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Mudravia Pilot — Terms of Service

Version: Interim 1.1 (pre-incorporation) · Effective: [on first publication] · versión en español

These Terms govern a free, time-limited pilot. They are deliberately short. The Data Processing Annex ("Annex 1") forms part of these Terms and is available on request at legal@mudravia.com.

1. Who we are

The service ("Mudravia" or the "Service") is currently provided by Mukesh Mohanlal Rebari, a sole proprietor resident in India ("Provider", "we"). An Estonian private limited company (OÜ) is in formation; §11 governs the transfer of this agreement to it. Contact: legal@mudravia.com. Our representative in the European Union for data protection purposes (Art. 27 GDPR) is [EU representative — appointment in progress].

2. The Pilot

2.1 The Service is provided free of charge as a pilot programme (the "Pilot"). No payment obligation arises under these Terms.

2.2 The Pilot runs until the earliest of: (a) 30 November 2026; (b) the launch of a paid subscription offering, of which we will give at least 30 days' notice; or (c) termination under §12.

2.3 At the end of the Pilot you may either enter a paid subscription on the terms then offered, or stop using the Service. Nothing in these Terms obliges you to purchase anything.

3. Eligibility — business use only

The Service is offered exclusively to businesses and professionals (transport operators, freight forwarders and their staff) acting within their trade or profession. It is not offered to consumers. You confirm the person accepting these Terms is authorised to bind the customer organisation (the "Customer", "you").

4. The Service

4.1 The Service assists with freight document workflows, including extraction of data from transport documents and generation of the Spanish electronic administrative control document ("DeCA") under the Resolución of 5 June 2026 (BOE-A-2026-12784) and Ley 9/2025.

4.2 Your responsibility for regulatory documents. The Service is an assistance tool. Automated extraction can contain errors. You must verify the accuracy and completeness of every DeCA and every other generated document before using it, and you remain solely responsible before the transport authorities (including in roadside inspections) for the documents you use. The Provider is not a party to your regulatory obligations.

4.3 We may modify, suspend or discontinue features of the Service during the Pilot. We will make reasonable efforts to give notice of material changes.

5. Your account and acceptable use

5.1 Keep credentials confidential; you are responsible for activity under your account.

5.2 You must not: use the Service unlawfully; upload content you have no right to process; attempt to breach security or access other tenants' data; resell the Service; or subject it to automated load outside normal use.

5.3 You warrant that you are entitled to submit the personal data you upload (drivers, consignors, consignees) and that you have provided any notices required of you as controller.

6. Data protection

6.1 For personal data you submit to the Service, you are the controller and the Provider is your processor under Annex 1 (Data Processing Annex), which is incorporated into these Terms.

6.2 For account registration and website data, the Provider is the controller as described in the Privacy Policy.

6.3 All personal data is hosted and processed within the European Union. No personal data is transferred to India (see Annex 1, §9).

7. Intellectual property

7.1 The Provider retains all rights in the Service and its software. You receive a non-exclusive, non-transferable licence to use the Service for your internal business purposes during the Pilot.

7.2 You retain all rights in the data and documents you upload ("Customer Data"). We process Customer Data only to provide the Service, per Annex 1. We do not use Customer Data to train models.

8. Warranty disclaimer

The Service is provided "as is" and "as available", without warranty of any kind — no warranty of accuracy, availability, fitness for a particular purpose, or uninterrupted operation, to the maximum extent permitted by law. No service levels apply during the Pilot.

9. Liability

9.1 The Service being free, the Provider's total aggregate liability under these Terms is limited to €100, to the maximum extent permitted by applicable law.

9.2 To the same extent, the Provider is not liable for indirect or consequential loss, loss of profit, loss of business, or administrative sanctions imposed on you by transport or other authorities, including sanctions arising from errors in generated documents that you did not verify per §4.2.

9.3 Nothing in these Terms excludes or limits liability for wilful misconduct (dolo), the advance waiver of which is void under Art. 1102 of the Spanish Civil Code, or for gross negligence (culpa grave, assimilated to dolo by Spanish Supreme Court case law under Arts. 1102–1103 CC), for death or personal injury caused by negligence, or for any liability that cannot lawfully be excluded.

10. Indemnity

You will indemnify the Provider against third-party claims arising from Customer Data you had no right to process, or from your use of the Service in breach of §5.

11. Assignment and novation to the OÜ

11.1 The Provider intends to incorporate an Estonian private limited company (osaühing) and to transfer the Service to it (the "Company").

11.2 You consent in advance to the transfer of this agreement — all rights and obligations, including Annex 1 — from the Provider to the Company, effective upon written notice to you (email suffices) identifying the Company by name and registry code. On that notice the Company replaces the Provider as your contracting party and processor, without any further signature. The notice will restate these Terms or state the changes.

11.3 You may not assign this agreement without our consent, except to a successor of your transport business.

12. Term, termination and switching

12.1 You may terminate at any time on notice (email suffices), with immediate effect. We may terminate: (a) on 15 days' notice for convenience; or (b) with immediate effect for your breach of §5 or where required by law.

12.2 For 30 days after termination or Pilot end (the "Transition Period"), you may export your Customer Data via the in-product export or by written request, free of charge, in a structured, commonly used and machine-readable format, and we will provide reasonable assistance with your migration to another provider or to on-premises systems. Thereafter we delete Customer Data per Annex 1, §11 (or return it first, at your election), save for what law requires us to retain.

12.3 Switching (Regulation (EU) 2023/2854 — Data Act). You may switch to another data processing service or erase your data on a maximum notice of two months; during the Pilot no termination fee or switching charge applies. The Transition Period may be extended once where migration is technically unfeasible in 30 days, per Art. 25(4) of the Data Act. Categories of exportable data: all Customer Data (uploaded documents, extracted fields, generated documents and associated metadata); export formats: JSON/CSV plus original document files [confirm formats against the export implementation before publication].

13. Changes to these Terms

We may amend these Terms on at least 15 days' notice. If you object, your remedy is to terminate under §12 before the change takes effect; continued use after the effective date is acceptance. Changes needed to comply with law may take effect immediately.

14. General

14.1 Governing law: Spanish law. Exclusive jurisdiction: the courts of Madrid, save where mandatory rules give another forum.

14.2 These Terms plus Annex 1 and the Privacy Policy are the entire agreement for the Pilot. If a provision is invalid, the rest stands.

14.3 These Terms are drafted in English; the Spanish version is a courtesy translation. If there is a conflict, the English version prevails.