KYC & Customer Verification Policy

1. Purpose of This Policy

Vocally applies customer verification controls to prevent fraud, spam, illegal calling activity, misuse of telecom infrastructure, and other activity prohibited by law or required to be restricted by upstream carriers.

Vocally performs verification to meet applicable telecom regulations, carrier requirements, and industry best practices.

2. Scope

This policy applies to customers who request or use Vocally features that involve telecom resources provided by carriers, including:

• Phone number provisioning
• Inbound AI voice calls over the PSTN
• Voice automation over the PSTN (including call routing)
• Any functionality that relies on carrier-provided telecom resources

Important: Customers may create an account, configure their workspace, and use web-only features that do not provision phone numbers and do not route calls over the PSTN (for example, a website widget that does not touch PSTN), before completing Telecom Verification.

Verification requirements are feature-based, not tier-based. The same feature requires the same verification regardless of subscription plan.

3. Definitions

• Account holder: a user who has created a Vocally account and can access the dashboard.
• Customer / tenant: the organization or individual operating a Vocally workspace.
• Telecom features: features that provision or operate carrier resources (numbers, PSTN calling, carrier routing).
• Web-only features: features delivered over the internet that do not use PSTN phone numbers or carrier call routing.
• Billing activation: the point at which Vocally begins charging a subscription or usage-based fees.

4. Verification Levels and Requirements

Vocally uses three verification levels. Each level unlocks specific features.

4.1 Telecom Verification (Standard)

Telecom Verification is required before provisioning phone numbers or activating inbound AI voice services over the PSTN (including any trial that uses real phone numbers or real PSTN inbound calling).

Telecom Verification requires:

• Full legal name (individual or business)
• Phone number (verified via OTP)
• Website or email address (on the same domain, verified)
• Government-issued ID (front and back)
• Business registration certificate (for legal entities)

4.2 Billing Verification (Payment)

Billing Verification is required at billing activation (subscription start, invoicing, and paid feature activation). Billing Verification includes all Telecom Verification requirements plus:

• Valid payment method
• Billing address
• VAT/Tax ID (optional, for invoicing)

Note: Vocally may collect payment details before Telecom Verification is completed, but billing activation and paid telecom feature activation remain gated until the required verification level is satisfied.

4.3 Enhanced Verification (Outbound Features)

Outbound calling capabilities are available only case-by-case following a compliance review. If outbound calling is approved, Enhanced Verification is required, including all Billing Verification requirements plus:

• Proof of address (dated within 3 months)
• Explicit approval from Vocally's compliance team
• Country-specific requirements (see Section 9)

5. Feature-to-Verification Mapping

The following table shows which verification level is required for each feature:

6. Transfer to Human Feature

The Transfer to Human feature connects an inbound caller to pre-configured staff phone numbers. Because the call is customer-initiated (inbound) and transfer destinations are controlled by the tenant (your own staff numbers), this feature is typically lower risk than outbound calling. However, because it connects to PSTN phone numbers and may involve paid usage, it requires Telecom Verification and Billing Verification.

7. Outbound Calling & International Features

Outbound calling features are not enabled by default and are available only on a case-by-case basis following a compliance review. Customers requesting outbound capabilities must complete Enhanced Verification and receive explicit approval from Vocally's compliance team before activation.

International outbound calling features are not currently offered.

8. Verification Process

Vocally may perform verification using one or more of the following methods:

• Email confirmation via verification link
• Phone number verification via OTP (one-time password)
• Payment method validation through secure payment processors
• Cross-checking business registration with public databases where available
• Document review (manual and/or automated) for authenticity and completeness, based on risk and carrier requirements (Enhanced always includes compliance review)

Vocally may request additional information if provided data is unclear, incomplete, inconsistent, or required by carriers or regulators.

9. Country-Specific Requirements: Italy (+39)

When provisioning Italian phone numbers, additional requirements may apply due to AGCOM and carrier rules.

For Natural Persons (Persona Fisica):

• Personal Tax Code (Codice Fiscale)
• Date and place of birth
• Proof of address (dated within 3 months)
• Any additional attestation required by the carrier or AGCOM for number assignment (for example, evidence of presence or eligibility as required by the carrier)

For Legal Entities (Persona Giuridica):

• VAT number (Partita IVA)
• Company registration certificate
• Authorized representative details
• Registered business address

For Sole Proprietorships (Ditta Individuale):

• Personal Tax Code (Codice Fiscale)
• VAT number (Partita IVA)
• Business registration details

10. Ongoing Monitoring

Vocally may conduct ongoing or periodic reviews of customer information when:

• Carrier requirements change
• Regulatory frameworks are updated
• Traffic patterns indicate elevated risk
• Customers request new features requiring higher verification levels
• Fraud or abuse triggers automated alerts

Customers must cooperate with reasonable requests for updated information.

11. Failure to Complete Verification

Vocally may refuse feature activation, suspend services, or terminate accounts if:

• Required verification is not completed
• Information is false, incomplete, or unverifiable
• Customer activity raises significant fraud or compliance concerns
• Carriers or regulators require suspension of service

Vocally may suspend services without notice in urgent regulatory or fraud situations.

12. Data Protection & Privacy

All verification information is processed in accordance with applicable data-protection laws, including GDPR.

• Verification data is stored securely and only for as long as required for compliance.
• It is used exclusively for identity verification, fraud prevention, and telecom compliance.
• Vocally may share verification information with upstream carriers or regulatory authorities only when required for compliance.
• Verification data is never used for marketing or unrelated purposes.

13. Updates to This Policy

Vocally may update this policy to comply with new regulations, carrier requirements, or industry best practices. Updates take effect upon publication on our website or official communication channels.

14. Contact

For questions regarding this policy, verification requirements, or documentation requests, contact:

support@vocally.me