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, sales managers and counsel
Lead reactivation works the homeowners your company has already paid to reach — people who asked for a quote or had a site survey, were followed up once or twice, and never signed. We rank them by likelihood to book a new consultation and work the list from the top, so your sales team spends its time on the homeowners most likely to sit down again.
Every one of those records carries rules with it: federal and state telemarketing law, the solar sales laws of states such as Texas, Utah and California, advertising rules on savings, tax credits and financing, and state privacy and breach laws. This document sets out, control by control, how the engagement keeps your company inside those rules — and which decisions stay with you. It is written to be read by your owner, your sales manager and your counsel, and kept with your vendor records.
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 sales team. 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, addresses and utility account numbers stay in a secure environment. The AI provider sees a random ID and a few short facts, nothing more.
- 02 · Nothing goes out without your approval — Your owner or sales manager approves every template and every batch before use. Our review sits on top of yours, never in place of it.
- 03 · Every message goes out under your name — Outreach is sent from your channels, names your company and is kept in your CRM. Your own staff take every reply.
- 04 · No evidenced consent, no text message — Consent, opt-outs, Do Not Call status and quiet hours are checked at the moment of sending. Opt-outs are permanent.
- 05 · Your data serves your engagement only — No model training, no reuse across clients, no sale, no outside enrichment without your written instruction.
- 06 · Breach notice within 72 hours — Without delay, and no later than 72 hours. State breach laws require a vendor to tell the data owner promptly; this puts a hard limit on it.
- 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 savings, credit or financing promises — Messages invite a new conversation with your team. No savings figures, tax-credit claims, payment terms or suggestion of a utility link.
- 09 · A fee structure your counsel chooses — A flat fee or a results-based fee, with how each is treated under state solar sales laws set out in section 14.
- 10 · Evidence on request — Every control here has something you can inspect. We complete your vendor questionnaire during onboarding.
02
The whole picture
The system on one page
The system works in three zones. Names and contact details stay on your side. Our scoring works only with a random ID and a few short facts. The results come back to your side, where your company approves and sends.
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 company works its old quotes today
- 02 Agreement — Roles, purpose, subprocessors, 72-hour notice
G1 - 03 Intake review — Lead sources, consent wording, states you sell in
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, customers, complaints
G2 - 07 Swap names for IDs — A random ID; the key stays with you
- 08 Notes into facts — Fixed-list answers; figures 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 — Owner or sales manager approves the wording
G5 - 15 Send — Re-checked at sending; from your channels
G6
Learn (ongoing)
- 16 Record outcomes — Booked, held, signed; 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; the states you sell in, your registrations and your fee model confirmed | Your company and Tez |
| G2 | As the list arrives | Opt-outs, Do Not Call, signed customers, 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, notes, exact figures or exact dates | Software, checked by Tez |
| G4 | After a summary is drafted | No personal data; no savings, credit or financing claims; nothing the facts do not support | Software, then your sales manager |
| G5 | Before any outreach | Your owner or sales manager approves the wording and the batch | Your company |
| G6 | At the moment of sending | Consent for that channel, Do Not Call, quiet hours in the homeowner’s time zone, opt-outs | Software, on your channels |
| G7 | Throughout, and at the end | Outcomes kept by random ID, used for your company only, returned or destroyed at termination | Tez, certified to you |
04
The ranking
How the list is put in order
Every lead is checked first, then looked at through four factors. The factors combine into one score, and the list is sorted by it. The sorting is plain arithmetic, not an AI model, so every score can be explained in a sentence.
| Factor | The question it answers | What it looks at, for a solar installer |
|---|---|---|
| Intent | How serious were they, and how long ago? | How far they got: quote request, call, site survey, proposal presented, signed then cancelled. Time since the last real conversation. Whether they replied before. How many follow-ups have already been tried. |
| Opening | Is there a real reason to get back in touch? | The reason they paused: price, timing, roof condition, financing, a spouse, another installer. A condition they named, such as “after the roof is replaced.” Whether that moment has passed. Interest in battery backup. |
| 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 the three-month inquiry window has passed. |
| Fit | Can your company still serve them? | Still the owner, in your service area and a state you sell in. Whether your surveyor marked the roof suitable, as a yes or no only. A utility territory your offer covers. |
How the ranking gets better
- 01It starts from your team’s experience — Your sales team tells us how often each kind of paused homeowner 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 consultations are booked, held or declined, the odds for each reason move toward what actually happened at your company.
- 03It becomes a model of your company alone — After about 300 recorded outcomes, the ranking is fitted to your company’s results. It is never trained on, or pooled with, another installer’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 sales team
Marcus Reyes is fictional. His record is shaped like a real one. Follow it through the four cards, left to right and top to bottom.
1 · Your CRM record (stays with you)
| Field | Value | Note |
|---|---|---|
| name | Marcus Reyes | key table |
| phone | (512) 555-0163 | key table |
| m.reyes@example.com | key table | |
| CRM ID | 00Q8d000004Tz | key table |
| status | Survey done — no decision | becomes a stage |
| note | New roof first (hail claim); asked about a battery | becomes facts |
| avg bill | $214 a month | becomes a tier |
| last contact | November 18, 2025 | becomes days |
2 · What we receive (leaves your side)
| Field | Value | Note |
|---|---|---|
| ID | s_4Rk8vN1c | random |
| stage | Site survey done | Intent |
| days since | 322 | Intent |
| reason | Timing | Opening |
| condition | Yes, waiting on a home project | Opening |
| interest | Battery backup mentioned | Opening |
| reach | Email yes · text no consent | Reachability |
| fit | Owner yes · service area yes | Fit |
| bill tier | 2 of 3, only if you opt in | optional |
Never leaves your side: his name, phone, email, address, CRM ID, the note itself, the bill amount, exact dates.
3 · What comes back (back to you)
| Field | Value | Note |
|---|---|---|
| ID | s_4Rk8vN1c | |
| score | 67 · tier A | |
| reasons | + named a condition · + site survey done · − 322 days since contact | |
| reason line | Survey done; paused for a home project that may now be finished. | fixed wording |
| summary | He paused for work on the house and asked about backup power. Open by asking whether the work is done. | AI, checked |
| next step | Email, Saturday morning his time |
4 · In your CRM (stays with you)
| Field | Value | Note |
|---|---|---|
| record | Marcus Reyes · tier A · 67 | matched back |
| fields | Reason line, summary and next step added to his record | |
| draft | “Hi {first_name}, …” with his name filled in only at sending | placeholder |
| flags | Text blocked, no consent · Do Not Call check required | G6 |
No text consent on file, so the next step is email. His survey was over three months ago, so a Do Not Call check comes before any call. The draft says nothing about the tax credit he was quoted, which ended for systems installed after 2025. Your team sees his name here, in your CRM, for the first time.
- 01His note became a few facts — “New roof first (hail claim)” left only as “waiting on a home project,” so the insurance claim never leaves your side. The battery question became one interest flag.
06
The suggestion
How the “why call” note is written and checked
Each lead comes back with a reason line in fixed wording and a short summary drafted by an AI model, both written only from the facts in card 2 of section 05. The AI writes; it does not decide. The order comes from arithmetic, and your company approves 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 savings, credits or terms — No savings figures, bill promises, tax-credit statements, prices, payments or rates. The draft invites a new consultation, nothing more.
- Nothing made up — Every statement in the summary must trace back to one of the facts it was given. A statement that does not is treated as a failure.
- Your never-say list — Phrases your company rules out are blocked — with “free solar” and any utility or government program blocked by default.
07
Roles
Your company stays the seller
Under telemarketing law your company is the seller, responsible for anyone who contacts homeowners for it; under state solar sales laws it is the retailer, with its own registrations and duty to supervise salespeople. Tez I Solutions is a service provider, using your data only on your written instructions. If you arrange financing, your counsel may treat you as a financial institution under the FTC Safeguards Rule; our controls meet that standard either way.
| Obligation | Your company | Tez I Solutions |
|---|---|---|
| Privacy notices and opt-outs | Owns | Honours your suppression and opt-out lists |
| Approval of communications | Owner or sales manager approves before use | Submits templates; never alters approved wording |
| Selling, quoting and scheduling | Your registered or employed staff | Never; every reply is routed to your team |
| Licences and solar registrations | Holds them: contractor licence, Texas or Utah retailer registration | Puts your licence number in templates where your state requires it |
| Contracts and disclosures | Owns the forms and cancellation notices your state requires (AZ, CA, FL, NV, TX, UT) | Never sends, summarises or replaces them |
| Message records | Keeps them in your CRM | Sends from your channels; keeps the consent and send history for five years |
| 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 homeowners | Owns, under each state’s law | Notifies you within 72 hours and supports the investigation |
| Access, deletion, return | Receives requests and instructs | Executes within your deadline; certifies destruction 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, postal and service address | Held only in the encrypted key table on your side; used to address a message when it is sent. | No |
| Utility bills, account and meter numbers, usage history | Not requested: California bars sharing usage data without consent (Civil Code 1798.98). Found in a note, the value is removed. | No |
| Financing applications, credit results, SSN, bank details | Excluded from the export; never used to rank. | No |
| Monthly bill amount, quoted price, system size | Only if you agree: a three-level tier made on your side. The figure never leaves. | No |
| Quote, survey and contact dates | Converted to intervals — “11 months since last contact.” | Interval only |
| Lead source, stage, status, sales rep | Kept as categories; rep names replaced with codes. | As categories |
| Call, survey and rep notes | Turned into fixed-list answers on your side (section 09). The note never leaves. | Fixed-list answers only |
| Consent records and opt-outs | Kept as an append-only history and enforced at send time. | No |
| Roof and survey photos; insurance claims; age, ethnicity, health | 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 company — 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 channels. | Holds: the message, in your CRM |
Notes are the most sensitive part of a record and the most useful. So they are read where they already are, and only short answers leave. Five layers make sure of it.
| Layer | What it does |
|---|---|
| 1 · Field allow-list | Only approved columns are read. Structured identifiers are separated by rule, not by a model’s judgement. |
| 2 · Identifiers stripped first | Phone numbers, emails, utility account and meter numbers, card and Social Security 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 condition, which kind of event — by choosing from a list your sales manager has seen. It cannot write free text. |
| 4 · Unsure means a person decides | An answer the model is not confident about is not guessed. The record is held for a person to review. The process fails closed. |
| 5 · Final scan | Every record is scanned again before it leaves. A record carrying anything outside the approved fields is held back, not sent. |
10
Where it runs
Two ways to run the secure environment
The secure environment is where identifiable data lives during the engagement, and your company chooses where it sits. In both options the key table never leaves it, and the AI provider receives only a random ID and fixed-list facts.
| Inside your environment | On a Tez-operated workstation | |
|---|---|---|
| Where raw data sits | Your infrastructure; it never leaves your perimeter | An encrypted workstation operated by Tez, in a separate encrypted volume per company |
| Access | You control it. We use a named, least-privilege account you can revoke at any time | One named individual, with multi-factor authentication |
| Network | Your controls | Outbound limited to the AI provider and your sending channels |
| Logging | Your logging stack | Access log kept for the engagement, provided on request |
| Suits | Companies with an IT team or managed IT provider | Companies without capacity to host it |
Workstation standard, when Tez operates it
- Encrypted at rest — Full-disk encryption, plus a separate encrypted volume for each company’s data.
- Dedicated and locked down — An OS account used only for client data, multi-factor sign-in, screen lock, current patches, endpoint protection.
- No cloud sync — Client data is never stored in a synced folder or consumer cloud backup, and is excluded from sync by configuration.
- Wiped at the end — The company’s volume is destroyed at termination and the destruction certified in writing.
11
Security and incidents
The controls, and what happens if one fails
| Control | Evidence you can ask for |
|---|---|
| Written information security program, modelled on Massachusetts 201 CMR 17.00 | The program document |
| Encryption in transit and at rest | Configuration record |
| Multi-factor authentication on every account that touches your data | Account inventory |
| Access limited to named individuals, reviewed quarterly | Access list and review log |
| Access to your data logged | Log extract |
| Background check for anyone with access, on your request | Written confirmation |
| Raw data held only for the life of the engagement | Retention schedule |
| Return or destruction within 30 days of termination | Signed certificate |
| Cyber liability insurance, where your contract requires it | Certificate of insurance |
| Written incident response plan, reviewed each year | The plan and its last review |
If something goes wrong
- 01 · Contain — Stop sending, revoke the affected credential, isolate the system.
- 02 · Notify you within 72 hours at the latest — Which records and fields, what window, what we have done. State breach laws expect a vendor to tell the data owner without delay; this is our outer limit.
- 03 · Preserve evidence — Logs, send records and the consent history are kept intact for your investigation.
- 04 · Support your notice, never pre-empt it — Notice to homeowners is your company’s decision, under the breach law of each one’s state. We never contact your customers about it.
12
Sales and advertising
What outreach may say, and who may say it
Five rules, built into every template and checked at gate G4, drawn from state law and from the FTC’s 2023 solar telemarketing case, U.S. and Arizona v. Vision Solar.
- 01Your people sell; we draft — From September 1, 2026, Texas requires anyone selling or offering residential solar for pay to register with TDLR; Utah requires appointment setters for a retailer to be its employees; California exempts only scheduling. We never quote, negotiate, schedule or converse with a homeowner.
- 02No savings or financing claims — Savings turn on usage, rates and tariff, such as California’s net billing tariff; claims must be supported (FTC Act section 5), and the CFPB has flagged promises to end bills. Drafts give no savings figure, and no payment, rate, “$0 down” or lease term — each a trigger term under Regulation Z or M.
- 03Tax credits stated accurately, or not at all — The federal homeowner credit (IRC 25D) ended for systems installed after 2025. Drafts mention no credit unless your approved wording does; in Texas it must advise independent tax advice (16 TAC 71.52).
- 04No utility or government link — Drafts name your company and nothing else: no “free solar,” no “government program.” A false utility or government link is barred in Texas (Occupations Code 1806.201) and was central to the FTC’s case.
- 05Your licence number, and your disclosures — Templates carry your licence number where required (California B&P Code 7030.5, Fla. Stat. 489.119). Outreach never replaces the CSLB disclosure, CPUC guide, Texas disclosure form or a Cooling-Off Rule notice; California first messages can link to the CPUC guide, as the CPUC recommends.
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. The federal reading is also moving: the Supreme Court narrowed the autodialer definition in 2021, the FCC’s one-to-one consent rule was vacated in January 2025, and since June 2025 courts need not follow the FCC’s interpretations. So we work to the strictest reading, apply state rules on top, and enforce consent in software at the moment of sending.
- 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 leads without evidenced consent — Email, or your own staff calling after a Do Not Call check — not text. A quote request or survey over three months old is no established business relationship.
- 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 9pm in the homeowner’s local time, narrower where required. Florida, Oklahoma, Maryland, Washington and Texas SB 140 rules applied by state.
- 06 · Opt-out everywhere, permanently — STOP, a request in any words, or one made to your rep is honoured on every channel and every kind of message, 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 state solar sales laws that register salespeople, so 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 consultations booked, contracts signed or systems installed.
- Texas. Registration turns on whether a person sells or offers solar for pay. We do neither, and a fee not tied to sales keeps that clear on paper.
- Utah. The employee rule for anyone who sets appointments or discusses solar applies whatever the fee. We stay out of both.
- The simplest model to approve, document and explain.
Model B: Results-based fee
A share of revenue from installs attributed to reactivated leads, measured from your CRM’s own records.
- Texas. Pay tied to closed sales is how a solar salesperson is paid. It raises the question of whether our role is residential solar retail for compensation, which needs registration from September 1, 2026.
- Utah. Anyone paid by commission to sell for a retailer is a sales representative and must be its employee. Not offered for Utah homeowners without your counsel’s written approval.
- Offered only where your counsel approves the structure in writing, state by state.
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, notes or exact figures. Not used for training by default under Anthropic’s commercial terms; zero data retention requested where offered; can run through your own cloud provider instead | Every engagement |
| Your CRM and messaging providers | Messages and replies, 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 copied into your CRM |
| Operator console hosting | Named in your agreement, with what it holds | Where your team uses our console |
The full list is an exhibit to your agreement. We give 30 days’ notice before adding or changing a subprocessor.
What the agreement contains
- Roles and purpose — Your company controls the data; Tez is a service provider, using it only for this engagement and on your written instructions.
- 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 company’s representation of how the leads were obtained, including from lead vendors.
- Privacy requests — Access, correction and deletion within your deadlines, under any state privacy law that covers your company.
- 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, revocation, Do Not Call, quiet hours, records | 07 13 |
| State telemarketing laws, incl. Texas SB 140 | State consent and calling-hours rules | 13 |
| CAN-SPAM | Unsubscribe, address, accurate headers | 13 |
| Texas Occupations Code ch. 1806; 16 TAC ch. 71 | Seller registration; misleading claims; tax advice | 07 12 14 |
| Utah Code Title 13, Chapter 52 | Sales representatives must be employees | 07 12 14 |
| California B&P Code 7152, 7169, 7030.5 | Salesperson registration; disclosure; licence number | 07 12 |
| AZ, FL and NV contract laws; Cooling-Off Rule | Disclosures and cancellation rights | 07 12 |
| FTC Act section 5 | No deceptive savings, affiliation or credit claims | 12 |
| IRC 25D, as amended in July 2025 | Homeowner credit ended after 2025 | 05 12 |
| Regulation Z 1026.24; Regulation M 1013.7 | Financing and lease advertising | 12 |
| FTC Safeguards Rule, 16 CFR 314 | Vendor oversight, where you arrange financing | 07 |
| California Civil Code 1798.98 | Usage data not shared without consent | 08 |
| Mass. 201 CMR 17.00; state breach laws | Security program, encryption, prompt notice | 01 11 |
| State comprehensive privacy laws | Access, deletion, no sale, where you are covered | 15 |
| NIST IR 8053, SP 800-188 | De-identification practice | 08 09 |
17
References
Every requirement, traced to its source
Each commitment here rests on a primary source: a statute, a regulation, a regulator’s own guidance or case, or a court decision, listed so your counsel can check our reading. 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) | Prior express written consent, Do Not Call, quiet hours, revocation, reassigned numbers | 13 |
| FCC Order DA 25-312, April 7, 2025 (docs.fcc.gov/public/attachments/DA-25-312A1.pdf) | Delay of the rule applying one opt-out to every message from a sender, which we apply now | 13 18 |
| Telemarketing Sales Rule, 16 CFR Part 310 (ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310) | Established business relationship: 540 days after a purchase, 90 days after an inquiry; five-year records | 07 13 |
| National Do Not Call Registry; FCC Reassigned Numbers Database (donotcall.gov · reassigned.us) | The two checks run before any number is contacted | 13 |
| 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. Supreme Court, June 2025) | Narrow federal autodialer definition; one-to-one consent rule vacated; courts not bound by FCC readings of the TCPA | 13 |
| Florida Telephone Solicitation Act, Fla. Stat. 501.059; Texas SB 140 (2025), Tex. Bus. & Com. Code ch. 302 (capitol.texas.gov/tlodocs/89R/billtext/html/SB00140F.htm) | State rules that treat texts as solicitation, applied by the homeowner’s state | 13 |
| CAN-SPAM Act, 15 U.S.C. 7701 et seq.; FTC compliance guide (ftc.gov/business-guidance/resources/can-spam-act-compliance-guide-business) | Unsubscribe within 10 business days, physical address, accurate headers | 13 |
| U.S. and Arizona v. Vision Solar LLC, Solar Xchange LLC and Mark Getts, No. 2:23-cv-01387 (D. Ariz., filed July 18, 2023) (ftc.gov/legal-library/browse/cases-proceedings/2223063-solar-xchange-us-v) | Do Not Call violations, false utility and government affiliation, misleading savings claims by a solar telemarketer | 12 |
| Solar sales and advertising | Relied on for | Sections |
|---|---|---|
| Texas Occupations Code ch. 1806, Residential Solar Retailer Regulatory Act (SB 1036, 2025) (statutes.capitol.texas.gov/Docs/OC/htm/OC.1806.htm) | Registration of solar retailers and salespersons; retailer responsibility; prohibited acts | 07 12 14 |
| TDLR, Residential Solar Retailers program (tdlr.texas.gov/residential-solar-retailers/) | Registration from September 1, 2026; enforcement of two disclosure rules paused until November 1, 2026 | 14 18 |
| 16 TAC Chapter 71, incl. 71.52; adoption in the Texas Register, June 26, 2026 (sos.texas.gov/texreg/archive/June262026/Adopted%20Rules/16.ECONOMIC%20REGULATION.html) | No implied utility link; tax-incentive statements paired with advice to seek independent tax advice | 12 |
| Utah Code Title 13, Chapter 52, Residential Solar Energy Consumer Protection Act (le.utah.gov/xcode/Title13/Chapter52/13-52.html) | Sales representative includes appointment setters (13-52-102); must be an employee (13-52-401); retailer registration (13-52-302) | 07 12 14 |
| California B&P Code 7152, Home improvement salesperson (leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC§ionNum=7152) | Registration to solicit or sell; exemption only for scheduling appointments | 12 |
| California B&P Code 7169; CSLB Solar Energy System Disclosure Document (cslb.ca.gov/Consumers/Solar_Requirements.aspx) | The disclosure on the front of every residential solar contract | 07 12 |
| CPUC, California Solar Consumer Protection Guide (cpuc.ca.gov/solarguide) | Signed guide for interconnection; CPUC recommends giving it at first contact | 12 |
| California B&P Code 7030.5; Fla. Stat. 489.119(5)(b) | Contractor licence number in advertising | 12 |
| Ariz. Rev. Stat. 44-1763; Fla. Stat. 520.23; Nev. Rev. Stat. 598.9801 to 598.9822 | Contract disclosures and rescission rights that stay with your company | 07 |
| CPUC Decision D.22-12-056, net billing tariff, December 2022 (cpuc.ca.gov/nemrevisit) | Why savings depend on the tariff, and are never promised in outreach | 12 |
| FTC Act section 5, 15 U.S.C. 45 (law.cornell.edu/uscode/text/15/45) | Savings and affiliation claims must be truthful and supported | 12 |
| FTC Cooling-Off Rule, 16 CFR Part 429 (ecfr.gov/current/title-16/chapter-I/subchapter-D/part-429) | Three-day cancellation notice for sales made at the buyer’s home | 12 |
| Tax credits and financing | Relied on for | Sections |
|---|---|---|
| IRS, FAQs on sections 25C, 25D and others under Public Law 119-21, August 2025 (irs.gov/newsroom/faqs-for-modification-of-sections-25c-25d-25e-30c-30d-45l-45w-and-179d-under-public-law-119-21-139-stat-72-july-4-2025-commonly-known-as-the-one-big-beautiful-bill-obbb) | No homeowner credit where installation is completed after December 31, 2025 | 05 12 |
| Regulation Z, 12 CFR 1026.24; Regulation M, 12 CFR 1013.7 (ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.24 · ecfr.gov/current/title-12/chapter-X/part-1013/section-1013.7) | Trigger terms in credit and consumer lease advertising | 12 |
| CFPB, Solar Financing Market Issue Spotlight, August 2024 (files.consumerfinance.gov/f/documents/cfpb_solar-financing-issue-spotlight_2024-08.pdf) | Misleading statements that solar will eliminate energy bills; tax-credit assumptions in loans | 12 |
| FTC Safeguards Rule, 16 CFR Part 314 (ecfr.gov/current/title-16/chapter-I/subchapter-C/part-314) | Security and service-provider oversight where an installer arranges financing | 07 |
| Privacy, security and AI | Relied on for | Sections |
|---|---|---|
| California Civil Code 1798.98, energy usage data | Express consent before smart-meter usage data is shared with a third party | 08 |
| Massachusetts 201 CMR 17.00 (mass.gov/regulations/201-CMR-1700-standards-for-the-protection-of-personal-information-of-residents-of-the-commonwealth) | Written security program, encryption on laptops and in transit, service-provider contracts | 11 |
| State breach notification laws, for example Tex. Bus. & Com. Code 521.053 and Cal. Civil Code 1798.82 | A vendor must tell the data owner promptly; the owner notifies residents | 01 11 |
| California Consumer Privacy Act, Cal. Civil Code 1798.100 et seq.; Texas Data Privacy and Security Act, Tex. Bus. & Com. Code ch. 541 | Processor duties by contract: access, deletion, correction, no sale | 15 |
| NIST IR 8053, De-Identification of Personal Information, 2015; SP 800-188, De-Identifying Government Datasets, 2023; SP 800-122, Protecting the Confidentiality of PII, 2010 (nvlpubs.nist.gov/nistpubs/ir/2015/NIST.IR.8053.pdf · csrc.nist.gov/pubs/sp/800/188/final) (csrc.nist.gov/pubs/sp/800/122/final) | Quasi-identifiers and re-identification risk; why pseudonymization is reversible; figures generalized into bands; which fields are identifying | 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 company, state by state. This document tells them what we do so they can.
- 02Not a SOC 2 report — We do not hold a SOC 2 attestation. We complete your vendor questionnaire and provide the policies and evidence behind each control instead.
- 03Not a solar seller — Tez I Solutions is not a contractor, solar retailer, salesperson or lender. We do not sell, quote, finance or install, and we hold no solar sales registration in any state. Where counsel concludes our role in a state needs one, that state stays out of scope until it is in place.
- 04Not permanent — Current as of October 2026. Rules in this area are moving: Texas solar registration began September 1, 2026 with two of its rules not yet enforced, and the FCC has delayed part of its consent revocation rules more than once. 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 homeowners to contact first, not who will book. Until your company’s 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
Solar
What your industry's rules mean for your AI tools
Residential solar sales are now regulated message by message in several states, and federal regulators have brought cases over misleading savings and utility-affiliation claims. AI tools make both mistakes easily. They promise bills will disappear, describe a federal tax credit that ended with 2025, and write as if the installer were working with the utility. Solar records also hold a sensitive kind of data most businesses never see: a homeowner's energy usage. These are the rules that bear on your AI tools, and what we do about each.
| Rule | What it means for AI tools | How we handle it |
|---|---|---|
| FTC Act section 5; CPUC net billing decision D.22-12-056 [1][2][3] | Savings and affiliation claims must be true and supported. Savings depend on the tariff, and regulators have acted against solar sellers for false utility or government affiliation. | Drafts never promise savings or an end to energy bills, and never imply a link to a utility or government programme. Approved claims are a fixed list. |
| IRC 25D, as amended in July 2025 [4] | There is no homeowner credit where installation is completed after December 31, 2025. AI tools trained on older material still describe the 30% credit. | Federal tax credits are off the approved list by default. Any incentive is stated only in wording you confirm is current. |
| Texas Occupations Code ch. 1806; 16 TAC ch. 71 [5][6][7] | Texas bars implying a utility link and requires any statement about tax incentives to come with advice to seek independent tax advice. Retailers and salespersons register. | Your Texas registration details and the independent-tax-advice line are built into templates. No drafted message implies a utility relationship. |
| California B&P Code 7152, 7169 and 7030.5; CPUC Solar Consumer Protection Guide [8][9][10] | Licence number in advertising; the solar disclosure document and the CPUC guide belong to your sales process. | Your licence number is set in every template. AI tools do not draft or edit the disclosure document or contract. |
| Utah Code Title 13, Chapter 52 [11] | Utah counts appointment setters as sales representatives and requires them to be your employees. | For Utah homeowners, appointment-setting workflows are run by your own employees, not by us. |
| Regulation Z 1026.24; Regulation M 1013.7 [12] | Loan or lease payments in an ad trigger disclosures, and regulators have flagged misleading tax-credit assumptions built into solar loans. | Payment terms appear only with your full, approved disclosure. Drafts make no assumption that a credit will pay down a loan. |
| California Civil Code 1798.98 [13] | Smart-meter energy usage data may not be shared with a third party without the customer's express consent. Putting that data into an AI tool may share it with the tool's vendor. | Energy usage data and utility bills are kept out of AI connections unless your records show the customer's express consent for that use. |
| FTC Safeguards Rule, 16 CFR Part 314 [14] | Where you arrange financing, the rule's security and vendor-oversight duties can apply. | The settings record and access record (A4, A5) are written for your vendor oversight file. |
| TCPA, Do Not Call and CAN-SPAM [15][16] | A message a workflow sends follows the same consent rules as one a person sends. | Workflows draft; a person sends, from your channels. |
| State breach and privacy laws [17] | A vendor must tell the data owner promptly. AI tools holding homeowner data are part of what a breach could expose. | Incident notice to you without delay and no later than 72 hours; help with access and deletion requests in the tools we set up. |
In practice
- A workflow may draft a follow-up to a homeowner who got a quote, from the system size and quote date. It never mentions the federal credit, promised savings or the utility.
- A proposal assistant may help your designers write up a system description. Usage figures from the homeowner's utility account are used only where your records show consent.
- An assistant may answer staff questions about permitting and interconnection steps from your own procedures.
- Contracts, disclosure documents and cancellation notices stay on your locked templates.
A8
Sources
Where these rules come from
1. FTC Act section 5, 15 U.S.C. 45 — https://www.law.cornell.edu/uscode/text/15/45 2. U.S. and Arizona v. Vision Solar LLC, Solar Xchange LLC and Mark Getts (D. Ariz., filed July 18, 2023) — https://www.ftc.gov/legal-library/browse/cases-proceedings/2223063-solar-xchange-us-v 3. CPUC, net billing tariff, Decision D.22-12-056 — https://www.cpuc.ca.gov/nemrevisit 4. IRS, FAQs on sections 25C, 25D and others under Public Law 119-21 — https://www.irs.gov/newsroom/faqs-for-modification-of-sections-25c-25d-25e-30c-30d-45l-45w-and-179d-under-public-law-119-21-139-stat-72-july-4-2025-commonly-known-as-the-one-big-beautiful-bill-obbb 5. Texas Occupations Code ch. 1806 — https://statutes.capitol.texas.gov/Docs/OC/htm/OC.1806.htm 6. TDLR, Residential Solar Retailers — https://www.tdlr.texas.gov/residential-solar-retailers/ 7. 16 TAC Chapter 71, Texas Register, June 26, 2026 — https://www.sos.texas.gov/texreg/archive/June262026/Adopted%20Rules/16.ECONOMIC%20REGULATION.html 8. California B&P Code 7152 — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC§ionNum=7152 9. CSLB, Solar Energy System Disclosure Document (B&P Code 7169) — https://www.cslb.ca.gov/Consumers/Solar_Requirements.aspx
- 01CPUC, California Solar Consumer Protection Guide — https://www.cpuc.ca.gov/solarguide
- 02Utah Code Title 13, Chapter 52 — https://le.utah.gov/xcode/Title13/Chapter52/13-52.html
- 03Regulation Z, 12 CFR 1026.24 — https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.24 · Regulation M, 12 CFR 1013.7 — https://www.ecfr.gov/current/title-12/chapter-X/part-1013/section-1013.7 · CFPB, Solar Financing Market Issue Spotlight, August 2024 — https://files.consumerfinance.gov/f/documents/cfpb_solar-financing-issue-spotlight_2024-08.pdf
- 04California Civil Code 1798.98 (official text at leginfo.legislature.ca.gov)
- 05FTC Safeguards Rule, 16 CFR Part 314 — https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-314
- 06Telephone Consumer Protection Act, 47 U.S.C. 227 — https://www.law.cornell.edu/uscode/text/47/227
- 07FTC, CAN-SPAM Act: A Compliance Guide for Business — https://www.ftc.gov/business-guidance/resources/can-spam-act-compliance-guide-business
- 08Texas Business and Commerce Code 521.053 — https://statutes.capitol.texas.gov/Docs/BC/htm/BC.521.htm