Terms of Service

Mentivox Ltd (“Mentivox”, “we”, “us” or “our”) is a company registered in England and Wales under company number 17271375, incorporated on 9 June 2026 under the Companies Act 2006, with its registered office at 3 Manchester Road, Thornton-Heath, CR7 8HH, United Kingdom. Mentivox is registered with the UK Information Commissioner’s Office (“ICO”) as a data controller under reference ZC154942.

Mentivox was founded to address a problem the founders believe is under-served by existing digital products: the loneliness, emotional stress, and cultural displacement experienced by young adults, including migrants, students, and people living far from family and familiar cultural contexts. Mentivox is an AI companion application designed to check in on users proactively, to remember relevant context from earlier conversations so that interactions feel continuous rather than starting from zero each time, and to engage with cultural nuance rather than a one-size-fits-all conversational style. The product is currently aimed principally at young adults aged 18–40, but Mentivox also permits registration by younger teenagers subject to the safeguards set out in Section 3 of these Terms.

Mentivox is built, and is described throughout these Terms of Service (these “Terms”), on a simple and important premise that we ask every user to read and understand before using the Service: Mentivox is a companion, not a clinician. It does not replace therapy, counselling, psychiatric care, or any other form of professional mental health treatment. It does not diagnose conditions, does not prescribe or recommend treatment, and is not equipped to manage a mental health crisis. Section 10 of these Terms (Crisis & Emergency Disclaimer) sets out, in plain and prominent terms, what a user in crisis should do instead of relying on Mentivox, and we ask every user, and every parent or guardian consenting to a younger user’s account, to read that section with particular care.

These Terms, together with our Privacy Policy, AI Safety & Responsible Use Policy, Acceptable Use Policy, Cookie Policy, Copyright & Intellectual Property Policy, and Data Retention Policy (together, the “Policies”), form the whole of the legal agreement between Mentivox and each person who registers for or uses the Service. By creating an account, accessing, or using the Service, you agree to be legally bound by these Terms and the Policies referenced within them. If you do not agree, you must not register for or use the Service.

Mentivox is presently offered on a free-of-charge basis. No payment is currently required to access the Service, and Section 6 of these Terms explains how this will change, if at all, in the future, and what protections will apply if and when paid tiers are introduced.

1.1 What these Terms cover

These Terms govern your access to and use of the website, mobile application(s), and any other software, features, or services made available by Mentivox under the Mentivox name (together, the “Service”), including any updates, improvements, or new features we add to the Service from time to time. These Terms apply to every user of the Service, whether you access it as an individual consumer, as a parent or guardian consenting to a minor’s use of the Service, or (in the limited circumstances described in Section 6.4) as a representative of an institutional user such as a university, employer, or non-governmental organisation.

1.2 Acceptance

You accept these Terms, and they become a binding agreement between you and Mentivox, at the earliest of the following:

the point at which you tick, click, or otherwise activate an “I agree” or equivalent mechanism presented to you during account registration;

the point at which you first access or use any part of the Service, if no such explicit mechanism is presented; or

in the case of a user aged 13–17, the point at which the requirements of Section 3.3 (Parental Consent for Users Aged 13–17) have been satisfied, whichever of registration by the child or consent by the parent or guardian occurs later.

Where a parent or guardian provides consent on behalf of a child aged 13–17, both the parent or guardian and the child (to the extent the child is capable of understanding these Terms, having regard to their age and maturity) are treated as having accepted these Terms, and the parent or guardian additionally accepts the specific obligations addressed to parents and guardians throughout these Terms and the Privacy Policy.

1.3 Capacity to contract

By accepting these Terms, you confirm that:

if you are 18 years of age or older, you have the legal capacity to enter into a binding contract with Mentivox in your own right;

if you are aged 13–17, you understand that a parent or legal guardian must provide verifiable consent in accordance with Section 3.3 before your account becomes active, and that your continued use of the Service remains subject to that parent or guardian’s ability to review, restrict, or terminate your account at any time; and

all information you provide to us during registration and thereafter is true, accurate, current, and complete, and you will promptly update such information if it changes.

1.4 Relationship to the Policies

These Terms incorporate by reference, and must be read together with:

our Privacy Policy, which explains what personal data we collect, why, and how we protect it;

our AI Safety & Responsible Use Policy, which explains the nature, limitations, and safeguards of the AI systems underlying the Service;

our Acceptable Use Policy, which sets out conduct that is prohibited on the Service;

our Cookie Policy, which explains our use of cookies and similar technologies;

our Copyright & Intellectual Property Policy, which explains how we handle intellectual property rights, including third-party infringement notices; and

our Data Retention Policy, which explains how long we keep different categories of data.

Each of these Policies is available within the Service or on our website, and each forms part of the agreement between you and Mentivox as if set out in full in these Terms. Where these Terms and a Policy address the same subject in different terms, these Terms take precedence in relation to contractual matters (such as liability and termination), and the relevant Policy takes precedence in relation to its specialist subject matter (such as the specific data protection lawful bases relied upon, which are addressed in the Privacy Policy).

1.5 Changes to these Terms

We may update these Terms from time to time in accordance with Section 19 (Changes to These Terms). Your continued use of the Service after changes take effect constitutes your acceptance of the updated Terms, subject to the notice requirements in that Section.

In these Terms, the following capitalised terms have the meanings set out below, unless the context requires otherwise. Other capitalised terms are defined in the section in which they first appear.

“Acceptable Use Policy” or “AUP” means the Mentivox Acceptable Use Policy referenced in Section 9, as amended from time to time.

“Account” means the registered user profile created by or on behalf of a person to access the Service.

“AI Safety Policy” means the Mentivox AI Safety & Responsible Use Policy referenced in Section 11, as amended from time to time.

“Companion” or “AI Companion” means the conversational, AI-driven feature of the Service through which a user exchanges messages with Mentivox’s systems, including any proactive check-in messages initiated by the Service.

“Content” means any text, message, information, data, or other material.

“Institutional User” means a university, employer, non-governmental organisation, or similar body that has entered into a separate written agreement with Mentivox for institutional or aggregate-level access to the Service, as described in Section 6.4.

“Intellectual Property Rights” means all patents, patent applications, trade marks, trade names, service marks, copyrights (including rights in software), database rights, design rights, domain names, trade secrets, know-how, and any other intellectual or industrial property rights of any kind, whether registered or unregistered, and whether existing now or in the future, anywhere in the world.

“Mentivox Materials” means the Service and all software, text, graphics, logos, interface designs, trade marks, audio, video, and other content made available by Mentivox as part of the Service, excluding User Content.

“Parent or Guardian” means a person with parental responsibility for a child, within the meaning given to that term under the law of England and Wales, or the equivalent concept under the law of the jurisdiction in which the child is resident.

“Personal Data” has the meaning given to it in the UK GDPR and the Data Protection Act 2018, and, where relevant to a user resident in the EU, the meaning given to it in the EU GDPR.

“Policies” means, collectively, the Privacy Policy, AI Safety Policy, Acceptable Use Policy, Cookie Policy, Copyright & Intellectual Property Policy, and Data Retention Policy, each as amended from time to time.

“Privacy Policy” means the Mentivox Privacy Policy referenced in Section 14, as amended from time to time.

“Service” has the meaning given in Section 1.1.

“Subscription” means any paid tier of the Service that Mentivox may introduce in the future, as described in Section 6.

“UK GDPR” means the United Kingdom General Data Protection Regulation, being Regulation (EU) 2016/679 as it forms part of retained EU law and as amended, together with the Data Protection Act 2018.

“User Content” means any Content that you submit, upload, input, or otherwise provide to the Service, including messages sent to the AI Companion, profile information, and any files or text you share within the Service.

“we”, “us”, “our” means Mentivox Ltd, company number 17271375.

“you”, “your” means the individual (or, where the context requires, the Parent or Guardian acting on behalf of a child, or the authorised representative of an Institutional User) who has accepted these Terms and who registers for or uses the Service.

3.1 Minimum age

The Service is not directed at, and must not be used by, anyone under the age of 13. We have set 13 as our absolute minimum age of use, consistent with the age at which the UK GDPR permits a child to consent to information society services in their own right (see Article 8 UK GDPR and section 9 of the Data Protection Act 2018). We do not knowingly permit registration by, or knowingly collect Personal Data from, anyone under 13, and if we become aware that we have done so we will close the Account and delete the associated data promptly, as further described in our Privacy Policy and Data Retention Policy.

3.2 A deliberately more protective standard for 13–17 year-olds

Although UK data protection law would, in principle, allow a 13 to 17 year-old to consent to an information society service such as Mentivox in their own right, we have made a deliberate policy choice, going beyond what the law strictly requires, to treat every user aged 13 to 17 as requiring verifiable Parent or Guardian consent before they may use the Service. We have adopted this more protective standard because Mentivox is an emotionally sensitive product dealing with loneliness, emotional stress, and personal disclosure, and we believe that meaningful parental involvement is appropriate for younger teenagers using a product of this nature, even though the general law would not compel it. This policy may be revisited only if we conclude, following further product development and safeguarding review, that a different approach would better serve the best interests of children who use the Service, and any change of this kind would only ever move in a more protective direction, never a less protective one, without prior notice and an opportunity for existing users and their Parents or Guardians to comment.

3.3 Self-registration for users aged 18 and over

If you are 18 years of age or older, you may create an Account and accept these Terms in your own right, without requiring consent from any other person, provided you meet the other requirements of this Section 3.

3.4 Parental consent for users aged 13–17

If you are aged 13 to 17, the following process applies before your Account becomes active and before you may use any part of the Service beyond the initial age declaration and consent-collection screens:

Age declaration. At the point of registration, you will be asked to declare your date of birth or age range. Providing false information about your age is a breach of these Terms and, if discovered, will result in immediate suspension of the Account pending verification, as described in Section 3.6.

Identification of a Parent or Guardian. If you declare an age of 13 to 17, you will be asked to provide the name and a verifiable contact method (typically an email address, and in some cases a mobile number) for a Parent or Guardian.

Consent request. We will contact the identified Parent or Guardian directly, separately from the child’s own registration flow, to explain what Mentivox is, what data will be collected about the child, and to request their explicit consent to the child’s use of the Service. This communication will include a summary of the child-specific protections described in Section 3.5 and will link to the full Privacy Policy.

Verification. We will use a verification method reasonably designed to confirm that the person providing consent is in fact the child’s Parent or Guardian and is themselves an adult, which may include verified email confirmation, a short identity-assurance step, or another mechanism proportionate to the sensitivity of the data involved, consistent with ICO guidance on age assurance and parental consent under the Age Appropriate Design Code (Children’s Code).

Activation. The child’s Account will not be activated for substantive use of the Companion, and no proactive check-in messages will be sent, until verifiable Parent or Guardian consent has been received and recorded. Until that point, the Account remains in a dormant, pre-activation state.

Ongoing parental control. At any time after activation, the consenting Parent or Guardian may contact us using the details in Section 21 to (i) review a summary of the categories of data held about the child, (ii) withdraw consent and require the Account to be suspended or closed, or (iii) request deletion of the child’s data, in each case as further described in the Privacy Policy. Withdrawal of consent will result in suspension or closure of the child’s Account in accordance with Section 15.

3.5 Additional protections for accounts of users aged 13–17

Where an Account belongs to a user aged 13 to 17, and for so long as that user remains under 18, Mentivox applies the following protections, consistent with the ICO’s Age Appropriate Design Code and the best-interests-of-the-child standard that we treat as the guiding principle for all product and policy decisions affecting younger users:

High privacy by default. Privacy settings for the Account are set to the most protective configuration available by default, and the user (or their Parent or Guardian) must take a deliberate action to change any setting to a less protective configuration, to the extent we offer such configurability at all.

Data minimisation. We collect only the data reasonably necessary to provide the Service to a younger user, as described in the Privacy Policy, and we do not seek to collect additional data purely because it might be commercially useful.

No nudge techniques. We do not use design techniques intended to encourage a child to weaken their privacy protections, extend their engagement with the Service beyond what is healthy, or disclose more personal information than they otherwise would.

No profiling for marketing. We do not use a child’s data to build a marketing profile, and we do not serve targeted advertising to child Accounts (we do not currently serve targeted advertising to any user, but this commitment is stated explicitly and permanently for child Accounts regardless of any future change in our general advertising practices).

Geolocation off by default. Any geolocation functionality we may introduce in the future will default to “off” for child Accounts and will require explicit, separate Parent or Guardian consent before activation.

Parental visibility and control. The mechanisms described in Section 3.4(f) remain available throughout the period the Account belongs to a user under 18.

Best interests of the child. Where we are required to exercise judgement in the design or operation of the Service as it affects a child user, we treat the best interests of that child as a primary consideration, consistent with the standard reflected in the ICO’s Age Appropriate Design Code.

Further detail on these protections, and on the specific lawful bases and safeguards applied to children’s Personal Data, is set out in our Privacy Policy.

3.6 Age verification, misrepresentation, and consequences

We are entitled to take reasonable steps to verify a user’s declared age at any time, including where we have reason to believe an age declaration is inaccurate. If we determine, or reasonably suspect, that:

a user under 13 has registered or is using the Service, we will suspend the Account immediately and proceed to delete the associated data in accordance with our Data Retention Policy, save to the extent we are required to retain limited data to comply with a legal obligation or to investigate the circumstances of the registration;

a user aged 13–17 has registered without the Parent or Guardian consent required by Section 3.4, we will suspend the Account until consent is obtained or, if it is not obtained within a reasonable period, close the Account; or

a user has misrepresented their age in any other way, we may suspend or terminate the Account in accordance with Section 15.

3.7 Geographic and other eligibility

The Service is currently offered in the English language only, and while we welcome users from any jurisdiction, you are responsible for ensuring that your use of the Service complies with the laws applicable to you in the place where you are located, in addition to these Terms. Multilingual support is a planned future development and is not currently available.

You may not use the Service if you have previously been suspended or removed from the Service by us, unless we have given you specific written permission to re-register.

4.1 What Mentivox is

Mentivox is an AI companion application designed to support young adults, and eligible younger users under the safeguards in Section 3, who are navigating loneliness, emotional stress, or cultural displacement. The Service is centred on two core features:

Proactive check-ins. With your consent, given at the point you enable this feature, the Service may initiate outreach to you — for example, a message checking in on how you are doing — rather than waiting for you to start every conversation. You can adjust the frequency of these check-ins, or turn them off entirely, in your Account settings at any time.

Persistent conversation memory. Within the bounds described in our Privacy Policy and AI Safety Policy, the Service retains relevant context from your past conversations so that later interactions can build on what has come before, rather than each conversation starting from a blank slate. You can review, and in most cases request deletion of, this stored context at any time, as described in the Privacy Policy.

The Service is also designed with an awareness of cultural context and nuance, reflecting our founders’ belief that generic, one-size-fits-all conversational products do not serve people navigating displacement, migration, or cross-cultural life circumstances well. We describe the practical effect of this design focus — greater sensitivity to cultural context in conversation — without describing the internal mechanisms by which it is achieved, which remain confidential to Mentivox and, in part, the subject of pending patent applications as described in Section 8.

4.2 What Mentivox is not

It is essential that you understand, and that any Parent or Guardian consenting on behalf of a younger user understands, what Mentivox is not:

Mentivox is not a substitute for therapy, counselling, psychiatric treatment, or any other form of professional mental health care.

Mentivox does not diagnose any medical, psychological, or psychiatric condition.

Mentivox does not treat, cure, or prescribe medication or treatment for any condition.

Mentivox is not a crisis service and is not designed, staffed, or equipped to intervene in a mental health emergency. Section 10 sets out what you must do instead if you or someone else is in crisis.

Mentivox does not replace the judgement, advice, or care of a qualified doctor, therapist, counsellor, psychiatrist, or other licensed professional, and nothing in the Service should be read as encouraging you to delay or forgo professional care.

The Companion is an artificial intelligence system, not a human being. It does not have lived experience, does not have feelings in the way a human companion does, and its responses, however natural they may seem, are generated by software. Section 11 (AI-Specific Terms) and our AI Safety Policy address this in more detail, including our commitment to never present the Companion as human or as possessing capabilities it does not have.

4.3 Institutional and business use (planned)

Mentivox is exploring, but has not yet launched, arrangements under which institutions such as universities, employers, and non-governmental organisations could offer access to the Service to their students, staff, or beneficiaries, receiving only anonymised, aggregate-level data about usage and wellbeing trends (for example, aggregate engagement statistics), and never individual conversation content. No such institutional product is live as at the date of these Terms. If and when an institutional offering is launched, it will be governed by a separate written agreement with the relevant institution in addition to these Terms, and we will update this Section 4.3 and our Privacy Policy accordingly before any such offering goes live.

4.4 Future features

We may, at our discretion, introduce new features to the Service over time. Certain features are currently at the planning stage only and are not live as at the date of these Terms, including: passive mood tracking, an automated crisis detection and escalation protocol, expanded language support beyond English, a directory of third-party therapist referrals, and elderly-focused voice or video interaction. We mention these planned developments so that you understand the direction of the product, but you should not rely on any of them being available, and nothing in these Terms obliges us to build or launch any particular feature by any particular date. We will update these Terms and the relevant Policies before any such feature becomes live, particularly the AI Safety Policy in the case of any future crisis detection and escalation functionality.

4.5 Availability of the Service

We aim to make the Service available continuously, but we do not guarantee uninterrupted availability. Section 13 (Disclaimers of Warranties) and Section 17.6 (Force Majeure) address service interruptions in more detail.

4.6 Currently English-only

The Service is currently available in English only. We recognise that a meaningful proportion of the people Mentivox is designed to help — young adults navigating cultural displacement — may be more comfortable expressing themselves in a language other than English, and expanded language support is part of our product roadmap. However, no multilingual functionality is live as at the date of these Terms, and you should not register for or rely on the Service if you require support in a language other than English. We will update these Terms, and give appropriate notice, before launching support for any additional language.

4.7 How the Service is not a monitoring or surveillance tool

Mentivox is designed to be a companion that you choose to engage with, not a passive monitoring or surveillance tool operating in the background of your life. Save for the proactive check-in feature described in Section 4.1(a), which you must affirmatively opt into and can disable at any time, the Service does not observe, log, or act upon your activity outside the app, and does not access data from other applications on your device unless you explicitly connect such a data source in the future and separately consent to that connection. Any future passive mood-tracking feature referenced in Section 4.4 would, if and when built, be opt-in, clearly explained, and subject to its own consent flow and update to these Terms and the Privacy Policy before launch.

4.8 Cultural intelligence and non-discrimination

One of the design goals of the Service is to respond with sensitivity to the cultural background and context a user brings to a conversation, rather than treating every user identically regardless of their circumstances. We describe this as a design goal and an outcome we work towards, not as a guarantee that every response will always reflect perfect cultural understanding — as explained in Section 10 (AI-Specific Terms), AI-generated responses can be inconsistent or imperfect. This cultural sensitivity focus operates alongside, and does not diminish, our broader non-discrimination commitments described in our AI Safety Policy, under which the Service must not produce outputs that demean, stereotype, or discriminate against any user or group on the basis of a protected characteristic or cultural background.

5.1 Creating an Account

To use the substantive features of the Service, you must register for an Account by providing the information requested during the sign-up process, which will typically include your name, email address, and date of birth or age declaration, and, where applicable, the Parent or Guardian information required by Section 3.4.

5.2 Accuracy of information

You agree to provide accurate, current, and complete information when creating your Account and to keep that information up to date. You must not create an Account using a false identity, impersonate any other person, or create an Account on behalf of another person without their knowledge and authorisation (except where a Parent or Guardian is lawfully creating or consenting to an Account on behalf of a child in accordance with Section 3.4).

5.3 One Account per person

You may maintain only one Account, save where we have given specific written permission for additional Accounts (for example, in a future institutional context). If we discover duplicate Accounts, we may merge, suspend, or close them.

5.4 Account security

You are responsible for maintaining the confidentiality of your Account credentials and for all activity that occurs under your Account. You agree to:

use a strong, unique password or authentication method for your Account;

notify us immediately at the contact details in Section 21 if you become aware of any unauthorised access to, or use of, your Account, or any other breach of security;

not share your Account credentials with any other person; and

log out of, or otherwise secure, your Account on any shared or public device.

We are not liable for any loss or damage arising from your failure to comply with this Section 5.4, save to the extent such liability cannot be excluded under Section 16 (Limitation of Liability).

5.5 Parental access to a child’s Account

Where an Account belongs to a user aged 13–17, the consenting Parent or Guardian may request certain access and controls in relation to that Account as described in Section 3.4(f) and in our Privacy Policy. This does not mean the Parent or Guardian has open, real-time access to the substantive content of the child’s conversations by default; rather, it means the Parent or Guardian may request a review of the categories of data held, request deletion, or withdraw consent, each of which we will action in accordance with the relevant Policy and applicable law.

5.6 Suspicious activity

We reserve the right to require additional verification, or to temporarily suspend an Account, where we detect activity that appears inconsistent with genuine personal use of the Service, is suspicious, or otherwise raises a concern about security, fraud, or breach of these Terms or the Acceptable Use Policy. We will act reasonably and proportionately in exercising this right and, save where legally prohibited or where doing so would frustrate a legitimate security or safeguarding purpose, will notify you of any such action and the reason for it.

6.1 Current status: free of charge

As at the Effective Date of these Terms, Mentivox is provided entirely free of charge. There is no paid tier of the Service currently available, and you are not required to provide payment card details or any other payment method to register for or use the Service.

6.2 Future paid tiers: placeholder framework

We may, at some point in the future, introduce one or more paid subscription tiers of the Service (“Subscriptions”), offering additional or enhanced features beyond those available free of charge. This Section 6.2 sets out, in advance, the framework of protections and commitments that will apply if and when we do so. It is not, and must not be read as, a description of live billing terms, since no Subscription is currently available.

If we introduce a Subscription in the future, we commit that, before requiring any payment from you:

we will provide clear pre-contract information required by the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, including the total price, the main characteristics of the paid features, the duration of the contract, and cancellation rights, presented in a durable and accessible format before you commit to pay;

where you are a consumer contracting at a distance (which will ordinarily be the case, since the Service is provided online), you will have a statutory cooling-off period of 14 days from the date the Subscription contract is formed, during which you may cancel for any reason and receive a full refund of amounts paid for the cancelled period, save to the extent you have already made active use of premium features during that period and have been clearly informed, and have expressly consented, that your right to cancel will be lost or reduced as a result of that early use, in accordance with the Consumer Contracts Regulations 2013;

we will clearly state pricing in pounds sterling (£), including any recurring billing frequency, and will give reasonable advance notice (of no less than 30 days) of any price increase to an existing Subscription, together with a right to cancel before the increase takes effect;

we will update these Terms, and issue a dedicated Subscription Terms document if appropriate, with full billing mechanics (including renewal, cancellation, refund, and failed-payment handling) before any Subscription becomes live, and will require fresh, explicit acceptance of those terms from any user who chooses to subscribe; and

free-tier functionality that exists at the time a Subscription is introduced will not be withdrawn from existing free-tier users solely as a means of compelling an upgrade, save where we are discontinuing a feature for all users, including paying users, for a genuine product, safety, legal, or technical reason.

6.3 No live billing terms today

Because there is no Subscription available today, this Section 6 does not create any payment obligation for you, and no provision of these Terms should be read as authorising us to charge you for the Service unless and until a Subscription is introduced and you have separately and expressly agreed to it in accordance with Section 6.2.

6.4 Institutional pricing (planned)

Any future institutional or B2B arrangement of the kind described in Section 4.3 will be priced and contracted separately with the relevant institution and will not affect the free availability of the consumer Service to individual users, unless expressly agreed otherwise in that separate arrangement.

7.1 Ownership of your User Content

As between you and Mentivox, you retain ownership of the Intellectual Property Rights (if any) in the User Content you submit to the Service, including the messages you send to the Companion. We do not claim ownership of your User Content.

7.2 Licence you grant to us

By submitting User Content to the Service, you grant Mentivox a worldwide, non-exclusive, royalty-free, sublicensable (only to our sub-processors engaged to help operate the Service, such as our data-hosting provider) licence to store, process, reproduce, and use your User Content solely for the following purposes:

providing, operating, maintaining, and improving the Service for you, including generating Companion responses, retaining relevant conversational context as described in Section 4.1(b), and delivering proactive check-ins you have opted into;

safeguarding the Service, including detecting and preventing abuse, fraud, or breaches of the Acceptable Use Policy;

complying with our legal obligations, including responding to lawful requests as described in our Law Enforcement Requests Policy; and

where you have given separate, specific consent (which is never bundled into these Terms and can be withdrawn at any time), improving our AI systems more generally, as described in our AI Safety Policy and Privacy Policy.

This licence is granted for so long as we hold your User Content in accordance with our Data Retention Policy, and terminates (save for any residual copies retained lawfully, for example in backups pending deletion, or as required by law) when that User Content is deleted.

7.3 No resale or commercial exploitation of your content

We will not sell your User Content, and we will not share the substantive content of your conversations with third parties for commercial purposes, including for advertising or marketing purposes. This commitment is described in more detail in our Privacy Policy, and nothing in this Section 7 or elsewhere in these Terms authorises any different use.

7.4 Your responsibility for User Content

You are solely responsible for the User Content you submit. By submitting User Content, you represent that:

you have all necessary rights to submit it and to grant the licence in Section 7.2;

it does not infringe the Intellectual Property Rights, privacy rights, or other rights of any third party;

it complies with the Acceptable Use Policy; and

it does not contain unlawful material.

We do not pre-screen User Content before it is processed by the Companion, but we may take the actions described in Section 9 (Acceptable Use) and Section 15 (Termination & Suspension) where User Content breaches these Terms or the Acceptable Use Policy.

7.5 Nature of conversational memory

As described in Section 4.1(b), the Service may retain relevant context from your past conversations to inform later interactions. You may review and request deletion of specific pieces of this retained context, or request deletion of your entire conversation history, through your Account settings or by contacting us using the details in Section 21, subject to the retention and deletion mechanics described in our Data Retention Policy and Privacy Policy.

7.6 Feedback

If you choose to send us feedback, suggestions, or ideas about the Service, you grant us an unrestricted, royalty-free, perpetual licence to use that feedback for any purpose, without any obligation to compensate or credit you, and without this being treated as User Content for the purposes of Sections 7.1 to 7.3 (since feedback about the Service, as opposed to your personal conversational content, is treated as a contribution to product development rather than personal conversational content).

8.1 Mentivox’s Intellectual Property Rights

The Service, including the Mentivox Materials, is protected by copyright, trade mark, and other Intellectual Property Rights owned by or licensed to Mentivox. Save for the limited rights expressly granted to you in Section 8.2, we and our licensors reserve all right, title, and interest in and to the Service and the Mentivox Materials.

8.2 Licence to use the Service

Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-transferable, revocable licence to access and use the Service for your own personal, non-commercial use. This licence does not permit you to:

copy, modify, or create derivative works of the Service or the Mentivox Materials;

distribute, sell, lease, sublicense, or otherwise make the Service available to any third party;

use the Service for any commercial purpose without our prior written consent; or

remove, obscure, or alter any proprietary notice on the Service.

8.3 Trade marks

“Mentivox” and associated names, logos, and marks are trade marks of Mentivox Ltd (registered, pending registration, or protected under the law of passing off, as applicable). You may not use our trade marks without our prior written consent, save for accurate, non-misleading factual reference to the Service (for example, in a review or article).

8.4 Patent-pending notice

Mentivox has made, and may continue to make, applications for patent protection in respect of certain innovations underlying aspects of the Service. Where a feature or aspect of the Service is the subject of a pending patent application, we may mark it as “patent pending” or similar, and you acknowledge that such a marking does not constitute a representation as to the scope, validity, or eventual grant of any patent. We do not publicly disclose the technical detail of pending or contemplated patent applications, and nothing in these Terms, the Service, or any other Mentivox communication should be read as such a disclosure. No provision of these Terms grants you any licence, express or implied, under any patent or patent application owned by or licensed to Mentivox, beyond the limited right to use the Service as provided in Section 8.2.

8.5 No reverse engineering

You must not, and must not permit or assist any third party to, reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code, underlying ideas, algorithms, structure, or organisation of the Service, except to the limited extent such restriction is prohibited by applicable law. This includes attempting to extract, infer, or reconstruct the design, configuration, or operating logic of the AI systems underlying the Service, whether through technical means, systematic prompting, or any other method. This restriction exists to protect Mentivox’s confidential and patent-pending innovations, and breach of this Section 8.5 is treated as a serious breach of these Terms and of the Acceptable Use Policy, which sets out further detail on prohibited attempts to extract system information from the Companion.

8.6 Copyright and takedown

Complaints about alleged infringement of Intellectual Property Rights by material on the Service are handled under our Copyright & Intellectual Property Policy, which sets out our notice-and-takedown procedure under the framework of the Copyright, Designs and Patents Act 1988.

9.1 Incorporation of the Acceptable Use Policy

Your use of the Service is subject to our Acceptable Use Policy, which sets out in detail the conduct that is prohibited on the Service. The Acceptable Use Policy is incorporated into, and forms part of, these Terms.

9.2 Summary of key prohibitions

Without limiting the full terms of the Acceptable Use Policy, you must not use the Service to:

engage in unlawful activity or encourage others to do so;

harass, abuse, threaten, or attempt to manipulate the Companion into producing harmful, unlawful, or policy-violating outputs, including through adversarial prompting or “jailbreak” attempts;

attempt to extract, reconstruct, or infer Mentivox’s system prompts, model configuration, training data, or other confidential or patent-pending technical information, as further addressed in Section 8.5;

impersonate any person or entity, or misrepresent your affiliation with any person or entity;

upload or transmit unlawful, defamatory, obscene, or otherwise objectionable Content;

use automated means (bots, scrapers, or similar) to access the Service other than through officially supported interfaces;

resell, sublicense, or otherwise commercially exploit access to the Service; or

use the Service in any way that harms, or risks harming, a minor.

9.3 Consequences of breach

Breach of the Acceptable Use Policy or this Section 9 may result in warning, suspension, or termination of your Account in accordance with Section 15, and, where the breach involves unlawful conduct, may be reported to the relevant authorities in accordance with our Law Enforcement Requests Policy.

9.4 Reporting concerns about another user or about the Service

Because the Service is a one-to-one product between you and the Companion, rather than a multi-user platform, most acceptable-use concerns will relate to your own use of the Service rather than the conduct of other users. However, if you become aware of a security vulnerability, a way in which the Service could be misused to harm a minor, or any other conduct or technical issue that concerns you, we encourage you to report it promptly through the incident reporting and feedback channel described in our AI Safety Policy. We take such reports seriously and will investigate them in accordance with the governance process described in that Policy.

9.5 Enforcement is not a substitute for the Crisis & Emergency Disclaimer

Where enforcement action under this Section 9 is taken in response to Content that indicates a risk to your own safety or the safety of another person, that enforcement action (such as a message declining to engage, or an Account restriction) is not, and must never be understood as, a crisis intervention or safety response. Section 11 (Crisis & Emergency Disclaimer) governs what you should do in that situation, and nothing in this Section 9 qualifies or reduces the honesty of the disclosures made in Section 11.

10.1 Nature of the Companion

The Companion is powered by artificial intelligence systems operated by Mentivox. Responses generated by the Companion are produced algorithmically, on the basis of patterns learned from data and the context of your conversation, and are not the product of human review of each individual message before it is sent to you. Our AI Safety Policy describes, in outcome-focused terms, the design principles, limitations, and safeguards that apply to the Companion, and is incorporated into these Terms by this reference.

10.2 No guarantee of accuracy

AI-generated content, including everything the Companion says to you, may be inaccurate, incomplete, out of date, or simply wrong. AI systems, including the one underlying the Companion, are known to occasionally produce plausible-sounding but false statements (sometimes called “hallucinations”), to misunderstand context, and to respond inconsistently to similar prompts. You must not treat anything the Companion says as guaranteed to be accurate, and you should exercise your own judgement, and where appropriate seek independent verification or professional advice, before relying on anything the Companion tells you.

10.3 Not professional advice

Nothing the Companion says constitutes medical, psychological, psychiatric, legal, financial, or other professional advice, even if phrased in a way that resembles such advice. The Companion is not a licensed professional in any field and cannot take on the responsibilities of one. If you are seeking medical, mental health, legal, or financial advice, you should consult an appropriately qualified and licensed professional.

10.4 The Companion does not replace human relationships or professional care

While the Companion is designed to be warm, attentive, and responsive to cultural context, it is not a substitute for human relationships, community, or professional care, including the mental health care addressed in Section 10.6 and our AI Safety Policy. We encourage you to maintain and build real-world relationships and, where appropriate, to seek professional support in addition to, not instead of, using the Service.

10.5 Transparency: you are speaking with an AI

We will not represent the Companion as a human being, and we will not use deceptive means to make you believe you are speaking with a person when you are not. If you are ever unsure whether you are interacting with the Companion or a human representative of Mentivox (for example, in customer support), we will make this clear on request.

10.6 Cross-reference to Crisis & Emergency Disclaimer

Section 11 and our AI Safety Policy set out, in detail and in plain language, the honest and important limits of the Companion’s ability to respond to a mental health crisis. You must read that section, and we ask that you do so now if you have not already, particularly if you or someone you know may be at risk.

10.7 Changes to the Companion’s behaviour

We may update, retrain, adjust, or otherwise change the behaviour of the Companion over time, including to improve safety, accuracy, or the quality of responses. We do not guarantee that the Companion’s responses will remain consistent over time or that any particular past behaviour will be replicated in future interactions.

11.1 This is not a crisis service

Mentivox is not a crisis service, is not a substitute for emergency medical or psychiatric care, and must never be relied upon in a mental health emergency. If you are experiencing suicidal thoughts, thoughts of self-harm, or any other mental health emergency, or if you are concerned about the immediate safety of yourself or another person, do not rely on the Companion. Instead, please contact one of the following resources immediately:

If you are in the United Kingdom: - Samaritans — call 116 123, free, 24 hours a day, 7 days a week, or email jo@samaritans.org. - Emergency services — call 999 if there is an immediate risk to life. - NHS 111 — call 111 for urgent (but non-life-threatening) medical or mental health advice.

If you are in Nigeria: - Contact Nigeria’s national emergency services, or the Nigeria Suicide Prevention Initiative or another relevant national mental health helpline available to you. We do not publish a specific Nigerian crisis line number within this document because we are not able to independently verify the continued accuracy of a specific number at all times, and we do not wish to direct you to an outdated or incorrect number in an emergency; please use your device’s emergency dialling function or search for the current national emergency number if you are unsure.

If you are elsewhere in the world: - Contact your local emergency services number. - The 988 Suicide & Crisis Lifeline is available by call or text in the United States. - findahelpline.com and Befrienders Worldwide (befrienders.org) maintain directories of crisis lines by country and are a good starting point if you are unsure what is available where you are.

11.2 What the Companion currently does, and does not do, if you mention crisis or self-harm

We want to be completely honest with you about the current limits of the Service, because your safety matters more to us than presenting the product in the best possible light. As at the date of these Terms:

if a message you send indicates that you may be experiencing suicidal ideation, self-harm, or another acute crisis, the Companion is designed to decline to engage substantively with that content — it will not attempt to counsel you through the crisis, provide crisis intervention, or offer clinical guidance;

the Service does not currently perform any automated escalation of such messages to emergency services, to a human moderator at Mentivox, or to a next-of-kin or emergency contact; there is, as at the date of these Terms, no human being who is automatically alerted when you send such a message; and

the Companion’s refusal response does not currently, by default, surface the crisis-line information listed in Section 11.1 within the chat itself. We are telling you this candidly, and separately signposting that information here and throughout the AI Safety Policy, precisely because the in-product signposting does not yet exist as a live feature.

We consider strengthening our in-product crisis-resource signposting, so that this information is presented automatically within the app at the point a crisis-related message is detected, to be a near-term product priority, and this commitment is repeated and expanded upon in our AI Safety Policy under “Continuous Improvement.” However, until any such feature is built, tested, and live, you must not assume that the Service will proactively provide you with crisis-line information, and you must independently know, and if necessary act upon, the information in Section 11.1.

11.3 Planned future development

A more structured crisis-detection-and-escalation protocol is on our long-term product roadmap but is not currently live. We mention it so you understand our direction of travel, not so that you rely on it as a present safeguard. If and when such a protocol is built and made live, we will update these Terms, the AI Safety Policy, and the Privacy Policy accordingly, and we will be clear and specific about exactly what the feature does and does not do, to avoid any risk of a user believing more protection is in place than actually is.

11.4 Your acknowledgement

By using the Service, you acknowledge and accept that:

the Companion is not able to provide crisis intervention;

you are solely responsible for seeking appropriate emergency help for yourself or others when needed, using the resources in Section 11.1 or your own local equivalent; and

Mentivox’s liability in connection with any crisis, emergency, self-harm, or safety-related outcome is addressed in Section 16 (Limitation of Liability), subject always to the non-excludable carve-outs described in that Section for death or personal injury caused by our negligence and for fraud.

12.1 Third-party links and integrations

The Service may, from time to time, contain links to third-party websites, resources, or services (for example, a link to Samaritans or another crisis resource as described in Section 11, or a future therapist referral directory as described in Section 4.4). We provide such links for your convenience and do not endorse, and are not responsible for, the content, accuracy, policies, or practices of any third-party website or service.

12.2 Sub-processors

We use a limited number of third-party infrastructure providers, described in our Privacy Policy as sub-processors, to help us operate the Service — for example, our data-hosting provider, Supabase, which stores data in the EU (Ireland) region. Our use of sub-processors, and our commitments regarding data protection agreements with them, is described fully in the Privacy Policy and is not repeated in full here.

12.3 No third-party AI model providers

As a matter of design choice which we consider relevant to your privacy, conversational processing for the Companion takes place on infrastructure operated by Mentivox, using AI systems that are self-hosted by Mentivox, rather than being routed through third-party AI model providers. Further detail, framed around outcome rather than technical architecture (consistent with our confidentiality obligations regarding pending patent applications), is provided in our Privacy Policy and AI Safety Policy.

12.4 No liability for third-party services

Save as expressly stated in these Terms or required by law, we are not responsible for any loss or damage arising from your use of, or reliance on, any third-party website, resource, or service linked from or referenced within the Service.

12.5 No current payment processors, analytics, or email providers

Because the Service is currently free of charge, we do not currently engage a third-party payment processor. We also do not currently rely on a named third-party analytics provider or a dedicated third-party transactional email provider beyond what is necessary for basic account administration. If and when we introduce such providers — for example, a payment processor ahead of any paid Subscription tier described in Section 6, or an analytics provider to help us understand aggregate usage of the Service — we will update our Privacy Policy and our sub-processor list to name that provider, explain its role, and confirm the data protection safeguards that apply to it, consistent with the sub-processor commitments described in the Privacy Policy, before that provider begins processing your data.

12.6 Future institutional integrations

If the institutional and B2B arrangements described in Section 4.3 are launched in the future, they may involve limited technical integration with systems operated by the relevant university, employer, or non-governmental organisation (for example, to facilitate access for eligible students, staff, or beneficiaries). Any such integration will be addressed in the separate written agreement with the relevant institution referenced in Section 4.3, and will not result in the institution receiving individual conversation content, consistent with the anonymised, aggregate-only data model described in that Section.

13.1 Cross-reference to the Privacy Policy

Our collection, use, storage, and protection of your Personal Data is governed by our Privacy Policy, which forms part of these Terms by reference. The Privacy Policy explains, among other things: what categories of data we collect (including special category data such as inferences about mental or emotional wellbeing); the lawful bases on which we process your data under the UK GDPR; how long we retain different categories of data; who we share data with (including our sub-processor, Supabase, hosted in the EU (Ireland) region); the international transfer mechanisms that apply to UK, EU, and Nigerian users; your rights as a data subject; and how to contact us about privacy matters.

13.2 Headline commitments

Without limiting the fuller detail in the Privacy Policy, we confirm that:

we do not sell your Personal Data;

we do not share the substantive content of your conversations with third parties for commercial purposes; and

we do not use your data to profile you for marketing purposes.

13.3 Children’s data

Where you are the Parent or Guardian of a user aged 13–17, or where you are yourself a user in that age range, the Privacy Policy contains a dedicated section on children’s data explaining how the protections described in Section 3.5 of these Terms are implemented in practice.

14.1 Your right to close your Account

You may close your Account at any time, using the account-deletion function within the Service or by contacting us at the details in Section 21. Where you are the Parent or Guardian of a child user, you may close the child’s Account in the same way, or by withdrawing consent as described in Section 3.4(f).

14.2 Our right to suspend or terminate

We may suspend or terminate your Account, or restrict your access to particular features of the Service, where:

you breach these Terms, the Acceptable Use Policy, or any other Policy;

we reasonably believe your continued use of the Service poses a risk to Mentivox, other users, or any third party;

required to do so by law, regulation, or a valid order of a court or regulator;

we discover that eligibility requirements in Section 3 have not been met (for example, a user under 13, or a 13–17 year-old without valid parental consent); or

we decide, in our reasonable commercial discretion, to discontinue the Service in whole or in part, in which case Section 14.4 applies.

14.3 Process

Save where immediate suspension is necessary for safety, security, or legal reasons, we will give you reasonable notice of an intended suspension or termination and an opportunity to remedy the underlying issue, where remediable. Where we terminate your Account other than for your breach of these Terms, we will use reasonable efforts to give you the opportunity to export a copy of your User Content, to the extent technically feasible, before final deletion.

14.4 Discontinuation of the Service

If we decide to discontinue the Service in its entirety, we will give you at least 30 days’ advance notice where reasonably possible, save where earlier discontinuation is required by law or by circumstances outside our reasonable control.

14.5 Effect of termination

On termination or closure of your Account:

your right to access and use the Service ends immediately;

your User Content will be deleted in accordance with our Data Retention Policy, save to the extent we are permitted or required to retain limited data (for example, for legal, regulatory, fraud-prevention, or dispute-resolution purposes); and

any provision of these Terms which by its nature should survive termination (including, without limitation, Sections 8, 13, 15, 16, 17, and 18) will survive.

15.1 Service provided “as is”

To the maximum extent permitted by applicable law, and subject always to Section 15.3, the Service is provided on an “as is” and “as available” basis, without warranties of any kind, whether express, implied, or statutory, including implied warranties of satisfactory quality, fitness for a particular purpose, and non-infringement.

15.2 No warranty as to specific outcomes

Without limiting the generality of Section 15.1, we do not warrant that:

the Service will meet your individual requirements or expectations;

the Service will be uninterrupted, timely, secure, or error-free;

any AI-generated response will be accurate, complete, or suitable for any particular purpose, as further addressed in Section 10;

use of the Service will produce any particular emotional, psychological, or wellbeing outcome; or

any defect in the Service will be corrected.

15.3 Statutory rights preserved

Nothing in this Section 15 excludes or limits any warranty, condition, right, or liability which may not lawfully be excluded or limited, including your statutory rights under the Consumer Rights Act 2015 in respect of digital content and services supplied with reasonable care and skill. Where the Consumer Rights Act 2015 implies a term into your contract with us that cannot lawfully be excluded, that term applies, and this Section 15 must be read subject to it.

16.1 Purpose of this Section

This Section 16 sets out the full extent of Mentivox’s liability, and your sole and exclusive remedies, in connection with the Service, these Terms, and your use of the Service. It should be read together with Section 15 (Disclaimers of Warranties) and Section 11 (Crisis & Emergency Disclaimer). Nothing in this Section 16 is intended to exclude or limit liability that cannot lawfully be excluded or limited, and Section 16.2 takes precedence over every other provision of this Section 16 in the event of any conflict.

16.2 Liability that is never excluded or limited (mandatory carve-outs)

Nothing in these Terms excludes or limits, in any way, Mentivox’s liability for:

death or personal injury caused by our negligence, or the negligence of our employees, agents, or sub-contractors, which cannot be excluded or limited under the Unfair Contract Terms Act 1977 or the Consumer Rights Act 2015;

fraud or fraudulent misrepresentation, by us or on our behalf;

any breach of the obligations implied by section 2 of the Supply of Goods and Services Act 1982 or Part 1 of the Consumer Rights Act 2015 (title and quiet possession, and equivalent protections for digital content and services), to the extent those obligations cannot lawfully be excluded or limited; and

any other liability which cannot lawfully be excluded or limited under the law of England and Wales, including under the Consumer Rights Act 2015 (in particular, the requirement that contract terms be fair and transparent, under Part 2 of that Act) and the Unfair Contract Terms Act 1977.

If any provision of this Section 16 would otherwise purport to exclude or limit liability described in this Section 16.2, that provision is void and of no effect to that extent, but the remainder of this Section 16 continues in full force.

16.3 General exclusions (subject always to Section 16.2)

Subject always to Section 16.2, and to the extent permitted by applicable law, Mentivox excludes all liability for:

any loss arising from your reliance on AI-generated output or Companion responses, including any inaccurate, incomplete, or unsuitable response, as described in Section 10;

indirect, special, or consequential loss, including loss of profits, loss of business, loss of anticipated savings, or loss of opportunity, in each case whether arising in contract, tort (including negligence), or otherwise;

loss of data, including User Content, save to the extent caused by our failure to comply with our security obligations described in the Privacy Policy;

emotional or psychological outcomes arising from your use of, or inability to use, the Service, including any outcome connected to the limitations described in Section 11 (Crisis & Emergency Disclaimer), save to the extent such an outcome amounts to personal injury caused by our negligence, which falls within the non-excludable carve-out in Section 16.2(a);

any Content posted or provided by a third party, including any third-party website linked from the Service; and

any interruption, suspension, or discontinuation of the Service, including as described in Section 14.

16.4 Cap on liability

Subject always to Section 16.2, our total aggregate liability to you in connection with these Terms and the Service, whether arising in contract, tort (including negligence), breach of statutory duty, or otherwise, is limited to the greater of:

the total fees you have paid to us for the Service in the 12 months immediately preceding the event giving rise to the claim (which, for so long as the Service remains free of charge, will ordinarily be nil); or

£100 (one hundred pounds sterling).

We consider this cap reasonable having regard to the fact that the Service is currently provided free of charge, that the nominal sum in Section 16.4(b) ensures a meaningful remedy remains available even where you have paid nothing, and that the mandatory carve-outs in Section 16.2 ensure that our most serious potential liabilities — for death, personal injury caused by negligence, and fraud — are never capped or excluded at all.

16.5 Statutory rights and fairness

Nothing in these Terms affects your statutory rights as a consumer, including your rights under the Consumer Rights Act 2015. We have sought to draft this Section 16 fairly and transparently, as required by Part 2 of the Consumer Rights Act 2015, and if any part of this Section 16 is found by a court or regulator to be unfair or unenforceable as against a consumer, that part will not apply to the extent of the unfairness, and the remainder of these Terms will continue to apply.

16.6 Basis of the bargain

You acknowledge that the limitations and exclusions in this Section 16, together with the disclaimers in Section 15, reflect a reasonable allocation of risk between you and Mentivox given the nature of the Service (an AI companion product, not a professional or clinical service) and the fact that it is currently provided free of charge, and that we would not be able to offer the Service on its current terms without these limitations.

17.1 Your indemnity to us

To the extent permitted by applicable law, you agree to indemnify and hold Mentivox, its officers, directors, employees, and agents harmless from and against any claims, liabilities, damages, losses, and expenses, including reasonable legal fees, arising out of or in any way connected with:

your breach of these Terms or any Policy;

your User Content, including any claim that it infringes the rights of a third party;

your violation of any applicable law; or

your negligent or wrongful conduct in connection with the Service.

17.2 Limits on the indemnity

This indemnity does not apply to the extent a claim arises from Mentivox’s own breach of these Terms, negligence, or wilful misconduct, and nothing in this Section 17 requires you to indemnify us for a liability that could not lawfully be imposed on you as a consumer under the Consumer Rights Act 2015 or other applicable consumer protection law. Where you are a consumer, this Section 17 will be interpreted and applied so as not to cause a significant imbalance in the parties’ rights and obligations to your detriment, contrary to Part 2 of the Consumer Rights Act 2015.

17.3 Process

We will give you prompt notice of any claim subject to this indemnity, and you will have the opportunity to participate in the defence of that claim at your own expense, save that we retain the right to control the defence and settlement of any claim that affects our Intellectual Property Rights or our ability to operate the Service.

18.1 Governing law

These Terms, and any dispute or claim arising out of or in connection with them or their subject matter (including non-contractual disputes or claims), are governed by, and construed in accordance with, the law of England and Wales.

18.2 Jurisdiction

Subject to Section 18.3, you and Mentivox each irrevocably agree that the courts of England and Wales have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with these Terms or their subject matter.

18.3 Saving clause for mandatory consumer protections

If you are a consumer resident in Scotland, Northern Ireland, another part of the United Kingdom, or in the European Union, nothing in Section 18.2 removes any right you may have under mandatory consumer protection law to bring proceedings in the courts of the country in which you are resident, and nothing in Section 18.1 deprives you of the protection of any mandatory provisions of the law of the country in which you are resident, where applicable law grants you such rights. This Section 18.3 is a saving clause only, intended to preserve rights you cannot lawfully be asked to give up, and does not itself confer additional rights beyond those already available to you under applicable law.

18.4 Informal resolution encouraged

Before commencing formal proceedings, we encourage you to contact us using the details in Section 21 so that we can try to resolve any concern informally. We aim to acknowledge complaints promptly and to work with you in good faith to find a resolution.

18.5 No arbitration requirement

We do not require you to submit disputes to binding arbitration, and nothing in these Terms prevents you from bringing a claim before the courts identified in this Section 18, subject to Section 18.3.

19.1 Our right to make changes

We may update these Terms from time to time to reflect changes in the Service, our practices, or applicable law, or for other legitimate business reasons, including the introduction of a paid Subscription tier as described in Section 6.

19.2 Notice of changes

Where we make a material change to these Terms, we will provide notice by at least one of the following methods, at our discretion, no less than 14 days before the change takes effect (save where a shorter period is required to comply with law or to address an urgent safety or security issue, in which case we will give as much notice as is reasonably practicable): (a) an in-app or email notification; (b) a prominent notice on the Service; or (c) an updated “Last Updated” date on this document together with a summary of the material changes made.

19.3 Effect of continued use

Your continued use of the Service after a change to these Terms takes effect constitutes your acceptance of the updated Terms. If you do not agree to a material change, you should stop using the Service and close your Account before the change takes effect, and, if the Service is or has become a paid Subscription for you at that point, you may exercise any applicable cancellation rights described in Section 6.2.

19.4 Changes affecting children’s accounts

Where a material change to these Terms affects a user aged 13–17, we will also take reasonable steps to notify the consenting Parent or Guardian, using the contact details provided under Section 3.4, in addition to the notice given under Section 19.2.

20.1 Entire agreement

These Terms, together with the Policies incorporated by reference, constitute the entire agreement between you and Mentivox in relation to the Service, and supersede all prior agreements, representations, and understandings, whether written or oral, relating to the same subject matter, save for any separate written agreement entered into between you (or, where relevant, an Institutional User) and Mentivox that expressly states it varies or supplements these Terms.

20.2 Severability

If any provision of these Terms is found by a court or regulator of competent jurisdiction to be invalid, illegal, or unenforceable, that provision will be deemed modified to the minimum extent necessary to make it valid, legal, and enforceable, or, if it cannot be so modified, will be severed, and the remaining provisions of these Terms will continue in full force and effect.

20.3 No waiver

No failure or delay by either party in exercising any right under these Terms will operate as a waiver of that right, nor will any single or partial exercise of a right preclude any other or further exercise of that right or the exercise of any other right. A waiver of any breach of these Terms will not be treated as a waiver of any subsequent breach.

20.4 Assignment

You may not assign, transfer, or sub-contract any of your rights or obligations under these Terms without our prior written consent. We may assign, transfer, or sub-contract our rights or obligations under these Terms, including in connection with a merger, acquisition, corporate reorganisation, or sale of assets, provided that any assignee agrees to be bound by these Terms and, in the case of any change affecting the entity acting as data controller of your Personal Data, we will notify you in accordance with our Privacy Policy.

20.5 Notices

Notices to you under these Terms may be given by email to the address associated with your Account, by an in-app notification, or by a prominent notice on the Service. Notices to us should be sent to the contact details in Section 21. Notices are deemed received: if sent by email, on the next business day after sending; if given by in-app or on-service notification, when posted.

20.6 Force majeure

Neither party will be liable for any failure or delay in performing its obligations under these Terms (other than a payment obligation, once a Subscription is live) to the extent that such failure or delay is caused by circumstances beyond that party’s reasonable control, including acts of God, war, terrorism, civil unrest, industrial action, failure of a public utility or telecommunications network, or a widespread failure of internet infrastructure, provided that the affected party uses reasonable efforts to mitigate the effect of the relevant event and to resume performance as soon as reasonably possible.

20.7 No partnership or agency

Nothing in these Terms creates a partnership, joint venture, agency, or employment relationship between you and Mentivox.

20.8 Third-party rights

Save as expressly stated (including in relation to a Parent or Guardian’s rights described in Section 3), a person who is not a party to these Terms has no right, under the Contracts (Rights of Third Parties) Act 1999 or otherwise, to enforce any term of these Terms.

20.9 Confidentiality

Each party agrees to keep confidential any non-public information disclosed by the other party in connection with the Service that is designated as confidential or would reasonably be understood to be confidential given its nature, including, in Mentivox’s case, information relating to its technology, product roadmap, and pending patent applications referenced in Section 8.4, and, in your case, your own Account information and User Content. This Section 20.9 does not restrict either party’s ability to comply with a legal obligation to disclose information, including our obligations described in our Law Enforcement Requests Policy.

20.10 Language

These Terms are drafted in English. Any translation provided is for convenience only, and the English-language version prevails in the event of any inconsistency.

20.11 Interpretation

Headings in these Terms are for convenience only and do not affect interpretation. References to “including” mean “including without limitation.” References to statutes include any amendment, re-enactment, or replacement of that statute from time to time.

If you have any questions about these Terms, wish to exercise any right described in them, or wish to raise a concern, you can contact us as follows:

Mentivox Ltd Registered office: 3 Manchester Road, Thornton-Heath, CR7 8HH, United Kingdom Company number: 17271375 ICO registration reference: ZC154942

For general queries about these Terms or the Service, please use the contact or support channel provided within the Service.

For privacy-specific queries, including data subject rights requests and parental consent matters described in Section 3.4, please refer to the contact details in our Privacy Policy.

For copyright and intellectual property notices, please refer to the contact details in our Copyright & Intellectual Property Policy.

For law enforcement requests, please refer to our Law Enforcement Requests Policy.

If you are experiencing a mental health emergency, please do not contact us through these channels — instead, refer immediately to Section 11.1 of these Terms and contact Samaritans (116 123), 999, NHS 111, or your local emergency services.

These Terms have been prepared with reference to, and are intended to operate consistently with, the following UK, EU, and Nigerian legal and regulatory sources. This section is provided for transparency and does not itself create additional rights or obligations beyond those set out elsewhere in these Terms.

Companies Act 2006 — governing the incorporation and constitution of Mentivox Ltd. legislation.gov.uk

UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018 — the primary data protection framework applicable to Mentivox as a data controller registered with the ICO (reference ZC154942). gov.uk collection · legislation.gov.uk

Regulation (EU) 2016/679 (EU General Data Protection Regulation) — applies extraterritorially to Mentivox’s processing of the personal data of individuals located in the EU, by virtue of Article 3(2) (offering of services to data subjects in the EU). legislation.gov.uk (retained text)

ICO Age Appropriate Design Code (the “Children’s Code”) — the statutory code of practice under the Data Protection Act 2018 informing the child-specific protections described in Section 3.5 of these Terms. ICO — Age appropriate design: a code of practice for online services

Nigeria Data Protection Act 2023 (“NDPA”), enforced by the Nigeria Data Protection Commission (“NDPC”) — applicable to Mentivox’s Nigerian users and addressed in detail in the Privacy Policy. NDPC — Nigeria Data Protection Act 2023

Consumer Rights Act 2015 — governs the fairness and transparency of consumer contract terms (Part 2) and implies terms as to the quality of digital content and services, referenced in Sections 15 and 16 of these Terms. legislation.gov.uk

Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 — will govern pre-contract information and cancellation rights once any paid Subscription tier is introduced, as described in Section 6.2. legislation.gov.uk (SI 2013/3134)

Unfair Contract Terms Act 1977 — underlies the non-excludable liability carve-outs in Section 16.2 of these Terms, including the prohibition on excluding liability for death or personal injury caused by negligence. legislation.gov.uk

Online Safety Act 2023 — considered in determining that Mentivox, as a one-to-one AI companion service without user-to-user content sharing or search functionality, does not currently fall within the scope of a “regulated user-to-user service” or “search service” under the Act, consistent with published Ofcom guidance; this position is kept under ongoing review as the Service evolves. gov.uk — Online Safety Act: explainer · legislation.gov.uk

Copyright, Designs and Patents Act 1988 — the primary UK statute governing copyright, referenced in Section 8 of these Terms and addressed in detail in the Copyright & Intellectual Property Policy. legislation.gov.uk

This document is one of a suite of Mentivox legal documents, comprising these Terms of Service, the Privacy Policy, the AI Safety & Responsible Use Policy, the Acceptable Use Policy, the Cookie Policy, the Copyright & Intellectual Property Policy, the Law Enforcement Requests Policy, and the Data Retention Policy. Each document should be read together with the others for a complete understanding of the legal and policy framework governing the Service.

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