Terms & Conditions

1.1 Limited Service

Dialoro is a Number-Based Interpersonal Communications Service (NB-ICS) provided on a “best-efforts” basis. It is not a replacement for a primary phone line.

1.2 Access to UK Emergency Services

You can call the UK emergency numbers 999 and 112 free of charge from Dialoro. These calls will be routed to the appropriate UK emergency organisations.

1.3 Uptime

Access depends on your internet connection and third-party network providers. We do not warrant that the Service will be uninterrupted, timely, or error-free.

1.4 Service provider

Dialoro is provided by PassWithAI Limited (trading as Dialoro), a company registered in England and Wales with company number 16288293. Registered address: 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ. The company is not VAT registered. The company operates this service under the General Conditions of Entitlement set by Ofcom.

1.5 Telephone numbers and Caller ID

Any telephone numbers provided to you, displayed to you, or used as Caller Line Identification (CLI) for outbound calls are allocated to and owned by Dialoro or its suppliers/carriers. You have no ownership, property, portability, or other rights in any such numbers.

You have no right to demand, require, or select any specific telephone number for any current or future call. The choice, allocation, presentation, and availability of any CLI is an operational decision solely at the discretion of Dialoro and its suppliers/carriers. We may change, withdraw, reallocate, or restrict numbers at any time without notice or liability, including for regulatory compliance, operational, technical, fraud prevention, or availability reasons.

2.1 Usage Restrictions

You must not use the Service, or allow others to use the Service:

• To commit, facilitate, or be involved in any criminal offence.
• To engage in any illegal activity or anti-social behaviour.
• For nuisance, harassment, or to cause distress or anxiety to any person.
• For “testing” fraudulent schemes, stress-testing our platform, or bypassing security safeguards.
• To circumvent telecommunications regulations or “spoof” Caller IDs.
• For automated dialling (robocalling) or unsolicited marketing.

2.2 Enforcement

If we reasonably suspect your account is involved in prohibited activity, we may suspend or terminate your account immediately without a refund. We reserve the right to proactively contact law enforcement and share relevant metadata where we reasonably believe it is necessary to prevent or investigate serious crime or to prevent serious harm.

2.3 Eligibility and Verification

To use the Service, you must:

• Be at least 18 years old (or the age of legal majority in your jurisdiction, if higher) and have full legal capacity to enter into these Terms.
• Not be located in, or a resident/national of, any country or territory subject to comprehensive UK, EU, US, or UN sanctions (including but not limited to Crimea, Cuba, Iran, Russia, North Korea, Syria, and certain regions of Ukraine — the list may change; check current government sources). We reserve the right to refuse or terminate service if we believe you are in a sanctioned jurisdiction.

Before placing any call (including to emergency numbers 999 or 112), you must successfully verify a valid physical phone number (mobile or landline) capable of receiving SMS messages, to our reasonable satisfaction. This verification is required for account access, authentication, and all calls.

We may, at our discretion, require additional proof of identity, address, or other information (e.g., ID documents or utility bills) if we suspect fraud, misuse, money laundering, or non-compliance with these Terms or applicable laws.

We reserve the right to suspend, restrict, or terminate your account (without refund) if:

• You fail to provide satisfactory verification or additional information when requested.
• We cannot verify your details to our reasonable satisfaction.
• You do not meet the eligibility criteria above.

3.1 Statutory Rights

Nothing in these terms excludes or limits your non-excludable statutory rights under the Consumer Rights Act 2015.

3.2 Warranty Exclusion

Subject to clause 3.1, we provide the Service “as-is” and exclude all implied warranties and conditions to the maximum extent permitted by law.

3.3 Cap on Liability

Our total aggregate liability to you for any claim arising out of this agreement shall not exceed 150% of the total amount paid by you to Dialoro in the 12 months preceding the claim.

3.4 Exclusion of Consequential Loss

We shall not be liable for any indirect or consequential losses, including but not limited to loss of profits, loss of business, or reputational damage.

3.5 External Failures

We are not liable for failures caused by events outside our reasonable control, including third-party vendor failures, internet service provider outages, or power failures.

4.1 Currency

All balances and fees are in USD ($).

4.2 Fees

There is a minimum top-up amount of $1.00. Every top-up incurs a $0.20 fee. Unanswered calls incur a Network Access Fee ($0.05 or 25% of the minute rate). Calls to UK emergency numbers (999 and 112) are free and do not incur any charges.

Rates for specific calls (including per-minute rates to destinations) will be clearly displayed to you before you initiate the call and are subject to change from time to time without prior notice (due to factors such as carrier costs or exchange rates). By initiating a call after viewing the displayed rate, you consent to be charged at that rate.

Calls are billed per started minute (e.g., a call lasting 61 seconds will be charged as 2 minutes).

4.3 Inactivity

Balances expire after 12 months of inactivity. We will attempt to notify you via SMS 30 days before expiry, but failure to deliver this notice does not invalidate the expiry.

4.4 Refunds

Within the 14-day cooling-off period (provided no chargeable calls have been made), you may request a refund. We may deduct non-refundable transaction costs where permitted by law.

4.5 Legal nature of top-ups

Top-ups made any credit that you hold on your account are not electronic money, stored value, or a payment instrument. Any amounts you pay to Dialoro are prepayments for access to services provided by Dialoro only and do not constitute a deposit or the issuance of electronic money under the Electronic Money Regulations 2011. Any credit that you hold on your account:

• has no cash or monetary value
• is not redeemable, refundable (except as expressly set out in these Terms), or exchangeable for cash
• is not transferable and may only be used by the account holder
• cannot be used to pay third parties and is accepted solely by Dialoro for the provision of its Services.

Holding credit with Dialoro does not create a monetary claim against Dialoro, and Dialoro does not provide payment services or issue electronic money.

4.6 Access to credit and authentication

Your wallet balance and credit from top-ups are associated with the mobile phone number you register and verify with Dialoro. To access your account, wallet, or initiate calls, you must maintain access to this registered phone number (including for authentication purposes, such as receiving verification codes).

You are solely responsible (at your own expense and risk) for maintaining access to your registered phone number. Dialoro is not liable for any loss of access to your wallet, credit, or account if you lose control of or access to that phone number (e.g., due to SIM loss, number porting issues, or carrier changes). We recommend keeping your registered number active and secure.

5.1 Metadata

We retain call metadata for 12 months for regulatory compliance and fraud prevention.

5.2 Disclosures

We may disclose your information to law enforcement agencies where required by law or where we reasonably believe disclosure is necessary to prevent, detect, or investigate serious crime or to prevent serious harm.

6.1 Process

Send complaints to support@dialoro.com. We aim to acknowledge receipt within 3 working days.

6.2 ADR Rights

If your complaint remains unresolved after 8 weeks (or 6 weeks for complaints raised after 8 April 2026), or if we reach a “deadlock” earlier, you may refer the dispute to an Ofcom-approved Alternative Dispute Resolution (ADR) scheme (details will be provided in a “deadlock” letter).

7.1 Right to Amend

We may from time to time update these Terms to reflect changes in law or our Service.

7.2 Material Changes

If we make a change that is to your material detriment, we will provide at least 30 days' notice via SMS or website notice. Your continued use after the change constitutes acceptance.

8.1 Ownership

The Service, including all software, apps, websites, branding, trademarks (including “Dialoro”), and associated materials, is owned by Dialoro or its licensors. All intellectual property rights remain with us.

8.2 Limited Licence

We grant you a limited, non-exclusive, non-transferable, revocable licence to use the Service for personal, non-commercial purposes in accordance with these Terms. You may not copy, modify, distribute, reverse engineer, decompile, or create derivative works from the Service (except as permitted by law).

8.3 User Feedback

If you provide suggestions or feedback, you grant Dialoro a perpetual, royalty-free licence to use and incorporate it without compensation or attribution.

9.1 Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court or regulatory authority, the remaining provisions shall continue in full force and effect. Where possible, the invalid provision will be modified to the minimum extent necessary to make it valid and enforceable while preserving its original intent.

9.2 Headings

The section headings in these Terms are for convenience only and shall not affect the interpretation or construction of these Terms.

9.3 Entire Agreement

These Terms constitute the entire agreement between you and Dialoro regarding the Service and supersede any prior agreements or understandings (written or oral).

9.4 No Third-Party Rights

These Terms do not confer any rights on third parties under the Contracts (Rights of Third Parties) Act 1999 or otherwise.

9.5 Waiver

No failure or delay by Dialoro in exercising any right under these Terms shall operate as a waiver of that right, nor shall any single or partial exercise preclude any further exercise.

9.6 Assignment

Dialoro may transfer its rights and obligations under these Terms to another organisation. You may not transfer your rights or obligations without our prior written consent.

10.1 Jurisdiction

These terms are governed by the laws of England and Wales. Any legal proceedings must be brought in the courts of England and Wales.

11.1 Privacy Policy forms part of these Terms

The Privacy Policy forms part of these Terms. By using the Service, you agree to the terms of the Privacy Policy. Privacy Policy may be updated from time to time, in accordance with these Terms. You can find the Privacy Policy here.