TERMS AND CONDITIONS OF USE OF BREEZ BY BOSCO AI LTD

Effective Date: 24/04/2025

PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY

This agreement (“Agreement”) is a legal agreement between you (“Customer” or “You”) and Bosco AI LTD, a company registered in Scotland with its registered address at Silver Moon, Clora Brae, Oxton, Scotland (“Bosco AI” or “we”) and governs your access to and use of the Breez software, documentation, and any related services. Each of Bosco AI and You are a “party” and together the “parties.”

By signing up for Breez, installing, accessing, or otherwise using Breez, you agree to be bound by the terms of this Agreement. If you do not agree to these terms, you must not use the Breez software or services.

1. DEFINITIONS

The definitions in Schedule 1 (Definitions and Interpretation) apply to this Agreement.

2. RIGHTS OF USE

2.1 Subject to this Agreement, Bosco AI grants you a non-exclusive, non-transferable, non-sublicensable licence to access and use Breez and its documentation for your internal dental practice purposes only.

2.2 Access is permitted for authorised users only, and you shall not permit any user account to be shared.

3. OPERATING SYSTEM REQUIREMENTS

3.1 In order to use Breez, you must meet the following system requirements: Supported operating system as listed in our documentation;
Active internet connection;
Any browser or software dependencies required by Breez, which may change from time to time.

4. AUTHORISED USERS AND USE RESTRICTIONS

4.1 Each authorised user must be an individual who has been issued unique login credentials. Accounts may not be shared or used by more than one individual.

4.2 You shall not:
Decompile, reverse engineer, disassemble, or otherwise reduce Breez to a human-perceivable form;
Create derivative works based on Breez;
Use Breez for any unlawful or unethical purpose;
Sell, rent, sublicense, or distribute Breez to any third party.

4.3 You shall ensure that all authorised users comply with these terms and promptly notify us of any unauthorised access or security breaches.

5. OUR OBLIGATIONS

5.1 Bosco AI shall provide Breez and associated documentation to you and use commercially reasonable efforts to support and maintain the service.

5.2 Bosco AI may suspend your access if we suspect misuse, security issues, or payment failures.

6. HARDWARE (MICROPHONES)

6.1 One microphone is provided per account during the trial period. The microphone is subject to a one-year limited warranty.

6.2 Failure to return the Hardware in good working order within thirty (30) days of cancellation may result in a fee equivalent to one (1) month’s Subscription Fee, unless the damage was caused in transit or due to a verified fault.

6.3 Additional microphones can be purchased separately by the Customer.

7. SUBSCRIPTION AND PAYMENT

7.1 Subscription pricing and payment terms are specified on our website at the time of sign-up.

7.2 Card details must be submitted before the Trial Period begins. Monthly billing will start automatically after the 14-day trial, unless the subscription is cancelled.

7.3 Subscription fees are exclusive of VAT unless otherwise stated.

7.4 All charges are billed in full for each Billing Cycle. Bosco AI LTD does not apply prorated charges.

7.5 Bosco AI LTD reserves the right to increase Subscription Fees with 30 days’ notice. Customers may cancel before the new fee takes effect.

8. CANCELLATION AND TERMINATION

8.1 You may cancel your subscription at any time by providing 30 days' notice. Cancellation takes effect at the end of the next Billing Cycle.

8.2 No refunds or prorated credits are issued for partial Billing Cycles.

8.3 Bosco AI LTD may terminate the Agreement for material breach, including non-payment, misuse, or legal violations. Immediate termination applies in cases of fraud or unlawful activity.

9. DATA PROTECTION AND SECURITY

9.1 Audio data and transcriptions are processed by secure third-party tools under GDPR-compliant frameworks.

9.2 Recordings may be retained for up to 10 years to comply with clinical record-keeping requirements. Transcripts are anonymised and may be retained indefinitely for analytics.

9.3 Customers will have 30 days post-cancellation to access and download their data.

9.4 See Schedule 2 (Data Protection) for full terms.

9.5 Breez may use anonymised or aggregated data to enhance the quality, performance, or reliability of its services. This may include using such data to support the improvement of system outputs or internal processes. No identifiable patient data is used for these purposes unless explicitly authorised by the Customer. All data processed for these purposes is handled in accordance with applicable data protection laws.

10. LIABILITY AND INDEMNITY

10.1 Breez is provided “as is.” Bosco AI disclaims all warranties to the extent permitted by law.

10.2 The Customer indemnifies Bosco AI for any misuse or legal violations.

10.3 Bosco AI’s liability is limited to the amount paid by the Customer in the previous 12 months.

11. GOVERNING LAW AND JURISDICTION

This Agreement shall be governed by the laws of Scotland. All disputes shall be resolved in the Scottish courts.

12. CONTACT INFORMATION

For questions or support, please contact:

📍 Bosco AI LTD, Silver Moon, Clora Brae, Oxton, Scotland
📧 bosco@breez-dental.com


Schedule 1 – Definitions and Interpretation

“Authorised User” means an individual who has been granted access to Breez by the Customer and who has been assigned unique login credentials. Authorised Users must not share their credentials with others, and each account must be used only by the individual to whom it is issued.

“Confidential Information” means any non-public information, whether oral, written, visual, electronic, or in any other form, disclosed by one party to the other that is marked or otherwise identified as confidential, or which ought reasonably to be understood to be confidential given the nature of the information and the circumstances of disclosure. This includes but is not limited to business plans, strategies, data, financial information, technical information, trade secrets, customer and supplier lists, operational processes, proprietary technology, software source code, patient-related data, and any information relating to either party’s operations, affairs, or business

“Customer Data” Any information, content, or data input into, generated by, or transmitted through the Software or Services by or on behalf of the Customer or its Authorised Users. This includes, but is not limited to: audio recordings, transcripts, patient-related information, anonymised or non-anonymised dental notes, account registration details, billing information, and usage logs. Customer Data may contain personal data and is subject to applicable data protection laws. Unless otherwise stated, the Customer retains ownership of their Customer Data. Bosco AI LTD processes Customer Data solely for the purpose of providing the Services and in accordance with this Agreement and applicable privacy policies.

“Effective Date” means the date on which the Customer first accepts these Terms and Conditions by completing the sign-up process, installing, or first using the Breez software, whichever occurs earliest.

“Intellectual Property Rights” All patents, rights to inventions, copyright and related rights, trademarks, trade names, domain names, rights in computer software (including source code and object code), database rights, moral rights, know-how, and any other intellectual property rights, whether registered or unregistered, and including all applications and rights to apply for and be granted such rights, anywhere in the world.

“Software” The Breez desktop application and any associated components provided by Bosco AI LTD, including tools used for account management via the Breez website. This includes all related software, updates, upgrades, interfaces, and documentation, whether accessed locally or via an internet connection. The Software does not include any third-party services integrated into the platform.

“Subscription” A paid licence granted to the Customer to access and use the Software and related services on a recurring basis, subject to payment of the applicable fees. Subscriptions may be offered on a monthly, annual, or other basis, as specified at the time of purchase. Bosco AI LTD may, at its discretion, offer a free trial period. Subscriptions will automatically renew unless cancelled with a minimum of one (1) month's notice prior to the next billing cycle. Access will continue through the paid billing period following cancellation.

“Trial Period” A limited period of time, as specified by Bosco AI LTD at the time of account activation, during which the Customer may use the Software and any accompanying Hardware on a trial basis without paying a Subscription fee. The Trial Period is offered at Bosco AI LTD’s sole discretion and may be withdrawn or modified at any time. During the Trial Period, certain features or services may be limited, and the Customer may cancel at any time without incurring charges, subject to the return of any Hardware provided.

“Third-Party Services” Any products, services, software, or platforms provided by entities other than Bosco AI LTD that are integrated with, accessed through, or used in connection with the Software. This includes, but is not limited to, transcription APIs, AI processors, cloud hosting providers, and payment processors. Bosco AI LTD is not responsible for the performance, availability, or data handling practices of such Third-Party Services.

“Hardware” The physical equipment provided by Bosco AI LTD for use with the Software, including but not limited to the microphone issued to the Customer. Hardware is provided in exchange for a fixed, upfront deposit. If the Customer cancels their use of the Software and returns the Hardware in good working condition within twelve (12) months from the Effective Date, the deposit may be refunded following an inspection by Bosco AI LTD. If the Customer continues use of the Software beyond this period, the deposit shall be retained by Bosco AI LTD and ownership of the Hardware shall transfer to the Customer. Additional or replacement Hardware may be offered for purchase under separate terms. Hardware use is subject to the warranty, usage, and return conditions set out in this Agreement.

“Account” The Customer’s registered profile within the Breez platform, created upon acceptance of this Agreement. The Account contains subscription details, user credentials, authorised user management settings, and contact and billing information. The Customer is responsible for maintaining the accuracy of the Account data and ensuring that login credentials are kept secure and used only by assigned individuals. Bosco AI LTD may support multi-user setups under a single Account, subject to applicable subscription terms. Payment processing and billing services may be handled by third-party providers such as Stripe, as further described in this Agreement.

“Documentation” The user-facing materials provided by Bosco AI LTD to support the use of the Software. This includes written guides, setup instructions, frequently asked questions (FAQs), technical specifications, and onboarding or training content, whether provided within the Software, on the official Breez website, or through Bosco AI LTD’s verified social media channels. Documentation also includes support services made available via email, live chat, or messaging platforms such as WhatsApp, as may be offered from time to time. Documentation is provided for informational purposes only and does not form part of the Software or carry any warranty.

“Payment Method” The valid credit card, debit card, bank account, or other approved method of payment provided by the Customer and held on file by Bosco AI LTD or its authorised payment processor. The Payment Method must be submitted and successfully authorised before the commencement of any Trial Period or the dispatch of any Hardware. It will be used to initiate billing for the Subscription following the expiry of any applicable Trial Period, and for any additional charges incurred under this Agreement, including charges for unreturned or damaged Hardware. The Customer is responsible for ensuring that their Payment Method remains current, valid, and capable of processing charges.

“Billing Cycle” The recurring monthly period for which Subscription Fees are charged and payable by the Customer. The Billing Cycle begins immediately after the conclusion of any applicable Trial Period and repeats on the same calendar day each month (e.g., if billing begins on the 20th, future charges will occur on the 20th of each subsequent month). Bosco AI LTD does not apply prorated charges. All Subscription Fees are charged in full for each Billing Cycle. The Customer is responsible for ensuring their Payment Method is active on their billing date. Charges for additional services or non-returned or damaged Hardware may be applied separately.

“Price Changes” Bosco AI LTD reserves the right to change its pricing at any time. In the event of a Subscription Fee increase, the Customer will be notified at least thirty (30) days in advance via email or through the Breez platform. The new pricing will take effect from the Customer’s next Billing Cycle following the end of the notice period. If the Customer does not agree to the updated pricing, they may cancel their Subscription in accordance with the cancellation terms of this Agreement before the new pricing takes effect.

“Cancellation and Notice Period” The Customer may cancel their Subscription at any time by providing Bosco AI LTD with a minimum of thirty (30) days' written notice via email or through the Breez platform. Cancellation will take effect at the end of the Customer’s next Billing Cycle following the completion of the notice period. No refunds or prorated credits will be provided for any partial Billing Cycle. The Customer remains responsible for all charges incurred up to the effective cancellation date, including any applicable charges for non-returned or damaged Hardware.

“Cancellation Date” The date on which the Customer’s Subscription is scheduled to terminate, following the completion of the required thirty (30) day notice period. The Cancellation Date will coincide with the end of the Customer’s final Billing Cycle, unless otherwise agreed in writing with Bosco AI LTD.

“Returns” The process by which the Customer sends back Hardware to Bosco AI LTD following cancellation of their Subscription, or in the event of receiving faulty or damaged Hardware. Returned Hardware must be received by Bosco AI LTD within thirty (30) days of the effective Cancellation Date. The Hardware must be in good working condition, subject to inspection. Failure to return the Hardware within the specified timeframe, or returning Hardware that is materially damaged or unusable (excluding transit-related issues reported upon delivery), may result in a charge equivalent to one (1) month’s Subscription Fee. Returns related to faulty Hardware received at the outset of service must be reported within seven (7) days of receipt to qualify for replacement.

“Warranty“ A limited assurance provided by Bosco AI LTD that the Hardware supplied to the Customer will be free from material defects in workmanship and functionality under normal use for a period of twelve (12) months from the date of dispatch. This Warranty covers repair or replacement of defective Hardware at no cost to the Customer, provided the issue is not caused by misuse, unauthorised modification, neglect, or accidental damage. Claims under this Warranty must be submitted to Bosco AI LTD in writing with supporting evidence (e.g., photos, descriptions of the issue). Replacement Hardware may be subject to availability and will be provided at Bosco AI LTD’s discretion. Returned or defective Hardware may be recycled or refurbished by Bosco AI LTD in line with its circular economy principles.

“Termination for Breach” The right of either party to terminate this Agreement with immediate effect in the event that the other party commits a material breach of its obligations under the Agreement, and (where the breach is capable of remedy) fails to remedy that breach within thirty (30) days of receiving written notice to do so. Material breaches include, but are not limited to: (i) repeated or intentional non-payment of Subscription Fees; (ii) unauthorised sharing, sublicensing, or tampering with the Software or Hardware; (iii) use of the Software or Hardware with unauthorised third-party tools or platforms; (iv) violation of applicable data protection or privacy laws; or (v) use of the Software in a manner that may cause reputational or legal harm to Bosco AI LTD or others. Bosco AI LTD reserves the right to terminate this Agreement immediately and without notice in the event of fraud, gross negligence, or illegal activity by the Customer. Upon termination for breach, the Customer shall immediately cease all use of the Software and return any applicable Hardware within the specified timeframe. Any outstanding amounts, including charges for unreturned or damaged Hardware, shall remain due.

“Force Majeure” An event or circumstance beyond the reasonable control of either party which prevents or delays the performance of any obligation under this Agreement. This includes, but is not limited to: natural disasters, war, civil unrest, terrorist acts, strikes, labour disputes, epidemics or pandemics, acts of government, power or internet outages, or failures in third-party infrastructure. Neither party shall be liable for any failure or delay in performing its obligations (except payment obligations) where such failure or delay results from a Force Majeure event. The affected party shall use reasonable efforts to mitigate the impact and must notify the other party in writing (including by email) without undue delay.

“Support” Assistance provided by Bosco AI LTD to the Customer in connection with the use of the Software and Hardware. Support is available during normal UK business hours (Monday to Friday, 9:00am to 5:00pm, excluding public holidays). Customers may initiate support via WhatsApp messaging, including text and photo submissions. If required, Bosco AI LTD may follow up by phone; however, inbound calls from Customers are not supported. Support covers guidance with installation, troubleshooting Software or Hardware issues, and general usage enquiries. Bosco AI LTD does not guarantee specific response times and is not responsible for resolving issues related to third-party software, internet connectivity, or hardware not supplied by Bosco AI LTD. Support may be limited during peak periods or system outages, and is provided at Bosco AI LTD’s discretion.

“Data Retention” The period during which Bosco AI LTD stores Customer Data in connection with the use of the Software. Audio recordings may be retained for up to ten (10) years to support clinical record-keeping standards, unless a shorter or longer retention period is required by law or agreed with the Customer. Transcripts and notes are anonymised automatically and may be retained indefinitely as part of aggregated analytics data, provided they are no longer identifiable. Upon cancellation of a Subscription, the Customer will have thirty (30) days to access and download any relevant Customer Data before access is removed and data is deleted or archived in accordance with Bosco AI LTD’s internal policies. Account and billing data will be retained as required to meet legal and regulatory obligations.

“Data Deletion” The process by which Bosco AI LTD removes or anonymises Customer Data from its systems. Customers may request deletion of their personal data in accordance with their rights under applicable data protection laws, including the UK GDPR. Bosco AI LTD will honour such requests unless retention is required for legal, regulatory, or contractual reasons (such as clinical record-keeping, audit logs, or financial reporting). Where full deletion is not possible, data may be anonymised or access-restricted instead. In the event of Subscription cancellation, Customers will have thirty (30) days to access and download any relevant Customer Data before data is permanently deleted, anonymised, or archived. Deleted data cannot be recovered, and Customers are responsible for exporting any required information before deletion occurs.

“Third-Party Tools” External software, platforms, APIs, or services that are integrated with, support, or are used in connection with the Breez Software or Services. These tools may include providers of functions such as transcription, AI processing, data storage, analytics, email delivery, or payment processing. Third-Party Tools are subject to their own terms of service and privacy policies. Bosco AI LTD is not responsible for the availability, accuracy, security, or data handling practices of any Third-Party Tools, and their inclusion does not imply endorsement or control.

“Analytics Data” Aggregated and anonymised data collected by Bosco AI LTD to understand how the Software and Services are used, monitor performance, improve functionality, and support internal business decisions. Analytics Data may include usage patterns, feature interaction logs, performance metrics, system events, and anonymised outputs such as dental note structures or word frequencies. Analytics Data does not include any personal data that can be used to directly identify a Customer, patient, or Authorised User.

“Anonymisation” The process by which personal identifiers are removed or transformed from data such that the data can no longer be used to directly or indirectly identify an individual. Bosco AI LTD applies anonymisation techniques, including but not limited to name removal from transcripts, to reduce privacy risks and enable safe retention of data for analytical or service improvement purposes. Anonymised data is no longer considered personal data under applicable data protection laws.

“User Responsibilities” The obligations of the Customer and their Authorised Users when using the Software, Hardware, or Services. These include, but are not limited to: (i) ensuring that login credentials are kept secure and not shared; (ii) using the Software only for lawful, professional purposes within a dental practice environment; (iii) maintaining the condition of any Hardware provided and returning it where required; (iv) complying with all applicable laws, regulations, and data protection standards; and (v) not using the Software or Services to upload, store, or transmit any unlawful, defamatory, or harmful content. The Customer is also responsible for ensuring that appropriate consent is obtained from patients where necessary, including in relation to audio recording and data processing.

“Licence” The limited, non-exclusive, non-transferable, and revocable right granted by Bosco AI LTD to the Customer to access and use the Software and associated Services during the Term of the Subscription, strictly for internal use within the Customer’s dental practice. The Licence is subject to the terms of this Agreement and does not include any right to sublicense, distribute, resell, or make the Software available to third parties. All rights not expressly granted under this Licence are reserved by Bosco AI LTD.

“Security Measures” The technical and organisational safeguards implemented by Bosco AI LTD to protect Customer Data against unauthorised access, disclosure, alteration, or destruction. These measures include, but are not limited to: encryption of data at rest and in transit, access controls, secure server environments, user authentication protocols, and the use of reputable third-party infrastructure providers. Bosco AI LTD reviews and updates its Security Measures periodically in line with industry best practices and applicable data protection laws.

“Intellectual Property” All intellectual property rights, including but not limited to copyrights, trademarks, patents, design rights, trade secrets, know-how, and all related goodwill, whether registered or unregistered, in and to the Software, Documentation, Services, branding, and any other materials provided by Bosco AI LTD. All such rights shall remain the exclusive property of Bosco AI LTD or its licensors. This Agreement does not grant the Customer any rights, title, or interest in or to any Intellectual Property, except for the limited Licence expressly granted under this Agreement.

“Operating System Requirements” The minimum technical conditions required to install and operate the Breez Software. These currently include a supported version of the Microsoft Windows operating system, a stable internet connection, and an up-to-date web browser. Bosco AI LTD may update these requirements from time to time to reflect technological advancements or security considerations. It is the Customer’s responsibility to ensure their systems meet these requirements to access and use the Services effectively.


Schedule 2 – Data Protection

1. Roles and Responsibilities 1.1 For the purposes of applicable data protection legislation, including the UK GDPR and Data Protection Act 2018:
The Customer is the Data Controller in respect of any personal data processed via the Breez Software relating to patients or clinical matters.
Bosco AI LTD acts as the Data Processor, processing such personal data solely on behalf of the Customer and in accordance with their instructions, as set out in this Agreement or otherwise provided in writing.

2. Customer Personal Data 2.1 “Customer Personal Data” means any personal data processed by Bosco AI LTD on behalf of the Customer in connection with their use of the Breez Software. This includes, without limitation:
Audio recordings of dental consultations,
Speech-to-text transcripts,
Patient names or identifiers (if not anonymised),
Appointment metadata (e.g. timestamps, durations),
Any other clinical information disclosed during recordings,
Information input or generated through the Breez Software as part of the note generation process.

2.2 Bosco AI LTD may retain and use Customer Personal Data only as necessary to provide the Services and to comply with legal obligations. Anonymised or aggregated data derived from Customer Personal Data may be retained beyond the active use of the Services and used internally to support service reliability, functionality improvements, performance monitoring, and enhancement of system outputs. Any such use will exclude identifiable personal data and will be carried out in accordance with applicable data protection laws and industry best practices.

3. Processor Obligations 3.1 Bosco AI LTD shall:
(a) Only process Customer Personal Data on documented instructions from the Customer, unless required to do so by applicable law. In such a case, Bosco AI LTD shall (unless legally prohibited) inform the Customer before processing;
(b) Ensure confidentiality by requiring that any personnel authorised to process Customer Personal Data are bound by confidentiality obligations;
(c) Assist the Customer, at the Customer’s cost, in responding to data subject rights requests under Chapter III of UK GDPR, including access, rectification, erasure, and objection requests, to the extent applicable;
(d) Provide reasonable assistance, at the Customer’s cost, to ensure compliance with the Customer’s obligations under Articles 32 to 36 of the UK GDPR (e.g. security, data breach notification, DPIAs);
(e) Make available information as reasonably required to demonstrate compliance with the obligations set out in this Schedule and permit audits by the Customer (subject to reasonable notice, confidentiality, and frequency limitations — e.g. no more than once per 12 months).

4. Security Measures 4.1 Bosco AI LTD shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks associated with processing Customer Personal Data. These measures include, but are not limited to:
Encryption of data at rest and in transit using industry-standard protocols;
Use of secure, access-controlled cloud infrastructure and encrypted storage environments;
Access controls limited to authorised personnel with role-based privileges;
Periodic review of systems for vulnerabilities or unauthorised access;
Secure transmission protocols (e.g. HTTPS/TLS 1.2 or higher) between the Breez frontend and backend services;
Secure password handling through hashing and salting techniques;
Ongoing internal reviews and assessments to enhance data protection measures.

4.2 Bosco AI LTD shall ensure that any person acting under its authority who has access to Customer Personal Data does not process such data except on the Customer’s instructions, unless required to do so by law.

5. Sub-Processors 5.1 The Customer acknowledges and agrees that Bosco AI LTD may engage third-party service providers (“Sub-Processors”) to support the provision of the Services, including but not limited to providers of:
Transcription services,
AI-powered note generation,
Cloud infrastructure and hosting,
Payment processing.

5.2 Bosco AI LTD shall ensure that any Sub-Processor is subject to a written agreement imposing data protection obligations that are no less protective than those set out in this Agreement.

5.3 Bosco AI LTD shall remain responsible for ensuring that any Sub-Processor processes Customer Personal Data in accordance with this Agreement and applicable data protection laws.

5.4 Bosco AI LTD will, upon reasonable request, provide the Customer with a list of current Sub-Processors and will notify the Customer in advance of any intended material changes concerning the addition or replacement of Sub-Processors. The Customer may object to such changes on reasonable data protection grounds within ten (10) business days of receiving the notice. In the event of a justified objection, the parties shall work in good faith to find a mutually acceptable resolution.

6. Data Breach Notification 6.1 In the event of a personal data breach affecting Customer Personal Data, Bosco AI LTD shall notify the Customer without undue delay after becoming aware of the breach.

6.2 Such notification shall include, to the extent known at the time:
A description of the nature of the breach (including, where possible, the categories and approximate number of affected data subjects and data records);
The likely consequences of the breach;
The measures taken or proposed to address the breach and mitigate its effects;
Contact details for further information.

6.3 Bosco AI LTD shall promptly investigate the breach and take reasonable steps to mitigate any harmful effects, and shall cooperate in good faith with the Customer to support any required notifications to supervisory authorities or data subjects.

7. International Data Transfers 7.1 The Customer acknowledges that certain Sub-Processors engaged by Bosco AI LTD (including, but not limited to, providers of transcription and AI services) may process Customer Personal Data in countries outside the United Kingdom.

7.2 Where such processing involves a transfer of Customer Personal Data to a third country or international organisation that is not subject to an adequacy decision by the UK Government, Bosco AI LTD shall ensure that appropriate safeguards are in place. These may include:
Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner’s Office (ICO), or
Another legally valid transfer mechanism under UK GDPR.

7.3 Upon request, Bosco AI LTD shall provide the Customer with a copy of the relevant safeguards used for such transfers, subject to reasonable redactions for commercial or security purposes.

8. Data Retention and Deletion 8.1 Bosco AI LTD shall retain Customer Personal Data only for as long as necessary to provide the Services and to comply with applicable legal and regulatory obligations.

8.2 Specifically:
Audio recordings may be stored for up to ten (10) years, in line with NHS dental record-keeping guidance;
Transcripts and clinical notes will be anonymised as part of the processing workflow and may be retained indefinitely for internal analytics, training, or improvement purposes, provided they are no longer considered personal data.

8.3 Upon termination of the Customer’s Subscription, Bosco AI LTD shall:
Retain access to Customer Data for a period of thirty (30) days to allow the Customer to export or download it;
After this period, delete or anonymise the remaining Customer Personal Data, except where retention is required by law.

8.4 The Customer may request early deletion of their Customer Personal Data at any time by contacting support, provided this does not interfere with Bosco AI LTD’s legal obligations.

9. Data Subject Rights Assistance 9.1 To the extent required by applicable data protection laws, Bosco AI LTD shall provide reasonable assistance to the Customer, at the Customer’s cost, in responding to requests from data subjects exercising their rights under UK GDPR, including:
The right of access,
Rectification or erasure of personal data,
Restriction of processing,
Data portability, and
Objection to processing.

9.2 Bosco AI LTD shall promptly notify the Customer if it receives a request directly from a data subject relating to Customer Personal Data, unless prohibited by law. Bosco AI LTD shall not respond to such requests without the Customer’s prior written authorisation.

10. Audit Rights 10.1 Bosco AI LTD shall, upon reasonable written request from the Customer and no more than once in any twelve (12) month period, make available such information as is reasonably necessary to demonstrate its compliance with this Schedule and applicable data protection laws.

10.2 If, after reviewing the information provided, the Customer reasonably believes that further assurances are required, the Customer may request to carry out an audit of Bosco AI LTD’s relevant data processing activities.

10.3 Any such audit shall:
Be conducted on at least thirty (30) days’ notice;
Be limited in scope to the processing of Customer Personal Data under this Agreement;
Not unreasonably interfere with Bosco AI LTD’s normal business operations;
Be subject to appropriate confidentiality obligations.

10.4 The Customer shall bear all costs of any audit unless the audit identifies a material breach by Bosco AI LTD of its obligations under this Agreement.