Part 1
Lead reactivation
How your list is checked, ranked and worked — what leaves your side, what never does, and the rules your industry adds.
What we take, where it goes, and who sees it.
For owners, office managers and operations
Lead reactivation works the people your business already knows — people who asked for a quote and never booked, customers who booked once, regulars who stopped, and facility managers who asked for a bid. We rank them by likelihood to book and work the list from the top, so your office spends its time on the people most likely to say yes.
Cleaning is lightly regulated, and we will not pretend otherwise. No federal privacy statute governs your customer list. What does apply is telemarketing law — the Telephone Consumer Protection Act and the state rules on texting — and the FTC’s rules on what advertising may claim. And there is one risk no regulation names: a cleaning company’s records often hold door codes, alarm codes and the days a home sits empty. This document sets out, control by control, how the engagement handles all of it, including the controls we run because they are right rather than because a rule requires them.
Sections 02 to 06 are the plain-English part. They show the whole system in pictures, explain the four things the ranking looks at, and follow one example lead from your CRM to your office. The sections after them are the detail to check before you sign.
01
Commitments
Ten commitments, before the detail
- 01 · Direct identifiers never reach an AI provider — Names, phone numbers, emails and service addresses stay in a secure environment. The AI provider sees a random ID and a few short facts, nothing more.
- 02 · Nothing goes out without your approval — Your owner or office manager approves every template before use. Our review sits on top of yours, never in place of it.
- 03 · Every message stays on your record — Outreach goes through your own channels, or is logged into your CRM as it is sent. Nothing off the record.
- 04 · No evidenced consent, no text message — Consent, opt-outs, Do Not Call status and quiet hours are checked at the moment of sending. Opt-outs are permanent.
- 05 · Your data serves your engagement only — No model training, no reuse across clients, no sale, no outside enrichment without your written instruction.
- 06 · Breach notice within 72 hours — As soon as possible and no later than 72 hours. No rule in your industry sets this window for a vendor; we commit to it anyway.
- 07 · Return and destruction, certified — At the end of the engagement your data, including the identity key, is returned or destroyed, and we confirm it in writing.
- 08 · No claim you cannot back up — Messages invite a booking or a quote. No made-up reviews, and no green, insured or background-check claim you have not confirmed in writing.
- 09 · A fee structure you choose — A flat fee or a results-based fee, with how each is treated set out in section 14.
- 10 · Evidence on request — Every control here has something you can inspect. We answer any vendor or security questionnaire during onboarding.
02
The whole picture
The system on one page
The system works in three zones. Names, addresses and contact details stay on your side. Our scoring works only with a random ID and a few short facts. The results come back to your side, where your business approves and sends.
Outcomes (booked, cleaned, back on a schedule) come back by random ID and improve your ranking only. G1 — the agreement and intake review — clears before any data moves. G7 covers retention and destruction.
Dashed gold-edged boxes, marked G1 to G7, are compliance gates. Nothing passes a gate until it clears. Section 03 lists what each one checks.
03
Step by step
From our first conversation to the first message
Seventeen steps in five phases. The gate marks show where a compliance check has to clear before the work moves on.
Onboard (before any data)
- 01 First conversation — How your business works its leads today
- 02 Agreement — Roles, purpose, subprocessors, 72-hour notice
G1 - 03 Intake review — Lead sources, consent wording, opt-outs
G1 - 04 Secure environment — In your environment, or our workstation
Prepare (on your side)
- 05 Map your stages — Your CRM statuses to eight shared stages
- 06 Check the list — Opt-outs, Do Not Call, complaints
G2 - 07 Swap names for IDs — A random ID; the key stays with you
- 08 Notes into facts — Access codes stripped; fixed-list answers
G3
Rank (Tez scoring)
- 09 Score — Intent, Opening, Reachability, Fit
- 10 Tier and reasons — A to D, with the top reasons
- 11 Short summary — Why call, and an opening line, checked
G4 - 12 Next step — Channel by consent, and timing
Act (on your side)
- 13 Match back — The ranked list appears in your CRM
- 14 Your approval — Owner or office manager approves the wording
G5 - 15 Send — Re-checked at sending; logged to your CRM
G6
Learn (ongoing)
- 16 Record outcomes — Booked, cleaned, kept; a held-back group
- 17 Improve and report — Your ranking only; results you can check
G7
| Gate | When | What has to be true to pass | Who decides |
|---|---|---|---|
| G1 | Before any data | Signed agreement; lead sources, consent wording and opt-outs reviewed; state registration and fee model confirmed | Your business and Tez |
| G2 | As the list arrives | Opt-outs, Do Not Call, active customers, complaints, damage claims and anyone hostile are set aside, never ranked | Software, on your rules |
| G3 | Before anything leaves your side | Only approved facts cross: no names, contact details, notes, access details, exact figures or dates | Software, checked by Tez |
| G4 | After a summary is drafted | No personal data, no unapproved claims, nothing the facts do not support | Software, then your office |
| G5 | Before any outreach | Your owner or office manager approves the wording and the batch | Your business |
| G6 | At the moment of sending | Consent for that channel, Do Not Call, quiet hours in the lead’s time zone, state rules, opt-outs | Software, on your channels |
| G7 | Throughout, and at the end | Outcomes kept by random ID, used for your business only, returned or destroyed at termination | Tez, certified to you |
04
The ranking
How the list is put in order
Every lead is checked first, then looked at through four factors. The factors combine into one score, and the list is sorted by it. The sorting is plain arithmetic, not an AI model, so every score can be explained in a sentence.
| Factor | The question it answers | What it looks at, for a cleaning business |
|---|---|---|
| Intent | How serious were they, and how long ago? | How far they got: quote, walkthrough, one-time clean, a regular schedule. Time since the last visit or quote. Whether they replied before. |
| Opening | Is there a real reason to get back in touch? | Why they stopped: price, a move, a schedule change, another company. A condition they named, such as “after the renovation” or “when our contract is up.” Whether that has passed. |
| Reachability | Can we reach them, and are we allowed to? | A working email or phone. Consent for each channel, marketing and reminders kept apart. Do Not Call status, and the 18-month or three-month window. |
| Fit | Can you still serve them? | Inside your service area. A service you still offer. A job size you take on, as a yes or no only. |
How the ranking gets better
- 01It starts from your team’s experience — Your office tells us how often each kind of lapsed customer or stalled quote comes back. Those estimates set the first odds, and until your results come in we say so.
- 02It corrects itself from your results — As cleans are booked, kept or declined, the odds for each reason move toward what actually happened at your business.
- 03It becomes a model of your business alone — After about 300 recorded outcomes, the ranking is fitted to your business’s results. It is never trained on, or pooled with, another business’s data.
- 04A held-back group keeps us honest — With your agreement, about one lead in ten is held back and not contacted for a set period. Comparing the two groups shows what the outreach actually changed, rather than what would have happened anyway.
05
A worked example
One lead, from your CRM to your office
Dana Whitfield is fictional. Her record is shaped like a real one, including the parts that should never travel. Follow it through the four cards, left to right and top to bottom.
1 · Your CRM record (stays with you)
| Field | Value | Note |
|---|---|---|
| name | Dana Whitfield | key table |
| phone | (512) 555-0137 | key table |
| dana.w@example.com | key table | |
| address | 1840 Cedar Lane | key table |
| status | Cancelled — biweekly | becomes a stage |
| note | Pausing until the move settles. Side door code 4417. Keep the gate shut for the dog. | becomes facts |
| per visit | $165 | becomes a tier |
| last visit | January 9, 2026 | becomes days |
2 · What we receive (leaves your side)
| Field | Value | Note |
|---|---|---|
| ID | r_4Kp8vN3d | random |
| stage | Regular schedule, lapsed | Intent |
| days since | 270 | Intent |
| reason | Life change | Opening |
| condition | Yes, waiting on an event | Opening |
| reach | Email yes · text for reminders only | Reachability |
| fit | Service area yes · service offered yes | Fit |
| value tier | 2 of 3, only if you opt in | optional |
Never leaves your side: her name, phone, email, address, CRM ID, the note itself, the door code, the dog, the visit price, exact dates.
3 · What comes back (back to you)
| Field | Value | Note |
|---|---|---|
| ID | r_4Kp8vN3d | |
| score | 68 · tier A | |
| reasons | + was a regular · + named a condition · − 270 days since last visit | |
| reason line | Former regular; paused for an event that may have passed. | fixed wording |
| summary | She paused her regular cleaning until a change at home settled. That may have happened by now. A good opener is to ask whether things have settled and whether she would like her old schedule back. | AI, checked |
| next step | Email, Thursday morning her time |
4 · In your CRM (stays with you)
| Field | Value | Note |
|---|---|---|
| record | Dana Whitfield · tier A · 68 | matched back |
| fields | Reason line, summary and next step added to her record | |
| draft | “Hi {first_name}, …” with her name filled in only at sending | placeholder |
| flags | Marketing text blocked, reminder consent only · Access code found in note | G3 G6 |
She agreed to appointment reminders by text, not marketing, so the next step is email. Her last paid visit was under 18 months ago, so a call from your office is not blocked by the Do Not Call list, unless she has asked you not to call. Your office sees her name here, in your own CRM, for the first time.
- 01Her door code never left your side — The code and the dog were stripped from the note before anything read it, and “until the move settles” left only as “waiting on an event.” The flag tells your office that this record holds an access code, so you can decide whether it belongs in your CRM at all.
06
The suggestion
How the “why call” note is written and checked
Each lead comes back with a reason line in fixed wording and a short summary drafted by an AI model, both written only from the facts in card 2 of section 05. The AI writes; it does not decide. The order comes from arithmetic, and your business approves anything sent.
The four checks at gate G4
- No personal data — The draft may not contain a name, number, email, address or anything about getting into a home. Names appear only as a placeholder, filled in on your side at sending.
- No claims you have not approved — No prices, discounts, plan terms, reviews, or green, insured or background-check claims unless they are on your approved list. Section 12 sets out why.
- Nothing made up — Every statement in the summary must trace back to one of the facts it was given. A statement that does not is treated as a failure.
- Your never-say list — Phrases and topics your business rules out are blocked, on top of the general rules above.
07
Roles
Your business stays in charge of the data
No federal privacy statute governs a cleaning company’s customer list; the Gramm-Leach-Bliley Act covers financial institutions, and the FTC Act’s bar on unfair practices is the only federal backstop. State privacy laws apply above size thresholds — in California, revenue over $26.625 million or data on 100,000 residents — and Texas exempts small businesses as the SBA defines them. Where one applies, you are the business or controller and we are the service provider or processor. Where none does, our contract does the same job. Either way the architecture here runs in full — for most cleaning businesses, more than the law requires.
| Obligation | Your business | Tez I Solutions |
|---|---|---|
| Privacy notice and opt-outs | Owns | Honours your suppression and opt-out lists |
| Approval of messages | Owner or office manager approves before use | Submits templates; keeps each draft, approval and approver for five years, as the Telemarketing Sales Rule does for scripts |
| Claims about your business | Confirms in writing what is true | Drafts only from your approved claims (section 12) |
| Record of what was sent | Owns your CRM and channels | Sends through them, or logs every message into your CRM |
| How leads were obtained | Warrants it in the agreement | Records the consent source and enforces it at send time |
| Security of data we hold | Oversees | Operates the controls in sections 10 and 11 |
| Breach notice to customers | Owns, under your state’s law | Notifies you within 72 hours and supports the investigation |
| Vendor and security review | Decides how much to ask | Answers questionnaires and supplies evidence |
| Access and deletion requests | Receives and instructs | Executes within your deadline and confirms |
| Return or destruction | Instructs | Executes and certifies in writing |
08
Data
What we take, and what we never take
The least data that lets the list be ranked and worked. Anything that helps someone get into a home or a building is never taken.
| Data | How it is handled | Reaches the AI model |
|---|---|---|
| Name, phone, email, service address | Held only in the encrypted key table on your side; used to address a message when it is sent. | No |
| Entry, alarm and lockbox codes; keys; badges | Never taken. If one appears in a note it is removed, the record is held, and your office is told which CRM record holds it. | No |
| Empty-home schedules; pets; health notes | Never taken. Stripped from notes before anything reads them. | No |
| Card and bank details | Never taken; quarantined if found in a note. | No |
| Quote, visit and contract values | Only if you agree: a three-level tier on your side. The figure never leaves. | No |
| Quote, visit and contact dates | Converted to intervals — “270 days since last visit.” | Interval only |
| Source, stage, service, frequency, crew | Kept as categories; staff names replaced with codes. | As categories |
| Visit notes and call notes | Read on your side and turned into fixed-list answers (section 09). The note itself never leaves. | Fixed-list answers only |
| Consent and opt-outs | An append-only history, enforced at send time. | No |
09
The privacy layer
Where AI sits, and what it sees
| Station | What happens | Holds or sees |
|---|---|---|
| 01 · Your business — Your CRM | Full records stay here. Only the agreed fields are read. | Holds: everything, as today |
| 02 · Secure env. — Separation, and notes into facts | A local model with no outside connection answers fixed questions about each note. The key lives only here. | Holds: identifiers, key table, notes |
| 03 · Tez scoring — Ranking, then a short summary | Ranking is arithmetic in our own code. Anthropic’s Claude words a summary from the facts. | Sees: random ID, fixed-list facts |
| 04 · Your channels — Approved, then sent | Names filled in on your side; consent checked; sent through your channels. | Holds: the message, on your record |
Notes are where door codes and “away until the 20th” end up. So they are read where they already are, and only short answers leave. Five layers make sure of it.
| Layer | What it does |
|---|---|
| 1 · Field allow-list | Only approved columns are read; access and payment fields never are. Identifiers are separated by rule, not by a model’s judgement. |
| 2 · Identifiers stripped first | Phones, emails, card numbers, any digits that could be a code, amounts and dates are removed first. Words like code, key, lockbox, alarm or gate hold the record for a person to check. |
| 3 · Fixed questions, fixed answers | The local model answers set questions — why they stopped, whether they named a condition, which kind of event — by choosing from a list your office has seen. It cannot write free text. |
| 4 · Unsure means a person decides | An answer the model is not confident about is not guessed. The record is held for a person to review. The process fails closed. |
| 5 · Final scan | Every record is scanned again before it leaves. A record carrying anything outside the approved fields is held back, not sent. |
10
Where it runs
Two ways to run the secure environment
The secure environment is where identifiable data lives during the engagement, and your business chooses where it sits. In both options the key table never leaves it, and the AI provider receives only a random ID and fixed-list facts.
| Inside your environment | On a Tez-operated workstation | |
|---|---|---|
| Where raw data sits | Your infrastructure; it never leaves your perimeter | An encrypted workstation operated by Tez, in a separate encrypted volume per business |
| Access | You control it. We use a named, least-privilege account you can revoke at any time | One named individual, with multi-factor authentication |
| Network | Your controls | Outbound limited to the AI provider and your sending channels |
| Logging | Your logging stack | Access log kept for the engagement, provided on request |
| Suits | Businesses with an IT provider or a franchisor’s systems | Most owner-run cleaning businesses |
Workstation standard, when Tez operates it
- Encrypted at rest — Full-disk encryption, as Massachusetts 201 CMR 17.00 requires on laptops, plus a separate encrypted volume for each business’s data.
- Dedicated and locked down — An OS account used only for client data, multi-factor sign-in, screen lock, current patches, endpoint protection.
- No cloud sync — Client data is never stored in a synced folder or consumer cloud backup, and is excluded from sync by configuration.
- Wiped at the end — The business’s volume is destroyed at termination and the destruction certified in writing.
11
Security and incidents
The controls, and what happens if one fails
| Control | Evidence you can ask for |
|---|---|
| Written information security program, modelled on Massachusetts 201 CMR 17.00 | The program document |
| Encryption in transit and at rest | Configuration record |
| Multi-factor authentication on every account that touches your data | Account inventory |
| Access limited to named individuals, reviewed quarterly | Access list and review log |
| Access to your data logged | Log extract |
| Background check for anyone with access, on your request | Written confirmation |
| Raw data held only for the life of the engagement | Retention schedule |
| Return or destruction within 30 days of termination | Signed certificate |
| Cyber liability insurance, where your contract requires it | Certificate of insurance |
| Written incident response plan, reviewed each year | The plan and its last review |
If something goes wrong
- 01 · Contain — Stop sending, revoke the affected credential, isolate the system.
- 02 · Notify you within 72 hours at the latest — Which records and fields, what window, what we have done. Updates follow as we investigate.
- 03 · Preserve evidence — Logs, send records and the consent history are kept intact for your investigation.
- 04 · Support your notice, never pre-empt it — Customer notice is your decision, on your state’s deadline. We tell you even where no statute would, such as an exposed entry code, and never contact your customers ourselves.
12
Claims and advertising
What outreach may say about your business
No licensing board reviews a cleaning company’s marketing. The Federal Trade Commission Act does: under section 5, a claim must be true, and backed up before it is made, whoever or whatever drafted it. These are the rules the drafting is built around.
- 01Reviews and testimonials — 16 CFR Part 465 — In force since October 21, 2024: no fake reviews or testimonials, AI-written ones included, and no reward conditioned on a review being positive. Outreach may ask for an honest review; it never writes one or pays for a good one.
- 02Recurring plans — automatic-renewal law — A message may invite a former regular back; it never signs anyone up. Enrollment happens in your booking flow, with the disclosures and consent that ROSCA and laws like California’s Automatic Renewal Law require. The FTC’s click-to-cancel rule was vacated on July 8, 2025; the FTC reopened the question in March 2026.
- 03Green and non-toxic claims — the Green Guides — No unqualified “green” or “eco-friendly” (16 CFR 260.4); “non-toxic” needs evidence for people and the environment. The EPA Safer Choice service logo only if you hold that certification; otherwise “we use Safer Choice-certified products,” only where true.
- 04Trust claims — bonded, insured, licensed, checked — Only as you confirm them in writing, and no wider: “every cleaner is background-checked” only if every one is. The checks themselves are your process under the Fair Credit Reporting Act. California janitorial employers must register with the Labor Commissioner, and hiring an unregistered one draws fines, so California bids wait for your registration.
- 05Rails the drafting stops at — Damage or theft claims, injuries, billing disputes and complaints go to your office. Outreach never asks for or repeats access details or when a home will be empty, and never asks for payment. Every draft passes gate G4 first (section 06).
13
Consent
No evidenced consent, no text message
Under the Telephone Consumer Protection Act the party that sends a message can be liable for it directly, so consent is enforced in software at sending. A facility manager’s mobile is covered like anyone’s, and CAN-SPAM covers business email.
- 01 · A consent history, not a checkbox — An append-only record of source, wording, channel and date. Reminder and marketing consent are kept apart; neither is ever overwritten.
- 02 · Checked when the message sends — Consent, suppression, Do Not Call and quiet hours are rechecked at sending, not at list-building. Yesterday’s opt-out holds today.
- 03 · Lapsed customers and the 18-month window — A paid visit within 18 months, or a quote request within three, is an established business relationship: under federal rules your office may call a number on the Do Not Call list. It is not consent to marketing texts, and it ends when they ask you to stop.
- 04 · No marketing consent on file — Email, or a call from your office — not text. A number given for appointment reminders is not consent to marketing.
- 05 · Do Not Call, reassigned numbers, hours — National Do Not Call Registry and FCC Reassigned Numbers Database, results dated and stored. 8am to 9pm local time, 8pm where Florida, Oklahoma or Washington require.
- 06 · Opt-out everywhere, permanently — STOP, a request in any words, or one made to your office is honoured on every channel at once, inside the FCC’s 10 business days, and survives any re-import.
14
How we are paid
Two fee models, and how each is treated
We offer two models. Fees are set in conversation and are not in this document. What belongs here is how each model is treated. In some industries, rules limit how a marketing vendor may be paid. We know of no such rule for cleaning, so the choice comes down to how you want to pay, not what you are allowed to.
Model A: Flat monthly fee
A fixed fee for operating the service. It does not depend on cleans booked or revenue earned.
- Treatment. No cleaning-industry rule restricts it. It is an ordinary service contract.
- What to agree. The scope of the work and the term. Nothing needs measuring.
- The simplest model to budget, approve and audit.
Model B: Results-based fee
A share of revenue from reactivated customers, measured from your CRM’s own records.
- Treatment. No cleaning-industry rule restricts it either. It is a contract question, not a regulatory one.
- What to agree. What counts as reactivated, and for how long a returning regular’s visits count. Conversions come from your CRM; we never mark them.
- The fee changes nothing about consent or claims: sections 12 and 13 apply in full.
15
Subprocessors and contract
Who else touches the data, and what we sign
| Subprocessor | What it holds | When |
|---|---|---|
| Anthropic (Claude API) | A random ID and fixed-list facts only. No names, contact details, addresses, notes or exact figures. Not used for training by default under Anthropic’s commercial terms; zero data retention requested where offered | Every engagement |
| Your CRM, email and texting providers | Records and messages, as they do today | Every engagement, under your contracts |
| Messaging provider operated by Tez | Phone numbers and message content | Only if you do not send through your own texting channel, and only with every message logged into your CRM |
| Operator console hosting | Named in your agreement, with what it holds | Where your team uses our console |
The full list is an exhibit to your agreement. We give 30 days’ notice before adding or changing a subprocessor.
What the agreement contains
- Roles and purpose — Your business as the owner of the data, Tez as service provider or processor; use limited to this engagement, with the contract terms state privacy laws require where they apply.
- No secondary use — No training, no sale, no reuse across clients, no enrichment without written instruction.
- Security exhibit and 72-hour notice — The controls in sections 08 to 11, as binding terms, including the never-taken list.
- Consent and claims warranty — Your representation of how the leads were obtained, and of the claims you approve about your business.
- Privacy requests — Access, correction and deletion within your deadlines — under a state privacy law where one applies, and on request where none does.
- Audit, return and destruction — Reasonable audit and questionnaire rights; return or certified destruction at termination.
16
Regulatory map
Each rule, and where it is addressed
| Rule | What it requires here | Section |
|---|---|---|
| TCPA and FCC rules, 47 CFR 64.1200 | Consent, revocation, Do Not Call, quiet hours, reassigned numbers | 13 |
| Telemarketing Sales Rule, 16 CFR 310 | Established business relationship; five-year script and call records | 07 13 |
| State telemarketing laws: Washington, Texas, Florida, Oklahoma | Advance consent for texts, hours and frequency | 13 |
| CAN-SPAM | Unsubscribe, address, accurate headers, business email included | 13 |
| FTC Act section 5 | Truthful, substantiated claims | 12 |
| FTC rule on reviews and testimonials, 16 CFR 465 | No fake reviews or testimonials; no paid positive reviews | 06 12 |
| ROSCA; California Automatic Renewal Law | Disclosure and consent when a recurring plan is sold | 12 |
| FTC Green Guides, 16 CFR 260; EPA Safer Choice | Qualified environmental claims; logo use | 12 |
| California Labor Code 1420–1434 | Janitorial employer registration | 12 |
| State comprehensive privacy laws | Service-provider terms, access, deletion, no sale, where thresholds are met | 07 15 |
| State breach notification laws | Notice to affected people; the business decides and sends | 07 11 |
| Massachusetts 201 CMR 17.00 | Written security program, encryption — built to, whether or not it binds | 10 11 |
| NIST IR 8053, SP 800-188 | De-identification practice | 08 09 |
17
References
Every requirement, traced to its source
Each commitment in this document rests on a primary source: a statute, a regulation, a regulator’s own order or guidance, or a court decision. They are listed here so you, or your counsel, can check our reading against the text. Links were current in October 2026.
| Privacy and data security | Relied on for | Sections |
|---|---|---|
| Gramm-Leach-Bliley Act, 15 U.S.C. 6801–6809 (law.cornell.edu/uscode/text/15/chapter-94) | Why it does not apply: it covers financial institutions, not cleaning businesses | 07 |
| California Consumer Privacy Act, Cal. Civ. Code 1798.100 et seq.; CPPA monetary thresholds, effective January 1, 2025 (cppa.ca.gov/regulations/cpi_adjustment.html) | The $26.625 million revenue threshold; service-provider contract terms; access, deletion and no-sale duties | 07 15 |
| Texas Data Privacy and Security Act, Tex. Bus. & Com. Code ch. 541 (statutes.capitol.texas.gov/Docs/BC/htm/BC.541.htm) | Exemption for small businesses as the SBA defines them | 07 |
| State security breach notification laws, NCSL index of all 50 states (ncsl.org/technology-and-communication/security-breach-notification-laws) | What triggers notice, and that your business gives it | 07 11 |
| Massachusetts 201 CMR 17.00 (mass.gov/regulations/201-CMR-1700-standards-for-the-protection-of-personal-information-of-ma-residents) | Written security program, encryption on laptops and in transit; the standard we build to | 10 11 |
| Advertising and claims | Relied on for | Sections |
|---|---|---|
| FTC Act section 5, 15 U.S.C. 45 (law.cornell.edu/uscode/text/15/45) | Claims must be truthful and substantiated, whoever drafts them; the only federal backstop on data practices | 07 12 |
| FTC Rule on the Use of Consumer Reviews and Testimonials, 16 CFR Part 465 (ecfr.gov/current/title-16/chapter-I/subchapter-D/part-465) | No fake or AI-written reviews or testimonials; no reward conditioned on a positive review | 06 12 |
| Custom Communications, Inc. v. FTC, No. 24-3137 (8th Cir., July 8, 2025) (ecf.ca8.uscourts.gov/opndir/25/07/243137P.pdf) | Vacatur of the FTC’s 2024 click-to-cancel amendments | 12 |
| FTC, Advance notice of proposed rulemaking, Negative Option Rule, 16 CFR Part 425, March 13, 2026 (federalregister.gov/documents/2026/03/13/2026-04952/rule-concerning-the-use-of-prenotification-negative-option-plans) | The FTC reopening rules on recurring plans and cancellation | 12 |
| Restore Online Shoppers’ Confidence Act, 15 U.S.C. 8401–8405 (law.cornell.edu/uscode/text/15/chapter-110) | Disclosure, consent and simple cancellation for online recurring plans | 12 |
| California Automatic Renewal Law, Cal. Bus. & Prof. Code 17600–17606, as amended from July 1, 2025 (leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=BPC&division=7.&title=&part=3.&chapter=1.&article=9.) | Express affirmative consent to continuous-service terms; why messages never enroll anyone | 12 |
| FTC Green Guides, 16 CFR Part 260 (ecfr.gov/current/title-16/chapter-I/subchapter-B/part-260) | General environmental benefit claims (260.4); non-toxic claims | 12 |
| EPA, Safer Choice Standard and Criteria (epa.gov/saferchoice/standard) | Cleaning service certification and logo use | 12 |
| Fair Credit Reporting Act, 15 U.S.C. 1681 et seq. (law.cornell.edu/uscode/text/15/chapter-41/subchapter-III) | Background checks are the employer’s process, outside our work | 12 |
| California Labor Code 1420–1434; Labor Commissioner, janitorial registration (dir.ca.gov/dlse/Janitorial_Providers_Contractors.html) | Registration of commercial janitorial employers; fines on those who hire unregistered ones | 12 |
| Telemarketing and email | Relied on for | Sections |
|---|---|---|
| Telephone Consumer Protection Act, 47 U.S.C. 227 (law.cornell.edu/uscode/text/47/227) | Consent for marketing texts and calls; statutory damages; sender liability | 13 |
| FCC rules, 47 CFR 64.1200 (ecfr.gov/current/title-47/chapter-I/subchapter-B/part-64/subpart-L/section-64.1200) | Do Not Call for texts; quiet hours; established business relationship, 18 months and three months; revocation within 10 business days | 13 |
| FCC 24-24, revocation of consent, February 2024; FCC DA 26-12, January 6, 2026 (docs.fcc.gov/public/attachments/FCC-24-24A1.pdf · docs.fcc.gov/public/attachments/DA-26-12A1.pdf) | Opt-out by any reasonable means; the revoke-all requirement delayed to January 31, 2027 | 13 18 |
| Telemarketing Sales Rule, 16 CFR Part 310 (ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310) | Established business relationship: 540 days and 90 days; five-year script and call records | 07 13 |
| National Do Not Call Registry; FCC Reassigned Numbers Database (donotcall.gov · reassigned.us) | The two checks run before any number is contacted | 13 |
| Washington, RCW 19.190.060 and 19.190.070 (app.leg.wa.gov/rcw/default.aspx?cite=19.190) | No commercial text to a Washington resident without clear advance consent | 13 |
| Texas SB 140 (2025), Tex. Bus. & Com. Code ch. 302 (statutes.capitol.texas.gov/Docs/BC/htm/BC.302.htm) | Texts as telephone solicitation | 13 |
| Florida Telephone Solicitation Act, Fla. Stat. 501.059; calling hours, 501.616 (flsenate.gov/Laws/Statutes/2026/501.059) | State consent and calling rules, applied by the lead’s state | 13 |
| CAN-SPAM Act, 15 U.S.C. 7701 et seq.; FTC compliance guide (ftc.gov/business-guidance/resources/can-spam-act-compliance-guide-business) | Unsubscribe within 10 business days, physical address, accurate headers; no business-email exception | 13 |
| De-identification and AI | Relied on for | Sections |
|---|---|---|
| NIST IR 8053, De-Identification of Personal Information, 2015 (nvlpubs.nist.gov/nistpubs/ir/2015/NIST.IR.8053.pdf) | Quasi-identifiers, re-identification risk, why pseudonymization is reversible | 08 09 |
| NIST SP 800-188, De-Identifying Government Datasets, 2023 (csrc.nist.gov/pubs/sp/800/188/final) | Generalization of figures into bands; de-identification as risk reduction | 08 09 |
| NIST SP 800-122, Guide to Protecting the Confidentiality of PII, 2010 (csrc.nist.gov/pubs/sp/800/122/final) | Classifying which fields are identifying and how sensitive each is | 08 |
| Anthropic, Commercial Terms of Service (anthropic.com/legal/commercial-terms) | No training on commercial API inputs and outputs by default | 09 15 |
18
Limits
What this document is not
- 01Not legal advice — You and your counsel decide how these rules apply to your business. This document tells them what we do so they can.
- 02Not a SOC 2 report — We do not hold a SOC 2 attestation. We answer your questionnaire and provide the policies and evidence behind each control instead.
- 03Not a cleaning company — Tez I Solutions does not clean, schedule crews, price jobs or run background checks, and holds no janitorial registration. Those, and the claims you make about them, stay yours.
- 04Not permanent — Current as of October 2026. Rules in this area are moving — the FCC’s revoke-all requirement was delayed and then narrowed by an order adopted in September 2026 that is not yet in force, and the FTC is reconsidering its rules on recurring plans. We review this document at least once a year and whenever a rule it relies on changes.
- 05Not a promise of results — A score says which leads to contact first, not who will book. Until your own outcomes are recorded, the odds behind it are estimates drawn from your team’s experience.
Part 2
AI services
How we handle your data inside your AI tools.
AI services puts a standing AI engineer across the AI tools your business already pays for — ChatGPT, Claude, Copilot, Gemini and the AI inside the software you use. We connect those tools to your CRM, inbox, calendar and files, build the workflows that do the repeat work, set up your processes and brand voice inside them, train your team, and look after the accounts. The tools stay yours, under your own contracts with each vendor. That changes how data protection works. In lead reactivation we keep names and contact details away from the AI provider by design. Here, a tool connected to your CRM will see the records it needs to do its job, names included. So the protections in this document are about something else: whose account it is, what each connection can reach, what the vendor's terms allow, who approves a workflow before it goes live, and how our access ends. Sections A1 to A6 are the same for every business we work with. Your industry's page adds sections A7 and A8: what your industry's rules mean for your AI tools, and where those rules come from.
A1
Commitments
Ten commitments, before the detail
- 01 · Your accounts, on business terms — We work only in accounts your business owns, on business plans. Never in a personal or consumer account — ours, yours or an employee's.
- 02 · A named user, never a shared password — You add us as a named user with our own sign-in and multi-factor authentication. We never ask for a shared password, and you should never send one to us by email.
- 03 · The least access that does the job — Each connection reaches only the data its workflow needs. Admin rights are used for set-up tasks, logged, and reduced afterwards.
- 04 · Nothing goes live without your approval — Every connection, workflow and set of instructions is approved by you, in writing, before it is switched on. So is every change to one that is already running.
- 05 · Automated where it is routine, a person in the loop where it is not — Routine, rule-based work can run on its own once you have approved it: sorting and tagging, summaries for your team, filing, and fixed-wording notices such as an appointment reminder from a template you signed off. Anything that needs a decision or a judgement — a reply written for a particular customer, a price, a term, a commitment, or anything your industry's page marks for review — has a person on your side in the loop before it goes anywhere. Each workflow's data sheet (A3) states which kind it is. Where your industry's page requires a person to review every customer message, that rule applies instead.
- 06 · Your data stays in your tools — We build and test inside your workspace. We do not copy your business data into Tez's own AI accounts. Where we need examples outside your tools, we use made-up records.
- 07 · Your data serves your business only — No reuse across clients, no sale, no training of anything by us. Prompts, instructions and workflows built from your material are yours and are not reused for anyone else.
- 08 · Vendor data settings confirmed in writing — During onboarding we read each tool's current data terms, set its controls with you, and give you a written record. We re-check it whenever a vendor changes its terms.
- 09 · Incident notice within 72 hours — As soon as possible and no later than 72 hours, or sooner where your industry's page says so.
- 10 · Access removed, everything handed over — At the end, our access is removed, every credential we created is revoked or rotated, and every workflow is documented and handed over. We confirm it in writing within 30 days.
Evidence on request: every control in this document has a record you can inspect, listed in section A5. If you send us a security questionnaire, we complete it during onboarding.
A2
Accounts and access
Whose accounts, and how we get in
The AI tools, the systems they connect to and the accounts that run them all belong to your business. We are given access to them; we never hold them. That is what makes the work portable: if we part ways, everything keeps running and nothing has to be moved out of our name.
Nothing in this section starts before you have decided to work with us. The first session is a conversation. We do not ask for logins, exports or files beforehand.
Who owns what
| Item | Who owns it | How we handle it |
|---|---|---|
| AI subscriptions and workspaces | Your business — in its name, on its payment method | We administer them for you. If a new tool would genuinely pay for itself, we say so and why, and it goes on your account, not ours. |
| The owner or super-admin role | Your business keeps it, with at least one person on your side who is not us | We take the lowest role that does the work. Admin rights for a set-up task are logged and reduced when the task is done. |
| Our sign-in | A named user for each Tez person, in your directory or invited as a guest | Multi-factor authentication on. No shared logins. Never a password by email, text or chat. |
| Connections — API keys, app authorisations, service accounts | Created in your accounts, owned by you | Each one is named, listed in the access record (A5), scoped to its workflow, and stored where you control it — never pasted into a document or a message. |
| Personal and consumer AI accounts | Their owners | Not used for business work. If the audit finds business work in personal accounts, we tell you and recommend moving it to business seats. We never connect your systems to a personal account. |
How access is set up
- 01 · You decide what we need — We list the systems and the role each one needs, and why. You agree or strike items out.
- 02 · You add us — Usually by adding us as a user, on a call where we walk through it together. A password is never sent.
- 03 · We confirm the safeguards — Multi-factor authentication on, role as agreed, sign-in recorded in the access record.
- 04 · Reviewed every quarter — We go through the access record with you and remove anything no longer needed.
- 05 · Removed at the end — Section A5 sets out how access ends.
Roles
| Obligation | Your business | Tez I Solutions |
|---|---|---|
| Contracts with AI vendors | Holds them; the vendor processes your data under them | Reads the data terms and records them for you (A4) |
| Who on your team uses which tool | Decides | Sets up the seats and permissions you decide |
| Approval of workflows and changes | Approves before anything goes live | Proposes, documents and builds; never switches on without approval |
| Review of customer-facing output | Your people review before sending | Builds the review step into the workflow |
| Industry rules — licensing, records, supervision, privacy notices | Owns them | Builds to them as set out on your industry's page (A7) |
| Security of the access we hold | Oversees | Operates the controls in A5 |
| Notice to customers or regulators after an incident | Decides | Tells you within 72 hours and supports the investigation |
| Privacy requests from your customers | Receives and instructs | Helps find and remove the data in the tools we set up, within your deadline |
Where a state privacy law reaches your business, we act as your service provider or processor for the access we hold, and the agreement says so.
A3
What the tools can see
Connections, scopes, and what stays out
An AI tool connected to one of your systems can see whatever that connection lets it see. An assistant that searches your files can surface anything the person using it is allowed to open — Microsoft says of its own Copilot that it "only surfaces organizational data to which individual users have at least view permissions." So the work starts with permissions, not prompts.
Before anything is connected
- Who can see what — Before an assistant is pointed at a shared drive, inbox or CRM, we review who can open what. Folders that are open to everyone but should not be are fixed first, with your approval.
- One data sheet per workflow — Every workflow gets a written sheet: what it reads, what it writes, who sees the result, and where a person reviews it. You approve the sheet before we build.
- Add-ons are vendors too — A plug-in, connector, custom GPT or agent from a third party is another company handling your data. None is installed without your approval and a record of its data terms.
What a data sheet looks like
Illustration — not real client data.
| Workflow | Reads | Writes | Who sees the result | Human in the loop |
|---|---|---|---|---|
| Morning summary of new inquiries | CRM records created in the last 24 hours: name, source, service asked about, notes | One summary in the office manager's inbox | Office manager | Read before anyone acts on it |
| First-draft reply to a quote request | The single inquiry being answered; your approved reply templates and brand voice | A draft in the shared inbox — never sent | The person replying | Edited and sent by a person |
| Meeting notes to CRM | The transcript of a meeting the attendees agreed to record | A note on the matching CRM record | The account owner | Checked before it is saved |
What stays out by default
Unless your written decision says otherwise, after we have shown you what the vendor's terms and your industry's rules say, these are kept out of every prompt, instruction file and connection:
- Social Security numbers, tax IDs, driver's licence and other government ID numbers
- Full bank account and card numbers
- Passwords, access codes, gate, door and alarm codes
- Health information
- Anything your industry's page (A7) marks as restricted
Where a connection would expose one of these — a folder of scanned IDs, a CRM field holding card numbers — the connection is narrowed to leave it out, or not built.
Before a workflow goes live
| Check | What has to be true |
|---|---|
| Data sheet | Approved by you, in writing |
| Access | The connection reaches only what the sheet lists |
| Test | Run on made-up records, or on a small set of real ones you choose, with the results shown to you |
| Human in the loop | Marked on the data sheet. In place wherever a decision or judgement is involved: a reply written for a particular customer, a price or a term, or anything your industry's page marks for review. Routine, rule-based steps you have approved may run without one |
| Owner | A named person on your side who can pause it |
| Documentation | Written up and stored where you keep it |
AI tools make mistakes. Every workflow is built on the assumption that a draft can be wrong, which is why the review step is part of the design rather than a suggestion.
A4
Model providers and training
What the vendors do with your data, and how we check
When your team or a workflow uses ChatGPT, Claude, Copilot or Gemini, the vendor processes that data under its contract with your business. Tez is not a reseller or partner of any AI vendor, and not a party to those contracts. Whether a vendor trains its models on your data, how long it keeps prompts, whether its staff can review them, and where it processes them are set by the vendor's terms and by the plan you are on. Those terms change. So we do not promise what a vendor will do. We promise what we will do.
What we do
- 01 · List every tool — Each AI tool and AI feature you pay for, the plan it is on, and who holds a seat.
- 02 · Read the current terms — For each one we record what the vendor says about training on your data, retention, human review, where data is processed, and which admin controls exist. Each entry carries the date and the address of the page we read.
- 03 · Set the controls with you — Where a tool offers a choice — training opt-outs, retention periods, chat history, which add-ons are allowed — we recommend the most protective setting that still does what you need, and you decide.
- 04 · Give you the record — The settings record is yours, in writing. Your compliance contact can file it with your vendor reviews.
- 05 · Re-check when terms change — When a vendor changes its data terms, we re-read them, update the record and tell you if anything moved. We also re-check the whole record at least every six months.
What the main vendors said when we checked
Read on each vendor's own page on 6 October 2026. This is the vendor's statement to its customers, not a commitment by Tez. If it changes, the vendor's current terms govern, and we update your record.
| Vendor | What its page said | Where |
|---|---|---|
| Anthropic — Claude, under its Commercial Terms | "Anthropic may not train models on Customer Content from Services." The Commercial Terms cover Anthropic's API and the business offerings that reference them, not its consumer plans. Effective June 17, 2025. | anthropic.com/legal/commercial-terms |
| OpenAI — API | Data sent to the API is not used to train or improve OpenAI's models unless you opt in, as of March 1, 2023. Abuse-monitoring logs are kept for up to 30 days by default. | developers.openai.com/api/docs/guides/your-data |
| OpenAI — ChatGPT business plans | Read during onboarding against OpenAI's published terms for your plan, and recorded the same way. | openai.com/enterprise-privacy |
| Microsoft — Copilot | "Prompts, responses, and data accessed through Microsoft Graph aren't used to train foundation LLMs." Copilot only surfaces data a user already has permission to view. | learn.microsoft.com/en-us/microsoft-365/copilot/microsoft-365-copilot-privacy |
| Google — Gemini in Google Workspace | Your content "is not human reviewed or otherwise used for Generative AI model training outside your domain without permission." | knowledge.workspace.google.com/admin/gemini/generative-ai-in-google-workspace-privacy-hub |
| AI inside your other software | Each vendor's own terms — your CRM, phone system or accounting software. Recorded the same way during onboarding. | Each vendor's data or AI terms page |
Consumer plans and personal accounts
Consumer plans run on different terms from business plans — Anthropic's Commercial Terms, for one, state that they do not cover its consumer offerings. We do not do business work in consumer or personal accounts, and we do not rely on a consumer plan's settings to protect business data.
Our own tools
We use AI tools of our own to write code and documentation. Your business data does not go into them. Anything we build for you is built and tested in your workspace, or against made-up records.
A5
Records, security and incidents
What we keep, how it is protected, and what happens if something fails
Records you can inspect
Records describe what we built and changed. They live in a location your business owns, and they do not contain your customers' data.
| Record | What it holds |
|---|---|
| Access record | Every Tez sign-in and every connection we created: system, role or scope, date added, date reviewed, date removed |
| Settings record | Each tool's plan, data terms as read on a given date, and the controls set (A4) |
| Workflow register | Every live workflow, with its approved data sheet (A3), its owner on your side and its documentation |
| Change log | Every change to a live workflow or connection: what changed, why, when, who approved it |
| Training record | Who was trained, on which tools and processes, and when |
Changes to something already running
Every change to a live workflow is described, approved by you, tested, logged and reversible — the previous version is kept. If a vendor update breaks a workflow, or a workflow starts doing something it should not, we may pause it at once to stop harm, and tell you the same day. We do not change what a workflow does without your approval.
Security controls
| Control | Evidence you can ask for |
|---|---|
| Written information security program, modelled on Massachusetts 201 CMR 17.00 | The program document |
| Multi-factor authentication on every account we use to reach your systems | Access record |
| Access limited to named individuals, reviewed with you quarterly | Access record and review log |
| Tez devices: full-disk encryption, screen lock, current patches, endpoint protection | Configuration record |
| Your data is not stored on Tez devices or in our cloud storage; where a task needs a file locally, it is deleted when the task ends | Written procedure |
| Background check for anyone with access, on your request | Written confirmation |
| Cyber liability insurance, where your contract requires it | Certificate of insurance |
| Written incident response plan, reviewed each year | The plan and its last review |
If something goes wrong
An incident includes a workflow sending or showing data to the wrong person, a connection reaching more than its sheet allows, a suspected compromise of a Tez sign-in, and a vendor incident we learn of that affects your workspace.
- 01 · Contain — Pause the workflow, revoke the affected credential or connection, and stop the exposure.
- 02 · Notify you within 72 hours at the latest — Which systems and data, what window, what we have done. Sooner where your industry's page sets a shorter time. Updates follow as we investigate.
- 03 · Preserve evidence — Logs, the change log and the vendor's audit records are kept intact for your investigation.
- 04 · Support your notice, never pre-empt it — Whether customers or regulators are told is your decision. We never contact your customers about it. A vendor's own incident notice comes to you under your contract with that vendor.
When the engagement ends
| Step | What happens |
|---|---|
| Access removed | Every Tez user and role removed from every system, checked against the access record |
| Credentials ended | Every key, app authorisation and service account we created is revoked, or rotated and handed to you |
| Nothing in our name | Anything that ended up in a Tez name is transferred to you first — by design there should be nothing |
| Handover pack | The workflow register, data sheets, settings record, change log and plain-English run notes, so your team or the next provider can keep it running |
| Written confirmation | Within 30 days of the end of the engagement |
Everything we build is yours — documented and portable. If we part ways, it keeps working and your team knows how it runs.
A6
Limits
What this document is not
- 01 · Not legal advice — Your counsel or compliance officer decides how your industry's rules apply to your business. This document tells them what we do so they can.
- 02 · Not a SOC 2 report — We do not hold a SOC 2 attestation. If you send a security questionnaire, we complete it and provide the policies and evidence behind each control instead.
- 03 · Not the vendor — We do not run the AI vendors' systems or set their terms. Their security, retention, outages and incidents are governed by your contract with them. We are not a reseller, partner or certified provider of any AI vendor.
- 04 · Your obligations stay yours — Using AI tools does not move your duties to us: licensing, supervision, record keeping, privacy notices and your staff's use of AI remain your business's responsibility. We build to them, as your industry's page sets out.
- 05 · Not a promise about AI output — AI tools can be wrong, and confidently so. That is why anything that needs a judgement has a person in the loop, and why no workflow makes a decision your business would otherwise make.
- 06 · Not permanent — Current as of October 2026. Vendor terms and the rules on AI change often. We review this document at least once a year, and whenever a vendor term or rule it relies on changes.
A7
Cleaning
What your industry's rules mean for your AI tools
Cleaning is lightly regulated, and that does not change because an AI tool is involved. What matters most is something no rule names: your scheduling software and your team's notes often say how to get into a customer's home, and when it sits empty. An assistant connected to those systems can repeat that to anyone who asks it the right question. The rest is advertising law, because AI tools are often asked to draft the messages, reviews requests and website copy that make claims about your service.
| Rule | What it means for AI tools | How we handle it |
|---|---|---|
| No rule — home-access details | Door, gate, alarm and lockbox codes, key locations and "home empty on Tuesdays" are not personal information under most breach laws, but they are the most dangerous data you hold. An assistant that can search job notes can surface them. | Kept out of every AI connection. Where codes sit in job notes, the connection leaves those notes out, and we show you which records hold them so your team can move them somewhere locked down. |
| FTC Act section 5 [1] | Every claim in a message must be true and backed up, whoever or whatever drafted it. "Background-checked," "insured," "satisfaction guaranteed" and "pet-safe" are claims. | Your approved claims go into the tools' brand-voice instructions as a fixed list. Drafts that make a claim outside it are flagged for your review. |
| FTC rule on reviews and testimonials, 16 CFR Part 465 [2] | AI-written reviews or testimonials presented as real customers' are banned, and so is any reward conditioned on a positive review. | We do not build anything that writes reviews or testimonials. A review-request workflow asks for an honest review and offers nothing for a good one. |
| Restore Online Shoppers' Confidence Act; California Automatic Renewal Law [3][4] | Recurring plans need clear terms and the customer's express consent. A chatbot or drafted reply that signs someone up, or implies they are signed up, can break these rules. | No AI tool enrols anyone in a recurring plan. Drafts can explain a plan and point to how to sign up; the sign-up itself stays in your own booking process. |
| FTC Green Guides, 16 CFR Part 260 [5] | "Eco-friendly" and "non-toxic" must be qualified and supported. AI tools write these words freely. | Environmental claims are on the fixed list only in the form you can support. |
| TCPA and state texting laws; CAN-SPAM [6][7][8] | A text or email a workflow sends is a marketing message under the same rules as one a person sends: consent for texts, opt-outs honoured, unsubscribe and address in email. | Workflows draft; a person sends, from your channels. If you ask for a workflow that sends on its own, consent and opt-out checks are built into it first. |
| State privacy and breach laws [9][10] | Larger businesses may meet a state privacy law's thresholds; every state has a breach law. AI tools holding customer data are part of what a breach could expose. | Incident notice to you within 72 hours, including exposure of access codes that no statute would count. Help with access and deletion requests in the tools we set up. |
In practice
- A workflow may draft a reply to a quote request from the details the customer gave. It does not read the job notes on that customer's past visits.
- A team assistant may answer questions about your cleaning checklists and policies. It is not connected to the scheduling system where entry instructions live.
- A drafted follow-up may say what your service includes. It may not say "eco-friendly" unless that exact claim is on your approved list.
- During the audit we check whether staff paste customer addresses or entry details into personal AI accounts. If they do, you hear it from us first.
A8
Sources
Where these rules come from
1. FTC Act section 5, 15 U.S.C. 45 — https://www.law.cornell.edu/uscode/text/15/45 2. FTC Rule on the Use of Consumer Reviews and Testimonials, 16 CFR Part 465 — https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-465 3. Restore Online Shoppers' Confidence Act, 15 U.S.C. 8401–8405 — https://www.law.cornell.edu/uscode/text/15/chapter-110 4. California Automatic Renewal Law, Cal. Bus. & Prof. Code 17600–17606 — https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=BPC&division=7.&title=&part=3.&chapter=1.&article=9. 5. FTC Green Guides, 16 CFR Part 260 — https://www.ecfr.gov/current/title-16/chapter-I/subchapter-B/part-260 6. Telephone Consumer Protection Act, 47 U.S.C. 227 — https://www.law.cornell.edu/uscode/text/47/227 7. FCC rules, 47 CFR 64.1200 — https://www.ecfr.gov/current/title-47/chapter-I/subchapter-B/part-64/subpart-L/section-64.1200 8. FTC, CAN-SPAM Act: A Compliance Guide for Business — https://www.ftc.gov/business-guidance/resources/can-spam-act-compliance-guide-business 9. California Consumer Privacy Act; California Privacy Protection Agency, monetary thresholds — https://cppa.ca.gov/regulations/cpi_adjustment.html
- 01NCSL, Security Breach Notification Laws — https://www.ncsl.org/technology-and-communication/security-breach-notification-laws