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Data Processing Agreement

Data Processing Agreement — BessCare Pro Tools

Version 1.0 · Effective 2026-09-27

This Data Processing Agreement (“DPA”) is entered into between:

  • Besscare OÜ, a company incorporated in Estonia, with registered office in Tallinn, Estonia (“BessCare“, “we“, “us“), acting as Processor (and, where it determines the means of processing, Controller); and
  • the user of the BessCare Pro Tools (“Customer“, “you“), acting as Controller in respect of Personal Data contained in documents you upload.

Together, the “Parties“.

This DPA supplements the BessCare Terms of Use and applies to your use of the following tools on bess.care (the “Tools“):

  1. Contract Risk Review — upload of warranty, SLA, LTSA or EPC contracts (PDF or Word);
  2. Offer Normaliser — upload of 2–4 competing quotes (PDF, Excel, CSV or pasted text).

1. Scope and roles

1.1. You are the Controller of any Personal Data contained in the documents or text you upload. You represent and warrant that you have a lawful basis to submit such documents for processing.

1.2. BessCare is the Processor acting on your behalf, for the sole and limited purpose of generating your report (the “Report“).

1.3. The Obligation Check tool processes no uploaded documents and no Personal Data; it runs entirely in your browser. It is outside the scope of this DPA.

2. Purpose and nature of processing

2.1. BessCare processes the uploaded documents only to:

  • extract text;
  • transmit that text to a large-language-model provider for automated analysis;
  • return a structured, printable report to you.

2.2. The processing is not used by BessCare to:

  • train, fine-tune or improve any model;
  • build profiles of you or any person named in your documents;
  • sell, license or otherwise disclose the data to any other party.

3. Duration and deletion

3.1. Immediate deletion. The uploaded document and the extracted text are deleted from our servers immediately after your Report is generated. We do not store the document, the extracted text, or any full-text copy after that point.

3.2. What is retained. Only the structured Report content (clause excerpts, notes, summary) is kept in transient server memory to deliver the result to your browser. This memory is cleared automatically within 24 hours and on any service restart. We do not persist the Report to disk or a database.

3.3. Model provider. The extracted text is transmitted to the model provider for the duration of the analysis call only. See Section 7 for the sub-processor and location.

4. Categories of data

4.1. The data processed is limited to whatever you choose to upload: contract text, quotation text, and any Personal Data contained therein (which may include names of signatories, contact details, and company information).

4.2. We ask that you redact any special categories of personal data (e.g. identification numbers, financial account details) before uploading. We do not require such data to provide the service.

5. Security

5.1. Technical measures:

  • Transport encryption (HTTPS/TLS) between your browser and our servers, and between our components;
  • Access to the processing backend is protected by a secret key held only on our server;
  • Uploaded files are processed in isolated temporary files and deleted (see 3.1);
  • No persistent database stores the uploaded documents or their text.

5.2. Organisational measures:

  • Access to the processing environment is limited to authorised personnel;
  • Processing logs record only metadata (timestamps, file count, token usage, cost) — never the document content.

6. Data subject rights and assistance

6.1. You remain responsible for responding to data subjects. BessCare will, taking into account the nature of processing, provide reasonable assistance to help you fulfil your obligations where possible.

6.2. Because documents are deleted immediately (Section 3), a request to access, rectify or erase data contained in a previously uploaded document generally cannot be fulfilled after deletion — there is nothing retained to return or erase. We will confirm deletion in response to any such request.

7. Sub-processors

7.1. BessCare uses the following sub-processor to perform automated document analysis:

Sub-processor Service Purpose Location of processing
Moonshot AI (Beijing Moonshot Technology Ltd.) kimi-k3 large language model Automated first-pass text analysis of your uploaded documents People’s Republic of China

7.2. International transfer. By using the Tools, you acknowledge and accept that the extracted text of your documents is transferred to the sub-processor in the People’s Republic of China for the duration of the analysis call. This transfer is:

  • strictly limited to the extracted text of the document(s) you upload;
  • necessary for the provision of the Tools.

7.3. If you cannot accept transfer of your document text to this sub-processor, do not upload documents containing personal or confidential data to the Tools. The Obligation Check tool remains fully available without any such transfer.

7.4. We will notify you of any change to the sub-processor list, and you may object by ceasing use of the affected Tools.

8. Confidentiality

8.1. BessCare treats the uploaded documents as confidential and does not disclose them to any third party except the sub-processor in Section 7, to the extent necessary to generate your Report.

8.2. BessCare personnel who access the processing environment are bound by confidentiality obligations.

9. Liability

9.1. To the maximum extent permitted by law, and without limiting the general limitations of liability in the Terms of Use, BessCare’s aggregate liability under this DPA is limited to the amount paid by you for the Tools in the 12 months preceding the event giving rise to liability. The Tools are provided free of charge; accordingly, no fee-based liability cap applies and our liability is limited to direct damages caused by our breach of this DPA.

9.2. The Tools provide automated first-pass screening only and do not constitute legal or investment advice.

10. Audit

10.1. Upon reasonable written request and subject to confidentiality, BessCare will provide information to demonstrate compliance with this DPA. Because no documents are retained (Section 3), audits of retained data are generally not applicable.

11. Governing law

11.1. This DPA is governed by the laws of Belgium, without regard to conflict-of-laws principles. The courts of Antwerp, Belgium have exclusive jurisdiction.

11.2. If the Customer is a consumer, nothing in this DPA limits rights under mandatory consumer-protection law of the Customer’s place of residence.

12. Contact

Besscare OÜ — Data protection: info@bess.care