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 your counsel
Lead reactivation works the leads your business has already paid for — homeowners who asked for a replacement quote, a second opinion or a tune-up, were followed up once or twice, and then were not. We rank them by likelihood to book and work the list from the top, so your team spends its time on the people most likely to say yes to a visit.
Most of what governs that list is telemarketing law: the TCPA, Do Not Call, and state rules that treat a text as a sales call. On top of it sit the rules for HVAC work — licence numbers in advertising, the federal heat pump and efficiency tax credits that ended with 2025, disclosures that a monthly payment brings with it, and renewal rules for maintenance plans. No federal privacy rule like the one banks follow covers an HVAC business, and most state privacy laws will not reach yours. We protect the data as if they did. This document sets out, control by control, what we do, which rules it answers, and where it goes further than they require.
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 rep’s phone. The sections after them are the detail your counsel will check.
01
Commitments
Ten commitments, before the detail
- 01 · Direct identifiers never reach an AI provider — Names, phone numbers, emails, street addresses and gate or alarm codes 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 — You, or the person you name, approve every template and every batch before it is used. Our review sits on top of yours, never in place of it.
- 03 · Every message goes out in your name — Under your licensed business name, with your licence number where your state requires it, from your own number or email domain, and logged in your CRM.
- 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 of leads, no outside enrichment without your written instruction.
- 06 · Breach notice within 72 hours — As soon as possible and no later than 72 hours. No law sets that window for your business; 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 credit, rebate or payment promises — Messages invite a visit or a call. No tax credits, rebate amounts or monthly payments, no price or savings promises, no made-up reviews.
- 09 · A fee structure that fits your work — A flat fee or a results-based fee. California work and insurance-funded jobs are treated separately, as section 14 explains.
- 10 · Evidence on request — Every control here has something you can inspect. If you send us a security questionnaire, we complete it 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 you approve and send.
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 team follows up on quotes today
- 02 Agreement — Roles, purpose, subprocessors, 72-hour notice
G1 - 03 Intake review — Lead sources, consent wording, plan members
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, open jobs, complaints
G2 - 07 Swap names for IDs — A random ID; the key stays with you
- 08 Notes into facts — Fixed-list answers; job values become tiers
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 — You approve the wording and the batch
G5 - 15 Send — Re-checked at sending; from your channels
G6
Learn (ongoing)
- 16 Record outcomes — Booked, sold, lost; 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; your lead sources, consent wording and opt-out records reviewed; your states, licence numbers, maintenance plans and fee model confirmed | Your business and Tez |
| G2 | As the list arrives | Opt-outs, Do Not Call, open jobs, complaints and anyone hostile are set aside and never ranked | Software, on your rules |
| G3 | Before anything leaves your side | Only approved facts cross: no names, contact details, addresses, notes, exact figures or exact dates | Software, checked by Tez |
| G4 | After a summary is drafted | No personal data, no credit, rebate or payment figures, no banned words, nothing the facts do not support | Software, then your rep |
| G5 | Before any outreach | You, or the person you name, approve 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, 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 an HVAC business |
|---|---|---|
| Intent | How serious were they, and how long ago? | How far they got: service call, in-home assessment, written replacement quote, financing discussed. Past customer or plan member. Time since the last real conversation. |
| Opening | Is there a real reason to get back in touch? | The reason they paused: price, waiting for the old system to give out, a second quote, a decision at home. A moment they named, such as “after the summer,” and whether it has passed. |
| Reachability | Can we reach them, and are we allowed to? | A working email or phone. Consent on file for each channel. Do Not Call status, and whether an inquiry, past-customer or plan-member window applies. |
| Fit | Can you still do the job? | An address inside your service area, as a yes or no only. Equipment you still install and service. Whether the job size suits your crews, as a tier, only if you opt in. |
How the ranking gets better
- 01It starts from your team’s experience — Your team tells us how often each kind of stalled replacement quote comes back. Those estimates set the first odds. Until your results come in, the scores are educated estimates, and we say so.
- 02It corrects itself from your results — As visits are booked and systems are sold or lost, 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 own results. It is never trained on, or pooled with, another company’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 rep
Renee Calloway is fictional. Her record is shaped like a real HVAC replacement lead. Follow it through the four cards, left to right and top to bottom.
1 · Your CRM record (stays with you)
| Field | Value | Note |
|---|---|---|
| name | Renee Calloway | key table |
| phone | (281) 555-0164 | key table |
| renee.c@example.com | key table | |
| address | 2207 Example Hollow Dr, Katy, TX | key table |
| status | Quote sent — no decision | becomes a stage |
| note | Heat pump 15 years old, still running. Wants to wait until after summer. Asked about the tax credit and a monthly payment. | becomes facts |
| quote | $14,900 heat pump replacement | becomes a tier |
| last contact | March 18, 2026 | becomes days |
2 · What we receive (leaves your side)
| Field | Value | Note |
|---|---|---|
| ID | s_7Kq2vN9e | random |
| stage | Written quote | Intent |
| days since | 202 | Intent |
| reason | Timing · named moment has passed | Opening |
| flag | Credit, payments raised · do not mention | G4 |
| reach | Email yes · text yes, consent on file | Reachability |
| fit | Service area yes · equipment offered yes | Fit |
| job tier | 2 of 3, only if you opt in | optional |
Never leaves your side: her name, phone, email, address, the note itself, the quote figure, the system’s exact age, exact dates.
3 · What comes back (back to you)
| Field | Value | Note |
|---|---|---|
| ID | s_7Kq2vN9e | |
| score | 81 · tier A | |
| reasons | + written quote · + named moment has passed · – 202 days since contact | |
| reason line | Written quote; she asked to wait for a moment that has now passed. | fixed wording |
| summary | She held off on replacing her heat pump until after the summer, which has passed. A good opener is to ask whether it is still on her list and offer a visit. | AI, checked |
| next step | A text, weekday late morning her time; email if no reply |
4 · In your CRM (stays with you)
| Field | Value | Note |
|---|---|---|
| record | Renee Calloway · tier A · 81 | matched back |
| fields | Reason line, summary and next step added to her record | |
| draft | A text for approval: offers a visit; your Texas licence number; STOP line | G5 |
| flags | Credit and payment terms blocked · consent, quiet hours rechecked | G6 |
Her quote request carried written consent to texts, so a text may go once you approve it. Your rep sees her name here, in your own CRM, for the first time.
- 01Her note became a few facts, and a flag — “Tax credit” and “monthly payment” left only as a do-not-mention flag. The federal credit she asked about ended for systems installed after 2025, and a payment figure in a message brings in Regulation Z disclosures, so the draft says neither (section 12).
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 you approve anything sent.
The four checks at gate G4
- No personal data — The draft may not contain a name, number, email or address. Names appear only as a placeholder, filled in on your side at sending.
- No credit, rebate or payment promises — No tax credits, rebate amounts, monthly payments, rates, prices or savings figures. No efficiency or refrigerant claim the facts do not support. The draft invites a visit, nothing more.
- Nothing made up — Every statement must trace back to one of the facts it was given. No invented reviews, neighbours or results. A statement that does not trace is a failure.
- Your never-say list — Phrases and topics you rule out are blocked, on top of the general rules above.
07
Roles
Your business stays in charge of the list
Your business owns the leads and decides how they are used. We work on your instructions as a service provider. Where a state privacy law reaches your business, we are your processor under it; under state breach laws we hold data on your behalf. The federal financial-privacy rule, GLBA, does not apply to an HVAC business, unless you lend to customers yourself. Telemarketing law is different: the business a message promotes and the party that sends it can both be liable. So consent is enforced in software, and responsibility is divided in writing.
| Obligation | Your business | Tez I Solutions |
|---|---|---|
| Privacy notices and opt-outs | Owns | Honours your suppression and opt-out lists |
| Approval of messages | You approve before use | Submits templates; never alters approved wording |
| Licence numbers and trade rules | Supplies your licence numbers | Puts them in every template; applies the rails in section 12 |
| Message records | Your CRM and channels hold them | Sends only through them; keeps the approval trail |
| 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 | Decides, under your state’s law | Notifies you within 72 hours and supports the investigation |
| Quotes, contracts, plan renewal notices | Owns, including in-home sale and maintenance-plan paperwork | Never writes quotes, contracts or renewal notices |
| 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. Where a figure carries signal, we keep a tier and drop the figure.
| Data | How it is handled | Reaches the AI model |
|---|---|---|
| Name, phone, email, street address | Held only in the encrypted key table on your side. The address is checked against your service area there; only a yes or no leaves. | No |
| Gate codes; card numbers; financing applications; SSN | Excluded from the export. If one appears in a note, the value is removed and the record quarantined. | No |
| Quote and job values | Only if you agree: turned into a three-level tier on your side, used for ranking. The figure never leaves. | No |
| Quote, visit and contact dates | Converted to intervals — “14 months since last contact.” | Interval only |
| Lead source, stage, status, equipment, rep | Kept as categories; equipment age as a band, such as “12 to 15 years”; rep names replaced with codes. | As categories |
| Call and visit notes | Read on your side and turned into fixed-list answers (section 09). The note itself never leaves. | Fixed-list answers only |
| Consent records and opt-outs | Kept as an append-only history and enforced at send time. | No |
| Property photos; household, age or health details | Not requested, not used to rank, not sent. | 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 from your number or domain. | Holds: the message, in your CRM |
Notes are the most sensitive part of a record and the most useful — one line can hold a gate code and a health condition. So they are read where they already are, and only short answers leave.
| Layer | What it does |
|---|---|
| 1 · Field allow-list | Only approved columns are read. Structured identifiers are separated by rule, not by a model’s judgement. |
| 2 · Identifiers stripped first | Phones, emails, addresses, gate codes, card and account numbers, dollar amounts and dates are removed from a note before the local model reads it. |
| 3 · Fixed questions, fixed answers | The local model answers set questions — why they paused, whether they named a moment, whether credits or financing came up — by choosing from a list you have 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 you choose 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 | A machine or cloud account you control; it never leaves it | An encrypted workstation operated by Tez, in a separate encrypted volume per client |
| 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 | Access log kept for the engagement, provided on request |
| Suits | Businesses with an IT provider or their own cloud account | Most owner-run businesses |
Workstation standard, when Tez operates it
- Encrypted at rest — Full-disk encryption, plus a separate encrypted volume for each client’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 — Your 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 — Whether customers are told is your decision. For a lead list your state’s breach law may require no notice at all. We never contact your customers about it.
12
Advertising and claims
What outreach may say, and what it never says
Every message we draft is your advertisement, sent in your name. That brings in your trade’s advertising rules and the FTC’s rules on honest claims. These are the ones that shape the wording.
- 01Your licence number, where the state asks for it — California counts “any electronic transmission” as advertising (B&P 7030.5; 16 CCR 861); Florida, Arizona, Nevada, Oregon and Washington require the number too. Texas wants it in all HVAC advertising, with a licensing statement on calls instead (16 TAC 75.71(h)). We put it in every text and email.
- 02No expired credits, no rebate promises — The federal 25C and 25D credits ended for systems placed in service after 2025, so an old quote is never revived on a credit. State home energy rebates open, close and change terms state by state. Drafts name no credit, rebate amount or availability.
- 03Financing: no payment figures — A monthly payment, down payment, number of payments or finance charge triggers Regulation Z disclosures, for contractors too (12 CFR 1026.24); deferred-interest and lease offers carry rules of their own (1026.16(h); 1013.7). Drafts say “financing available” at most.
- 04Efficiency, refrigerant and need: true claims only — ENERGY STAR is named only for certified models, never as an endorsement of you, and savings figures need support (FTC Act section 5). EPA’s refrigerant rules restrict new equipment, not servicing existing systems — so no “your refrigerant is banned.” Texas bars misrepresenting the need for service (16 TAC 75.71(b)).
- 05Plans, reviews and referrals — California requires express consent to plan renewals, an annual reminder and notice before a fee change (B&P 17602); we draft none of those, and plan offers use your terms. No fake or AI-written reviews (16 CFR 465), no referral rewards to homeowners in California (B&P 7157), no misleading subject lines (Washington, *Brown v. Old Navy*). Every template keeps its approval trail.
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, at $500 a message and up to $1,500 if wilful. Recent court decisions have narrowed some federal rules and loosened the FCC’s hold on others; we rely on neither, and work to the strictest reading. Consent is enforced in software at the moment of sending, not left to policy.
- 01 · A consent history, not a checkbox — Each lead’s consent is an append-only record of source, wording, channel and date. Contactability is derived from it, never 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 · Aged quotes without evidenced consent — Email, or your reps calling directly — not text. A quote request over three months old is no established business relationship for Do Not Call; a customer within 18 months of a job, or a current plan member, is.
- 04 · Do Not Call and reassigned numbers — Checked against the National Do Not Call Registry and the FCC Reassigned Numbers Database. Results dated and stored.
- 05 · Quiet hours and state law — 8am to 8pm in the lead’s local time, inside the federal 9pm limit; from 9am in Connecticut, noon on Texas Sundays. Three a day at most in Florida, Oklahoma and Maryland. No texts to Washington residents without clear prior consent.
- 06 · Opt-out everywhere, permanently — STOP, a request in any words, or one made to your rep or technician is honoured on every channel and survives any re-import. Email unsubscribes within 10 business days.
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 under the rules that apply to HVAC work, so you and your counsel can choose with that in view.
Model A: Flat monthly fee
A fixed fee for operating the service. It does not depend on visits booked, systems sold, or how a job is paid for.
- No rule we found restricts it, in any state.
- The model we start on in California until your counsel has confirmed Model B.
- The simplest model to budget for and to check.
Model B: Results-based fee
A share of revenue from reactivated jobs, measured from your CRM’s own records.
- Generally unproblematic. We found no federal or state rule that bars an HVAC business paying a marketing vendor this way.
- California. HVAC equipment is home improvement there, and a person paid to solicit, sell or negotiate those contracts must register as a salesperson (B&P 7151, 7152, 7157). We do none of that — your team quotes and sells — but your counsel confirms Model B first.
- Florida, insurance-funded jobs. No pay for referring work paid from property insurance (Fla. Stat. 489.147). Those jobs leave the base.
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, texting and email providers | Messages and records, 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, with every message and opt-out synced back to 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 owner of the data, Tez as service provider and processor; use limited to this engagement.
- 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 09 to 11, as binding terms.
- Consent warranty — Your representation of how the leads were obtained, segment by segment.
- Privacy requests — Access, correction and deletion within your deadlines, wherever a state privacy law applies to you.
- 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, 47 CFR 64.1200; Telemarketing Sales Rule | Consent, Do Not Call, quiet hours, relationship windows | 13 |
| State telemarketing laws: FL, OK, MD, WA, TX, CT | Consent, hours, daily limits, registration | 13 |
| CAN-SPAM; Washington CEMA | Unsubscribe, address, honest subject lines | 12 13 |
| Contractor licensing rules: CA, FL, TX, AZ, NV, OR, WA | Licensed name and number in ads; in Texas, no overstated need | 07 12 |
| IRC 25C and 25D; DOE Home Energy Rebates | No expired credits or unconfirmed rebates | 05 06 12 |
| Regulation Z, 1026.16 and 1026.24; Regulation M | Payment terms trigger disclosures | 05 06 12 |
| FTC Act section 5 and reviews rule; ENERGY STAR; EPA | True efficiency and refrigerant claims; real reviews | 06 12 |
| California renewal law; FTC Negative Option Rule | Plan renewal terms and notices stay with you | 07 12 |
| Cal. Bus. & Prof. Code 7151 to 7157 | No homeowner referral rewards; fee model checked | 12 14 |
| Fla. Stat. 489.147(2)(c) | No referral pay on insurance-funded jobs | 14 |
| Gramm-Leach-Bliley Act | Does not apply; the architecture is used anyway | 07 |
| State comprehensive privacy laws | Processor contract, access, deletion, no sale | 07 15 |
| State breach notification laws | Prompt notice to you; your notice decision | 07 11 |
| Massachusetts 201 CMR 17.00 | Written security program, encryption | 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 guidance, or a court decision. They are listed here so your counsel can check our reading against the text. Links were current in October 2026.
| 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) | Written consent, Do Not Call for calls and texts, 8am to 9pm federal hours, revocation of consent | 13 |
| FCC Consumer and Governmental Affairs Bureau, Order DA 26-12, January 6, 2026 (docs.fcc.gov/public/attachments/DA-26-12A1.pdf) | Delay of the “revoke all” part of the revocation rule to January 31, 2027 | 18 |
| Telemarketing Sales Rule, 16 CFR Part 310 (ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310) | Established business relationship: 18 months after a purchase, 3 months after an inquiry | 04 13 |
| National Do Not Call Registry; FCC Reassigned Numbers Database (donotcall.gov · reassigned.us) | The two checks run before any number is contacted | 13 |
| Facebook, Inc. v. Duguid, 592 U.S. 395 (2021); Insurance Marketing Coalition v. FCC (11th Cir., January 24, 2025); McLaughlin Chiropractic Associates v. McKesson Corp. (U.S., June 2025) | Autodialer scope; vacatur of the one-to-one consent rule; courts not bound by FCC readings | 13 |
| Florida Telephone Solicitation Act, Fla. Stat. 501.059; Florida Telemarketing Act, 501.616 (flsenate.gov/Laws/Statutes/2025/501.059) | Written consent for automated texts; 8am to 8pm; three calls a day on one subject | 13 |
| Maryland Stop the Spam Calls Act, Md. Code Com. Law 14-4501 et seq. (mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcl§ion=14-4502) | 8am to 8pm; three attempts a day on the same subject; written consent for automated messages | 13 |
| Oklahoma Telephone Solicitation Act, 15 O.S. 775C.1 et seq. (2022) | 8am to 8pm; three calls a day on the same subject | 13 |
| Connecticut Public Act 23-98 (SB 1058), Conn. Gen. Stat. 42-288a (cga.ct.gov/2023/ACT/PA/PDF/2023PA-00098-R00SB-01058-PA.PDF) | Sales calls and texts only between 9am and 8pm | 13 |
| Washington RCW 80.36.390 and RCW 19.190 (app.leg.wa.gov/RCW/default.aspx?cite=19.190) | 8am to 8pm calls; no commercial texts without clear prior consent; honest email subject lines | 12 13 |
| Brown v. Old Navy, LLC, Washington Supreme Court, April 17, 2025 (courts.wa.gov/opinions/pdf/1025921.pdf) | Any false or misleading subject line in a commercial email breaks CEMA | 12 |
| Texas SB 140 (2025); Tex. Bus. & Com. Code chs. 301 and 302 | Texts as telephone solicitation; Texas hours | 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 | 13 |
| Licensing and contractor rules | Relied on for | Sections |
|---|---|---|
| Cal. Bus. & Prof. Code 7030.5; 16 CCR 861; CSLB Industry Bulletin 20-21 (cslb.ca.gov/Resources/IndustryBulletins/2020/20-21_Advertising_on_Vehicles.pdf) | Licence number in all advertising, including any electronic transmission | 12 |
| Cal. Bus. & Prof. Code 7151, 7152, 7157; CSLB Contractors License Law & Reference Book, 2026 (cslb.ca.gov/Resources/GuidesAndPublications/2026/2026_CSLB_Law_Book.pdf) | HVAC equipment as home improvement; salesperson registration; no referral rewards to owners; limits on paying salespeople | 12 14 |
| Fla. Stat. 489.119(5) (flsenate.gov/Laws/Statutes/2025/489.119) | Licence number in every advertisement, regardless of medium | 12 |
| Fla. Stat. 489.147(2)(c) (flsenate.gov/Laws/Statutes/2025/489.147) | No compensation for referring work paid from property insurance | 14 |
| 16 Tex. Admin. Code 75.71 (law.cornell.edu/regulations/texas/16-Tex-Admin-Code-SS-75-71) | Licence number in HVAC advertising; licensing statement on calls; no misrepresenting the need for service | 12 |
| Ariz. Rev. Stat. 32-1124 (azleg.gov/ars/32/01124.htm) | ROC number on advertising and customer correspondence | 12 |
| Nev. Rev. Stat. 624.720 (leg.state.nv.us/nrs/nrs-624.html) | Company name and licence number in all advertising, including the internet | 12 |
| Or. Admin. R. 812-003-0120 (law.cornell.edu/regulations/oregon/Or-Admin-Code-SS-812-003-0120) | Licence number on internet and all written advertising | 12 |
| Wash. Rev. Code 18.27.100 (app.leg.wa.gov/rcw/default.aspx?cite=18.27.100) | Registration number on advertising and on materials soliciting homeowners | 12 |
| FTC Cooling-Off Rule, 16 CFR Part 429 (ecfr.gov/current/title-16/chapter-I/subchapter-D/part-429) | In-home sale cancellation notices stay with your business | 07 |
| Credits, financing and claims | Relied on for | Sections |
|---|---|---|
| IRS, Energy Efficient Home Improvement Credit (25C) (irs.gov/credits-deductions/energy-efficient-home-improvement-credit) | The credit covers property placed in service before the end of 2025 only | 05 12 |
| IRS, Residential Clean Energy Credit (25D) (irs.gov/credits-deductions/residential-clean-energy-credit) | Not available for property placed in service after December 31, 2025 | 12 |
| U.S. Department of Energy, Home Energy Rebates Program (energy.gov/scep/home-energy-rebates-programs) | Rebates run by each state, available in select states only | 12 |
| Regulation Z, 12 CFR 1026.24, and comment 2(a)(2)-2 (consumerfinance.gov/rules-policy/regulations/1026/24) | Payment terms in an ad trigger disclosures, for contractors as well as lenders | 05 06 12 |
| Regulation Z, 12 CFR 1026.16(h) (consumerfinance.gov/rules-policy/regulations/1026/16) | Deferred-interest offers in advertising | 12 |
| Regulation M, 12 CFR 1013.7 (consumerfinance.gov/rules-policy/regulations/1013/7) | Lease advertising; applies to merchants who are not lessors | 12 |
| ENERGY STAR Brand Guidelines (EPA) (energystar.gov/partner-resources/brand-guidelines) | No implied endorsement; certified products only | 12 |
| EPA, Technology Transitions HFC Restrictions by Sector (epa.gov/climate-hfcs-reduction/technology-transitions-hfc-restrictions-sector) | Limits on refrigerants in new equipment from January 1, 2025 | 12 |
| FTC Act section 5, 15 U.S.C. 45 (law.cornell.edu/uscode/text/15/45) | Claims must be truthful and supported | 06 12 |
| FTC Rule on Consumer Reviews and Testimonials, 16 CFR Part 465 (2024) (ecfr.gov/current/title-16/chapter-I/subchapter-D/part-465) | No fake or AI-written reviews; no paying for a sentiment | 06 12 |
| California Automatic Renewal Law, Cal. Bus. & Prof. Code 17600 et seq. (leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=BPC&division=7.&title=&part=3.&chapter=1.&article=9.) | Consent to renewal, annual reminders, notice before a fee change | 07 12 |
| FTC Negative Option Rule, 16 CFR Part 425; advance notice of proposed rulemaking, March 13, 2026 (federalregister.gov/documents/2026/03/13/2026-04952/rule-concerning-the-use-of-prenotification-negative-option-plans) | Federal renewal rules under review; current text restored in February 2026 | 12 |
| Privacy, security and de-identification | Relied on for | Sections |
|---|---|---|
| FTC Safeguards Rule, 16 CFR Part 314, definition in 314.2 (ecfr.gov/current/title-16/chapter-I/subchapter-C/part-314) | Why GLBA does not reach a business that only takes cards or offers a lender’s financing | 07 |
| California Consumer Privacy Act, Cal. Civ. Code 1798.100 et seq.; CPPA threshold adjustment (cppa.ca.gov/regulations/cpi_adjustment.html) | Who is covered; service-provider contracts; access and deletion | 07 15 |
| Texas Data Privacy and Security Act, Tex. Bus. & Com. Code ch. 541 | Small-business exemption; processor duties for covered clients | 07 15 |
| 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; definition of personal information | 10 11 |
| 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 |
| 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 — Your counsel decides 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. If you send a security questionnaire, we complete it and provide the policies and evidence behind each control instead.
- 03Not your contractor, salesperson or lender — Tez I Solutions is not a licensed contractor, a home improvement salesperson or a lender. We do not quote, sell, contract for or perform work, and we do not arrange financing or advise anyone on credits or rebates. Every message is your advertisement, in your name.
- 04Not permanent — Current as of October 2026. Rules in this area are moving — the FCC’s “revoke all” consent rule is due on January 31, 2027, and federal credits, state rebate programs and refrigerant rules have all changed since 2025. 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
HVAC
What your industry's rules mean for your AI tools
Most of what governs an HVAC business's AI tools is advertising law, because most of what those tools do is write: replacement follow-ups, maintenance-plan reminders, email subject lines, website copy. Two risks are specific to this trade. AI tools learn from material that is often years out of date, and the federal tax credits they like to mention ended with 2025. And they write payment terms — "$89 a month" — without the disclosures that must go with them. These are the rules that bear on the work, and what we do about each.
| Rule | What it means for AI tools | How we handle it |
|---|---|---|
| Contractor licensing and advertising rules — California, Florida, Texas, Arizona, Nevada, Oregon, Washington [1][2][3][4] | Your licensed name and number belong in advertising, electronic messages included. Texas also bars misrepresenting the need for service. | Your name and number for each state are set in the tools' instructions and every template. Drafts never say a system "needs" replacing unless your technician's finding says so. |
| IRC 25C and 25D; DOE Home Energy Rebates [5][6][7] | The 25C credit covers property placed in service before the end of 2025, and 25D is not available after December 31, 2025. State rebates run only in some states. AI tools often describe credits that no longer exist. | Tax credits are off the approved list by default. Rebates appear only in the wording you confirm for programmes open in your state. |
| Regulation Z, 1026.16 and 1026.24; Regulation M [8][9] | A monthly payment, rate, deferred-interest or lease term in an ad triggers required disclosures — for contractors as well as lenders. | Payment terms are left out of drafts unless your complete, approved disclosure goes with them as a fixed block. |
| FTC Act section 5 and reviews rule; ENERGY STAR; EPA refrigerant rules [10][11][12][13] | Efficiency, savings and refrigerant claims must be true and supported. ENERGY STAR may not be implied for uncertified equipment. AI-written reviews or testimonials are banned. | Approved claims are a fixed list. We do not build anything that writes reviews or testimonials. |
| California Automatic Renewal Law; FTC Negative Option Rule [14][15] | Maintenance-plan renewals need clear terms, consent and reminders. A chatbot or drafted reply that enrols or renews someone can break these rules. | No AI tool enrols or renews anyone. Renewal notices stay in your own billing process, in wording you control. |
| Cal. Bus. & Prof. Code 7151 to 7157 [16] | California bars rewarding homeowners for referrals on home improvement work. AI tools suggest referral rewards as a matter of course. | Referral-reward offers are blocked in drafts for California customers. |
| TCPA, Do Not Call, CAN-SPAM and Washington CEMA [17][18][19] | A message a workflow sends follows the same consent rules as one a person sends. Washington penalises any false or misleading email subject line — and AI tools write subject lines. | Workflows draft; a person sends, from your channels. Subject lines are reviewed with the message. |
| State privacy and breach laws [20] | Larger businesses may fall under a state privacy law. AI tools holding customer data are part of what a breach could expose. | Incident notice to you within 72 hours; help with access and deletion requests in the tools we set up. |
In practice
- A workflow may draft a follow-up on an unsold replacement quote from the system size, the quote date and your technician's notes. It may not mention a federal tax credit, or a monthly payment without your disclosure.
- A maintenance-plan reminder may tell a customer their visit is due. Whether the plan renews, and on what terms, stays in your billing system.
- An assistant may answer your team's questions about equipment specs and your service procedures. It is not given access to customers' payment details.
- Technician photos of a home's interior stay in your field-service software, and are not copied into a general AI workspace.
A8
Sources
Where these rules come from
1. Cal. Bus. & Prof. Code 7030.5; 16 CCR 861; CSLB Industry Bulletin 20-21 — https://cslb.ca.gov/Resources/IndustryBulletins/2020/20-21_Advertising_on_Vehicles.pdf 2. Fla. Stat. 489.119(5) — https://www.flsenate.gov/Laws/Statutes/2025/489.119 3. 16 Tex. Admin. Code 75.71 — https://www.law.cornell.edu/regulations/texas/16-Tex-Admin-Code-SS-75-71 4. Ariz. Rev. Stat. 32-1124 — https://www.azleg.gov/ars/32/01124.htm · Nev. Rev. Stat. 624.720 — https://www.leg.state.nv.us/nrs/nrs-624.html · Or. Admin. R. 812-003-0120 — https://www.law.cornell.edu/regulations/oregon/Or-Admin-Code-SS-812-003-0120 · Wash. Rev. Code 18.27.100 — https://app.leg.wa.gov/rcw/default.aspx?cite=18.27.100 5. IRS, Energy Efficient Home Improvement Credit (25C) — https://www.irs.gov/credits-deductions/energy-efficient-home-improvement-credit 6. IRS, Residential Clean Energy Credit (25D) — https://www.irs.gov/credits-deductions/residential-clean-energy-credit 7. U.S. Department of Energy, Home Energy Rebates Programs — https://www.energy.gov/scep/home-energy-rebates-programs 8. Regulation Z, 12 CFR 1026.24 and 1026.16 — https://www.consumerfinance.gov/rules-policy/regulations/1026/24 · https://www.consumerfinance.gov/rules-policy/regulations/1026/16 9. Regulation M, 12 CFR 1013.7 — https://www.consumerfinance.gov/rules-policy/regulations/1013/7
- 01FTC Act section 5, 15 U.S.C. 45 — https://www.law.cornell.edu/uscode/text/15/45
- 02FTC Rule on Consumer Reviews and Testimonials, 16 CFR Part 465 — https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-465
- 03EPA, ENERGY STAR Brand Guidelines — https://www.energystar.gov/partner-resources/brand-guidelines
- 04EPA, Technology Transitions HFC Restrictions by Sector — https://www.epa.gov/climate-hfcs-reduction/technology-transitions-hfc-restrictions-sector
- 05California Automatic Renewal Law, Cal. Bus. & Prof. Code 17600 et seq. — https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=BPC&division=7.&title=&part=3.&chapter=1.&article=9.
- 06FTC, Negative Option Rule, advance notice of proposed rulemaking, March 13, 2026 — https://www.federalregister.gov/documents/2026/03/13/2026-04952/rule-concerning-the-use-of-prenotification-negative-option-plans
- 07CSLB, Contractors License Law & Reference Book, 2026 (Cal. Bus. & Prof. Code 7151–7157) — https://cslb.ca.gov/Resources/GuidesAndPublications/2026/2026_CSLB_Law_Book.pdf
- 08Telephone Consumer Protection Act, 47 U.S.C. 227 — https://www.law.cornell.edu/uscode/text/47/227
- 09FTC, CAN-SPAM Act: A Compliance Guide for Business — https://www.ftc.gov/business-guidance/resources/can-spam-act-compliance-guide-business
- 10Brown v. Old Navy, LLC, Washington Supreme Court, April 17, 2025 — https://www.courts.wa.gov/opinions/pdf/1025921.pdf
- 11California Consumer Privacy Act; California Privacy Protection Agency, threshold adjustment — https://cppa.ca.gov/regulations/cpi_adjustment.html