1. Purpose and Status
This Compliance Policy describes how Satalya approaches legal and operational risk in supplying an invitation-only AI Dialer and Classic Dialer to Lawful Businesses. It is a commercial policy, not a government licence, not a certification, and not a warranty.
Satalya does not claim that it is authorised as a telecommunications operator, payment institution, credit institution, or law firm, unless a separate licence is expressly identified in writing. This Policy does not assert audited GDPR compliance or any other formal attestation.
This Policy is consistent with the Terms, AUP, Privacy Policy, Refund Policy, and Disclaimer. If a Customer’s internal policy is weaker than the AUP, the AUP prevails as a condition of using Satalya.
2. Lawful-Use Standard
Satalya’s product is intended solely for lawful commercial, professional, and institutional use. Satalya’s public website states that standard because it is a condition of access, not a slogan. Customers must obey all applicable laws. Satalya may refuse service to the fullest extent permitted by law.
3. Invitation, Refusal, and Know-Your-Customer Posture
There is no public registration. Satalya reviews access requests and may ask for organisational identity, intended use, and jurisdiction. Satalya may decline any request without providing a detailed reason. Satalya may re-review an existing Account if risk indicators appear.
Information collected during review is processed as described in the Privacy Policy. False statements are grounds for immediate termination and fee forfeiture as described in the Refund Policy.
4. Prohibited-Use Enforcement
Satalya treats fraud, phishing, impersonation, financial crime, money laundering, unauthorised access, and misuse of third-party data as termination events. Reasonable suspicion is a sufficient internal standard. Satalya may suspend first and review second where delay would increase harm.
Satalya is not an investigator of first resort for every called-party complaint, but it may act on credible evidence. Enforcement decisions are not public findings of fact.
5. Sanctions and Export Control
Satalya does not intend to deal with sanctioned persons or comprehensively sanctioned territories. Customers must not access the Service in violation of export-control or sanctions law. Satalya may screen names, countries, and, where relevant, wallet addresses. Screening is risk management, not a representation that every counterparty has been exhaustively verified.
6. Anti-Financial-Crime Posture
Satalya is a software vendor. It is not, by default, a money-laundering reporting entity in every jurisdiction. Nonetheless, Satalya may refuse payments, including cryptocurrency, that present unexplained risk, and may terminate relationships that appear to involve criminal proceeds. Customers must not use the Service to recruit mules, to layer funds, or to operate unlicensed remittance.
Cryptocurrency terms in the Terms of Service apply. Source-of-funds questions are permitted. Failure to answer may result in refusal.
7. Privacy Principles without Certification
Satalya’s Privacy Policy is drafted with regard to GDPR-style principles. That drafting choice is not a claim of certification, a claim of establishment in the EEA, or a claim that a supervisory authority has reviewed Satalya. Customers remain controllers of their lists and must run their own privacy programmes.
8. Telecommunications and Consent
Customers must obtain and record consent or another lawful basis for calling and recording. Satalya does not supply that basis. Features such as speed, AI assistance, or a Classic Dialer mode do not reduce consent duties. Customers must honour opt-outs.
9. Law Enforcement Requests Policy
Satalya cooperates with competent authorities only when it is legally obliged to do so, or when a request is made under valid legal process that Satalya reasonably determines it must honour. Satalya does not provide informal dumps of Customer Content to private litigants or to persons who merely assert official status without process.
Satalya may ask to see the instrument, may narrow overly broad demands where the law allows, and may notify the Customer unless notice is forbidden or would create a material risk. Satalya may preserve data when required. Compulsory disclosure is not a waiver of rights and is not an endorsement of any allegation.
Emergency disclosures, if ever made, will be limited to what Satalya reasonably believes is necessary to prevent imminent serious harm where the law permits or requires that step.
10. Record-Keeping and Holds
Satalya retains operational and billing records as described in the Privacy Policy. Customers must keep their own consent and campaign records. If Satalya issues a legal hold to a Customer, the Customer must preserve specified data. Satalya may preserve its own copies when legally required.
11. Vendor and Infrastructure Diligence
Satalya may use third-party hosting, communications, and payment infrastructure. Those vendors have their own terms. Satalya’s use of a vendor is not a warranty of that vendor’s certification status. Customers must not attempt to abuse vendor systems through Satalya.
12. Customer Residual Duties
Compliance at Satalya does not replace compliance at the Customer. The Customer remains fully responsible for campaigns, staff, vendors, lists, scripts, recordings, payments, taxes, and all laws applicable to its industry. The Indemnification, Warranty Disclaimer, and Limitation of Liability clauses in the Terms remain the commercial allocation of that risk.
Satalya may refuse service, suspend service, or terminate service where continued access would, in Satalya’s judgement, undermine this Policy.
13. Changes
Satalya may update this Policy by posting a new version. Continued use is acceptance. Questions: legal@satalya.com.
Annex A — Escalation
Internal escalation for suspected Prohibited Activity may include: preservation of logs; suspension of credentials; refusal of further cryptocurrency payments; notification to the Customer where permitted; and, where legally obliged, disclosure to a competent authority. Satalya staff are not to provide informal “tips” to private investigators without process.
Annex B — Training Expectation for Customers
Satalya expects Customers to train operators on identity rules, consent, opt-out, and the prohibition of credential harvesting. Satalya may request a written attestation that such training occurred. Failure to provide an attestation when asked is a risk factor and may lead to suspension.
This Policy will be reviewed when Satalya changes its access model, payment methods, or product scope. The “Last updated” date is the public signal of the current version.
14. Access-Review Factors
Without publishing a checklist that could be gamed, Satalya may consider, among other things: whether the applicant identifies a real organisation; whether the intended use is specific and lawful; whether the jurisdiction of operation is compatible with sanctions rules; whether the narrative is consistent; whether the applicant is willing to attest to the AUP; and whether open information suggests prior abuse of communications tools. No one factor is decisive. Satalya may refuse an applicant who satisfies every factor if residual risk remains unacceptable.
Satalya has no duty to complete a review within a stated number of days. Delay is not acceptance.
15. Ongoing Monitoring Posture
Satalya may review usage volumes, complaint intake, payment events, and security logs. Monitoring is risk-based and may be intermittent. Absence of monitoring is not a representation that a campaign was reviewed. Customers must not treat silence as a clean bill of health to show a regulator.
16. Sanctions Escalation
If a sanctions hit occurs after onboarding, Satalya may freeze the Account, refuse further payments, and seek advice. The Customer must cooperate. Assets already paid may be retained or dealt with as applicable sanctions and the Refund Policy allow. Satalya is not obliged to give a detailed public explanation that would itself create a sanctions risk.
17. Cryptocurrency Risk Controls
Satalya may specify accepted assets and networks, may refuse mixing-service proceeds, may request a simple explanation of source of funds, and may convert a request to a fiat invoice. These controls implement the Cryptocurrency Payment Terms. They are not a representation that Satalya is a virtual-asset service provider licensed in any particular state.
18. Interaction with Carriers
Upstream carriers may filter traffic, demand registration of campaigns, or cut routes. Satalya may pass through those requirements. A carrier’s demand is not a Satalya warranty. The Customer must not attempt to evade carrier rules by technical concealment.
19. Internal Separation
Satalya intends that persons who handle legal process are not the same persons who casually browse Customer scripts for curiosity. Implementation may be proportionate to the size of the operation. This statement is an intention, not an audited control report.
20. Customer Attestations
Satalya may require periodic written attestations that: the Customer remains a Lawful Business; lists remain lawfully sourced; staff have been trained; no regulator has prohibited the Customer’s calling programme; and no sanctioned person has acquired control of the Customer. False attestation is a material breach.
21. No Marketing of “Guaranteed Compliance”
Neither Satalya nor the Customer may market the Service as guaranteeing compliance with TCPA, PECR, GDPR, or any other statute. The website’s legal pages exist to allocate risk and to forbid crime, not to certify the Customer’s programme. Customers must not show this Policy to a third party as proof that the third party’s data will be processed in a particular certified manner.
22. Review Cycle
Satalya may review this Policy when it changes payment methods, hosting locations, or product modes, or when a material legal development occurs. The public signal is the “Last updated” date. Customers with Accounts should read the Legal Documents again after that date.
23. Contact Matrix
Access: contact@satalya.com. Legal process and AUP: legal@satalya.com. Privacy: privacy@satalya.com. Misdirected mail may be forwarded internally but Satalya does not warrant that a court deadline will be met if you used the wrong channel.
24. Lawful-Use Attestation Text
Without limiting any other representation, a Customer who submits an access request or who uses an Account is deemed to attest: “I am acting for a Lawful Business. I will use Satalya’s AI Dialer and Classic Dialer only for lawful purposes. I will not use them for fraud, phishing, impersonation, financial crime, money laundering, unauthorised access, misuse of other persons’ data, or any other illegal activity. I am solely responsible for my lists, scripts, staff, and campaigns. I have read the Terms of Service, Acceptable Use Policy, Privacy Policy, Refund Policy, Disclaimer, and this Compliance Policy. I understand that Satalya may refuse, suspend, or permanently terminate access if it has reasonable suspicion of unlawful use, and that Satalya is not responsible for my misuse.”
That attestation is repeated each time the Customer launches a campaign or pays an invoice. It is an electronic statement, not a ceremonial extra.
25. Refusal of Service — Worked Grounds
Illustrative grounds for refusal, without creating a closed list, include: an applicant who will not identify a beneficial organisation; an intended use described only as “leads” with no lawful basis; a request to spoof a bank or public authority; a request to run “verification calls” for unknown third parties; a payment from a wallet Satalya elects not to accept; a sanctioned nexus; a prior termination of a related Account; or a script that requests one-time codes. Satalya may also refuse because it does not wish to take the operational risk, even if the applicant asserts that the use is lawful.
26. Law-Enforcement Desk Procedure (Summary)
Instruments should be sent to legal@satalya.com. Satalya will record the date of receipt, review apparent validity and scope, and determine whether the request is compulsory. If it is not compulsory, Satalya will not produce Customer Content merely to be helpful to a private party. If it is compulsory, Satalya will produce what the instrument lawfully requires, may seek to narrow overbreadth where the law allows, and will notify the Customer unless notice is forbidden or would create a material risk of harm or obstruction.
Satalya staff are not authorised to accept service of process through social media or through the public website form, except where mandatory law treats such a channel as valid. Informal telephone assertions of official status are not process.
27. Export and Travel
Customers must not grant credentials to persons who will use them from a comprehensively sanctioned territory. If a user’s travel creates a sanctions or export risk, the Customer must pause that user’s access. Satalya may geo-block. Circumvention of a geo-block by a VPN for the purpose of evading sanctions is a material breach.
28. Residual Risk Statement
No private software vendor can eliminate the residual risk that a remote Customer will disobey the AUP. This Policy reduces that risk by invitation-only access, contractual prohibitions, termination rights, payment-risk controls, and a law-enforcement policy limited to compulsory process. It does not eliminate the risk, and it does not make Satalya the insurer of called parties or of the Customer’s regulatory programme.
Satalya’s owners and operators rely on this residual-risk statement, together with the Disclaimer and the Terms, as the commercial understanding on which the Service is offered.
29. Document Map
The Terms of Service are the master commercial contract, including invitation-only access, fees, cryptocurrency payment terms, intellectual property, warranty disclaimer, limitation of liability, indemnification, termination, export and sanctions, and law-enforcement cooperation. The Acceptable Use Policy particularises prohibited conduct. The Privacy Policy describes processing and states that GDPR-style principles inform drafting without a certification claim. The Refund Policy explains when money is earned and when it is forfeited. The Disclaimer states that Satalya is not responsible for misuse and that project creators are protected to the maximum lawful extent. This Compliance Policy describes Satalya’s internal posture for invitations, sanctions, financial-crime risk, privacy principles, consent residual duties, and compulsory process.
The documents are intended to be consistent. If two clauses can be read together, they should be. If they cannot, the clause that more specifically addresses the subject controls, except that lawful-use prohibitions, termination for reasonable suspicion, warranty disclaimer, limitation of liability, and indemnification always control over marketing copy and over any Customer policy.
30. Closing
Satalya is offered as a private, fast, intelligent AI Dialer with a conventional dialer mode, for premium Lawful Businesses, without public registration. Compliance here means a contractual and operational posture, not a government stamp. Questions: legal@satalya.com.