Legal

About Our AI System

Version 2.3, last updated 30 October 2026

This page transparently explains what the Vocalyy voice agent is, how it works, and what limitations it has. We publish this information per the EU Regulation on Artificial Intelligence (EU AI Act, Regulation (EU) 2024/1689), Article 50(1), which requires providers of AI systems intended for direct interaction with natural persons to ensure that those persons are informed that they are interacting with an artificial intelligence system, unless this is obvious from the context.

In short: When you call a Vocalyy number, you are speaking with an AI agent, not a human. The agent tells you this at the start. The agent's AI is xAI's Grok Voice, a speech-to-speech model: it hears your voice and answers you by voice, following instructions configured by the business you called. If the call is recorded, ElevenLabs transcribes the recording after the call, so that the business has a written transcript.

1. What is Vocalyy?

Vocalyy is a SaaS platform that provides AI voice agents, conversational systems that answer phone calls on behalf of a business. The agent:

Answers calls 24/7
Understands what the caller wants (booking, question, etc.)
Automatically books appointments in the business's calendar
Transfers the call to a human when necessary

2. Classification under the EU AI Act

The transparency obligations under Article 50 of the EU AI Act (Regulation (EU) 2024/1689) become applicable starting 2 August 2026 (per Art. 113 of the regulation). Vocalyy already proactively complies with these requirements, regardless of the date on which this page is consulted.

Under the risk-tier classification of the EU AI Act, the Vocalyy voice agent, used for customer interactions (bookings, service information), falls under:

Limited risk (Article 50), an AI system that interacts directly with natural persons
Main requirement: transparency, the caller must be informed that they are interacting with an AI system

Vocalyy is not:

An unacceptable-risk AI system (prohibited)
A high-risk AI system (recruitment, creditworthiness/credit scoring assessment, law enforcement, medical diagnosis, etc.)
A standalone general-purpose AI (GPAI) system

[VERIFICATION NEEDED]: The classification above reflects the agent's standard use (customer service, bookings). If a Vocalyy client uses the agent in a different context (for example, the medical field, with large-scale processing of health data), the risk-tier classification must be reassessed separately, together with a consultant specialized in the EU AI Act.

3. How it works technically

Call flow:

Call reception: The call reaches the Vocalyy agent via Telnyx (telephony/call-routing provider)
Disclosure: The agent informs you that it is an AI system and, where applicable, that the call is being recorded
Your voice → the agent: Your voice reaches xAI's speech-to-speech model Grok Voice (grok-voice-3.0), which hears you, decides the answers and actions, and answers you by voice, in real time, following the instructions and script configured by the business you called. If the agent may have misheard a short sentence, OpenAI's transcription model (gpt-4o-mini-transcribe) listens to that sentence again. For questions about the business, the agent searches its knowledge base using OpenAI embeddings (numerical representations of text).
Actions: If you requested a booking, the agent accesses the business's calendar and creates it
After the call: If the call is recorded, ElevenLabs (Scribe model) transcribes the recording so that the business has a written transcript, and OpenAI extracts from the transcript the details the business asked for (for example, your name or the booking you requested).

4. AI models used

xAI: the AI of the voice agent: Grok Voice (grok-voice-3.0), a speech-to-speech model that hears the caller, decides the answers and actions (e.g., which response to give, which action to trigger) and speaks the agent's replies
OpenAI: models used alongside the voice agent: gpt-4o-mini-transcribe, which during the call listens again to a short sentence the agent may have misheard; gpt-5.6-luna, which after the call extracts the details the business asked for; text-embedding-3-small, for the knowledge-base search
ElevenLabs: speech-to-text (Scribe model), used only after the call to transcribe the recording into the written transcript; it is not used during the call and is not the agent's voice. It does not store or host the recording: all recordings are stored on the Vocalyy platform
Anthropic Claude: used exclusively for AI-assisted drafting of support-ticket replies and, if the business connects one, for the replies of its Telegram chatbot (not in the call flow); processes the content of those messages

All are general-purpose foundation models, they are not specifically trained for Vocalyy. Their behavior is configured through text instructions (system prompts) specific to each client business, not through additional training of the models.

5. What the agent can do

What it can do

Answer calls in Romanian (or other configured languages)
Answer questions about the business (hours, services, prices)
Book appointments in the calendar
Confirm existing appointments
Understand the caller's intent from context
Transfer the call to a human on request

6. What the agent CANNOT do

What it cannot do

It does not make decisions with legal impact on you (it does not refuse a service, it does not issue legal contracts)
It does not provide medical, legal, or financial advice
It does not emotionally manipulate and does not use subliminal techniques
It does not identify people through biometric voice recognition
It does not assess your credit risk
It does not perform behavioral profiling beyond the purpose of the call
It does not handle medical or other emergencies: Vocalyy is exclusively a communication tool, not a medical, emergency, or advisory service

7. Known limitations

We are transparent about the technical limitations of the agent:

It can make mistakes: AI models sometimes generate inaccurate responses ("hallucinations")
It may not understand strong accents or background noise
It does not have access to real-time information beyond what has been configured (it cannot search the internet)
It does not remember previous conversations with the same caller: every call starts with no memory of earlier calls from the same number, and the agent is never told a caller's name or past requests
Latency may vary depending on network quality (typically 1-3 seconds)
It operates on a best-efforts basis, not an obligation of result: the agent is configured and maintained with reasonable diligence, but we cannot guarantee a specific outcome in every conversation

8. Your rights as a caller

As a person calling a Vocalyy number, you have the right:

To be informed that you are speaking with an AI system (we inform you at the start of the call)
To request transfer to a human at any point during the call
To hang up the call without consequences
To request deletion of the recording and transcript, the request should be addressed to the business you contacted, as it is the controller of your data
Not to be subject to automated decisions with legal impact on you (the agent does not make such decisions)

For full details on your rights under the GDPR and how callers' data is processed, see the Privacy Policy.

9. Call recording

Calls made through the Vocalyy agent may be recorded to ensure service quality, manage bookings, and for legal compliance. We inform you about the recording at the start of the call, where applicable.

It is important to understand who actually stores which data:

Vocalyy always stores, in the dashboard of the business you called: your phone number, the call metadata (date, time, duration), the full transcript of the conversation, and the audio recording.
All audio recordings are stored directly on the Vocalyy platform, in Supabase Storage, European Union (Frankfurt, Germany), for 30 days from the date of the call, after which they are automatically deleted. They can be listened to and downloaded by the business you called during that window, and can be fully disabled, per agent, from the agent's configuration.

If you do not want to be recorded or do not want the conversation transcript retained, you can hang up and contact the business through other channels (email, web form).

For the exact retention periods of this data, see the Retention Policy. For the full list of providers processing data on Vocalyy's behalf, see the List of Sub-processors.

10. AI model training

Your conversation is processed by xAI to run the agent during the call, by OpenAI to listen again to a sentence the agent may have misheard and to extract the details the business asked for, and, if the call is recorded, by ElevenLabs to transcribe it afterwards. None of them is used to teach the agent new behaviour: the agent is configured through instructions, not trained on calls.

Under xAI's enterprise terms, xAI does not use the content sent through its API to train its models. Under OpenAI's API terms, data sent through the API is not used to train OpenAI's models unless the customer opts in; Vocalyy has not opted in [to be confirmed from the OpenAI dashboard]. [To be confirmed with ElevenLabs: the no-training policy for audio processed through the Scribe API]; Vocalyy will publish its exact status once verified.

11. Human oversight

Per the "human in the loop" principle of the EU AI Act:

The business using the agent has dashboard access to all calls, metadata, and transcripts
The caller can request transfer to a human at any point during the conversation
Vocalyy monitors the technical operation of the agents for quality and safety
We have escalation procedures for unexpected situations or reported technical errors

12. Complaints and appeals

If you believe the AI agent treated you incorrectly, or you have concerns about how your data was used:

Contact directly the business you called, it is, as a rule, the controller of your data as a caller
Contact Vocalyy at agent@vocalyy.ro (privacy contact channel)
If you are not satisfied with the response, you can file a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP) for data-protection matters, or with the competent national authority for the EU AI Act (once designated in Romania) for matters related to the transparency of the AI system

13. Technical documentation

For B2B clients (the businesses using Vocalyy), we provide additional technical documentation on request:

The AI system's technical data sheet
Description of the data flow and the sub-processors involved (see the List of Sub-processors)
User manual for implementers
The Data Processing Agreement (DPA), see the Data Processing Agreement

Request these documents at agent@vocalyy.ro.

14. Contact

Technical questions: agent@vocalyy.ro
Personal data / privacy: agent@vocalyy.ro
D.O.D.O. OFFICE OUTLET S.R.L.: Romania

Governing version. This document is published in Romanian and in English. In case of any discrepancy between this English version and the Romanian version, the Romanian version prevails.