Legal, privacy, and operating terms for Warbler beta pilots.
These terms define how CowanWorks operates Warbler during beta testing and paid pilots: data handling, customer responsibility, AI and recording disclosure, service-provider use, security controls, acceptable use, and pilot boundaries.
Privacy Policy
Warbler processes information needed to provide AI customer service for beauty distributors, manufacturers, and their customers. CowanWorks does not sell customer data.
- Distributor admin information, including name, role, business contact details, login activity, setup notes, and support communications.
- Business support material supplied for the pilot, including customer-approved documents, policies, account rules, and operational records.
- Customer caller information, including caller name, business, phone number, account identifiers, questions, support requests, and interaction history provided during the interaction.
- Call and message data, including audio recordings when enabled, transcripts, summaries, timestamps, call metadata, AI responses, human overrides, test results, and quality-review notes.
- Technical information, including IP address, device/browser data, service logs, error logs, authentication records, and security/audit events.
- Operate, test, secure, monitor, improve, and support the Warbler service.
- Answer customer-service questions using customer-approved support information.
- Prepare summaries, follow-up records, escalation notes, and service-quality evidence.
- Detect misuse, debug service issues, enforce customer instructions, and maintain audit trails.
- Comply with applicable law, contractual requirements, and customer deletion/export instructions.
Warbler shares data only as needed to operate the service, support the customer, comply with law, use approved service providers, investigate abuse or security events, or complete a business transfer involving CowanWorks or Warbler. Distributor customer data is not shared with another distributor.
Beta retention is configured by pilot scope when available. Unless a different written setting applies, Warbler may retain customer content, transcripts, recordings, logs, summaries, QA evidence, and audit events for the pilot period plus a reasonable period needed for support, security, legal, and product-quality review. Customers may request export, deletion, or return of pilot data through their CowanWorks implementation contact.
Warbler does not train shared cross-customer memory on a customer's private data. Customer-specific content, account context, policy, call data, and corrections remain scoped to that customer's workspace unless the customer expressly approves broader use in writing or the material is already public and non-confidential.
Terms of Service
Warbler is an AI customer-service system for business use. Customers are responsible for configuring and using it lawfully, supplying accurate source material, and approving the operating boundaries for their pilot.
- Provide accurate, current, lawful support material and pilot instructions.
- Approve AI disclosure, recording/transcription language, escalation paths, and live-call boundaries.
- Confirm that Warbler has permission to process the data supplied for the pilot.
- Review Warbler before relying on it for live customers, restricted actions, regulated data, or sensitive workflows.
- Comply with calling, recording, privacy, employment, consumer-protection, telemarketing, and industry-specific laws that apply to the customer's business.
- Warbler is not legal, tax, medical, financial, emergency, HR, or compliance advice.
- Warbler should not be used for high-risk automated decisions or final decisions requiring professional judgment.
- Warbler may refuse or escalate questions when customer information is missing, ambiguous, expired, conflicting, or outside approved scope.
- Restricted account, order, inventory, payment, credit, return, substitution, or policy-exception actions require the authority gates agreed in the customer pilot.
Customers retain ownership of their customer content. Customers grant CowanWorks the limited rights needed to host, process, transmit, display, secure, analyze, troubleshoot, and improve Warbler for that customer and to provide support, QA, and audit functions.
CowanWorks may suspend or limit Warbler access if a customer uses the service unlawfully, violates acceptable-use rules, creates security risk, fails to pay agreed pilot fees, supplies unsafe instructions, or asks Warbler to operate outside approved boundaries.
Warbler beta is provided on an as-available pilot basis. To the maximum extent permitted by law, CowanWorks disclaims implied warranties and is not liable for indirect, consequential, special, punitive, lost-profit, lost-revenue, or lost-data damages. Customers are responsible for claims arising from their content, instructions, unlawful calling or recording practices, misuse of Warbler, or use outside approved pilot scope.
Data Processing Addendum
For distributor customer data supplied to Warbler, the distributor or manufacturer is the business/controller and CowanWorks acts as a processor/service provider operating Warbler under customer instructions.
CowanWorks processes personal information to provide Warbler, perform setup and support, secure the service, troubleshoot issues, maintain service records, comply with law, and follow documented customer instructions. CowanWorks will not use customer personal information for unrelated commercial purposes.
CowanWorks limits access to customer data to personnel, contractors, and service providers who need access to provide or secure the service and who are bound by confidentiality or equivalent obligations.
Warbler uses customer-separated workspaces, access controls, audit records, encrypted transport, controlled administrative access, customer-approved operating boundaries, and human escalation paths. Sensitive customer contexts are kept in Warbler infrastructure and are not mixed into FinBeauty or unrelated CowanWorks systems.
At pilot end or on written request, CowanWorks will reasonably assist with export, return, or deletion of customer data, subject to backup, security, legal, audit, and legitimate business retention needs. CowanWorks will reasonably assist with data-subject requests and security inquiries related to Warbler processing.
If CowanWorks confirms unauthorized access to customer personal information in Warbler, CowanWorks will notify the affected customer without undue delay after assessment and provide available information needed for the customer's investigation and response.
Call Recording and AI Disclosure Notice
Warbler can answer calls, generate transcripts, summarize conversations, and prepare follow-up actions. The customer must approve the exact live-call disclosure for its jurisdiction, phone system, and customer relationship.
Suggested opening language: "Thanks for calling. You are speaking with Warbler, an AI assistant for this business. This call may be recorded or transcribed to help answer your question, support your account, and improve service quality. I can route you to a person when needed."
Live-call settings may vary by customer, jurisdiction, channel, and pilot scope. No live customer deployment should begin until the customer approves its disclosure, recording or transcription posture, and fallback route.
Callers must have a practical path to human review or handoff when the request requires account authority, missing customer information, complaint handling, sensitive information, policy exception, payment issue, or customer escalation.
Service Provider Categories
Warbler uses service providers to host, secure, power, monitor, and deliver the product. Pilot-specific provider details are shared with customers through the applicable pilot agreement, DPA, security review, or implementation contact.
| Category | Purpose | Likely data categories |
|---|---|---|
| Telephony and messaging providers | Call routing, call metadata, and SMS or voice services where configured. | Phone numbers, call metadata, call content if enabled, routing details, message content if enabled. |
| AI, speech, and language providers | Speech processing, transcription, response generation, and related AI processing. | Audio, transcripts, generated responses, limited context needed for configured service delivery, and related metadata. |
| Database, storage, and authentication providers | Database, authentication support, storage, workspace data, audit records, imported files, and application persistence. | Workspace data, account/source records, imported files, user records, logs, QA evidence, audit events. |
| Hosting and infrastructure providers | Website, application hosting, serverless functions, routing, and deployment infrastructure. | Request metadata, application traffic, logs, limited operational payloads depending on route. |
| Logging, monitoring, email, and support vendors | Error review, uptime monitoring, support communication, notifications, incident response, and operational debugging. | Technical logs, contact details, support messages, error traces, status notifications. |
Customers may request the current pilot-specific service-provider list through their CowanWorks implementation contact.
Security Exhibit
Warbler security is built around customer isolation, source boundaries, auditability, and controlled action authority.
Customer data is held in tenant-scoped Warbler workspaces. Sensitive distributor data belongs in dedicated Warbler infrastructure and is not mixed into FinBeauty or unrelated CowanWorks product databases.
Administrative access is limited to approved operators and controlled through restricted server-side systems.
Warbler uses encrypted transport where supported by service providers. Application records, imported customer content, call artifacts, and audit logs are retained according to pilot settings and operational/security needs.
Warbler is designed to use approved customer sources, refuse or escalate missing or conflicting data, keep customer contexts separated, and require agreed authority checks before restricted actions.
CowanWorks investigates suspected unauthorized access, service abuse, unsafe configuration, service-provider incidents, and customer-reported anomalies. Confirmed incidents involving customer personal information are handled under the DPA security-incident process.
Acceptable Use Policy
Warbler cannot be used for unsafe, deceptive, unlawful, or high-risk automation.
- Illegal robocalling, spam, telemarketing, harassment, deceptive caller identity, or calls/messages without required consent.
- Unauthorized collection of sensitive personal information, payment-card data, health data, children's data, biometric voiceprints, passwords, or government identifiers.
- Legal, tax, medical, financial, emergency, or regulated professional advice.
- High-risk automated decisions affecting eligibility, employment, credit, housing, insurance, healthcare, legal rights, or similar material interests.
- Attempts to bypass authentication, customer isolation, rate limits, approved service boundaries, review requirements, or security controls.
- Restricted account, order, inventory, payment, credit, return, substitution, or policy-exception actions require customer-approved authority boundaries.
- Payment-card handling is not permitted unless a reviewed compliant payment path is approved in writing.
- Order-related workflows require customer-approved identity, authority, confirmation, and exception-handling rules before use with live customers.
- Promotional, inventory, substitution, credit, return, and policy-exception handling must remain within the customer's approved pilot scope.
Distributor Pilot Addendum
Warbler beta pilots are controlled deployments. The customer and CowanWorks must agree on what data is loaded, which channels are live, what actions Warbler may take, and who approves movement from test calls to customer calls.
- Define approved channels, customer audiences, support categories, and whether any order-related workflow is included.
- Identify approved customer information, systems, customer audiences, channels, languages, business hours, and escalation contacts.
- Separate test calls from live customer calls and mark sample data clearly.
- Approve AI/recording disclosure and human fallback route before live customer calls.
- Approve retention settings for recordings, transcripts, logs, imported files, and QA evidence.
- Approve which users may access Warbler customer records, call reviews, support material, and audit records.
- Approve any move from informational support to order-related workflows or other restricted actions.
Before a customer-facing pilot, CowanWorks and the customer should review representative test interactions, customer information coverage, escalation handling, disclosure behavior, restricted-action boundaries, and support quality.
Each pilot needs a named human fallback owner and a shutdown path. CowanWorks or the customer may pause live automation if Warbler gives unsafe answers, operates outside approved boundaries, misroutes calls, fails disclosure requirements, exposes data incorrectly, or creates material customer-service risk.
Beta terms built for controlled testing.
Warbler will keep evolving as pilots expose new requirements. The operating standard stays fixed: customer data stays scoped, callers get disclosure and fallback, and restricted actions stay behind customer-approved boundaries.