permitted by law: (a) the Consumer Guarantees Act 1993 (NZ) does not apply, as permitted by section 43 of that Act; (b) sections 9, 12A and 13 of the Fair Trading Act 1986 (NZ) do not apply, as permitted by section 5D of that Act; and (c) all other warranties, conditions and guarantees, whether express or implied by statute, custom or otherwise, are excluded. You agree it is fair and reasonable that the parties are bound by this clause.
17.2. Nothing in these Terms excludes, restricts or modifies any right or remedy, or any guarantee, warranty or other term implied or imposed by law, that cannot lawfully be excluded, restricted or modified, including under the Australian Consumer Law ("Non‑Excludable Rights").
17.3. Where our liability for breach of a Non‑Excludable Right can lawfully be limited, it is limited, at our option, to supplying the services again or paying the cost of having them supplied again.

18. Limitation of Liability

18.1. To the maximum extent permitted by law, we are not liable for any indirect, consequential, special, incidental, punitive or exemplary loss or damage, or for any loss of profit, revenue, data, goodwill, business opportunity or use, however arising (including in negligence), even if we were told it was possible.
18.2. To the maximum extent permitted by law, our total aggregate liability for all claims arising out of or relating to these Terms or the Platform, however arising (including in negligence), is limited to the greater of (a) the fees you paid to us in the three (3) months before the event giving rise to the first claim and (b) NZD 100.
18.3. We are not liable for any loss to the extent caused or contributed to by you, your Customer Data, your instructions or AI configuration, your breach of these Terms or of law, or any third‑party service.
18.4. Nothing in these Terms limits liability that cannot lawfully be limited, including liability for fraud or wilful misconduct.
18.5. You agree the limits in this Section are reasonable, reflect the low price of the Platform and the allocation of risk in these Terms, and that we would not supply the Platform at that price without them.

19. Indemnity by Customer

19.1. You indemnify us and our officers, directors, employees and agents against all claims, losses, damages, liabilities, fines, penalties, costs and expenses (including reasonable legal fees) to the extent arising out of:
‑ your Customer Data, contacts, or communications (including calls, messages and posts made by the AI on your behalf), including any claim that Customer Content infringes a third party's intellectual property, privacy or personality rights;
‑ your breach of these Terms, applicable law, or third‑party rights;
‑ any regulatory investigation, fine or penalty relating to your use of the Platform;
‑ your failure to give the AI disclosure required by Section 5, or to obtain the call‑recording, calling or messaging consent required by Sections 5, 6 or 7;
‑ any claim under the US TCPA, state wiretap or recording laws, or anti‑spam laws (or their equivalents in other jurisdictions), arising from your use of the Platform;
‑ any decision or action you take in reliance on AI output; and
‑ any claim that AI output generated from your prompts, instructions, data or configuration infringes a third‑party right.
19.2. Your indemnity is reduced to the extent the loss was caused by our own breach of these Terms, negligence or wilful misconduct. We will notify you promptly of any claim and let you conduct its defence at your cost, but you must not settle any claim that admits fault by us without our written consent.

20. Suspension & Termination

20.1. By us for cause. We may suspend or terminate your access immediately, by notice, if: (a) you materially breach these Terms or the Acceptable Use Policy (and, where the breach can be fixed, you do not fix it within seven (7) days of our notice); (b) your use creates a real risk of legal liability, harm to others, or loss of our carrier or Sub‑processor accounts, or generates repeated complaints or abuse reports; (c) a regulator, carrier, Sub‑processor or law‑enforcement authority requires it; or (d) you become insolvent. Where lawful and practicable we will tell you the reason. We may lift a suspension once the reason is resolved.
20.2. By you. You may cancel at any time under Section 10.2.
20.3. By us for convenience. We may terminate your Subscription for any reason on at least thirty (30) days' notice. If we do, we will refund any fees prepaid for the period after termination.
20.4. Effect. On termination your licence ends, all unpaid fees become due, and Section 15.3 applies to your data.

21. Account Security

21.1. You are responsible for keeping your login credentials confidential and, to the maximum extent permitted by law, for all activity under your account, except to the extent caused by our breach of our security obligations.
21.2. You must notify us promptly of any suspected unauthorised use.

22. Intellectual Property

22.1. We (and our licensors) retain all right, title and interest in the Platform, its software, design, trademarks and related IP.
22.2. We grant you a limited, non‑exclusive, non‑transferable, non‑sublicensable right to use the Platform solely for your internal business purposes while your Subscription is active.
22.3. Except as expressly permitted by these Terms or by law that cannot be excluded, you may not copy, modify, distribute, sell, lease, sublicense, reverse engineer, decompile, or create derivative works of the Platform, or use it to build a competing product, or use our name or trademarks without our prior written consent.
22.4. Customer Content licence. You retain ownership of your Customer Data and all other content you place in or generate through the Platform (together, "Customer Content"). You grant us and our Sub‑processors a worldwide, non‑exclusive, royalty‑free licence to host, store, copy, transmit, process and adapt (for formatting and technical delivery) Customer Content, and to display, perform and publish it to the social media, email, SMS, voice and website channels you connect to the Platform, solely as needed to provide the Platform and comply with law. This licence ends when Customer Content is deleted, except for copies kept in backups, logs, or as required by law. You warrant that you own or have all rights necessary to grant this licence, and that Customer Content does not infringe any third party's rights.
22.5. AI Output ownership. To the extent permitted by law, we assign to you any right, title and interest we may have in AI Output generated through your account. AI Output forms part of your Customer Content for the purposes of these Terms. AI Output may not be protectable by copyright or other intellectual property law, and similar or identical output may be generated for other customers using similar prompts or configurations.
22.6. No warranty on AI Output. We do not warrant that AI Output is original, unique, or free from third‑party rights (including personality rights). You must review AI Output before using, publishing or relying on it.
22.7. The licence in Section 22.2 terminates automatically when your Subscription ends.

23. Feedback

23.1. Any suggestions, ideas or feedback you give us about the Platform ("Feedback") are voluntary.
23.2. You grant us a perpetual, irrevocable, royalty‑free, worldwide, transferable, sublicensable licence to use, copy, modify, create derivative works from, and commercialise Feedback for any purpose, without compensation or attribution. Feedback is not your Confidential Information. To the extent permitted by law, you waive any moral rights in Feedback.

24. Confidentiality

24.1. Each party will keep confidential all non‑public information disclosed by the other that is marked or identified as confidential, or that a reasonable person would understand is confidential, and use it only for purposes of these Terms, except as required by law or to enforce these Terms.
24.2. These obligations survive termination for two (2) years, and indefinitely for trade secrets and personal information.

25. Force Majeure

25.1. Neither party is liable for failure or delay in performance (other than payment obligations) caused by events beyond its reasonable control, including natural disasters, pandemic, war, terrorism, labour disputes, internet or telecommunications failures, cyber‑attacks, or failures or actions of Sub‑processors or carriers.
25.2. The affected party must notify the other as soon as reasonably possible and may suspend performance until the event ends. If the event prevents use of the Platform for more than thirty (30) days, either party may terminate by notice.

26. Changes to Terms, Disputes & General Provisions

26.1. Changes. We may change these Terms only where reasonably necessary to protect our legitimate business interests — for example, to reflect changes in law, regulator or Sub‑processor requirements, security, or the features and pricing of the Platform. We will give at least thirty (30) days' notice by email and in the dashboard (or shorter notice where a change is required by law or a Sub‑processor on shorter notice). If you do not agree, you may cancel before the change takes effect without penalty and, if you cancel for that reason, we will refund any fees prepaid for the period after the change. Continuing to use the Platform after the change takes effect is acceptance of it. Changes do not apply to disputes that arose before the change.
26.2. Governing law & jurisdiction. These Terms are governed by the laws of New Zealand. Each party submits to the exclusive jurisdiction of the courts of New Zealand sitting in Auckland, except that either party may seek urgent injunctive relief in any court, and nothing in this clause removes a mandatory right you have to bring a claim in another forum.
26.3. Individual claims. To the maximum extent permitted by law, each party may bring claims against the other only in its individual capacity and not as a plaintiff or class member in any class, collective or representative proceeding, and there is no jury trial for any dispute.
26.4. Limitation period. To the maximum extent permitted by law, any claim against us must be commenced within two (2) years after you became aware (or ought reasonably to have become aware) of the facts giving rise to it.
26.5. Order of precedence. If documents conflict, this order applies (highest first): (a) any signed order form or written agreement signed by both parties that expressly overrides these Terms; (b) the Data Processing Addendum (for personal‑data matters only); (c) these Terms; (d) the Acceptable Use Policy; (e) the Privacy Policy; (f) plan descriptions and documentation.
26.6. Entire agreement. These Terms and the documents referred to in Section 26.5 are the entire agreement between you and us about the Platform and replace any earlier understanding. You have not relied on any statement not set out in them, and to the maximum extent permitted by law section 35 of the Contract and Commercial Law Act 2017 (NZ) applies accordingly.
26.7. Severability. If any provision (or part) is invalid, unenforceable or unfair under any law, it is read down to the extent needed to make it valid, or if that is not possible severed, in that jurisdiction only, and the remaining provisions continue in full force.
26.8. Assignment. You may not assign or transfer your rights or obligations without our prior written consent (not to be unreasonably withheld). We may assign or novate these Terms, in whole or part, to a related company or to a successor to all or part of our business or assets, by notice to you; you consent to that novation. We may subcontract our obligations.
26.9. Survival. Sections 3, 4, 5, 6, 7, 10.3–10.5, 11.3–11.4, 12.1, 15, 16, 17, 18, 19, 20.4, 22 (other than 22.2), 23, 24, 26 and any other provision that by its nature should survive, survive termination or expiry.
26.10. No waiver. A failure or delay in exercising a right is not a waiver of it.
26.11. Relationship. The parties are independent contractors. No partnership, agency, employment or joint venture is created.
26.12. No third‑party rights. Except for the persons indemnified under Section 19 (who may enforce it under Part 2, Subpart 1 of the Contract and Commercial Law Act 2017 (NZ)), no one other than you and us has any right to enforce these Terms.
26.13. Notices. Notices must be in writing and sent by email to support@ttsnz.info (for us) or to the email address in your account (for you), or through the dashboard. Email notice is received when sent, unless the sender receives a delivery‑failure message.

Effective Date: the date these Terms are published at pwoli.ai/terms. For existing customers, the date 30 days after we notify you of them.

Acceptable Use Policy

1. Purpose

This Pwoli Acceptable Use Policy (the "Policy") sets out the standards of conduct that Trust Technical Services Limited (trading as TTS NZ), NZBN 9429053014481, ("Provider", "we", "us", or "our") requires of customers who use the Pwoli platform (the "Service"). It is intended to protect the integrity of the Service, its users, and third parties, and to comply with applicable law. By using the Service, you agree to comply with this Policy to the maximum extent permitted by law.

2. Prohibited Content

You must not upload, transmit, store, or otherwise make available any content that:

  • Is illegal – violates any applicable law, regulation, or court order in New Zealand, Australia, or any other jurisdiction where the content is accessed.
  • Is hateful or harassing – targets a person or group on the basis of race, ethnicity, national origin, religion, gender, sexual orientation, disability, or other protected characteristic.
  • Is threatening or violent – includes threats of physical harm, encouragement of self‑harm, or graphic depictions of violence intended to intimidate.
  • Is sexual or adult in nature – pornographic material, explicit sexual content, or erotica that is not otherwise lawfully permitted.
  • Involves child exploitation – any content that depicts or describes sexual activity involving persons under 18 years of age.
  • Promotes extremist violence – content that advocates for violent extremist ideology or organizations.
  • Is misleading or deceptive – false claims, fraudulent representations, or any material designed to deceive users.
  • Is a scam or phishing attempt – attempts to obtain personal, financial, or login information through deception.
  • Infringes intellectual property – unlicensed use of copyrighted works, trademarks, trade secrets, or other protected rights (see Sections 10 and 11).
  • Impersonates a brand or person – uses another person's or business's name, logo, likeness, or voice in a way likely to mislead people about who is speaking or who endorses the content.
  • Is defamatory – false statements that harm the reputation of a person or entity.
  • Discloses private data without authority – personal information about any individual that you are not authorized to share, including but not limited to addresses, phone numbers, or identity documents.

Any such content may be removed, and the responsible account may be subject to enforcement action under Section 8.

3. Prohibited Messaging

When using Pwoli's communication features (SMS, email, voice calls, or social media posting), you must not:

  • Send spam or unsolicited commercial messages to individuals who have not provided explicit consent.
  • Use purchased, harvested, or otherwise non‑consensual contact lists.
  • Disregard opt‑out requests; you must honor "STOP" replies or unsubscribe links immediately.
  • Place calls or send SMS to numbers listed on any applicable do‑not‑call register without prior consent.
  • Contact recipients outside the calling hours permitted by the law of the recipient's location (which vary by country and state; for example the US TCPA default of 8 am–9 pm, with stricter state rules).
  • Impersonate another person, entity, or organization, or falsify header information to conceal your identity.
  • Conceal, or cause anyone to be misled about, the AI nature of any call, message or chat; remove or alter the Platform's AI and recording announcement; or record any call without the consent required by the law of every party's location. You are responsible for AI disclosure and recording consent in your jurisdiction and your recipients' jurisdictions.

Violations may result in immediate suspension or termination of your account and may be reported to relevant authorities.

4. AI Rules

The Service incorporates AI‑driven features. You agree not to use these features to:

  • Create or distribute AI content that is presented as coming from a human, or that is otherwise deceptive.
  • Provide legal, medical, financial, or other professional advice using AI and present that advice as if it were given by a licensed professional.
  • Generate deepfake media that misrepresents real individuals in a manner that could cause harm or deception.
  • Engage in any practice prohibited by Article 5 of the EU AI Act, including subliminal or manipulative techniques, exploiting the vulnerabilities of a person or group, social scoring, or workplace or education emotion recognition, where that Article applies to your use.
  • Make any decision that has a legal or similarly significant effect on an individual based solely on AI output, without meaningful human review.
  • Make outbound AI or artificial-voice calls, or leave AI-voiced voicemail, without the prior express consent required by law (see Section 7.3 of our Terms of Service — outbound AI calling is not currently available on the Service).
  • Clone or imitate a real person's voice or likeness without their written consent.
  • Collect health, biometric or payment-card data by voice through the Service unless we have agreed to this in writing.
  • Use the Service for emergency services or in a self-harm situation. The AI must direct any caller in an emergency or expressing risk of self-harm to the appropriate emergency number for their location (for example 111 in New Zealand, 000 in Australia, 911 in the US or Canada, 112 in the EU, or 999 in the UK).

All AI‑generated calls must include the required introductory disclosure (AI assistant and possible recording) as described in Section 3.

5. Platform Abuse

You must not engage in activities that impair the Service or its users, including but not limited to:

  • Attempting to hack, probe, or exploit vulnerabilities in the Service, its infrastructure, or related third‑party services (Stripe, Twilio, Telnyx, etc.).
  • Overloading the Service with excessive traffic, automated requests, or denial‑of‑service attacks.
  • Scraping, harvesting, or bulk downloading data from the Service without explicit permission.
  • Reverse‑engineering, decompiling, or modifying the Service's code or functionality.
  • Sharing your account credentials, reselling access, or providing the Service to third parties not covered by your subscription.

Such abuse may result in immediate termination of access and potential legal action.

6. Regulated Industries

If your business operates in a regulated sector (e.g., financial services, health care, legal services, or telecommunications), you must hold all licences, registrations, and authorisations required by the relevant regulator(s) before using the Service for any regulated activity. You are solely responsible for compliance with those regulatory obligations.

7. Reporting Abuse

If you encounter content, messages, or behaviour that appears to violate this Policy, please notify us promptly at support@ttsnz.info. Provide as much detail as reasonably possible to enable investigation. We will review all reports and take appropriate action. Copyright, trademark and impersonation complaints must follow the procedure in Section 10 so that we can act on them quickly.

8. Enforcement

We reserve the right, at our sole discretion and without prior notice, to:

  • Remove or block any content or message that breaches this Policy.
  • Suspend, limit, or terminate your access to the Service, including any associated accounts, subscriptions, or data.
  • Report suspected unlawful activity to law‑enforcement or regulatory bodies.

Enforcement actions may be taken without refund of any fees paid, and you may be liable for any costs, fines, or damages incurred as a result of your breach, including legal costs on a solicitor-client basis. Our actions are taken to the maximum extent permitted by law.

9. Governing Law

This Policy and any disputes arising out of or relating to it are governed by the laws of New Zealand, and the parties submit to the exclusive jurisdiction of the courts of Auckland.

10. Copyright, Trademark & Impersonation Complaints

We host content that our customers upload, generate, or publish. We do not review it before it goes live. We respond to valid complaints from rights holders as set out below. This procedure is intended to meet the notice-and-takedown requirements of the US Digital Millennium Copyright Act (17 U.S.C. §512), the New Zealand Copyright Act 1994 (sections 92B–92E), and the equivalent Australian and other laws, to the extent they apply to us.

10.1 How to send a copyright notice

Send your notice by email to support@ttsnz.info (subject line "Copyright Notice") or by post to our designated agent at Trust Technical Services Limited, 20 Roslyn Farm Street, Ramarama, Drury 2579, New Zealand. To be valid, your notice must include:

  1. Your physical or electronic signature (you, or a person authorised to act for the rights owner).
  2. Identification of the copyright work you say is infringed (or, for several works, a representative list).
  3. Identification of the material you say is infringing, with enough detail for us to find it — for example the exact URL(s), post, page, or message.
  4. Your name, postal address, telephone number, and email address.
  5. A statement that you have a good-faith belief that the use complained of is not authorised by the copyright owner, its agent, or the law (including after considering fair use or fair dealing).
  6. A statement that the information in the notice is accurate and, under penalty of perjury, that you are the owner or are authorised to act on the owner's behalf.

Incomplete notices may not be actioned. Under US law (17 U.S.C. §512(f)) and other laws, a person who knowingly makes a material misrepresentation in a notice or counter-notice may be liable for damages, including our costs and legal fees.

10.2 What we do when we receive a valid notice

We will act expeditiously to remove or disable access to the material identified, and take reasonable steps to notify the customer who posted it, giving them a copy of the notice (we may redact your personal details where the law allows). Where the material is on a customer's own external account (for example their own Facebook page or website on third-party hosting), we may only be able to remove it from the Pwoli copy, and we will tell you so.

10.3 Counter-notice (if you are the customer)

If your material was removed and you believe in good faith that this was a mistake or misidentification, you may send a counter-notice to the same address containing:

  1. Your physical or electronic signature.
  2. Identification of the material removed and where it appeared before removal.
  3. A statement under penalty of perjury that you have a good-faith belief the material was removed or disabled as a result of mistake or misidentification.
  4. Your name, address, and telephone number, and a statement that you consent to the jurisdiction of the US Federal District Court for the judicial district of your address (or, if your address is outside the US, any judicial district in which we may be found), and that you will accept service of process from the person who sent the original notice or their agent.

If we receive a valid counter-notice, we will send a copy to the complainant. Unless the complainant tells us within 10 business days that they have started court action to restrain the activity, we may restore the material 10 to 14 business days after we received the counter-notice. Restoring material is at our discretion where US law does not require it. Get legal advice before sending a counter-notice — it is a sworn statement and can lead to court proceedings.

10.4 Repeat-infringer policy

We will, in appropriate circumstances, terminate the accounts of customers who are repeat infringers. As a general guide, an account that is the subject of three or more valid, un-countered notices within any 12-month period will be terminated. We may terminate sooner for serious or deliberate infringement, and may take into account court findings or evidence of infringement from other sources. Termination under this policy is a breach-based termination under our Terms of Service and is without refund.

10.5 Trademark and impersonation complaints

If you believe content on the Service uses your trademark in a way likely to confuse, or impersonates you or your business, email support@ttsnz.info (subject line "Trademark Complaint" or "Impersonation Complaint") with: your contact details; the trademark and where it is registered (registration number, if any) or, for impersonation, proof of identity or authority to act; the exact location of the content; and an explanation of why it is infringing or misleading. We will review the complaint and may remove the content, require the customer to change it, or suspend the account. Trademark and impersonation complaints are assessed case by case; the counter-notice process in 10.3 does not automatically apply, but the customer may respond and we will consider that response.

10.6 Other jurisdictions

  • New Zealand: we act as an internet service provider under sections 92B–92E of the Copyright Act 1994 and will delete or prevent access to infringing material as soon as possible after we know or have reason to believe it infringes.
  • Australia: we respond to notices on the same basis as above; nothing in this Policy is an admission that any particular Australian statutory safe harbour applies to us.
  • European Union / United Kingdom / Canada: we accept notices under applicable notice-and-action or notice-and-notice laws (including the EU Digital Services Act) at the same address, and will process them as those laws require.

10.7 No legal advice; our discretion

We are not a court and cannot decide disputed ownership. We may remove material, keep it down, or restore it, where we reasonably consider this appropriate to limit legal risk, and nothing in this Section obliges us to host any particular content.

11. AI-Generated Content and Intellectual Property

  • You are responsible for AI output. Text, images, voice, posts, websites, and any other material generated through the Service's AI features at your direction ("AI Output") is your content for the purposes of this Policy and our Terms of Service. You are responsible for reviewing it before you publish, send, or rely on it.
  • No warranty of non-infringement. AI models may produce output that is similar or identical to existing third-party material. We do not warrant that AI Output is original, unique, protectable by copyright or trademark, or free from third-party rights, and you must not assume that it is.
  • Do not use AI to copy. You must not prompt or use AI features to reproduce or imitate a specific copyrighted work, a third party's trademark or brand identity, or the voice, name, or likeness of a real person without their permission.
  • Inputs. You must have all rights needed for anything you upload or provide as input (including images, voice samples, and reference material).
  • AI Output is subject to the complaint process in Section 10 in the same way as any other content.

Effective Date: 29 September 2026

Data Processing Agreement

Pwoli Data Processing Agreement

This Data Processing Agreement ("DPA") is between Trust Technical Services Limited, trading as TTS NZ (NZBN 9429053014481), of 20 Roslyn Farm Street, Ramarama, Drury 2579, New Zealand ("TTS", "we", "us"), and the business that has subscribed to the Pwoli platform ("Customer", "you"). It is incorporated into, and forms part of, the Pwoli Terms of Service. Effective date: 29 September 2026.

Capitalised terms not defined here have the meaning given in the Terms of Service. "Personal Data" means personal information processed by TTS on the Customer's behalf through Pwoli. "Applicable Data Protection Law" means, to the extent it applies to the processing: the New Zealand Privacy Act 2020; the Australian Privacy Act 1988 (including the Australian Privacy Principles); the EU General Data Protection Regulation 2016/679 ("GDPR"); the UK GDPR and Data Protection Act 2018; the California Consumer Privacy Act as amended by the CPRA ("CCPA"); Canada's PIPEDA; and any other data protection law that applies. "Controller", "processor", "data subject", "personal data breach" and "supervisory authority" have the meanings given in the GDPR, and equivalent terms under other laws are read accordingly.

1. Scope and roles

1.1 The Customer is the controller (or equivalent, including the "business" under the CCPA) of the Personal Data it submits to Pwoli. TTS is the processor (and "service provider" under the CCPA) and processes that Personal Data only on the Customer's behalf. For New Zealand purposes, TTS holds the Personal Data as the Customer's agent under section 11 of the Privacy Act 2020.

1.2 This DPA applies to Personal Data processed by TTS in providing the Pwoli service, a B2B software platform, with optional setup assistance, including an AI receptionist and AI phone answering (with call recording and transcription), CRM and contact management, SMS, email marketing campaigns, social media posting, website and booking widgets, calendar and appointment reminders, and bookkeeping tools. The details of processing are in Annex 1.

1.3 TTS is a controller for its own account, billing and service-administration data. That processing is governed by our Privacy Policy, not this DPA.

2. Processing only on the Customer's documented instructions

2.1 TTS will process Personal Data only on the Customer's documented instructions, including with regard to transfers of Personal Data to a third country or international organisation, unless required to do so by law to which TTS is subject. In that case TTS will inform the Customer of that legal requirement before processing, unless that law prohibits it on important grounds of public interest.

2.2 The Customer's documented instructions are: (a) the Terms of Service and this DPA; (b) the configuration, settings, workflows and content the Customer selects or submits in the Pwoli dashboard and connected integrations; and (c) any further written instructions the parties agree. Instructions must be lawful and within the scope of the service.

2.3 TTS will immediately inform the Customer if, in its opinion, an instruction infringes Applicable Data Protection Law. TTS may suspend performance of that instruction until it is confirmed or modified.

2.4 TTS will not itself use Personal Data to train general-purpose AI models. AI language-model and voice sub-processors listed in section 6 process Personal Data only to provide the service; TTS aims to use settings or terms with those sub-processors under which they may not use Personal Data to train their own general-purpose models (details available to the Customer on request).

3. Customer obligations

3.1 The Customer is responsible for the lawfulness of the Personal Data it submits and for having a valid lawful basis for the processing it instructs TTS to carry out.

3.2 The Customer is responsible for giving all notices and obtaining and maintaining all consents required for: collecting Personal Data from its contacts, including the notice required by Information Privacy Principle 3A of the NZ Privacy Act 2020 (from 1 May 2026) and APP 5 where Personal Data is collected from someone other than the individual; recording and transcribing calls (including AI-answered calls) under all applicable call-recording and telecommunications laws; using AI to interact with its contacts; sending SMS and email marketing; publishing to social media; and contacting its own contacts, leads, callers, customers and staff. Inbound AI calls placed through Pwoli use a default announcement stating that an AI assistant is handling the call and that it may be recorded. The Customer must ensure that this announcement, together with its own notices and consents, is sufficient to comply with the law of every jurisdiction where its callers are located, including all-party (two-party) recording consent laws and AI-disclosure laws such as the EU AI Act Article 50(1) (where the Customer is a deployer of the AI system) and the California Bot Disclosure Law (California Business and Professions Code section 17941). The Customer must not remove, disable or alter the default announcement in a way that would breach any such law.

3.3 The Customer is responsible for the accuracy of the data it submits, and must not submit special-category or similarly sensitive data (including health information), or data about children, unless it has a lawful basis and has told us in writing and we have agreed.

3.4 The Customer will not use Pwoli to make decisions producing legal or similarly significant effects on individuals solely by automated means unless it has put in place the notices and safeguards required by Applicable Data Protection Law. TTS does not itself use Personal Data to make automated decisions producing legal or similarly significant effects on data subjects.

3.5 The Customer will not use Pwoli to send unsolicited messages contrary to applicable anti-spam and marketing laws, and will honour opt-outs and do-not-call requests.

4. Confidentiality of TTS personnel

4.1 TTS will ensure that persons it authorises to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality, and are given access only as needed to provide and support Pwoli.

5. Security

5.1 Taking into account the state of the art, the costs of implementation, the nature, scope, context and purposes of processing, and the risks to individuals, TTS will implement and maintain appropriate technical and organisational measures to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access, as required by Article 32 GDPR and equivalent laws. These measures include, as appropriate, access controls and role-based permissions, personnel confidentiality obligations, and management of vendors and infrastructure.

5.2 The Customer acknowledges that no method of transmission or storage is completely secure, and that it is responsible for the security of its own account credentials, user access, endpoints and connected third-party accounts.

6. Sub-processors

6.1 The Customer gives TTS general written authorisation to engage sub-processors. The current sub-processors used in providing Pwoli are:

  • Stripe — payments and subscription billing
  • Twilio and Telnyx — phone and SMS
  • Retell AI — AI voice processing, call recording and transcription
  • Resend and Amazon Web Services (SES) — email delivery
  • Google — calendar, OAuth and Maps
  • Meta — Facebook and Instagram publishing
  • AI language-model providers — AI text and language processing
  • Hostinger — VPS hosting (server located in Malaysia)
  • Cloudflare — network and edge services

6.2 TTS will impose on each sub-processor, by written contract, data protection obligations that are materially no less protective than those in this DPA (in particular, sufficient guarantees to implement appropriate technical and organisational measures). TTS remains fully liable to the Customer for the performance of its sub-processors' obligations, subject to section 12.

6.3 TTS will give the Customer notice of any intended addition or replacement of a sub-processor by updating the published list and by notice in the dashboard or by email, at least 14 days before the change takes effect (except in an emergency affecting service continuity or security, when TTS will give notice as soon as practicable). The Customer may object on reasonable data protection grounds by written notice within 14 days of notice. If the parties cannot resolve the objection, the Customer may terminate the affected part of the service, or the Terms of Service, on written notice, without penalty, as its sole remedy.

7. International transfers

7.1 Pwoli is operated from New Zealand and uses sub-processors in various countries, principally the United States and Malaysia (our VPS host, Hostinger, is located in Kuala Lumpur, Malaysia). The Customer instructs TTS to transfer Personal Data to those locations, and to the sub-processors in section 6, as needed to provide the service.

7.2 To the extent the GDPR applies to a transfer to a country without an adequacy decision, the Standard Contractual Clauses approved by Commission Implementing Decision (EU) 2021/914 are incorporated by reference: Module Two (controller to processor) between the Customer and TTS, and Module Three (processor to processor) between TTS and its sub-processors where applicable, with Clause 7 (docking) included, Option 2 (general authorisation, 14 days) in Clause 9, the optional wording in Clause 11 omitted, Clause 17 governed by the law of Ireland and Clause 18 disputes before the courts of Ireland, and Annex I and II completed by Annex 1 and section 5 of this DPA. To the extent the UK GDPR applies, the UK International Data Transfer Addendum to those Clauses (or the UK IDTA) is incorporated and completed with the same information. New Zealand is currently recognised by the European Commission as providing adequate protection, so transfers from the EU/EEA to TTS in New Zealand may rely on that decision while it remains in force.

7.3 For New Zealand and Australian law, TTS will take reasonable steps (including contractual terms) so that overseas sub-processors — including our server host in Malaysia — protect Personal Data in a way comparable to IPP12 and APP 8.

8. Assistance

8.1 Taking into account the nature of processing, TTS will assist the Customer by appropriate technical and organisational measures, insofar as possible, to respond to requests from individuals exercising their rights (access, correction, deletion, restriction, objection, portability and CCPA rights). If TTS receives a request directly, it will refer the individual to the Customer and not respond itself except as the Customer instructs or law requires.

8.2 Taking into account the nature of processing and the information available to TTS, TTS will assist the Customer in ensuring compliance with its obligations relating to security of processing, notification of personal data breaches, data protection impact assessments and prior consultation with supervisory authorities (Articles 32 to 36 GDPR and equivalent laws).

8.3 The Customer should use the self-service tools in the dashboard first. Where assistance goes beyond those tools and beyond what is reasonable, TTS may charge the Customer its standard rates, notified in advance, except where the assistance is needed because of TTS's own breach of this DPA. Any such charge is payable by the Customer only; TTS does not charge individual data subjects for assistance under this DPA.

9. Personal-data breach notification

9.1 TTS will notify the Customer without undue delay (and aims to do so within 72 hours) after becoming aware of a personal data breach affecting Personal Data processed on the Customer's behalf. The notice will include, to the extent then known, the nature of the breach, the categories and approximate number of individuals and records affected, the likely consequences, and the measures taken or proposed; further information will follow in phases as it becomes available.

9.2 TTS will take reasonable steps to contain and mitigate the breach. TTS's notification is not an acknowledgment of fault or liability.

9.3 The Customer is responsible for assessing and, where required, notifying its own regulators (including the NZ Privacy Commissioner, the OAIC and any supervisory authority) and affected individuals. TTS will not notify the Customer's contacts or regulators about Customer Data unless the Customer instructs it or law requires it.

10. Deletion or return

10.1 On termination or expiry of the Terms of Service, TTS will, at the Customer's choice, delete or return Personal Data processed on the Customer's behalf within 30 days, and delete existing copies, unless law to which TTS is subject requires storage of the Personal Data. If the Customer makes no choice within that period, TTS will delete it.

10.2 Copies in backups are deleted in the ordinary backup rotation. Until then, they remain subject to this DPA and are not used for any purpose other than restoration or legal compliance.

11. Audits and information

11.1 TTS will make available to the Customer all information necessary to demonstrate compliance with this DPA and Article 28 GDPR (and equivalent laws), including documentation, completed security questionnaires and summaries of its sub-processor arrangements.

11.2 TTS will allow for and contribute to audits, including inspections, conducted by the Customer or an independent auditor mandated by the Customer (bound by confidentiality and not a TTS competitor), as follows: (a) audits are carried out first by documentation and questionnaire under section 11.1; (b) an on-site inspection may take place only where the documentation is reasonably shown to be insufficient to demonstrate compliance, where a supervisory authority requires it, or following a personal data breach; (c) the Customer must give at least 30 days' written notice (or shorter where a supervisory authority requires); (d) audits are limited to once in any 12-month period unless required by a supervisory authority or following a breach; (e) audits take place during business hours without unreasonably disrupting TTS's operations or exposing other customers' data; and (f) audits are at the Customer's cost, and TTS may charge reasonable costs for its time. Audits of sub-processors are satisfied by TTS providing the information and audit reports that the sub-processor makes available.

12. Liability

12.1 Each party's liability under or in connection with this DPA (including under any Standard Contractual Clauses incorporated in it, to the extent permitted by those Clauses) is subject to the limitations, exclusions and caps set out in the Terms of Service. To the maximum extent permitted by law, TTS is not liable for indirect, incidental, special or consequential loss, loss of profit, loss of data or loss of business.

12.2 Nothing in this DPA limits a data subject's rights under Applicable Data Protection Law or the Standard Contractual Clauses, or excludes any right or remedy that cannot lawfully be excluded, including under the New Zealand Consumer Guarantees Act 1993 and the Australian Consumer Law where they apply, or liability for fraud or wilful misconduct.

13. CCPA service-provider terms

13.1 Where the CCPA applies, TTS: (a) processes Personal Data only for the limited and specified business purposes set out in Annex 1; (b) will not sell or share (as those terms are defined in the CCPA) Personal Data; (c) will not retain, use or disclose Personal Data for any purpose (including any commercial purpose) other than those business purposes, or outside the direct business relationship with the Customer, except as permitted by the CCPA; (d) will not combine Personal Data with personal information it receives from or on behalf of others or collects itself, except as permitted by the CCPA; (e) will comply with the CCPA and provide the same level of privacy protection it requires; (f) grants the Customer the right to take reasonable and appropriate steps to ensure TTS uses Personal Data consistently with the Customer's CCPA obligations, and to stop and remediate unauthorised use on notice; and (g) will notify the Customer if it determines it can no longer meet its CCPA obligations. TTS certifies that it understands and will comply with these restrictions.

14. Order of precedence and duration

14.1 If there is a conflict, the order of precedence is: (a) any Standard Contractual Clauses incorporated under section 7; (b) this DPA (for data protection matters); (c) the Terms of Service; (d) any other document. Subject to that order and to section 12.2, this DPA does not reduce the Customer's obligations, or increase TTS's liability, under the Terms of Service.

14.2 This DPA lasts for as long as TTS processes Personal Data on the Customer's behalf.

Annex 1 — Details of processing

Parties: Customer (controller / data exporter); TTS (processor / data importer), contact support@ttsnz.info.

Data subjects: the Customer's contacts, leads, callers and enquirers, customers, and staff or team members whose details the Customer submits.

Categories of Personal Data: names, contact details (telephone numbers, email addresses, addresses), company details, message content (SMS, email, chat, social), call recordings (voice) and transcripts, AI-generated call summaries, call and appointment metadata, bookings and calendar entries, bookkeeping and invoice records, notes, and preferences.

Sensitive data: none intended; the Customer must not submit special-category or similarly sensitive data (including health information) unless agreed in writing under section 3.3. Callers may nonetheless volunteer health or other sensitive information during calls; the Customer remains responsible for that data under this DPA.

Frequency: continuous for the term.

Nature and purpose of processing (business purposes): hosting and storage; contact and CRM management; sending and receiving messages; AI call answering, recording, transcription and voice processing; AI text and language processing; social media publishing; website and booking widget operation; appointment scheduling and reminders; bookkeeping support; and technical support — all solely to provide the Pwoli service to the Customer.

Duration and retention: the term of the Terms of Service, plus up to 30 days after termination for deletion or return, subject to section 10.

Transfers / sub-processors: as listed in section 6.

Technical and organisational measures: as described in section 5.

Competent supervisory authority (SCCs): as determined under Clause 13 of the Standard Contractual Clauses.

Governing law: New Zealand law, with the courts of Auckland having exclusive jurisdiction, except that the Standard Contractual Clauses are governed as stated in section 7.2, and subject to any non-excludable rights.

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