AquaBio Control
Terms and Conditions
End-User Licence Agreement and Terms of Service for the AquaBio Control iOS application (iPad, iPhone and Apple Watch) and its web-link counterparty portals.
Biosecurity Execution-Proof, Mortality-Escalation and Stock-Risk Traceability Operating Layer for iPad, iPhone and Apple Watch.
Lock the zone. Catch the mortality. Defend the stock.
DOCUMENT
AquaBio Control — Terms and Conditions
STRUCTURE
Master Terms (Part I) + Schedule A · App-Specific Terms (Part II)
VERSION
1.0
EFFECTIVE
2026-09-01
OPERATOR
ML Consulting MB · Legal entity code 306991112
JURISDICTION
Republic of Lithuania
DISTRIBUTION
Apple App Store · iOS, iPadOS, watchOS + web-link counterparty portals
SUBSCRIBER PROFILE
Business User (B2B) — salmon, trout, carp and equivalent aquaculture producers (Mowi / Bakkafrost / Cooke / Scottish Sea Farms / Cermaq / Lerøy / SalMar / Grieg / Tassal / Huon / Multiexport / AquaChile / Camanchaca-tier), hatcheries, premium stocked fisheries, multi-site aquaculture groups, and contracted counterparties (aquaculture insurance underwriters, government aquaculture inspectors, major retailer procurement, ASC / BAP / GlobalG.A.P. / RSPCA Assured certification bodies, aquaculture veterinary authorities)
BILLING CHANNEL
Direct Channel (Order Form / Stripe) for all paid tiers — App Store Reader Rule pattern
WEBSITE
Preliminary Notice
Please read before you tap I Agree, before you sign an Order Form and before you authorise any site manager, biosecurity lead, hatchery technician, fish-farm worker, supervisor, bailiff, App Clip user or counterparty to use the App.
These Terms and Conditions are a legally binding agreement between ML Consulting MB, a private limited liability company organised under the laws of the Republic of Lithuania, legal entity code 306991112 (ML Consulting, we, us, our) and you, the natural or legal person who installs, accesses or uses the AquaBio Control iOS application or any counterparty portal made available in connection with it (you, your, Subscribing Customer or, where the context requires, User).
They incorporate the Apple Standard End User Licence Agreement to the extent required by Apple, applicable consumer-protection legislation of the European Union and of the Republic of Lithuania, the General Data Protection Regulation 2016/679 (GDPR), Regulation (EU) 910/2014 (eIDAS), and — where applicable to a Subscribing Customer operating in jurisdictions with aquaculture animal-health, notifiable-disease, veterinary-medicines, animal-welfare, marine, environmental, certification, retailer-compliance or worker-safety frameworks — Regulation (EU) 2016/429 (Animal Health Law) and Commission Delegated Regulation (EU) 2020/689 (surveillance, eradication programmes and disease-free status for listed and emerging diseases), Regulation (EU) 2019/6 on veterinary medicinal products, the U.K. Aquatic Animal Health (England and Wales) Regulations 2009 and the Aquaculture and Fisheries (Scotland) Acts 2007 and 2013, DEFRA / Cefas Fish Health Inspectorate guidance, Marine Scotland aquaculture licence conditions and the Crown Estate Scotland seabed leases, Norwegian Akvakulturloven and Mattilsynet rules, Faroese aquaculture law and the Heilsufrøðiliga starvsstovan rules, Chilean Ley General de Pesca y Acuicultura and SERNAPESCA rules, the Canadian Fisheries Act and DFO aquaculture conditions, the Irish Marine Institute aquaculture licensing regime, the Tasmanian Marine Farming Planning Act and DPIPWE rules, the WOAH (formerly OIE) Aquatic Animal Health Code listings for ISA, IHN, ISAV, EHN, koi herpesvirus disease, white spot disease, taura syndrome and other listed diseases, the Aquaculture Stewardship Council (ASC) Salmon Standard, the Best Aquaculture Practices (BAP) / Global Seafood Alliance standards, GlobalG.A.P. Aquaculture, Friend of the Sea (FOS), Soil Association Salmon and RSPCA Assured frameworks, the EU Veterinary Medicines Directorate (VMD) / FDA Center for Veterinary Medicine residue rules, and equivalent local frameworks identified on the Order Form.
AquaBio Control is a Business-to-Business (B2B) operational tool. It is not designed for personal, household or recreational use. It is designed to be deployed by the Subscribing Customer for the benefit of the Subscribing Customer's own site managers, biosecurity leads, hatchery technicians, fish-farm workers, supervisors, operations managers, bailiffs, App Clip users (visiting government inspectors, visiting veterinary authorities, visiting retailer auditors, visiting certification auditors) and contracted counterparties (major salmon producer HQs, aquaculture insurance underwriters, government aquaculture inspectors, major retailer procurement, ASC / BAP / GlobalG.A.P. / RSPCA Assured certification bodies, aquaculture veterinary authorities).
HOW TO READ THIS DOCUMENT
PART I — Master Terms and Conditions applies to every ML Consulting application. PART II — Schedule A is specific to AquaBio Control and prevails over the Master Terms wherever they conflict. Capitalised terms have the meanings given in clause 4 (Master Terms) and clause A1 (Schedule A). The Order Form signed between ML Consulting and the Subscribing Customer prevails over both where it contains express commercial terms.
BIOSECURITY, NOTIFIABLE-DISEASE AND VETERINARY DISCLAIMER
AquaBio Control is an iPad / iPhone / Apple Watch operating layer for biosecurity execution-proof capture, mortality-escalation orchestration, stock-risk traceability, Site-Lock evidence assembly and counterparty audit packs. It is not a veterinary diagnostic device or veterinary medical device, not a notifiable-disease laboratory (PCR, ELISA, virology, bacteriology, histopathology), not a Regulation (EU) 2016/429 Animal Health Law authority, not a Regulation (EU) 2019/6 veterinary medicines authority, not a WOAH (formerly OIE) Aquatic Animal Health Code reporting authority, not a DEFRA Cefas / Marine Scotland / Mattilsynet / Heilsufrøðiliga starvsstovan / SERNAPESCA / DFO / Irish Marine Institute / Tasmanian DPIPWE filing or licence, not an ASC / BAP / GlobalG.A.P. / FOS / RSPCA Assured / Soil Association certification, not a Tesco / Sainsbury's / Waitrose / Marks & Spencer / Whole Foods / Kroger / Aldi / Lidl / Coop / Costco / Carrefour / Auchan / Edeka / REWE / Albert Heijn / Coles / Woolworths / Loblaw retailer-compliance authority, not a CITES permit, not a worker-safety, drowning-prevention or maritime-safety authority, not a fire alarm, not an emergency dispatch service, not a 911 / 999 / 112 service, and not legal, veterinary, fish-health, fisheries, environmental, insurance or certification advice. The Subscribing Customer remains the aquaculture business operator under applicable law, the biosecurity duty-holder, the animal-welfare responsible person, the legal employer of site staff and the contracting party with the producer HQ, retailer, certification body, veterinary authority, inspectorate and insurer at all times, and remains solely responsible for all biosecurity, notifiable-disease, veterinary, mortality, stocking-density, welfare, escape, containment, sea-lice, marine-environment, residue, certification, retailer-compliance and contractual decisions.
ANIMAL WELFARE, MARINE-ENVIRONMENT AND WORKER-SAFETY DISCLAIMER
AquaBio Control processes operational data about fish welfare (mortality counts, gill-score observations, sea-lice counts, behavioural observations, welfare audits), marine environment (sea-lice management, escape containment, benthic monitoring sampling, seabed lease conditions), and worker safety (boot-bath compliance, lone-working at sea cages, drowning-prevention, hypothermia-prevention, cold-water immersion). It is not a substitute for any animal-welfare regime (including Directive 98/58/EC on the protection of animals kept for farming purposes, Council Regulation (EC) 1099/2009 on the protection of animals at the time of killing, the U.K. Animal Welfare Act 2006, the Aquaculture and Fisheries (Scotland) Acts, the Norwegian Animal Welfare Act and equivalents), is not a substitute for any marine-environment or escape-containment regime, is not a substitute for any worker-safety regime (OSHA / HSE / EU Framework Directive 89/391/EEC / Maritime and Coastguard Agency / Sjøfartsdirektoratet), is not a man-overboard or drowning-detection system, and is not an authority for any animal-welfare, environmental or worker-safety decision. If a worker or visitor falls into water, suffers hypothermia, suffers a manual-handling injury or any other medical emergency, the Subscribing Customer must immediately call 911 / 999 / 112 or the locally applicable public emergency number and follow established marine-safety and first-aid protocols.
Contents
What is in this document.
PART I — MASTER TERMS AND CONDITIONS
1. Agreement and Parties
2. Apps Covered and Per-App Schedules
3. Eligibility and Intended Users
4. Definitions
5. Licence to Use the App
6. What the App Does, and What It Does Not Do
7. Accounts, Credentials and Device Security
8. Subscriber Data and Permitted Use by Us
9. Privacy and Data Protection
10. Subscriptions, Billing and App Store Rules
11. Direct Billing for the App
12. Acceptable Use
13. AI / ML Features and Probabilistic Outputs
14. Intellectual Property
15. Updates, Availability and Support
16. Suspension and Termination
17. Consumer Rights
18. Disclaimers
19. Limitation of Liability
20. Indemnity for Business Users
21. Force Majeure
22. Governing Law and Disputes
23. Changes to this Agreement
24. General
25. Apple-Required Terms
26. Precedence — Schedules and Order Forms
PART II — SCHEDULE A · AQUABIO CONTROL
A1. App-Specific Definitions
A2. Description of AquaBio Control and Surfaces
A3. Subscribing Customer Responsibilities (Producer / Site / Hatchery / Multi-Site Group)
A4. Site Managers, Workers, App Clip Users and Counterparty Portals
A5. Face ID, PencilKit and Apple Watch Site-Lock — Not eIDAS, Not Veterinary Authority
A6. Apple Watch, Live Activities and Notifications — Not a Safety, Veterinary or Notifiable-Disease Authority
A7. Audit Log, Site-Lock Evidence and Counterparty Packs
A8. AI-Assisted Features (Vision Dead-Fish Counting) — Not Veterinary, Not Welfare Authority
A9. Aquaculture Animal Health Law, Notifiable Diseases and Veterinary Medicines
A10. ASC / BAP / GlobalG.A.P. / RSPCA Assured Certifications and Retailer Compliance
A11. Marine Environment, Animal Welfare, Containment / Escapes and Worker Safety
A12. Personal Data of Workers, App Clip Users and Counterparty Representatives
A13. Specific Prohibited Uses
A14. Plans, Billing and Liability
A15. Operational Contact Points
PART I
Master Terms and Conditions
Applicable to every iOS application published by ML Consulting MB on the Apple App Store, including AquaBio Control.
1
AGREEMENT AND PARTIES
Who is contracting, how acceptance happens, and how authority to bind works.
1.1. These Master Terms together with the applicable Schedule (Schedule A for the App), any Data Processing Addendum and any Order Form mutually signed between ML Consulting and the Subscribing Customer (together, the Agreement) form the entire legal agreement between ML Consulting and you regarding your installation, access and use of the App and any counterparty portal.
1.2. By tapping I Agree at first launch, by creating an account, by signing an Order Form, by accessing a Counterparty Portal via signed URL, by launching an App Clip session or by otherwise using the App, you confirm that you have read, understood and agreed to be bound by the Agreement.
1.3. If you act on behalf of an organisation, you warrant that you have the legal authority to bind that organisation, and the Subscribing Customer is that organisation. Where you access the App as an employee, contractor, freelance site manager, biosecurity lead, hatchery technician, fish-farm worker, supervisor, bailiff, App Clip user or counterparty representative, you do so under the authority of the Subscribing Customer who deployed the App for the relevant Site or Production Cycle.
1.4. No oral statement, marketing material, demonstration, design-partner conversation or pre-contract communication forms part of the Agreement unless it is expressly incorporated by reference in a signed Order Form.
2
APPS COVERED AND PER-APP SCHEDULES
How Master Terms compose with Schedule A and the Order Form.
2.1. These Master Terms apply to every ML Consulting iOS application. Each application is governed by its own Schedule, which describes the application, its intended scope and any app-specific terms.
2.2. For AquaBio Control, the applicable Schedule is Schedule A in Part II of this document.
2.3. In the event of conflict between a Master Term and a Schedule provision, the Schedule prevails for that application. In the event of conflict between a Schedule provision and an executed Order Form, the Order Form prevails to the extent of the conflict. In the event of conflict between the Order Form and any purchase order, vendor questionnaire, master services agreement, RFP response or other procurement document issued by the Subscribing Customer, the Order Form prevails unless expressly amended by mutually signed addendum.
3
ELIGIBILITY AND INTENDED USERS
Who may use the App, in what capacity, and what consumer-rights pathway applies.
3.1. The App is intended for business use by Subscribing Customers operating salmon, trout, carp and equivalent aquaculture sites, hatcheries, premium stocked fisheries, multi-site aquaculture groups, major salmon producer head offices, aquaculture insurance underwriter risk desks, government aquaculture inspectorates, major retailer procurement desks, ASC / BAP / GlobalG.A.P. / RSPCA Assured certification bodies and aquaculture veterinary authorities, and for the site managers, biosecurity leads, hatchery technicians, fish-farm workers, supervisors, operations managers, bailiffs, App Clip users and counterparty representatives they authorise.
3.2. You must be at least 18 years old and legally able to enter into a binding contract to use the App. The Subscribing Customer is solely responsible for ensuring that every User meets all applicable biosecurity training, veterinary-medicine handling competency, manual-handling training, working-at-water training, lone-working training, cold-water immersion training and Maritime and Coastguard Agency / Sjøfartsdirektoratet / equivalent maritime-safety training requirements before being granted access to the App.
3.3. The App is not directed at consumers within the meaning of Directive 2011/83/EU. Where the App is nevertheless made available to a natural person acting outside their trade, business, craft or profession, clause 17 (Consumer Rights) applies.
4
DEFINITIONS
How key terms are used throughout the Agreement.
In the Agreement, the following terms have the meanings set out below. Additional terms are defined in clause A1 (Schedule A).
App — the AquaBio Control iOS application published by ML Consulting on the Apple App Store, including its iPad, iPhone, Apple Watch, App Clip and offline-capable variants and any updates, together with associated server-side services and counterparty web-link portals.
Order Form — a written ordering document (electronic or paper) signed by an authorised representative of the Subscribing Customer and by ML Consulting, identifying the Plan, Subscription Fees, term, seat counts, counterparty seat counts, any Pre-Stocking Stand-by Service terms and any commercial variations.
Plan — a published or quoted commercial plan for the App, as described in clause A14.
Subscribing Customer — the legal entity that signs the Order Form and pays the Subscription Fees — typically a salmon, trout, carp or equivalent aquaculture producer (Mowi / Bakkafrost / Cooke / Scottish Sea Farms / Cermaq / Lerøy / SalMar / Grieg / Tassal / Huon / Multiexport / AquaChile / Camanchaca-tier), a hatchery operator, a premium stocked-fishery operator, a multi-site aquaculture group, an aquaculture insurance underwriter, a government aquaculture inspectorate, a major retailer procurement desk, an ASC / BAP / GlobalG.A.P. / RSPCA Assured certification body or an aquaculture veterinary authority.
User — any natural person who accesses the App or a Counterparty Portal under credentials issued by, or under the authority of, the Subscribing Customer — including site managers, biosecurity leads, hatchery technicians, fish-farm workers, supervisors, operations managers, bailiffs, App Clip users and counterparty representatives.
Counterparty Portal — a read-only, scope-correct web-link portal made available to a contracted counterparty (major salmon producer HQ, aquaculture insurance underwriter risk desk, government aquaculture inspectorate, major retailer procurement desk, ASC / BAP / GlobalG.A.P. / RSPCA Assured certification body, aquaculture veterinary authority) via signed URL.
Pack — a versioned, structured export bundle generated by the App — including, without limitation, the Audit Defence Pack PDF, the Site-Lock Evidence Pack, the Mortality Escalation Pack, the Biosecurity Zone Pack, the Notifiable-Disease Pre-Notification Pack, the Major Salmon Producer HQ Pack, the Aquaculture Insurance Underwriter Pack, the Government Aquaculture Inspector Pack, the Major Retailer Procurement Pack, the ASC / BAP / GlobalG.A.P. / RSPCA Assured Certification Pack and the Aquaculture Veterinary Authority Pack.
Subscription Fees — all fees payable by the Subscribing Customer in respect of the App, including recurring Plan fees, per-Site fees, additional seat / counterparty fees, professional-services fees and any Pre-Stocking Stand-by Service retainer and incident fees.
Subscriber Data — all data, content, photographs, voice memos, signatures, PencilKit site-map markup, AVFoundation mortality / welfare captures, Vision-framework dead-fish-counting outputs, CoreNFC scan records, Site-Lock acknowledgements and personal data of Users, producer HQ representatives, inspector representatives, retailer representatives, certifier representatives, veterinary representatives and counterparty representatives submitted to or generated through the App by, or on behalf of, the Subscribing Customer.
Site — a single discrete aquaculture site or hatchery, including its sea cages, pens, ponds, tanks, raceways, quarantine zones, biosecurity zones, boot-bath stations, cold-storage rooms, processing lines and adjacent water column / seabed lease area, as configured in the App by the Subscribing Customer.
Apple — Apple Inc. and its affiliates that distribute the App through the App Store.
5
LICENCE TO USE THE APP
Scope of the licence and limits on permitted uses.
5.1. Subject to your compliance with the Agreement and timely payment of any Subscription Fees, ML Consulting grants you a personal, limited, non-exclusive, non-transferable, non-sublicensable, revocable licence to install and use the App on Apple-branded devices that you own or control, solely for the internal business purposes of the Subscribing Customer in connection with one or more Sites.
5.2. You may not (and you must not permit any third party to): copy the App except as expressly permitted by the licence; modify, translate, adapt or create derivative works of the App; reverse-engineer, decompile, disassemble or attempt to derive source code from the App, except to the extent that applicable law expressly permits such acts notwithstanding this restriction; rent, lease, lend, sell, sublicense, assign, distribute, publish or transfer the App or any part of it; remove, alter or obscure any proprietary notices on the App; use the App to develop, train, fine-tune, evaluate or benchmark any competing product or any machine-learning model intended to imitate the App or to perform veterinary diagnosis, welfare-scoring, mortality-attribution, escape-attribution or certification analysis; or use the App in any manner inconsistent with the App Store Terms of Service or the Apple Standard EULA.
5.3. All rights not expressly granted are reserved by ML Consulting and its licensors.
6
WHAT THE APP DOES, AND WHAT IT DOES NOT DO
The scope of the operating layer and the operational boundary.
6.1. The App is an operating layer for biosecurity execution-proof capture, mortality-escalation orchestration, stock-risk traceability, Site-Lock evidence assembly and counterparty audit packs. It is iOS-native on the operator surface (iPad site manager / biosecurity lead cockpit at site office and hatchery control room with PencilKit + Apple Pencil Pro site-map markup; iPhone field capture by fish-farm workers, hatchery technicians, bailiffs and supervisors at sea cage, pond, tank and quarantine zone in waterproof case and waders with AVFoundation photography, Vision-framework dead-fish counting, Speech-framework dictation, CoreNFC zone-tag / boot-bath / equipment-tag scan and Face ID-signed task-execution per SOP; Apple Watch wrist haptic for the site manager, biosecurity lead and senior worker during operations) and web-link on the counterparty surface (read-only via signed URL).
6.2. The App does not stock, feed, vaccinate, treat, medicate, anaesthetise, slaughter, transport, gut, fillet, pack or refrigerate any fish, mollusc, crustacean or other aquatic animal; does not diagnose, sample, screen, identify, characterise, sequence or notify any pathogen (including Infectious Salmon Anaemia virus / ISAv, Pancreas Disease virus / PDV, Salmon Rickettsial Septicaemia / SRS, Infectious Pancreatic Necrosis virus / IPNv, Infectious Haematopoietic Necrosis virus / IHNv, Bacterial Kidney Disease / BKD, sea lice Lepeophtheirus salmonis and Caligus elongatus and Caligus rogercresseyi or any other agent); does not measure or warrant any water quality, dissolved oxygen, temperature, salinity, pH, ammonia, nitrite, nitrate, turbidity, chlorophyll-a or harmful-algal-bloom parameter; does not authorise any veterinary medicinal product administration, residue / withdrawal-period determination, prescribing decision, off-label use or cascade decision under Regulation (EU) 2019/6 or equivalents; does not lodge any Animal Health Law, WOAH (formerly OIE), Marine Scotland, DEFRA Cefas, Mattilsynet, Heilsufrøðiliga starvsstovan, SERNAPESCA, DFO, Irish Marine Institute or Tasmanian DPIPWE filing or notification; does not constitute an ASC / BAP / GlobalG.A.P. / FOS / Soil Association / RSPCA Assured certification or audit decision; does not run payroll or any payment-services activity; and does not constitute legal, veterinary, fish-health, fisheries, environmental, animal-welfare, certification, retailer-compliance, insurance or fiscal advice.
6.3. You acknowledge that the App is a record-keeping, evidence-capture and acknowledgement-orchestration system. The actual fish husbandry, biosecurity execution, mortality picking and counting, sea-lice counting, sampling, veterinary diagnosis and treatment, water-quality monitoring, escape containment, marine-environment compliance, certification and retailer-audit cooperation is performed by the Subscribing Customer's qualified personnel and veterinarians and remains their sole responsibility.
7
ACCOUNTS, CREDENTIALS AND DEVICE SECURITY
Who controls credentials and what you must do on incident.
7.1. You are responsible for safeguarding the credentials (Apple ID, App-issued PIN, biometric enrolments, App Clip session tokens, CoreNFC tokens, Counterparty Portal signed URLs and any other authentication factors) used to access the App, and for all activity occurring under those credentials.
7.2. You must notify ML Consulting promptly at support+aquabio@mlconsulting.lt of any actual or suspected unauthorised access, credential compromise, lost or stolen device, leaked Counterparty Portal URL, leaked App Clip session token or other security incident affecting the App.
7.3. You must keep the App, the underlying iOS, iPadOS and watchOS versions and the host Apple device firmware reasonably up-to-date. ML Consulting may decline to support, or may suspend access to, devices running materially out-of-date system software where this presents a security or compatibility risk.
7.4. ML Consulting may suspend access to the App or to any Counterparty Portal where necessary to protect the security or integrity of the App, the Subscriber Data, the personal data of workers, App Clip users and counterparty representatives, or other Users — and to protect the confidentiality of producer HQ commercial information, biosecurity strategy, mortality data, certification audit findings and retailer-allocation arrangements.
8
SUBSCRIBER DATA AND PERMITTED USE BY US
Who owns the Site records and on what basis we process them.
8.1. As between you and ML Consulting, the Subscribing Customer retains all rights in the Subscriber Data.
8.2. You grant ML Consulting a worldwide, royalty-free, non-exclusive licence to host, store, transmit, display, reformat and process the Subscriber Data solely as necessary to provide and improve the App, deliver the Packs, operate the Counterparty Portals, prevent abuse, fulfil legal obligations and otherwise perform the Agreement.
8.3. ML Consulting may generate aggregated, anonymised statistical information from the Subscriber Data that does not directly or indirectly identify any natural person, Subscribing Customer, Site, producer, retailer, certification body, veterinary authority, government inspectorate, insurer or counterparty, and may use such aggregated information for product analytics, benchmarking and service improvement.
8.4. ML Consulting does not use Subscriber Data — including AVFoundation mortality / welfare photographs, Vision dead-fish-counting outputs, PencilKit site-map markup, Speech-framework voice memos, CoreNFC scan records, Face ID-signed acknowledgements, Site identifiers, producer identifiers, retailer identifiers, certification-body identifiers, veterinary identifiers or inspectorate identifiers — to train or fine-tune any general-purpose or third-party machine-learning model, and does not disclose Subscriber Data to any third-party model provider without the express written consent of the Subscribing Customer. ML Consulting does not use Subscriber Data to construct, populate or supplement any veterinary diagnostic, welfare-scoring, mortality-attribution, escape-attribution, certification-risk or retailer-risk database, registry, market index or service.
9
PRIVACY AND DATA PROTECTION
How GDPR and worker-monitoring law map to the App.
9.1. ML Consulting processes personal data in accordance with the GDPR, the Lithuanian Law on Legal Protection of Personal Data and the AquaBio Control Privacy Policy published on mlconsulting.lt.
9.2. Where ML Consulting processes personal data on behalf of the Subscribing Customer (including personal data of site managers, biosecurity leads, hatchery technicians, fish-farm workers, supervisors, bailiffs, producer HQ representatives, inspector representatives, retailer representatives, certifier representatives, veterinary representatives and counterparty representatives), ML Consulting acts as a processor and the Subscribing Customer acts as a controller. Article 28 GDPR data-processing terms apply in the form set out in the Data Processing Addendum incorporated by reference into the Order Form.
9.3. Where ML Consulting determines the means and purposes of processing — for example, for security telemetry, fraud prevention, billing or product analytics on anonymised data — ML Consulting acts as a controller.
9.4. Where the App is used in the employment or freelance-engagement context — including for aquaculture-sector workers and contractors — the Subscribing Customer is responsible for compliance with Article 88 GDPR (processing in the context of employment), the rules adopted under Article 88 by the relevant Member State, the rules of any applicable collective bargaining agreement (Norwegian Hovedavtalen, Faroese aquaculture CBAs, Scottish Sea Fish Industry Authority agreements, Chilean Federación de Trabajadores Pesqueros and equivalents), the rules of any works-council or workforce-representative consultation procedure, the French Code du travail and equivalent local provisions of every Site jurisdiction.
9.5. Where the Subscribing Customer is a regulated person under the UK Modern Slavery Act 2015, the Norwegian Transparency Act 2022 (Åpenhetsloven), the Australian Modern Slavery Act 2018 or equivalents, the Subscribing Customer is responsible for the relevant human-rights due diligence, supply-chain reporting and modern-slavery statements independently of the App.
10
SUBSCRIPTIONS, BILLING AND APP STORE RULES
How the App is sold and how Apple-managed payments interact.
10.1. The App is offered to Subscribing Customers under the Plans described in clause A14. Subscription Fees are exclusive of value-added tax, sales tax, withholding tax and other applicable taxes, which are payable in addition where due.
10.2. Where the App is acquired through the Apple App Store on a paid basis, the applicable Apple-managed payment terms, refund policy and family-sharing rules apply. Where the Apple App Store version of the App is free, all paid functionality is procured by the Subscribing Customer through the Direct Billing channel described in clause 11.
10.3. Subscriptions auto-renew unless the Subscribing Customer cancels in writing in accordance with clause 16 (Suspension and Termination) and the applicable Order Form.
11
DIRECT BILLING FOR THE APP
How the Reader Rule pattern maps to the Plans.
11.1. All paid Plans for the App are sold under the Direct Channel — meaning the Subscribing Customer signs an Order Form with ML Consulting and pays the Subscription Fees by bank transfer or by card via Stripe. Apple In-App Purchase is not used for these Plans, in compliance with the App Store Reader Rule pattern.
11.2. Invoices are issued in EUR. Payment terms are net thirty (30) days from invoice date unless otherwise specified on the Order Form. Late payments accrue interest at the rate provided for in Directive 2011/7/EU on combating late payment in commercial transactions.
11.3. The Subscribing Customer is responsible for its own withholding-tax, VAT-reverse-charge and any payment-services-provider obligations arising in the Subscribing Customer's jurisdiction.
12
ACCEPTABLE USE
What you must not do with the App.
You must not, and you must not permit any User to:
▪ use the App in any manner that infringes applicable law, including aquaculture animal-health law (Regulation (EU) 2016/429, Commission Delegated Regulation (EU) 2020/689, the U.K. Aquatic Animal Health (England and Wales) Regulations 2009, the Aquaculture and Fisheries (Scotland) Acts 2007 and 2013, the Norwegian Akvakulturloven, the Faroese aquaculture law, the Chilean Ley General de Pesca y Acuicultura, the Canadian Fisheries Act, the Tasmanian Marine Farming Planning Act and equivalents), veterinary-medicines law (Regulation (EU) 2019/6, the U.K. Veterinary Medicines Regulations 2013 as amended, the FDA Center for Veterinary Medicine residue rules and equivalents), notifiable-disease law (WOAH Aquatic Animal Health Code), marine-environment law (the U.K. Marine Strategy Regulations, the EU Marine Strategy Framework Directive 2008/56/EC, the Norwegian Forurensningsloven, the Chilean Ley sobre Bases Generales del Medio Ambiente and equivalents), animal-welfare law (Directive 98/58/EC, Council Regulation (EC) 1099/2009, the U.K. Animal Welfare Act 2006, the Norwegian Animal Welfare Act and equivalents), worker-safety law (OSHA, U.K. HSE, EU Framework Directive 89/391/EEC, the Maritime and Coastguard Agency / Sjøfartsdirektoratet rules on working at water and lone-working and equivalents), modern-slavery and transparency law (UK Modern Slavery Act 2015, Norwegian Transparency Act 2022, Australian Modern Slavery Act 2018), GDPR, eIDAS, intellectual-property law, defamation law, anti-bribery law or competition law;
▪ upload, capture or transmit any content that is unlawful, defamatory, obscene, hateful, harassing, or that infringes the intellectual property, image, publicity, privacy, producer-HQ confidentiality, retailer-allocation, certification-audit, veterinary or worker-safety rights of any third party;
▪ introduce viruses, worms, malware or other harmful code, or attempt to gain unauthorised access to the App, to other Users, to Counterparty Portals or to underlying infrastructure;
▪ interfere with or disrupt the integrity or performance of the App or the data contained therein, or with any feeding system, oxygen-injection system, sea-cage net-pen, dead-fish-recovery / lift-up system, sea-lice-treatment well-boat system, fish-pump, grader, slaughter line, refrigeration system, water-quality probe, telemetry buoy or other production-critical system on or around the Site;
▪ use the App to process special categories of personal data within the meaning of Article 9 GDPR (including worker health data, injury reports, occupational-health surveillance results, cold-water immersion or hypothermia incident data), except where this is strictly necessary, supported by an appropriate legal basis under Articles 6 and 9 GDPR and subject to suitable safeguards;
▪ use the App for any decision that produces legal effects concerning a natural person or similarly significantly affects them within the meaning of Article 22 GDPR — including worker disciplinary decisions, blacklisting decisions, modern-slavery investigation outcomes or accident-attribution decisions — without an appropriate human-in-the-loop process and a documented legal basis;
▪ use the App to circumvent any producer-HQ confidentiality undertaking, retailer-procurement confidentiality, certification-audit confidentiality, veterinary-confidentiality, marine-environment-monitoring confidentiality, modern-slavery-investigation confidentiality or insurance-claim-handling confidentiality obligation.
13
AI / ML FEATURES AND PROBABILISTIC OUTPUTS
How the App's AI helpers are designed to be used.
13.1. The App may include features that use machine-learning models running on-device (CoreML), the Apple Vision framework and / or server-side models to suggest mortality wording, classify AVFoundation mortality / welfare photographs (for example, "possible gill lesion observed" or "fin damage suspected"), count dead fish from photographs of cull bins, transcribe Speech-framework voice memos, summarise post-shift wrap notes, detect anomalies in mortality trends, biosecurity-zone violations or boot-bath compliance and generate other probabilistic outputs.
13.2. Such outputs are probabilistic. They may be incomplete, inaccurate, misleading, biased, outdated, hallucinated, mistranscribed or unsuitable for a particular purpose. They must not be relied upon as a substitute for human judgement, professional advice or independent verification by qualified veterinary surgeons, fish-health professionals, biosecurity officers, marine biologists, environmental specialists, certification auditors, insurance, legal or fiscal personnel.
13.3. You are responsible for reviewing, verifying and editing every AI-assisted output before it is acted on, shared with any User, shared with any third party (including a major salmon producer HQ, an aquaculture insurance underwriter, a government aquaculture inspector, a major retailer procurement desk, an ASC / BAP / GlobalG.A.P. / RSPCA Assured certification body, an aquaculture veterinary authority, a court, a regulator, a customer, an insurer or an auditor) or used as the basis of any operational, biosecurity, veterinary, welfare, environmental, certification, retailer-compliance, employment or insurance decision.
13.4. AI-assisted features are not used and must not be used to diagnose any notifiable disease (ISA, PD, SRS, IPN, IHN, BKD, sea-lice infestation thresholds, harmful-algal-bloom toxicity or any other agent listed by the WOAH Aquatic Animal Health Code), to prescribe or authorise any veterinary medicinal product, to determine residue / withdrawal periods, to determine welfare scores or stocking-density compliance, to determine certification outcomes (ASC / BAP / GlobalG.A.P. / RSPCA Assured / FOS / Soil Association), to determine retailer-allocation, or to generate behavioural, employability, blacklist or ranking profiles of any worker, contractor or counterparty representative.
14
INTELLECTUAL PROPERTY
Who owns the App and how feedback is treated.
14.1. All right, title and interest in and to the App (including all software, source code, object code, designs, templates, taxonomies, machine-learning models, Vision-framework configurations, training data, prompts, configurations, scoring methods, schemas, documentation, look-and-feel and trademarks) are and remain the exclusive property of ML Consulting and its licensors. No rights are granted to you other than those expressly set out in the Agreement.
14.2. Feedback, suggestions and ideas you provide to ML Consulting about the App may be used by ML Consulting freely and without obligation, provided that such feedback is treated as non-confidential and is not personal data and does not embed Subscribing Customer, producer-HQ, retailer, certification-body, veterinary-authority or government-inspectorate confidential information, biosecurity strategy, mortality data, certification audit findings, retailer-allocation arrangements or marine-environment baselines.
15
UPDATES, AVAILABILITY AND SUPPORT
What you can and cannot expect from the service.
15.1. ML Consulting may release updates, upgrades, bug fixes, security patches and configuration changes to the App at any time. Some updates may be required for the App to remain operable and may require the latest supported iOS, iPadOS or watchOS version.
15.2. The App is provided on a commercially reasonable best-efforts basis. The App, the Counterparty Portals and the Packs are not warranted to be uninterrupted, error-free, free of defects, free of security vulnerabilities or continuously available, and may be subject to scheduled maintenance, App Store review windows, Apple system outages, sea-cage / island / loch / remote-Wi-Fi outages, cellular dead zones, sea-spray-induced device failure and force majeure events. The App is not designed or warranted to function as the sole or primary tool of veterinary authority, notifiable-disease authority, welfare authority, certification authority, retailer-compliance authority, environmental authority or safety-critical control during any Site operation.
15.3. Support is provided at the level specified in the Order Form and otherwise via support+aquabio@mlconsulting.lt on a best-effort basis during ML Consulting's business hours in Vilnius, Lithuania. Pre-Stocking Stand-by Service, where purchased, is governed by clause A14.
16
SUSPENSION AND TERMINATION
When access can be paused or ended and what happens to your data.
16.1. You may stop using the App at any time by uninstalling it. Where the App is subscribed to under an Order Form, termination is governed by the Order Form.
16.2. ML Consulting may suspend or terminate your access to the App, in whole or in part, with or without notice, if (a) you materially breach the Agreement; (b) ML Consulting is required to do so by law, by court order or by Apple; (c) suspension is necessary to protect the security or integrity of the App, the Subscriber Data, other Users, the personal data of workers, App Clip users or counterparty representatives, or third parties; or (d) the Subscribing Customer fails to pay any Subscription Fee when due and does not cure within fourteen (14) days of written notice.
16.3. On termination, your right to use the App ceases. The Subscribing Customer may export Subscriber Data within thirty (30) days of termination using the export functions provided in the App, after which ML Consulting may delete Subscriber Data in accordance with its retention schedule and applicable aquaculture animal-health, veterinary-medicines, certification, retailer-compliance and insurance retention obligations.
17
CONSUMER RIGHTS
How EU consumer protections interact with the Agreement.
17.1. Where you are a consumer within the meaning of Directive 2011/83/EU, nothing in the Agreement affects your mandatory rights under applicable consumer-protection law of your country of habitual residence.
17.2. You acknowledge that, where the App is provided as digital content / digital service on demand and you have given express prior consent and acknowledgement of loss of the right of withdrawal, the fourteen-day right of withdrawal under Article 16(m) of Directive 2011/83/EU does not apply.
18
DISCLAIMERS
How the as-is / as-available framing works in practice.
18.1. Except as expressly stated in the Agreement and except to the extent that liability cannot be excluded or limited under applicable law, the App and the Counterparty Portals are provided on an "as is" and "as available" basis, without warranties of any kind, whether express, implied, statutory or otherwise, including any implied warranties of merchantability, fitness for a particular purpose, satisfactory quality, accuracy, completeness, timeliness, integration, title and non-infringement.
18.2. ML Consulting does not warrant that the App, the Counterparty Portals or the Packs will meet any specific aquaculture animal-health, notifiable-disease, veterinary-medicines, welfare, marine-environment, certification (ASC / BAP / GlobalG.A.P. / FOS / RSPCA Assured / Soil Association), retailer-compliance, government-inspectorate, insurance, modern-slavery, fiscal or audit standard or expectation. The Subscribing Customer is responsible for evaluating fitness for purpose before any operational reliance — and the App must never be relied upon as the sole or primary mechanism of veterinary authority, notifiable-disease authority, welfare authority, certification authority, retailer-compliance authority, environmental authority or safety-critical control during any Site operation.
19
LIMITATION OF LIABILITY
The boundaries of recoverable loss.
19.1. To the maximum extent permitted by applicable law, neither ML Consulting nor its directors, officers, employees, affiliates, contractors or licensors are liable for any indirect, incidental, consequential, special, exemplary or punitive damages, including death, drowning, hypothermia, cold-water immersion injury, manual-handling injury, electrocution, infection or other harm to any worker, contractor or visitor; mortality, mass mortality, mandatory cull, harvest-at-loss, partial harvest or total stock loss; loss of biosecurity status, notifiable-disease-free status, ASC / BAP / GlobalG.A.P. / FOS / RSPCA Assured / Soil Association certification; loss of producer-HQ, retailer, certification body, veterinary, inspectorate or insurer relationship; loss of retailer allocation, market access or supply contract; loss of aquaculture licence, sea-bed lease or marine permit; loss of insurance cover or premium increase; loss of revenue, profits, contracts, goodwill, reputation or expected savings; loss or corruption of data; or business interruption, however caused and on any theory of liability, arising out of or in connection with the Agreement or the App.
19.2. To the maximum extent permitted by applicable law, the aggregate liability of ML Consulting and its directors, officers, employees, affiliates, contractors and licensors arising out of or in connection with the Agreement or the App — whether in contract, tort (including negligence), restitution, statute or otherwise — is limited as set out in clause A14.4 of Schedule A.
19.3. Nothing in the Agreement excludes or limits liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or for any other liability which cannot be excluded or limited under applicable law.
20
INDEMNITY FOR BUSINESS USERS
What the Subscribing Customer underwrites in respect of third-party claims.
20.1. Where you are a Subscribing Customer, you will defend, indemnify and hold harmless ML Consulting and its directors, officers, employees, affiliates and contractors from and against any third-party claims, losses, damages, liabilities, fines, penalties, costs and reasonable legal fees arising out of or in connection with (a) your or any of your Users' use of the App in breach of the Agreement or applicable law; (b) Subscriber Data, including any claim that Subscriber Data infringes intellectual property, privacy, producer-HQ, retailer, certification-body, veterinary, government-inspectorate or insurer confidentiality, or worker-privacy rights; (c) any biosecurity, notifiable-disease, veterinary, welfare, environmental, certification, retailer-compliance, modern-slavery, fiscal, producer-HQ or contractual decision or action taken by you, your Users, your contractors or any third party on the basis of the App, the Packs or the Counterparty Portals; (d) any allegation that you failed to obtain the legal bases, worker representative consultations, biosecurity training records, veterinary prescriptions, residue / withdrawal-period records, marine permit, sea-bed lease conditions, environmental impact assessment, modern-slavery diligence or certification clearances required under applicable law; and (e) any allegation that you failed to perform any biosecurity training, veterinary diagnosis, sample collection or notifiable-disease pre-notification that you should have performed independently of the App.
21
FORCE MAJEURE
Events beyond reasonable control.
21.1. Neither party is liable for any failure or delay in the performance of its obligations (other than payment obligations) to the extent caused by an event beyond its reasonable control, including acts of God, fire, flood, earthquake, storm, harmful algal bloom, sea-water-temperature anomaly, jellyfish bloom, pandemic or epidemic, war, terrorism, civil unrest, strike or industrial dispute affecting third parties, failure of public infrastructure, Apple App Store outage, mobile carrier outage, sea-cage / pen storm damage, hatchery oxygen-injection failure or governmental or regulatory action (including a mandatory cull order).
21.2. The affected party will promptly notify the other and use commercially reasonable efforts to mitigate the impact of the force majeure event.
22
GOVERNING LAW AND DISPUTES
How disagreements are resolved.
22.1. The Agreement is governed by the laws of the Republic of Lithuania, excluding its conflict-of-laws rules and excluding the United Nations Convention on Contracts for the International Sale of Goods.
22.2. Any dispute arising out of or in connection with the Agreement which cannot be resolved amicably will be submitted to the exclusive jurisdiction of the competent courts of Vilnius, Republic of Lithuania, subject to mandatory consumer protection rules that may apply to you under the law of your country of habitual residence.
23
CHANGES TO THIS AGREEMENT
How amendments are communicated and how you can object.
23.1. ML Consulting may amend these Master Terms and the applicable Schedule from time to time. ML Consulting will provide reasonable advance notice of material changes by in-app notice, email to the Subscribing Customer's billing contact or notice on mlconsulting.lt.
23.2. Continued use of the App after the effective date of a change constitutes acceptance of the amended Agreement. If the Subscribing Customer does not accept a material change, the Subscribing Customer may terminate the Order Form for the affected App by written notice within thirty (30) days of the change becoming effective, and ML Consulting will refund any prepaid Subscription Fees for the unused remainder of the then-current term.
24
GENERAL
Entire-agreement, severability, waiver and assignment.
24.1. The Agreement is the entire agreement between you and ML Consulting in respect of the App and supersedes all prior or contemporaneous communications, proposals and representations.
24.2. If any provision of the Agreement is held to be invalid or unenforceable, the remaining provisions remain in full force and effect.
24.3. No failure or delay by ML Consulting in exercising any right under the Agreement constitutes a waiver of that right.
24.4. You may not assign or transfer the Agreement or any of your rights or obligations under it without ML Consulting's prior written consent. ML Consulting may assign the Agreement in connection with a merger, acquisition, corporate reorganisation or sale of all or substantially all of its assets.
24.5. Notices to ML Consulting under the Agreement must be sent to support+aquabio@mlconsulting.lt with a copy to the registered office of ML Consulting MB as published on mlconsulting.lt.
25
APPLE-REQUIRED TERMS
Apple's standard third-party-beneficiary regime.
25.1. You acknowledge that the Agreement is between you and ML Consulting and not with Apple. Apple is not responsible for the App or the content of the App.
25.2. Apple has no obligation to provide maintenance or support services for the App.
25.3. In the event of any failure of the App to conform to any applicable warranty, you may notify Apple, and Apple will, where the App was acquired through the App Store under a paid model, refund the purchase price of the App to you. To the maximum extent permitted by applicable law, Apple has no other warranty obligation whatsoever with respect to the App.
25.4. ML Consulting (and not Apple) is responsible for addressing any claims of you or any third party relating to the App or your possession and use of the App, including product-liability claims, claims that the App fails to conform to any applicable legal or regulatory requirement, and claims arising under consumer-protection or similar legislation.
25.5. In the event of any third-party claim that the App or your possession and use of the App infringes that third party's intellectual property rights, ML Consulting (and not Apple) is solely responsible for the investigation, defence, settlement and discharge of any such claim.
25.6. You represent and warrant that (a) you are not located in a country that is subject to a U.S. Government embargo or that has been designated by the U.S. Government as a "terrorist supporting" country; and (b) you are not listed on any U.S. Government list of prohibited or restricted parties.
25.7. Apple and Apple's subsidiaries are third-party beneficiaries of the Agreement, and upon your acceptance of the Agreement, Apple will have the right (and will be deemed to have accepted the right) to enforce the Agreement against you as a third-party beneficiary.
26
PRECEDENCE — SCHEDULES AND ORDER FORMS
Which document wins where they conflict.
26.1. Where these Master Terms conflict with a Schedule, the Schedule prevails for that App. Where a Schedule conflicts with a signed Order Form, the Order Form prevails to the extent of the conflict.
PART II
Schedule A · AquaBio Control
App-specific terms for AquaBio Control. These terms prevail over the Master Terms in Part I to the extent of any conflict.
A1
APP-SPECIFIC DEFINITIONS
How the Site, the biosecurity chain and the counterparty seats are defined.
In this Schedule A, capitalised terms have the meanings given in clause 4 of the Master Terms, supplemented as follows.
Biosecurity Zone — a defined area at a Site (red / amber / green; quarantine; clean; dirty; transitional; perimeter; visitor-entry) configured in the App, with associated boot-bath, hand-hygiene, equipment-disinfection, vehicle-disinfection and PPE requirements.
Mortality Event — a recorded observation of dead or moribund fish, mollusc, crustacean or equivalent aquatic animal at a Site, captured by a User with AVFoundation photographs, Speech-framework voice memos and Face ID-signed acknowledgements.
Notifiable Disease — any disease listed by Regulation (EU) 2016/429 / Commission Delegated Regulation (EU) 2020/689, the WOAH (formerly OIE) Aquatic Animal Health Code or the locally applicable competent-authority list — including Infectious Salmon Anaemia (ISA), Infectious Haematopoietic Necrosis (IHN), Salmon Rickettsial Septicaemia (SRS), Infectious Pancreatic Necrosis (IPN), Bacterial Kidney Disease (BKD), Koi Herpesvirus Disease, White Spot Disease, Taura Syndrome and equivalents.
Site Lock — the site-manager- or biosecurity-lead-initiated moment at which the Site's biosecurity, mortality and SOP-execution record is locked at end-of-shift handover, captured by a Face ID-signed (and optionally Apple-Watch-initiated) acknowledgement.
App Clip — an on-demand, install-free Apple App Clip session for a visiting government inspector, visiting veterinary authority representative, visiting retailer auditor or visiting certification auditor at the Site entrance, scoped to a single Site visit window.
CoreNFC Token — an NFC tag affixed to a Biosecurity Zone, boot-bath station, piece of equipment, well-boat, transport tank or visitor pass used by the App to identify the asset for chain-of-custody and zone-violation tracking.
Counterparty Pack — a scope-correct read-only Pack made available via Counterparty Portal to a major salmon producer HQ, aquaculture insurance underwriter, government aquaculture inspectorate, major retailer procurement desk, ASC / BAP / GlobalG.A.P. / RSPCA Assured certification body or aquaculture veterinary authority.
Pre-Stocking Stand-by Service — an optional, founder / partner-led operational concierge service governed by clause A14. It is an operational concierge — it is not a guaranteed response time, not an emergency dispatch service, not a veterinary service, not a fish-health service substitute and not a substitute for the Subscribing Customer's own qualified crew or qualified public emergency services.
A2
DESCRIPTION OF AQUABIO CONTROL AND SURFACES
What the operator and counterparty surfaces actually do.
A2.1. AquaBio Control is a biosecurity execution-proof, mortality-escalation, stock-risk traceability, Site-Lock evidence and counterparty audit operating layer for salmon, trout, carp and equivalent aquaculture producers, hatcheries, premium stocked fisheries, multi-site aquaculture groups and their contracted counterparties. The operator surface is iOS-native on iPad (site manager / biosecurity lead cockpit at site office and hatchery control room with PencilKit + Apple Pencil Pro site-map markup), iPhone (workers, hatchery technicians, bailiffs and supervisors at sea cage, pond, tank and quarantine zone in waterproof case and waders — with AVFoundation mortality / welfare photo capture, Vision-framework dead-fish counting, Speech-framework dictation, CoreNFC zone / boot-bath / equipment scan and Face ID-signed task-execution per SOP) and Apple Watch (site manager, biosecurity lead and senior worker wrist haptic during operations — mortality-threshold-exceeded alert, biosecurity-zone-violation alert, SOP-skipped alert, escalation-required pulse, Site-Lock readiness countdown). The counterparty surface is web-link only, scope-correct and read-only, accessed via signed URL.
A2.2. AquaBio Control does not stock, feed, vaccinate, treat, medicate, anaesthetise, slaughter, transport, gut, fillet, pack or refrigerate any aquatic animal. It does not diagnose, sample, screen, identify, characterise, sequence or notify any Notifiable Disease or other pathogen. It does not measure or warrant any water-quality, dissolved-oxygen, temperature, salinity, pH, ammonia, nitrite, nitrate, turbidity, chlorophyll-a or harmful-algal-bloom parameter using any calibrated instrument. It does not authorise any veterinary medicinal product administration, prescribing decision, off-label use, cascade decision or residue / withdrawal-period determination under Regulation (EU) 2019/6 or equivalents. It does not control any feeding system, oxygen-injection system, net pen, sea-lice treatment well-boat, fish-pump, grader, slaughter line, refrigeration system, water-quality probe or telemetry buoy. It does not screen any worker, contractor or counterparty representative against any sanctions, OFAC, modern-slavery, criminal-background, right-to-work or work-permit list.
A2.3. AquaBio Control is an operational record-keeping and evidence-assembly tool. The Subscribing Customer remains the aquaculture business operator under applicable law, the biosecurity duty-holder, the animal-welfare responsible person, the marine-permit and sea-bed lease holder, the legal employer of site staff, the contracting party with the producer HQ, retailer, certification body, veterinary authority, inspectorate, insurer and any government, and the party responsible for all biosecurity, notifiable-disease, veterinary, mortality, welfare, escape, marine-environment, certification, retailer-compliance and insurance decisions.
A3
SUBSCRIBING CUSTOMER RESPONSIBILITIES (PRODUCER / SITE / HATCHERY / MULTI-SITE GROUP)
What stays with you, not with us.
The Subscribing Customer is solely responsible for, and ML Consulting has no liability arising from:
▪ the fish themselves — including their welfare, mortality, stocking density, growth, behaviour, feed conversion, environmental enrichment, slaughter under Council Regulation (EC) 1099/2009 and equivalents, and any biological outcome including total or partial stock loss;
▪ biosecurity execution — including red / amber / green zoning; boot-bath, hand-hygiene and PPE compliance; equipment disinfection; vehicle disinfection at gatehouse; visitor screening; well-boat and harvest-vessel biosecurity; and the implementation of any biosecurity SOP, audit, escalation or corrective action;
▪ compliance with all applicable aquaculture animal-health regimes — including Regulation (EU) 2016/429 (Animal Health Law), Commission Delegated Regulation (EU) 2020/689, the U.K. Aquatic Animal Health (England and Wales) Regulations 2009, the Aquaculture and Fisheries (Scotland) Acts 2007 and 2013, the Norwegian Akvakulturloven and Mattilsynet rules, the Faroese aquaculture law and Heilsufrøðiliga starvsstovan rules, the Chilean Ley General de Pesca y Acuicultura and SERNAPESCA rules, the Canadian Fisheries Act and DFO conditions, the Irish Marine Institute regime, the Tasmanian Marine Farming Planning Act and the WOAH (formerly OIE) Aquatic Animal Health Code;
▪ compliance with all applicable veterinary-medicines regimes — including Regulation (EU) 2019/6, the U.K. Veterinary Medicines Regulations 2013 as amended, the FDA Center for Veterinary Medicine residue rules and equivalents — including veterinary prescriptions, withdrawal periods, off-label / cascade use and residue testing;
▪ compliance with all applicable animal-welfare regimes — including Directive 98/58/EC, Council Regulation (EC) 1099/2009 on the protection of animals at the time of killing, the U.K. Animal Welfare Act 2006, the Norwegian Animal Welfare Act, the RSPCA Assured Salmon Welfare Standard and equivalents;
▪ compliance with all applicable marine-environment, escape-containment, sea-bed-lease, sea-lice-management and benthic-monitoring regimes — including the EU Marine Strategy Framework Directive 2008/56/EC, the U.K. Marine Strategy Regulations, the Norwegian Forurensningsloven, the Norwegian containment-rules NS 9415 / NS 9416, the Crown Estate Scotland sea-bed leases, the Chilean Ley sobre Bases Generales del Medio Ambiente and equivalents;
▪ compliance with all applicable certification standards that the Subscribing Customer holds or seeks — including the Aquaculture Stewardship Council (ASC) Salmon Standard, Best Aquaculture Practices (BAP) / Global Seafood Alliance, GlobalG.A.P. Aquaculture, Friend of the Sea (FOS), Soil Association Salmon and RSPCA Assured — and all associated audit cooperation;
▪ compliance with all applicable retailer-compliance frameworks — including Tesco Producer Sustainability Standards, Sainsbury's Sourced with Integrity, Waitrose Aquaculture Standards, Marks & Spencer Plan A and Aquaculture Code, Whole Foods Quality Standards, Kroger Sustainability, Aldi / Lidl supplier codes, Carrefour Filière Qualité, Albert Heijn / REWE / Edeka sustainable-sourcing programmes and equivalents;
▪ all worker-engagement obligations — including freelance worker contracts, working-time records, rest-break records, occupational-safety procedures, manual-handling for fish, working-at-water training, lone-working procedures, cold-water immersion / hypothermia training, drowning-prevention protocols and Maritime and Coastguard Agency / Sjøfartsdirektoratet / equivalent maritime-safety procedures, and equivalent local provisions of every Site jurisdiction;
▪ compliance with applicable modern-slavery, transparency and human-rights due-diligence regimes — including the U.K. Modern Slavery Act 2015, the Norwegian Transparency Act 2022 (Åpenhetsloven), the Australian Modern Slavery Act 2018, the U.S. California Transparency in Supply Chains Act and equivalents;
▪ all decisions to share a Counterparty Pack with a major salmon producer HQ, an aquaculture insurance underwriter, a government aquaculture inspectorate, a major retailer procurement desk, an ASC / BAP / GlobalG.A.P. / RSPCA Assured certification body, an aquaculture veterinary authority, a court, a regulator, an insurer, a customer or any other third party;
▪ the accuracy, completeness, lawfulness and legal basis of all data submitted into or generated by the App, including AVFoundation mortality / welfare photographs, Vision dead-fish-counting outputs, PencilKit site-map markup, Speech-framework voice memos, CoreNFC scans, Face ID-signed acknowledgements, Site identifiers, zone identifiers, equipment identifiers, producer identifiers, retailer identifiers, certification-body identifiers, veterinary identifiers and inspectorate identifiers;
▪ all decisions about whether and when to stock, feed, treat, harvest, cull, transport or escalate any fish population — irrespective of any green / amber / red indicator, Apple Watch wrist haptic, Live Activity, Dynamic Island, ClockKit complication, CoreNFC scan match, Vision dead-fish-count result or notification displayed by the App;
▪ insurance — the App is not a substitute for stock mortality cover, business-interruption, public-liability, employer-liability, product-liability, marine-pollution, escape-recapture, environmental-damage or any other applicable cover, and the Subscribing Customer remains responsible for procuring and maintaining all required cover at appropriate limits.
A4
SITE MANAGERS, WORKERS, APP CLIP USERS AND COUNTERPARTY PORTALS
Issuing, scoping and revoking the access surface.
A4.1. The Subscribing Customer is responsible for issuing, managing and revoking PINs, biometric enrolments, App-issued credentials, App Clip session tokens, CoreNFC tokens and Counterparty Portal signed URLs, and for ensuring that every User holds the required biosecurity training, veterinary-medicine handling competency, manual-handling, working-at-water, lone-working, cold-water immersion and maritime-safety training before being granted access to corresponding surfaces of the App.
A4.2. Where the Subscribing Customer enables App Clip access for visiting government inspectors, visiting veterinary authority representatives, visiting retailer auditors or visiting certification auditors, the Subscribing Customer is responsible for scoping the App Clip session to the appropriate Site visit window, for posting clear notice that App Clip use is operational and not an entitlement to producer-HQ commercial information, biosecurity strategy, mortality data or retailer-allocation arrangements, and for revoking the session at the end of the engagement.
A4.3. Counterparty Portals are read-only, scope-correct and provided via signed URL. The Subscribing Customer is responsible for the issuance of Counterparty Portal URLs only to authorised counterparty representatives and for the prompt revocation of URLs where the counterparty engagement ends, where a representative changes role or where a URL is suspected to have been leaked or shared with an unauthorised third party.
A4.4. Visiting inspectors, veterinarians, auditors and retailer representatives are data subjects, not Users, except where they are expressly invited to operate the App or an App Clip in a defined operational capacity.
A5
FACE ID, PENCILKIT AND APPLE WATCH SITE-LOCK — NOT EIDAS, NOT VETERINARY AUTHORITY
What the App's signature surfaces are and what they are not.
A5.1. Face ID-based acknowledgements, PencilKit site-map markup on iPad, Apple Watch-initiated Site-Lock signatures, AVFoundation photographs, Vision-framework dead-fish-counting outputs, CoreNFC scans and PIN entries captured by the App are operational acknowledgements designed to create an internal evidence trail for biosecurity, mortality, SOP execution, zone control and end-of-shift handover. They are not Qualified Electronic Signatures (QES) or Advanced Electronic Signatures (AES) under Regulation (EU) 910/2014 (eIDAS), are not notarial deeds, are not court-admissible declarations on their own, are not a substitute for a wet-ink contract or producer-HQ instruction where one is required, are not a veterinary prescription, withdrawal-period certificate or cascade authorisation, are not a Notifiable Disease pre-notification or confirmation, are not an ASC / BAP / GlobalG.A.P. / FOS / RSPCA Assured / Soil Association certification, are not a Tesco / Sainsbury's / Waitrose / Marks & Spencer / Whole Foods / Kroger / Aldi / Lidl / Coop / Costco / Carrefour / Auchan / Edeka / REWE / Albert Heijn / Coles / Woolworths / Loblaw retailer clearance, are not a CITES permit, are not an aquaculture insurance underwriting decision, are not a marine-permit / sea-bed-lease / environmental-impact assessment, are not a worker-safety training certificate and are not a regulatory submission to DEFRA Cefas, Marine Scotland, Mattilsynet, Heilsufrøðiliga starvsstovan, SERNAPESCA, DFO, the Irish Marine Institute, the Tasmanian DPIPWE or any other competent authority.
A5.2. Acknowledgement of a biosecurity step, a mortality observation, a SOP execution, a Notifiable-Disease pre-notification or a Site Lock within the App is an operational acknowledgement that the affected User has received and confirmed the step. It is not, on its own, the formation, variation, novation or termination of any contract between the Subscribing Customer and the producer HQ, retailer, certification body, veterinary authority, inspectorate, insurer or any other third party.
A5.3. Where the Subscribing Customer requires a qualified or advanced electronic signature for any legal, regulatory, veterinary, certification, retailer-compliance, modern-slavery, insurance or contractual purpose, the Subscribing Customer must use an appropriate third-party qualified trust service.
A6
APPLE WATCH, LIVE ACTIVITIES AND NOTIFICATIONS — NOT A SAFETY, VETERINARY OR NOTIFIABLE-DISEASE AUTHORITY
What the wrist surface is, and what it is not.
A6.1. AquaBio Control delivers mortality-threshold-exceeded alert pulses, biosecurity-zone-violation alerts, SOP-skipped alerts, escalation-required pulses and Site-Lock countdown complications to the site manager, biosecurity lead and senior worker Apple Watch via watchOS notifications, ActivityKit Live Activities, Dynamic Island and ClockKit complications, and may surface incident push notifications on iPhone and iPad. These signals are operational helpers — they are not, individually or in aggregate, a 911 / 999 / 112 / locally applicable emergency-services call, a man-overboard alarm, a drowning-detection system, a hypothermia / cold-water immersion alarm, a fire / smoke / gas / evacuation alarm, a veterinary diagnostic instrument, a Notifiable-Disease detection authority, a water-quality / dissolved-oxygen / harmful-algal-bloom instrument, a stocking-density / welfare-scoring authority, a residue / withdrawal-period authority, an ASC / BAP / GlobalG.A.P. / RSPCA Assured certification authority, a retailer-compliance authority, a marine-permit authority, a modern-slavery investigation authority, an insurance underwriting authority or a safety-critical system within the meaning of any aquaculture, marine, occupational-safety or veterinary standard.
CRITICAL RELIANCE PROHIBITED — VETERINARY AND EMERGENCY AUTHORITY STAYS WITH QUALIFIED PEOPLE
The Subscribing Customer must not rely on the App, on the Apple Watch wrist haptic, on the Live Activity, on the Dynamic Island, on the ClockKit complication, on any CoreNFC scan match, on any Vision dead-fish-count result or on any notification as the sole or primary trigger for life-safety actions, including drowning, cold-water immersion, hypothermia, manual-handling injury, electrocution, fire or any other medical emergency; or for Notifiable-Disease pre-notification, veterinary diagnosis, prescribing, residue / withdrawal-period determination, mass mortality declaration, mandatory-cull decision, ASC / BAP / GlobalG.A.P. / RSPCA Assured certification decisions, retailer-allocation decisions or marine-environment decisions. Calling 911 / 999 / 112 or the locally applicable public emergency number remains mandatory whenever any person is in apparent danger of death or serious harm. Veterinary authority remains with the Subscribing Customer's named fish-health professional, marine veterinary surgeon, fish vet and the relevant competent authority (DEFRA Cefas, Marine Scotland, Mattilsynet, Heilsufrøðiliga starvsstovan, SERNAPESCA, DFO, the Irish Marine Institute, the Tasmanian DPIPWE, VMD, FDA Center for Veterinary Medicine and equivalents); biosecurity authority remains with the qualified biosecurity lead; welfare authority remains with the animal-welfare responsible person; and worker-safety authority remains with the safety-trained crew, vessel master and competent persons — in each case independently of the App.
A7
AUDIT LOG, SITE-LOCK EVIDENCE AND COUNTERPARTY PACKS
How the evidence chain works and what it does not warrant.
A7.1. The App maintains an internal audit log of biosecurity events, mortality observations, sea-lice counts, SOP-execution events, Notifiable-Disease pre-notifications, Site-Lock events, CoreNFC scans, AVFoundation captures, Vision dead-fish-counting outputs, PencilKit site-map markup, Face ID-signed acknowledgements, App Clip sessions and Counterparty Portal accesses. The Audit Defence Pack, Site-Lock Evidence Pack, Mortality Escalation Pack, Biosecurity Zone Pack, Notifiable-Disease Pre-Notification Pack, Major Salmon Producer HQ Pack, Aquaculture Insurance Underwriter Pack, Government Aquaculture Inspector Pack, Major Retailer Procurement Pack, ASC / BAP / GlobalG.A.P. / RSPCA Assured Certification Pack and Aquaculture Veterinary Authority Pack are versioned, timestamped, scope-correct exports drawn from this log.
A7.2. The Packs are evidence assistance — they are not, and the Subscribing Customer must not represent them to be, a veterinary diagnostic decision, a Notifiable-Disease confirmation or pre-notification to a competent authority, a residue / withdrawal-period certificate, an ASC / BAP / GlobalG.A.P. / FOS / RSPCA Assured / Soil Association certification or audit outcome, a Tesco / Sainsbury's / Waitrose / Marks & Spencer / Whole Foods / Kroger / Aldi / Lidl / Coop / Costco / Carrefour / Auchan / Edeka / REWE / Albert Heijn / Coles / Woolworths / Loblaw retailer clearance, a marine-permit / sea-bed-lease / environmental-impact assessment, an aquaculture insurance underwriting decision or claims-settlement decision, a modern-slavery diligence outcome or a regulatory submission to DEFRA Cefas, Marine Scotland, Mattilsynet, Heilsufrøðiliga starvsstovan, SERNAPESCA, DFO, the Irish Marine Institute, the Tasmanian DPIPWE, VMD, FDA Center for Veterinary Medicine, WOAH or any other competent authority.
A7.3. The Subscribing Customer is responsible for the legality, completeness and onward use of any Pack the Subscribing Customer chooses to share with a major salmon producer HQ, an aquaculture insurance underwriter, a government aquaculture inspectorate, a major retailer procurement desk, an ASC / BAP / GlobalG.A.P. / RSPCA Assured certification body, an aquaculture veterinary authority, a court, a regulator, an insurer, a customer or any other third party — and for ensuring that such sharing does not breach any producer-HQ commercial confidentiality, retailer-allocation, certification-audit, veterinary, modern-slavery investigation or insurance-claim-handling confidentiality obligation.
A8
AI-ASSISTED FEATURES (VISION DEAD-FISH COUNTING) — NOT VETERINARY, NOT WELFARE AUTHORITY
How probabilistic outputs are scoped, and what they must not be used for.
A8.1. AquaBio Control may use on-device CoreML, the Apple Vision framework and / or server-side machine-learning models to suggest mortality wording, classify AVFoundation mortality / welfare photographs (for example, "possible gill lesion observed" or "fin damage suspected"), count dead fish from photographs of cull bins, transcribe Speech-framework voice memos, summarise post-shift wrap notes, detect anomalies in mortality trends, biosecurity-zone violations or boot-bath compliance and generate other probabilistic outputs.
A8.2. These outputs are advisory only. They must not be used to (a) diagnose any Notifiable Disease (ISA, IHN, PD, SRS, IPN, BKD, sea-lice infestation thresholds, harmful-algal-bloom toxicity, koi herpesvirus disease, white spot disease, taura syndrome or any other agent listed by the WOAH Aquatic Animal Health Code or the locally applicable competent authority); (b) prescribe or authorise any veterinary medicinal product; (c) determine residue / withdrawal periods under Regulation (EU) 2019/6 or equivalents; (d) determine welfare scores, stocking-density compliance, mortality-attribution, escape-attribution or sea-lice-management outcomes; (e) determine ASC / BAP / GlobalG.A.P. / FOS / RSPCA Assured / Soil Association certification or audit outcomes; (f) determine Tesco / Sainsbury's / Waitrose / Marks & Spencer / Whole Foods / Kroger / Aldi / Lidl / Coop / Costco / Carrefour / Auchan / Edeka / REWE / Albert Heijn / Coles / Woolworths / Loblaw retailer-compliance outcomes; (g) determine marine-permit / sea-bed-lease / environmental-impact outcomes; (h) determine any insurance underwriting or claims-handling decision; (i) make any employment, disciplinary, scheduling, hiring or modern-slavery-investigation decision concerning a worker, contractor or counterparty representative.
A8.3. The Subscribing Customer is responsible for reviewing, verifying and editing every AI-assisted output before it is acted on, shared or logged as a finding. AI-assisted features are not used to generate behavioural, employability, blacklist, ranking or financial-risk profiles of any worker, contractor, talent, host, manufacturer representative or counterparty representative.
A9
AQUACULTURE ANIMAL HEALTH LAW, NOTIFIABLE DISEASES AND VETERINARY MEDICINES
The regulated layer that remains entirely with the Subscribing Customer.
A9.1. The Subscribing Customer is the aquaculture business operator under applicable law — including Regulation (EU) 2016/429, the U.K. Aquatic Animal Health (England and Wales) Regulations 2009, the Aquaculture and Fisheries (Scotland) Acts 2007 and 2013, the Norwegian Akvakulturloven, the Faroese aquaculture law, the Chilean Ley General de Pesca y Acuicultura, the Canadian Fisheries Act, the Irish Marine Institute regime, the Tasmanian Marine Farming Planning Act and equivalents — and the biosecurity duty-holder for every Site. The App does not transfer any duty-holder obligation to ML Consulting.
A9.2. Notifiable-Disease pre-notification, sampling, laboratory confirmation, control-zone establishment, mandatory-cull execution and movement-restriction implementation under Regulation (EU) 2016/429 / Commission Delegated Regulation (EU) 2020/689, the WOAH Aquatic Animal Health Code and equivalents are the sole responsibility of the Subscribing Customer and the relevant competent authority (DEFRA Cefas, Marine Scotland, Mattilsynet, Heilsufrøðiliga starvsstovan, SERNAPESCA, DFO, the Irish Marine Institute, the Tasmanian DPIPWE and equivalents).
A9.3. Veterinary-medicines compliance — including Regulation (EU) 2019/6, the U.K. Veterinary Medicines Regulations 2013 as amended, the FDA Center for Veterinary Medicine residue rules and equivalents — is the sole responsibility of the Subscribing Customer and its named veterinary surgeons, including prescribing decisions, off-label / cascade use, withdrawal periods and residue testing. The App does not constitute a Veterinary Information Document, a prescription, a Special Import Certificate or a residue / withdrawal-period certificate.
A9.4. Where any suspected Notifiable Disease, mass mortality, harmful-algal-bloom event, water-quality crash, escape / containment breach, slaughter incident or other significant fish-health or marine-environment event occurs, the Subscribing Customer is solely responsible for the investigation, response, escalation, pre-notification, mandatory-cull cooperation and any other regulatory cooperation, irrespective of any indicator displayed by the App.
A9.5. The Subscribing Customer is responsible for compliance with applicable veterinary-medicines record-keeping, traceability, antibiotic-stewardship, antiparasitic-stewardship and resistance-monitoring obligations.
A10
ASC / BAP / GLOBALG.A.P. / RSPCA ASSURED CERTIFICATIONS AND RETAILER COMPLIANCE
How certification and retailer-compliance obligations interact with the App.
A10.1. The Subscribing Customer is solely responsible for compliance with any certification standard that it holds or seeks — including the Aquaculture Stewardship Council (ASC) Salmon Standard, Best Aquaculture Practices (BAP) / Global Seafood Alliance, GlobalG.A.P. Aquaculture, Friend of the Sea (FOS), Soil Association Salmon and RSPCA Assured. The App does not constitute a certification, an audit pass, a certifying-body endorsement, a chain-of-custody confirmation, an organic certification or a welfare-scheme membership confirmation.
A10.2. The Subscribing Customer is solely responsible for compliance with any retailer-procurement framework — including Tesco Producer Sustainability Standards, Sainsbury's Sourced with Integrity, Waitrose Aquaculture Standards, Marks & Spencer Plan A and Aquaculture Code, Whole Foods Quality Standards, Kroger Sustainability, Aldi / Lidl supplier codes, Carrefour Filière Qualité, Albert Heijn / REWE / Edeka sustainable-sourcing programmes, Coles / Woolworths supplier programmes, Loblaw sustainable-sourcing and equivalents.
A10.3. Where the Subscribing Customer chooses to share a Counterparty Pack with an ASC / BAP / GlobalG.A.P. / FOS / RSPCA Assured / Soil Association certification body, an industry auditor, a major retailer procurement desk or a sustainability watchdog, the Subscribing Customer is solely responsible for the legality, completeness and onward use of the Pack and for ensuring that such sharing does not breach any certification confidentiality, retailer-procurement confidentiality or producer-HQ confidentiality obligation.
A10.4. Where a certification, audit, retailer-allocation or sustainability-watchdog finding adverse to the Subscribing Customer arises, the Subscribing Customer is solely responsible for the response, remediation, escalation and any consumer-facing communication, irrespective of any indicator displayed by the App.
A11
MARINE ENVIRONMENT, ANIMAL WELFARE, CONTAINMENT / ESCAPES AND WORKER SAFETY
Environmental, welfare and worker-safety obligations layered on top of biosecurity.
A11.1. The Subscribing Customer is solely responsible for compliance with applicable marine-environment regimes — including the EU Marine Strategy Framework Directive 2008/56/EC, the U.K. Marine Strategy Regulations, the Norwegian Forurensningsloven and Norwegian NS 9415 / NS 9416 containment standards, the Crown Estate Scotland sea-bed leases, the Chilean Ley sobre Bases Generales del Medio Ambiente and equivalents — including benthic monitoring, water-column monitoring, sea-lice management, escape prevention and reporting, wild-fish interaction, pinniped interaction and any related impact assessment.
A11.2. The Subscribing Customer is solely responsible for compliance with applicable animal-welfare regimes — including Directive 98/58/EC, Council Regulation (EC) 1099/2009, the U.K. Animal Welfare Act 2006, the Norwegian Animal Welfare Act, the RSPCA Assured Salmon Welfare Standard, the Compassion in World Farming aquaculture position and equivalents — including stocking density, environmental enrichment, slaughter-method validation and humane-killing supervision.
A11.3. The Subscribing Customer is solely responsible for compliance with applicable worker-safety regimes — including OSHA, U.K. HSE, EU Framework Directive 89/391/EEC, the Maritime and Coastguard Agency working-at-water rules, the Sjøfartsdirektoratet aquaculture-vessel rules, lone-working-at-water and drowning-prevention rules, cold-water immersion and hypothermia prevention, manual-handling for fish and harvest equipment, working at height on net pens and equivalents.
A11.4. Where any escape, containment breach, marine pollution, sea-lice exceedance, benthic-monitoring exceedance, animal-welfare incident, drowning, hypothermia or other significant marine or worker event occurs, the Subscribing Customer is solely responsible for the investigation, response, escalation and cooperation with the competent environmental, animal-welfare or maritime-safety authority.
A12
PERSONAL DATA OF WORKERS, APP CLIP USERS AND COUNTERPARTY REPRESENTATIVES
How worker and counterparty data is treated.
A12.1. The App processes personal data of site managers, biosecurity leads, hatchery technicians, fish-farm workers, supervisors, operations managers, bailiffs, App Clip users (visiting government inspectors, visiting veterinary authority representatives, visiting retailer auditors, visiting certification auditors) and counterparty representatives, including names, role assignments, PINs, biometric verifications, PencilKit markup, AVFoundation photographs, voice memos, CoreNFC scans, acknowledgements and timestamps. Where the Subscribing Customer chooses to record them, the App may also process User-claimed biosecurity-training, manual-handling, working-at-water, lone-working, cold-water immersion and maritime-safety training certification identifiers; the App does not verify the validity of those credentials.
A12.2. Where the App is used in the employment or freelance-engagement context, the Subscribing Customer is the controller within the meaning of Article 4(7) GDPR and is responsible for ensuring that the rules adopted under Article 88 GDPR by the relevant Member State, the rules of any applicable hospitality- or aquaculture-sector collective bargaining agreement, the rules of any works-council or workforce-representative consultation procedure and the rules of applicable labour law (including the French Code du travail and equivalents) are observed.
A12.3. Where the App captures AVFoundation photographs that include the image of a worker, visitor or counterparty representative, the Subscribing Customer is responsible for obtaining all required image-rights, name-and-likeness and confidentiality clearances independently of the App.
A12.4. Where the Subscribing Customer is a regulated person under the U.K. Modern Slavery Act 2015, the Norwegian Transparency Act 2022, the Australian Modern Slavery Act 2018, the U.S. California Transparency in Supply Chains Act or equivalents, the Subscribing Customer is responsible for the relevant human-rights due diligence, supply-chain reporting and modern-slavery statements independently of the App.
A13
SPECIFIC PROHIBITED USES
Concrete things you must not do with AquaBio Control.
In addition to the Acceptable Use restrictions in clause 12 of the Master Terms, the Subscribing Customer and its authorised users must not:
▪ rely on the App, the Apple Watch surface, any APNs notification, any ActivityKit Live Activity, any ClockKit complication, any CoreNFC scan match, any Vision dead-fish-counting result or any Site-Lock signature as a 911 / 999 / 112 / locally applicable emergency-services call, a man-overboard alarm, a drowning-detection or hypothermia alarm, a fire / smoke / gas / evacuation alarm, a veterinary diagnostic instrument, a Notifiable-Disease detection authority, a water-quality / dissolved-oxygen / harmful-algal-bloom instrument, a stocking-density / welfare-scoring authority, a residue / withdrawal-period authority, an ASC / BAP / GlobalG.A.P. / RSPCA Assured certification authority, a retailer-compliance authority, a marine-permit authority, a modern-slavery investigation authority or an insurance underwriting authority;
▪ connect the App, its outputs or its data to any feeding system, oxygen-injection system, sea-lice treatment well-boat system, fish-pump, grader, slaughter line, refrigeration system, water-quality probe, telemetry buoy, generator, alarm panel, EHR / veterinary-records system, fisheries-management system, customs system or modern-slavery investigation system, except via interfaces that we expressly authorise in writing;
▪ represent or imply that the App, the Apple Watch surface or any Pack is a Regulation (EU) 2016/429 / 2020/689 / 2019/6 compliance certification, a WOAH Aquatic Animal Health Code submission, a DEFRA Cefas / Marine Scotland / Mattilsynet / Heilsufrøðiliga / SERNAPESCA / DFO / Irish Marine Institute / Tasmanian DPIPWE filing or licence, a veterinary prescription or withdrawal-period certificate, an ASC / BAP / GlobalG.A.P. / FOS / RSPCA Assured / Soil Association certification, a Tesco / Sainsbury's / Waitrose / Marks & Spencer / Whole Foods / Kroger / Aldi / Lidl / Coop / Costco / Carrefour / Auchan / Edeka / REWE / Albert Heijn / Coles / Woolworths / Loblaw retailer clearance, a Mowi / Bakkafrost / Cooke / Scottish Sea Farms / Cermaq / Lerøy / SalMar / Grieg / Tassal / Huon / Multiexport / AquaChile / Camanchaca producer-HQ commitment, an AXA XL Aquaculture / Sunderland Marine / Lloyd's / Munich Re / Skuld / Gard / NorClub aquaculture-insurance underwriting decision, a marine-permit or sea-bed-lease determination, a U.K. Modern Slavery Act / Norwegian Transparency Act / Australian Modern Slavery Act compliance certification or a court-admissible declaration of biosecurity or welfare;
▪ use the App for covert monitoring of workers, contractors, visiting inspectors, veterinarians, retailer or certification auditors or any other person, or describe the App to any such person as anything other than an operational biosecurity, mortality, SOP-execution and Site-Lock evidence tool;
▪ use the App to build, train, fine-tune or evaluate any machine-learning model, veterinary diagnostic model, welfare-scoring model, mortality-attribution model, escape-attribution model, certification-risk model, retailer-risk model, behavioural-profiling system or counterparty-risk score, or to share Subscriber Data with any third-party AI provider for that purpose;
▪ enter false biosecurity, mortality, SOP, sea-lice count, Notifiable-Disease, CoreNFC scan, AVFoundation photograph, Vision dead-fish-counting or Speech-framework voice-memo data into the App;
▪ fabricate, alter or backdate Face ID acknowledgements, PencilKit site-map markup, Apple Watch Site-Lock signatures, AVFoundation photographs, Vision dead-fish-counting outputs, Pack contents, Counterparty Portal entries, App Clip session entries or audit-log entries;
▪ forge, replay, share with unauthorised parties or otherwise abuse a Counterparty Portal signed URL, an App Clip session token, a CoreNFC token or a signed Pack export — including by sharing a Major Salmon Producer HQ Pack with a competing producer, sharing a Major Retailer Procurement Pack outside the contracted retailer, sharing a Government Aquaculture Inspector Pack outside the contracted inspectorate, sharing a Veterinary Authority Pack outside the contracted authority, or sharing a Notifiable-Disease Pre-Notification Pack with any unauthorised media outlet;
▪ use the App to present an AVFoundation photograph, Vision dead-fish-counting output, PencilKit markup, Face ID acknowledgement, Apple Watch Site-Lock signature, CoreNFC scan or Pack as a Qualified or Advanced Electronic Signature under Regulation (EU) 910/2014 (eIDAS), as a notarised or legally formed contract, as a veterinary prescription, as a Notifiable-Disease pre-notification, as an ASC / BAP / GlobalG.A.P. / RSPCA Assured certification, as a retailer clearance or as a regulatory submission;
▪ represent or imply that ML Consulting, the App or any Pack is endorsed, certified, approved, audited, sponsored or warranted by Apple, by DEFRA Cefas, by Marine Scotland, by Mattilsynet, by Heilsufrøðiliga starvsstovan, by SERNAPESCA, by DFO, by the Irish Marine Institute, by the Tasmanian DPIPWE, by WOAH, by VMD, by the FDA Center for Veterinary Medicine, by any salmon producer (Mowi / Bakkafrost / Cooke / Scottish Sea Farms / Cermaq / Lerøy / SalMar / Grieg / Tassal / Huon / Multiexport / AquaChile / Camanchaca and equivalents), by any retailer (Tesco / Sainsbury's / Waitrose / Marks & Spencer / Whole Foods / Kroger / Aldi / Lidl / Coop / Costco / Carrefour / Auchan / Edeka / REWE / Albert Heijn / Coles / Woolworths / Loblaw and equivalents), by any certification body (ASC / BAP / GlobalG.A.P. / FOS / Soil Association / RSPCA Assured and equivalents) or by any insurance carrier (AXA XL Aquaculture / Sunderland Marine / Hill Dickinson / Lloyd's / Munich Re / Skuld / Gard / NorClub and equivalents) — except to the extent that any such endorsement is expressly published in writing by the relevant body;
▪ use the App as a substitute for any required veterinary prescription, withdrawal-period certificate, Notifiable-Disease pre-notification, ASC / BAP / GlobalG.A.P. / RSPCA Assured / FOS / Soil Association certification or audit, retailer-procurement audit, marine permit, sea-bed lease, environmental impact assessment, modern-slavery diligence, biosecurity training certificate, manual-handling training certificate, maritime-safety training certificate or insurance documentation;
▪ use the App in any manner inconsistent with the Apple Standard EULA, the Apple Developer Program Agreement or the App Store Review Guidelines.
A14
PLANS, BILLING AND LIABILITY
Commercial structure and the liability cap.
A14.1. Plans. AquaBio Control is offered under the following Plans, each governed by an Order Form executed between ML Consulting and the Subscribing Customer:
▪ Pilot — EUR 15,000 fixed, single high-stakes Site or hatchery, design-partner engagement;
▪ Single Site Pro — EUR 18,000 per year, single Site or hatchery;
▪ Multi-Zone Site Pro — EUR 36,000 per year, single Site with multiple biosecurity zones;
▪ Multi-Site Group Pro — EUR 60,000 per year, multi-site aquaculture group;
▪ Salmon Producer Site — EUR 120,000 per year, single salmon-producer Site at a major producer;
▪ Major Salmon Producer HQ Multi-Region — EUR 240,000 per year for a Mowi / Bakkafrost / Cooke / Scottish Sea Farms / Cermaq / Lerøy / SalMar / Grieg / Tassal / Huon / Multiexport / AquaChile / Camanchaca-tier global producer HQ, with SSO and data-residency commitments as specified in the Order Form;
▪ Major Salmon Producer HQ Portal — EUR 60,000 per year per producer, read-only Counterparty Portal access scoped to opted-in Subscribing Customers;
▪ Aquaculture Insurance Underwriter Risk Desk — EUR 60,000 per year per desk, read-only Counterparty Portal access scoped to opted-in Subscribing Customers;
▪ Government Aquaculture Inspector Portal — EUR 36,000 per year per agency, read-only Counterparty Portal access scoped to opted-in Subscribing Customers;
▪ Major Retailer Procurement Portal — EUR 60,000 per year per retailer, read-only Counterparty Portal access scoped to opted-in Subscribing Customers;
▪ ASC / BAP / GlobalG.A.P. / RSPCA Assured Certification Body Portal — EUR 36,000 per year per body, read-only Counterparty Portal access scoped to opted-in Subscribing Customers;
▪ Aquaculture Veterinary Authority Portal — EUR 36,000 per year per authority, read-only Counterparty Portal access scoped to opted-in Subscribing Customers;
▪ Pre-Stocking Stand-by Service — EUR 18,000 retainer plus EUR 5,000 per incident, founder / partner-led operational concierge service for the pre-stocking window.
A14.2. Billing. All Plans are sold under the Direct Channel — Order Form plus Stripe or bank transfer. Apple In-App Purchase is not used. Subscription Fees are exclusive of VAT and other applicable taxes.
A14.3. Pre-Stocking Stand-by Service. Where the Subscribing Customer purchases the Pre-Stocking Stand-by Service, ML Consulting will, on a commercially reasonable best-efforts basis, acknowledge an opened incident via Apple Watch and dispatch a founder / partner-level operator to assist with operational coordination during the pre-stocking window. The service is an operational concierge — it is not, and the Subscribing Customer must not represent it as, a guaranteed response time, an emergency dispatch service, a veterinary service, a fish-health service, a Notifiable-Disease pre-notification service, a marine-rescue service, a man-overboard service, a mass-mortality service or a substitute for the Subscribing Customer's own qualified crew or qualified public emergency services.
LIABILITY CAP — 12 MONTHS' SUBSCRIPTION FEES ONLY
To the maximum extent permitted by applicable law, the aggregate liability of ML Consulting and its directors, officers, employees, affiliates, contractors and licensors arising out of or in connection with AquaBio Control — whether in contract, tort (including negligence), restitution, statute or otherwise — is limited in any twelve-month period to an amount equal to the Subscription Fees actually paid by the Subscribing Customer (the legal entity that signed the Order Form — typically a salmon, trout, carp or equivalent aquaculture producer, hatchery operator, multi-site aquaculture group, major salmon producer head office, aquaculture insurance underwriter, government aquaculture inspectorate, major retailer procurement desk, ASC / BAP / GlobalG.A.P. / RSPCA Assured certification body or aquaculture veterinary authority) for AquaBio Control during the twelve (12) months immediately preceding the event giving rise to the claim. No fixed monetary floor applies — where no Subscription Fees have been paid in that period, the cap is zero. This clause does not apply to liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or for any other liability which cannot be excluded or limited under applicable law.
Clause A14.4 is the operative liability cap for the purposes of clause 19.2 of the Master Terms.
A15
OPERATIONAL CONTACT POINTS
Where to send everything that needs to reach us.
A15.1. Support, security incidents, GDPR data-subject requests, App Store-related issues and Order Form queries for AquaBio Control are received at support+aquabio@mlconsulting.lt.
A15.2. The operator and data controller (where ML Consulting acts as controller) is ML Consulting MB, legal entity code 306991112, registered in the Republic of Lithuania. Postal correspondence may be addressed to that entity at its registered office as published on mlconsulting.lt.
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