COOKIE POLICY

(Cookie Policy)

Version 1.0 · Effective date: 6 August 2026 · Odonta360 Platform · Bolutions LTD

1. INTRODUCTION

Welcome to the Odonta360 website and SaaS platform.

This Cookie Policy (hereinafter: the “Policy”) explains the manner in which Bolutions LTD, company number 16576182, 71-75, Shelton Street, Covent Garden, London, WC2H 9JQ, UNITED KINGDOM, E-mail: office@odonta360.com

the provider of the Odonta360 platform available at odonta360.com (hereinafter: “Bolutions”, “we”, “our”) uses cookies and other similar technologies in connection with the use of the website and the Platform.

The purpose of this Policy is to give users clear information about the types of cookies we use, their purpose, their duration, the legal basis for their use, and the options available for managing cookie settings.

This Policy forms an integral part of:

1. the General Terms of Use;
2. the Privacy Policy;
3. other documents governing the use of Bolutions' services.

By using the website or the Platform, the user confirms that they are aware of this Policy.

2. SCOPE OF APPLICATION

In order to make the use of cookies clearly understandable, Bolutions distinguishes between two separate information systems:

2.1. The website

The website is the publicly accessible part of Bolutions, intended for:

1. presenting products and services;
2. informing visitors;
3. contacting Bolutions;
4. marketing activities;
5. analysing website traffic.

The following may be used on the website:

1. essential cookies;
2. analytical cookies;
3. marketing cookies.

2.2. The SaaS Platform

The Platform is an information system intended for registered users who use Bolutions to manage the business operations of dental practices.

The Platform makes it possible, among other things, to:

1. maintain electronic medical records;
2. manage patient charts;
3. schedule appointments;
4. manage user accounts;
5. administer business operations.

Unlike the website, the Platform does not use analytical or marketing cookies.

While the Platform is being used, only technically essential cookies enabling its proper functioning are used.

3. WHAT ARE COOKIES?

Cookies are small text files that a browser stores on the user's device when they visit a particular website or use a web application.

Cookies make it possible for a website or application to recognise the user's device for the duration of a session or on subsequent visits.

Cookies are not programs in themselves, cannot contain viruses and do not provide access to data held on the user's device.

Their basic purpose is to improve the functionality of the website, increase security, improve the user experience and enable certain technical functionalities.

4. LEGAL BASIS FOR THE USE OF COOKIES

Bolutions uses cookies in accordance with the applicable regulations governing personal data protection and electronic communications, including, where applicable:

1. the Personal Data Protection Act of the Republic of Serbia (“Official Gazette of the RS”, No. 87/2018);
2. the General Data Protection Regulation of the European Union (GDPR);
3. other applicable regulations governing the use of cookies and similar technologies.

The legal basis for the use of cookies depends on their type.

Essential cookies

Essential cookies are used in order to enable the basic functioning of the website or the Platform.

No specific consent of the user is required for their use, given that without them the requested electronic service cannot be provided.

Analytical cookies

Analytical cookies are used solely on the website, in order to understand how visitors use the website and to improve its content.

Such cookies are activated only after the user has given the relevant consent through the cookie banner, unless the applicable regulations permit otherwise.

Marketing cookies

Marketing cookies are used solely on the website, in order to measure the success of marketing campaigns, display more relevant content and track conversions.

Their use is based on the prior consent of the user.

The user may withdraw the consent given at any time.

5. USER CONSENT

On a first visit to the website, the user will be shown a banner that allows them to make a choice regarding the use of cookies.

The user may:

1. accept all cookies;
2. reject all non-essential cookies;
3. adjust the settings and select individual categories of cookies.

The preferences given may be changed at any time through the cookie settings available on the website or through the browser settings.

Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

6. GENERAL CLASSIFICATION OF COOKIES

Depending on their duration, cookies may be:

Session cookies

These cookies exist only for the duration of the user session.

They are deleted automatically when the browser is closed.

They are most commonly used in order to:

1. maintain a signed-in session;
2. provide secure authentication;
3. protect against unauthorised access;
4. ensure the proper functioning of the website or the Platform.

Persistent cookies

Persistent cookies remain stored on the user's device after the browser is closed.

They are used in order to:

1. remember user settings;
2. analyse website traffic;
3. improve the user experience;
4. measure the success of marketing activities.

The duration of these cookies depends on their purpose and on the settings of the particular service that places them.

7. ESSENTIAL COOKIES

Essential cookies are cookies without which the website or the Platform cannot function properly.

Their purpose is not to track user behaviour or to display personalised advertising, but solely to enable the basic functionalities of the system.

These cookies may enable:

1. the establishment and maintenance of a user session;
2. the authentication of signed-in users;
3. protection against unauthorised access;
4. protection against CSRF (Cross-Site Request Forgery) attacks;
5. the correct routing of requests between the user and the server;
6. the preservation of the security of the information system;
7. remembering the user's choice regarding the use of cookies.

Essential cookies are used both on the website and on the Platform.

Without their use it is not possible to ensure the proper functioning of the service requested by the user.

For that reason, their use does not require the prior consent of the user, to the extent permitted by the applicable regulations.

8. FUNCTIONAL COOKIES

Functional cookies allow the website or the Platform to remember certain choices made by the user in order to improve the user experience.

Such cookies may enable, among other things:

1. remembering the selected language;
2. remembering user preferences;
3. remembering certain interface settings;
4. other functionalities that are not a necessary condition for the operation of the system but improve its usability.

At the time this Policy is adopted, the Odonta360 Platform uses only functionalities that are necessary for its operation, while functional cookies may be used on the public website if functionalities requiring them are introduced.

Should they be used in the future, this Policy will be updated accordingly.

9. ANALYTICAL COOKIES (GOOGLE ANALYTICS)

The Odonta360 website uses Google Analytics 4 (GA4), an analytics service provided by Google LLC or the relevant company within the Google group, in order to collect statistical data on the use of the website.

Google Analytics enables Bolutions to better understand how visitors use the website, so that it can improve its content, functionalities and user experience.

Google Analytics may collect information such as:

1. the number of visits to the website;
2. the pages visited;
3. the order in which pages were viewed;
4. the duration of the visit;
5. the time spent on individual pages;
6. how the visitor arrived at the website (search, direct access, social networks and similar);
7. the type of device;
8. the operating system;
9. the browser;
10. the approximate geographic location (country or region);
11. anonymous device identifiers.

Bolutions does not use Google Analytics to identify individual users, nor to link the analytical data collected with medical records or other data processed through the Platform.

Google Analytics uses its own cookies in order to generate aggregated statistical reports.

Analytical cookies are activated only after the user has given the relevant consent through the cookie banner, unless the applicable regulations permit otherwise.

Further information on how Google processes data is available in its privacy policy.

Google Analytics is activated only after the prior consent of the user, where such consent is required by the applicable legislation.

10. MARKETING COOKIES (META PIXEL)

The public Odonta360 website uses Meta Pixel, a technology of Meta Platforms Ireland Limited, in order to analyse the success of marketing activities and improve digital advertising.

Meta Pixel enables Bolutions to measure the effectiveness of advertising campaigns on Meta platforms (Facebook and Instagram) and to better understand how users interact with the website.

Depending on the consent given by the user, Meta Pixel may enable:

1. conversion measurement;
2. analysis of the success of advertising campaigns;
3. the creation of custom audiences (Custom Audiences);
4. the display of more relevant advertisements to users who have previously visited the website (remarketing);
5. the optimisation of future marketing campaigns.

Bolutions does not use Meta Pixel within the SaaS Platform, nor in connection with the processing of patient data.

Meta Pixel is used solely on the publicly accessible website.

The use of Meta Pixel technology is based on the prior consent of the user, unless the applicable regulations permit otherwise.

Further information on the processing of data by Meta is available in its privacy policy.

Meta Pixel is activated only after the prior consent of the user, where such consent is required by the applicable legislation.

11. THIRD-PARTY COOKIES

Certain functionalities of the website may use third-party services that place their own cookies.

Such cookies are subject to the privacy rules of the relevant service providers.

At the time this Policy is adopted, the website uses the following third-party services:

Bolutions has no control over the content, privacy policies or practices of third parties that place their own cookies.

Users are advised to familiarise themselves with the privacy policies and cookie policies of the relevant service providers as well.

12. COOKIES ON THE PLATFORM

Unlike the public website, the Odonta360 SaaS Platform is intended for registered users who manage the business operations of dental practices and process medical records.

For that reason, the Platform applies a distinct approach to the use of cookies.

The Platform does not use:

1. Google Analytics;
2. Meta Pixel;
3. marketing cookies;
4. remarketing technologies;
5. cookies for behavioural advertising;
6. technologies intended for user profiling.

While the Platform is being used, only technically essential cookies are used, the purpose of which is:

1. user authentication;
2. maintaining a signed-in session;
3. protecting the user account;
4. preserving the security of the system;
5. preventing misuse;
6. ensuring the proper functioning of the information system.

Data processed through the Platform is not used for marketing activities, user profiling, personalised advertising or other commercial purposes unrelated to the provision of the contracted SaaS service.

The use of technically essential cookies is a condition for the secure functioning of the Platform.

13. OVERVIEW OF COOKIE CATEGORIES

In order to make the way Bolutions uses cookies easier to understand, an overview of the categories of cookies that may be used on the website and on the Platform is given below.

The use of individual categories of cookies may change as the website or the Platform develops. Should new categories of cookies or new service providers be introduced, this Policy will be updated accordingly.

13a. LIST OF COOKIES USED

Essential — Platform and website:

sb-<project>-auth-token — Bolutions (Supabase) — maintaining a signed-in session and authenticating the user — duration: until the session expires / until sign-out — no consent required.

odonta360-cookie-consent — Bolutions — remembering the user's choice regarding cookies — duration: 6 months — no consent required.

Analytical — website only (activated only after consent):

_ga — Google — distinguishing visitors — duration: 2 years.

_ga_<ID> — Google — maintaining session state (GA4) — duration: 2 years.

Marketing — website only (activated only after consent):

_fbp — Meta — conversion measurement and remarketing — duration: 3 months.

_fbc — Meta — recording arrival from a Meta advertisement — duration: 3 months.

Note: this list is updated whenever the services used change. At the time of publication of this Policy, only essential cookies are used on the Platform.

14. COOKIE RETENTION PERIODS

The duration of cookies depends on their type and purpose.

Session cookies

Session cookies are deleted automatically when the browser is closed.

They are used primarily in order to:

1. maintain a signed-in session;
2. authenticate the user;
3. protect against misuse;
4. ensure the proper functioning of the Platform.

Persistent cookies

Persistent cookies remain stored on the user's device for a specified period of time or until they are deleted manually.

Their duration is determined by the provider of the particular service or by the purpose for which they are used.

Google Analytics and Meta Pixel may use persistent cookies in accordance with their privacy policies and technical specifications.

Bolutions does not determine the duration of cookies placed by third parties; this is governed by the rules of the relevant service providers.

15. MANAGING COOKIES

The user may manage the use of cookies at any time.

This may be done in one of the following ways:

1. through the cookie banner displayed on the website;
2. by changing the consent settings previously given;
3. through the browser settings;
4. by deleting existing cookies from their device.

Refusing certain categories of cookies may affect the availability or proper functioning of certain website functionalities.

Refusing analytical or marketing cookies will not affect the ability to use the basic functionalities of the website.

However, disabling essential cookies may result in certain parts of the website or the Platform not functioning properly.

The user may withdraw previously given consent at any time, whereby the withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

16. BROWSER SETTINGS

Most modern browsers allow users to:

1. view existing cookies;
2. delete cookies;
3. block certain types of cookies;
4. block all cookies;
5. restrict third-party cookies;
6. delete cookies automatically after the browser is closed.

The way cookies are managed differs depending on the browser used.

Detailed instructions are available in the documentation of the relevant browser.

17. INTERNATIONAL DATA TRANSFERS

Certain service providers whose cookies are used on the website may process data on servers located outside the Republic of Serbia or the European Economic Area.

Where applicable, Bolutions will endeavour to use service providers that ensure an adequate level of personal data protection in accordance with the applicable regulations.

In cases where data is transferred to countries for which no adequacy decision has been adopted, such a transfer may be based on appropriate safeguards, including Standard Contractual Clauses (SCC), or on another appropriate legal basis provided for by the applicable regulations.

Further information on how Google and Meta process data is available in their privacy policies.

18. PROTECTION OF PERSONAL DATA

The use of cookies may involve the processing of certain personal data.

Such processing is carried out in accordance with:

1. the Bolutions Privacy Policy;
2. the Personal Data Processing Agreement (DPA), where applicable;
3. the applicable regulations governing personal data protection.

The cookies used on the website do not in any way affect the processing of medical records carried out through the Platform.

Data processed through the SaaS Platform is not used for marketing profiling or for the purposes of digital advertising.

19. CHANGES TO THE COOKIE POLICY

Bolutions reserves the right to amend or supplement this Policy in order to:

1. align it with changes in the applicable regulations;
2. introduce new functionalities of the website or the Platform;
3. engage new service providers;
4. improve the protection of personal data;
5. address other justified business reasons.

Every new version of the Policy will be published on the website together with the date of the last update.

Should the changes significantly affect the use of cookies, users may be asked to give new consent, where this is required by the applicable legislation.

20. CONTACT

Should users have questions relating to this Cookie Policy or to the way Bolutions uses cookies and other similar technologies, they may contact Bolutions using the contact details published on the website.

For questions relating to the processing of personal data, users may use the contact details set out in the Privacy Policy.

21. FINAL PROVISIONS

This Policy forms an integral part of the legal documentation of Bolutions and applies together with:

1. the General Terms of Use;
2. the Privacy Policy;
3. the Personal Data Processing Agreement (DPA), where applicable;
4. other documents governing the use of Bolutions' services.

In the event of any inconsistency between this Policy and mandatory regulations governing personal data protection or electronic communications, the relevant regulations will prevail.

This Policy enters into force on the date of its publication on the Bolutions website and applies from that date to all visitors to the website and users of the Platform.