Legal Document

Terms of Service

Last Updated: February 20, 2026

1. Introduction

Welcome to Rank Capture Grow LLC, operating as Willow CSR ("Willow CSR," "we," "us," or "our"). These Terms of Service ("Terms") govern your access to and use of our AI-powered customer service platform and related services (the "Services").

By accessing or using our Services, you ("Subscriber," "Client," "you," or "your") agree to be bound by these Terms. If you are using the Services on behalf of a business or other legal entity, you represent that you have the authority to bind that entity to these Terms.

If you do not agree to these Terms, you may not access or use the Services.

2. Service Description

Willow CSR provides smart call infrastructure delivered through our AI-powered Customer Service Representative ("Willow") designed for:

  • Inbound call interception and response
  • SMS-based lead qualification and triage
  • Appointment scheduling
  • Customer communication management

The Services are designed to help businesses respond to customer-initiated inquiries via A2P 10DLC compliant SMS dialogue. Willow CSR does not initiate outbound marketing communications. All automated responses are triggered exclusively by inbound customer contact and only after explicit DTMF consent is obtained.

3. Eligibility

To subscribe to our Services, you must:

  • Be at least 18 years of age
  • Be authorized to bind the business or entity on whose behalf you are using the Services
  • Operate a legitimate business within the United States
  • Not have been previously suspended or removed from the Services
  • Comply with all applicable federal, state, and local laws and regulations
  • Not operate in a prohibited industry (see Section 9)

4. Account Registration

To access the Services, you must create an account and provide accurate, complete, and current information. You are responsible for:

  • Maintaining the accuracy of your account information
  • Safeguarding your account credentials
  • All activities that occur under your account
  • Notifying Willow CSR immediately of any unauthorized use of your account

Willow CSR reserves the right to suspend or terminate accounts that contain inaccurate or fraudulent information.

5. Business Verification

Willow CSR reserves the right to request business verification documents from you at any time. These documents may include, but are not limited to:

  • Government-issued identification
  • Business registration documents
  • Proof of business address
  • EIN or tax identification verification
  • Proof of consent collection practices

You acknowledge and agree that compliance with business verification requests is essential for using the Services and maintaining A2P 10DLC carrier compliance.

If you are unable to sufficiently comply in a reasonable timeframe and in a manner deemed satisfactory by Willow CSR, we reserve the right to suspend or terminate your access to the Services.

6. SMS Messaging Terms

The Services include SMS messaging capabilities. By using these features, you acknowledge and agree to the following:

6.1 Application-to-Person (A2P) Messaging

Willow CSR treats all messaging transmitted via the Service as Application-to-Person ("A2P") messaging. All A2P messages originating from Willow CSR are subject to this Messaging Policy and registered with The Campaign Registry (TCR) for 10DLC compliance.

6.2 Customer-Initiated Contact

All SMS communications sent through the Services are in direct response to customer-initiated contact. Willow CSR does not initiate outbound marketing communications or place outbound voice calls.

6.3 Consent Capture via Willow Voice

Prior to any SMS message being sent, Willow obtains express consent from the customer through our deterministic voice greeting system:

"Hi, I'm Willow, the AI assistant for [Business]. We're currently helping another customer. The fastest way to get things started is by text. To receive a text message about your request, press 1. Message and data rates may apply. To leave a voicemail, press 2."

Consent is captured when the customer presses 1 (DTMF input). This explicit mechanical action constitutes express consent to receive SMS messages related to their inquiry. Consent is deterministic — no speech recognition or interpretation is involved.

6.4 Consent Records

Willow CSR logs all consent events including:

  • Timestamp of consent
  • Phone number (normalized E.164 format; encrypted at rest)
  • Consent method (numeric_dtmf)
  • DTMF digit pressed
  • Business identifier
  • Call SID (Twilio)

These records are retained for a minimum of five (5) years for compliance purposes and are available upon request for carrier inquiries.

6.5 Required Disclosures

All communications include required disclosures:

  • Voice Greeting: AI disclosure, "Message and data rates may apply"
  • First SMS: Business identification, opt-out instruction (Reply STOP to opt-out)
  • Every SMS: Clear identification of sending business

6.6 Opt-Out Handling

Customers may opt out of receiving SMS messages at any time by replying with any of the following keywords:

STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, QUIT

These keywords are recognized in English, Spanish, Mandarin, French, and Portuguese.

Upon receipt of an opt-out request:

  • All SMS communication ceases immediately
  • A confirmation message is sent acknowledging the opt-out
  • The opt-out is logged permanently in our suppression list
  • The phone number cannot receive further messages until re-consent is obtained
  • Opt-out records are permanent and platform-wide per provisioned number. Account deletion, re-registration, or Subscriber account changes do not reset suppression status for previously opted-out recipients. Suppression records persist for the lifetime of the platform.

6.7 Message Frequency

Message frequency varies based on customer interaction and the nature of the service inquiry being addressed. We do not send recurring marketing messages.

6.8 Message and Data Rates

Standard message and data rates may apply to customers based on their mobile carrier plan.

6.9 Carrier Liability

Mobile carriers are not liable for delayed or undelivered messages. Willow CSR does not guarantee message delivery and is not responsible for failures caused by carrier networks, device incompatibility, or other factors outside our control.

6.10 Phone Number Ownership and Campaign Registration

All telephone numbers provisioned through the Service are owned by and registered to Rank Capture Grow LLC. Subscriber receives a non-exclusive, non-transferable license to use the assigned number solely in connection with the Services for the duration of the active subscription.

Rank Capture Grow LLC reserves the right to register, associate, and manage all A2P 10DLC campaign registrations on Subscriber's behalf, including associating Subscriber's business identity with Rank Capture Grow LLC's registered Brand for carrier compliance purposes. Subscriber authorizes Rank Capture Grow LLC to submit business information to The Campaign Registry (TCR), mobile carriers, and related compliance bodies as necessary to maintain messaging capability.

Upon termination of the subscription, the assigned phone number is reclaimed by Rank Capture Grow LLC and may be reassigned at its sole discretion after the period specified in Section 15.3. Subscriber has no ownership interest in the phone number and may not port, transfer, or claim the number upon termination.

7. Subscriber SMS Compliance Responsibility

You acknowledge that while Willow CSR provides tools to facilitate customer communication, you are solely responsible for ensuring that your use of the Services complies with all applicable laws and regulations, including but not limited to:

  • Telephone Consumer Protection Act (TCPA)
  • FCC 2024 AI Voice Declaratory Ruling
  • Cellular Telecommunications Industry Association (CTIA) guidelines
  • A2P 10DLC registration requirements
  • State privacy and consumer protection laws
  • Industry-specific regulatory requirements
  • Mobile carrier terms and policies

Willow CSR provides the technology platform but does not provide legal advice.

Call Recording Compliance

Subscriber acknowledges that voice interactions with Willow may be recorded for consent verification and quality assurance purposes. Subscriber is solely responsible for complying with all applicable federal and state call recording laws, including two-party consent states.

AI Identity Disclosure Obligation

Willow identifies itself as an AI assistant at the beginning of every voice and SMS interaction, in compliance with the FCC 2024 AI Voice Declaratory Ruling. Subscriber shall not represent Willow CSR as a live human agent in any customer-facing materials, communications, advertising, or marketing. Subscriber agrees not to circumvent, alter, suppress, or instruct others to suppress the AI identity disclosure delivered by the Service.

Violation of this section constitutes a material breach of these Terms and may result in immediate termination of Services under Section 15.2.

8. Third-Party Data Prohibition

You may only use the Services to communicate with customers who have provided direct consent to your specific business. The following are strictly prohibited:

  • Use of purchased lead lists
  • Use of third-party contact databases
  • Contacts who have not directly initiated communication with your business
  • Sharing or selling of customer phone numbers or SMS opt-in data
  • Transferring consent obtained for one business to another business

Violation of this section may result in immediate termination of Services.

9. Prohibited Uses

9.1 Prohibited Content (S.H.A.F.T.)

The Services may not be used to send messages containing or promoting:

  • Sex: Adult content, pornography, escort services, or sexually explicit material
  • Hate: Content promoting hatred, discrimination, or violence against any group
  • Alcohol: Promotion or sale of alcoholic beverages
  • Firearms: Promotion or sale of weapons, ammunition, or explosives
  • Tobacco: Promotion or sale of tobacco, vaping, or related products

9.2 Prohibited Industries

The Services may not be used by businesses in the following industries:

  • Cannabis, CBD, or kratom products, and marketing of any substance federally classified as a controlled substance, regardless of state-level legality
  • Gambling, lottery, or casino services
  • Payday loans, high-interest lending, or debt collection
  • Debt consolidation or credit repair programs
  • Cryptocurrency promotions or investment schemes
  • Multi-level marketing or pyramid schemes
  • "Get rich quick" schemes
  • Third-party lead generation services
  • Affiliate marketing that buys, sells, or shares consumer information
  • Political campaign messaging
  • Telemarketing or cold outreach

Willow CSR reserves the sole and absolute discretion to determine industry eligibility, independent of TCR campaign approval status. Approval by The Campaign Registry or any carrier does not guarantee continued access to the Services if Willow CSR determines, in its sole judgment, that the Subscriber's industry, content, or messaging practices present unacceptable compliance risk.

9.3 Prohibited Activities

  • Sending unsolicited messages (spam)
  • Harassment, threats, or abusive communications
  • Impersonation or misrepresentation of identity
  • Phishing, scams, or deceptive content
  • Interference with or disruption of the Services
  • Attempting to gain unauthorized access to any systems
  • Reverse engineering, decompiling, or disassembling the Services
  • Using the Services for the benefit of a third party without authorization
  • Any illegal activity or promotion of illegal activity

10. Fees and Payment

10.1 Subscription Fees

Access to the Services requires a paid subscription. Subscription fees are billed monthly in advance. Current pricing tiers are:

  • Pro: $389/month
  • Enterprise: $789/month
  • Platform: License Agreement

10.2 Setup Fee

A one-time $99 White-Glove Setup fee applies to all new accounts. This fee covers:

  • Account onboarding
  • A2P 10DLC campaign registration
  • Dedicated phone number provisioning
  • Carrier compliance verification

10.3 Payment Terms

  • All fees are non-refundable except as required by law
  • You are responsible for all applicable taxes
  • Failed payments may result in suspension after a 7-day grace period
  • Willow CSR reserves the right to adjust pricing with 30 days' advance notice

10.4 Carrier and Messaging Fees

You are responsible for any carrier messaging fees, SMS usage costs, and applicable taxes associated with use of the Services that exceed plan limits.

11. Data Ownership

11.1 Subscriber Data

You retain ownership of your customer contact information, message content, and business data ("Subscriber Data"). Willow CSR acts as a service provider and processes Subscriber Data solely to provide the Services, in accordance with our Privacy Policy.

Willow CSR does not sell, rent, or share customer mobile phone numbers or SMS opt-in data with third parties for marketing or promotional purposes.

11.2 Willow CSR Property

Willow CSR retains ownership of the Services, including all AI models, software, algorithms, user interfaces, workflows, and aggregated performance metadata. Nothing in these Terms transfers ownership of any Willow CSR intellectual property to you.

11.3 Aggregated Data

Willow CSR may create aggregated, de-identified, or anonymized data from Subscriber Data for purposes of improving the Services, provided such data cannot be linked to any specific Subscriber or customer.

12. Intellectual Property

The Services, including all content, features, and functionality, are owned by Rank Capture Grow LLC and are protected by United States and international intellectual property laws.

Subject to your compliance with these Terms, Willow CSR grants you a limited, non-exclusive, non-transferable, revocable license to access and use the Services for your internal business purposes.

13. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WILLOW CSR SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO LOSS OF PROFITS, DATA, BUSINESS OPPORTUNITIES, OR GOODWILL, ARISING OUT OF OR RELATED TO YOUR USE OF THE SERVICES.

WILLOW CSR'S TOTAL LIABILITY FOR ANY CLAIMS ARISING UNDER THESE TERMS SHALL NOT EXCEED THE TOTAL AMOUNT PAID BY YOU TO WILLOW CSR DURING THE TWELVE (12) MONTHS PRECEDING THE CLAIM.

The Services are provided "AS IS" and "AS AVAILABLE" without warranties of any kind, either express or implied.

13.1 Emergency Services Disclaimer

Willow CSR is not a replacement for 911 or emergency services. The Services are not monitored in real-time by humans and cannot dispatch emergency assistance. If you or a caller experience a life-threatening emergency, hang up and dial 911 immediately.

14. Indemnification

You agree to indemnify, defend, and hold harmless Rank Capture Grow LLC, its officers, directors, employees, agents, and affiliates from and against any and all claims, damages, losses, liabilities, costs, and expenses arising out of or related to:

  • Your use of the Services
  • Your violation of these Terms
  • Your violation of any applicable law or regulation, including TCPA
  • Your violation of any third-party rights
  • Any content or data you transmit through the Services
  • Any claims by customers or third parties related to messages sent on your behalf

15. Termination

15.1 Termination by You

You may cancel your subscription at any time. Cancellation takes effect at the end of the current billing period. No refunds are provided for partial months.

15.2 Termination by Willow CSR

Willow CSR may suspend or terminate your access to the Services immediately, without prior notice, if we reasonably believe you have violated these Terms, any applicable law or carrier requirement, engaged in fraudulent or abusive behavior, failed to comply with a business verification request, or received multiple complaints from message recipients.

15.3 Effect of Termination

Upon termination: your right to use the Services immediately ceases; you may request export of your Subscriber Data within 30 days; after 30 days, Willow CSR may delete your data in accordance with our retention policies; your phone number may be released for reassignment after 45 days.

16. Modifications to Terms

Willow CSR reserves the right to modify these Terms at any time. For material changes, we will provide at least 30 days' advance notice via email or through the Services. Your continued use of the Services after the effective date of any modifications constitutes your acceptance of the updated Terms.

17. Governing Law and Disputes

These Terms shall be governed by and construed in accordance with the laws of the State of Louisiana, without regard to its conflict of law provisions.

Any disputes arising out of or relating to these Terms or the Services shall be resolved exclusively in the state or federal courts located in Lafayette Parish, Louisiana.

17.1 Class Action Waiver

Any dispute resolution proceedings will be conducted only on an individual basis and not in a class, consolidated, or representative action.

18. Contact Information

For questions about these Terms, or for legal inquiries:

Legal / Registered Agent
Rank Capture Grow LLC, operating as Willow CSR
201 Rue Beauregard, Ste. 202
Lafayette, LA 70508

General Support & Compliance
Email: info@rankcapturegrow.com
Website: willowcsr.com

19. Related Policies

These Terms incorporate the following policies by reference:

20. Severability

If any provision of these Terms is held to be unenforceable or invalid, that provision shall be limited or eliminated to the minimum extent necessary so that these Terms shall otherwise remain in full force and effect.

21. Entire Agreement

These Terms, together with our Privacy Policy, Messaging Policy, and Fair Use Policy, constitute the entire agreement between you and Willow CSR regarding the Services.