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Mudravia Pilot — Terms of Service

Version: 2026-10-07 (replaces Interim 1.1) · Effective: from its first publication at /es/legal/terms · Versión en español (texto vinculante)

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 provided by Mudravia OÜ, a private limited company (osaühing) registered in Estonia under registry code 17617532, with its registered office at Tartu mnt 67/1-13b, 10115 Tallinn, Estonia ("Provider", "we"). Contact: legal@mudravia.com.

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 and formation

The Service is offered exclusively to businesses and professionals acting within their trade or profession. It is not offered to consumers. The person accepting these Terms confirms that they are authorised to bind the customer organisation (the "Customer", "you").

3(a) Eligible customers. The Service is offered to gestorías and asesorías, carriers, shippers, and businesses that file ICS2 entry summary declarations (ENS), each acting within its trade.

3(b) Competing software. "Competing software" means software supplied to third parties for consideration that prepares, files or manages DeCA, eCMR or ENS documents, or comparable transport or customs filings. A business that supplies or develops competing software, or anyone acting for such a business, is not eligible. "Acting for" means applying for, or using, the Service on the instructions of, for the benefit of, or as an employee, contractor or agent of such a business. Exception: a business that also holds a transport authorisation or a gestor administrativo colegiado number, and uses the Service for that activity, is eligible.

3(c) Accuracy warranty. The applicant warrants that what it states when applying is accurate and complete, and that §3(b) does not apply to it.

3(d) Duty to notify. The Customer notifies the Provider without delay if §3(b) comes to apply to it.

3(e) Checks. The Provider may check public registers and ask for documents, before and after opening an account.

3(f) Formation. Submitting the application is an offer. The contract is formed only when the Provider approves the application. Until then, only this §3, §6.2 and §14 bind.

3(g) Refusal. The Provider may decline an application without giving reasons, without prejudice to the applicant's rights under data-protection law.

3(h) Scope. The Service is built first for Spanish operations. This describes its features, not who may apply.

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.

5.4 You must not, except to the extent that mandatory law allows it: (a) scrape the Service or extract data from it by automated means, other than through the interfaces the Provider offers for that purpose; (b) benchmark the Service for publication, or for building or improving a competing product; or (c) reverse engineer, decompile or disassemble the Service or any part of it, or observe, study or test it in order to obtain its trade secrets. Paragraph (c) is an obligation that validly prevents obtaining information by those means for the purposes of Article 2.1.b of Ley 1/2019, de 20 de febrero, de Secretos Empresariales.

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 Customer Data is hosted and processed within the European Union on the Service's servers, which Hetzner Online GmbH provides in Germany and Finland. On its way between your users and those servers, Customer Data passes through the network of Cloudflare, Inc., which protects and forwards the traffic without storing its content, and may handle it at an edge location outside the European Union; Cloudflare is a sub-processor under Annex 1, §7, and the safeguards for that transit are set out in Annex 1, §9. Apart from Cloudflare's processing described in Annex 1, §9, no Customer Data is transferred to India or to any other country outside the European Union. The data the Provider processes as controller when a business applies to use the Service, including the bot check run by Cloudflare, Inc. in the United States and access by the Provider's staff from India, is described in the Privacy Policy.

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. This does not affect the administrative response commitment in §12.2 (data export requests), which is a fixed deadline for answering a specific request, not a service level or an availability commitment.

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

11.1 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; (b) with immediate effect for your breach of §5 or where required by law; or (c) with immediate effect, in addition to (a) and (b), where a statement made under §3(c) was false, or where §3(b) comes to apply to you.

12.2 For 30 days after termination or Pilot end (the "Transition Period"), you may obtain a copy of your Customer Data by written request to the contact address in §1, free of charge, in a structured, commonly used and machine-readable format. We will respond within 10 working days. An in-product self-service export is on the roadmap and is not available during the Pilot. We will provide reasonable assistance with your migration to another provider or to on-premises systems. A request made within the Transition Period suspends deletion of the Customer Data concerned until we have answered the request. 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 for extracted field values and shipment metadata, CSV on request for tabular data, and the original uploaded files and generated DeCA PDFs in their native formats.

12.4 Revocation. Where the Provider approved an application on the strength of a false statement made under §3(c), it may revoke the approval with immediate effect by written notice (email suffices). The contract then ends on the date of the notice, and §12.2 applies to the Customer Data held at that date, without prejudice to any other remedy available under Spanish law.

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 are the entire agreement for the Pilot. The Privacy Policy referred to in §6.2 is an information notice under Arts. 13 and 14 GDPR, given to you for information; it is not a term of this agreement and does not form part of it. If a provision is invalid, the rest stands.

14.3 These Terms are published in Spanish and in English. The Spanish version is binding; the English version is provided for convenience and, in the event of any conflict, the Spanish version prevails.