Truck Delay Evidence - Terms and Conditions

ML CONSULTING MB

TruckDelay Evidence

Terms and Conditions

End-User Licence Agreement and Terms of Service for the TruckDelay Evidence iOS application.

Turn waiting time into defensible evidence.

DOCUMENT

TruckDelay Evidence — Terms and Conditions

STRUCTURE

Master Terms + Schedule A (App Schedule)

VERSION

1.0

EFFECTIVE

2026-05-20

OPERATOR

ML Consulting MB · Legal entity code 306991112

JURISDICTION

Republic of Lithuania

DISTRIBUTION

Apple App Store · iOS, iPadOS

USER PROFILE

Business User (B2B) — haulage & drayage operators

BILLING CHANNEL

Direct Channel (Order Form)

WEBSITE

mlconsulting.lt

SUPPORT

Support+truckdelay@mlconsulting.lt

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 and Security

8. Your 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. Governing Law and Disputes

22. Changes to this Agreement

23. General

24. Apple-Required Terms

25. Precedence — Schedules and Order Forms

PART II — SCHEDULE A · TRUCKDELAY EVIDENCE

A1. App-Specific Definitions

A2. Description of TruckDelay Evidence

A3. Organisation, Employer and Driver Responsibilities

A4. Location, Evidence and Privacy-Sensitive Data

A5. Evidence Integrity and Acceptable Use Additions

A6. Claim Packs, Terms Snapshots and Calculations

A7. AI-Assisted Features and Redaction Discipline

A8. Driver Personal Data and Worker Monitoring

A9. Specific Prohibited Uses

A10. Plans, Billing

A11. Operational Contact Points

Preliminary Notice

Read together with Schedule A — TruckDelay Evidence App Schedule.

READ THIS — MASTER TERMS + SCHEDULE A.

These Terms and Conditions apply whenever you download, install, sign in to, subscribe to or otherwise use the TruckDelay Evidence iOS / iPadOS application published by ML Consulting MB on the Apple App Store. The Master Terms (Part I) apply to every iOS / iPadOS application we publish; Schedule A (Part II) addresses TruckDelay Evidence-specific definitions, plan tiers, data warranties, AI feature scope, regulatory carve-outs and liability adjustments. Where Schedule A expressly modifies a provision of the Master Terms, Schedule A prevails for TruckDelay Evidence only (section 25).

This Agreement is concluded between you and ML Consulting MB, a Lithuanian small partnership (legal entity code 306991112) registered in Lithuania (“ML Consulting”, “we”, “us”, “our”). Apple Inc. (“Apple”) is not a party to this Agreement; Apple and its subsidiaries are third-party beneficiaries of the Apple-required terms in section 24.

TruckDelay Evidence is enterprise software intended for business users (B2B) sold under a written Order Form in addition to App Store distribution. The Master-plus-Schedule structure exists so that the App is governed by terms that match its actual function and risk profile.

PART I

Master Terms and Conditions

Agreement and Parties

Who is bound, by what, and from when.

1.1. These Master Terms and Conditions (the “Agreement”) form a binding contract between you and ML Consulting MB, a Lithuanian small partnership with legal entity code 306991112, website mlconsulting.lt, support email support+truckdelay@mlconsulting.lt (“ML Consulting”, “we”, “us”, “our”). They govern your download, installation and use of the TruckDelay Evidence iOS / iPadOS application we publish on the Apple App Store (the “App”) and any related services we make available through the App or our website.

1.2. By downloading, installing, creating an account, signing in, subscribing to, or otherwise using the App, you accept this Agreement and our Privacy Policy (published at https://mlconsulting.lt/privacy-policy). If you do not accept, do not download, install or use the App.

1.3. The App is supplemented by Schedule A (Part II of this document), which addresses App-specific definitions, plan tiers, data warranties, AI feature scope, regulatory carve-outs and liability adjustments. Where Schedule A expressly modifies a provision of these Master Terms, Schedule A prevails for the App only.

1.4. The App is distributed exclusively through the Apple App Store. This Agreement is between you and ML Consulting only. Apple is not a party. Your use of the App is also subject to Apple’s Media Services Terms and Conditions and Apple’s applicable Usage Rules. Apple-specific provisions are set out in section 24 (Apple-Required Terms).

1.5. The App is licensed, not sold. You acquire only the rights expressly granted to you in this Agreement and Schedule A.

Apps Covered and Per-App Schedules

The portfolio framework and the App Schedule that supplements these Master Terms for TruckDelay Evidence.

These Master Terms apply to every iOS / iPadOS application published by ML Consulting MB on the Apple App Store. The TruckDelay Evidence App is supplemented by Schedule A (Part II of this document). Additional Apps published by ML Consulting are listed at https://mlconsulting.lt/app-specific-schedules-hub.

2.1. Current App. TruckDelay Evidence — a waiting-time evidence App for haulage, drayage and road-transport operators. Schedule A sets out App-specific definitions, plan tiers, prices, data warranties, AI feature scope, regulatory carve-outs and liability adjustments.

2.2. Future Apps. ML Consulting may publish additional Apps under these Master Terms by adding new App Schedules. Each new App Schedule takes effect on its Effective Date and applies only to the App it identifies.

2.3. Withdrawn Apps. If we discontinue the App, Schedule A ceases to apply prospectively, but the rights and obligations relating to your use of the App before withdrawal continue under the version of the Agreement in force at the time of that use.

2.4. No silent override across Apps. A provision of Schedule A applies only to TruckDelay Evidence. References in any App Schedule to a regulatory regime, evidentiary standard, data warranty or liability cap do not propagate to other Apps. Cross-App contagion is excluded.

Eligibility and Intended Users

Who may use the App, and in what capacity.

3.1. Age. You must meet any age requirement set by the law of your country of residence. Schedule A may specify a higher minimum age.

3.2. Capacity. You represent that you have the legal capacity to enter into a binding contract.

3.3. Consumer or business user. TruckDelay Evidence is offered for business use only, in accordance with Schedule A. You may not use the App as a consumer.

3.4. Authority for business users. Where you use the App as a business user, the individual creating the account or signing an Order Form represents and warrants that they are authorised to bind the relevant entity (the “Workspace Owner”), and that the entity will use the App in compliance with this Agreement and Schedule A.

3.5. Sanctions and export restrictions. You represent that you are not located in, controlled by, or a national or resident of any country subject to a comprehensive embargo by the European Union, the United States or the United Nations, and that you are not on any restricted-party list maintained by those authorities.

Definitions

Terms used throughout this Agreement.

Capitalised terms used in this Agreement have the meanings set out below. Additional capitalised terms used in respect of TruckDelay Evidence are defined in Schedule A, clause A1.

Account — Your user identity in the App, established via Sign in with Apple, Google sign-in (where supported) or email-and-password authentication.

Agreement — These Master Terms and Conditions, Schedule A (TruckDelay Evidence App Schedule), the Apple-Required Terms (section 24), the Privacy Policy and (where applicable) the relevant Order Form.

Apple — Apple Inc. and its subsidiaries.

App — The TruckDelay Evidence iOS / iPadOS application published by ML Consulting MB on the Apple App Store.

App Schedule / Schedule A — The schedule specific to TruckDelay Evidence that supplements these Master Terms, set out in Part II of this document.

Business User — A natural or legal person using the App for purposes within their trade, business, craft or profession.

Consumer — A natural person using an App for purposes outside their trade, business, craft or profession (Article 2(1) of Directive 2011/83/EU). TruckDelay Evidence is not offered to Consumers (clause 3.3).

Customer Data — All data submitted by, or generated for, you through the App, including content you create, import or upload.

Direct Channel — Billing by ML Consulting under an Order Form (typically by invoice and bank transfer or external card payment), as opposed to App Store IAP.

Order Form — A written or electronic ordering document signed or accepted by a Business User that sets out the Plan, term, fees, limits and any agreed services for the App.

Plan — A tier of access to the App offered by ML Consulting from time to time, as specified in Schedule A and (where applicable) the Order Form.

Privacy Policy — Our privacy notice published at https://mlconsulting.lt/privacy-policy.

Services — The App together with the cloud-based services accessed through it, including any associated website services.

Subscription — A paid (fixed-term or renewing) plan giving access to the App’s paid features.

Subscription Term — The period during which a Subscription is active.

Workspace Owner — The legal entity identified in the Order Form as the account holder and data controller for Customer Data in TruckDelay Evidence.

You / Your — The legal entity (and authorised users acting on its behalf) using the App.

Licence to Use the App

What we grant you, and what you must not do.

5.1. Licence grant. Subject to your continuing compliance with this Agreement, 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, in accordance with the Usage Rules in the Apple Media Services Terms and Conditions, solely for the purposes for which the App is made available.

5.2. Restrictions. You shall not, and shall not permit any third party to:

▪ copy, modify, distribute, rent, lease, sell, sublicence or commercially exploit the App or any part of it, except as expressly permitted by this Agreement, Schedule A or mandatory law;

▪ reverse-engineer, decompile, disassemble, decrypt or otherwise attempt to derive the source code, non-public APIs, non-public algorithms or non-public datasets of the App, except to the extent applicable law (including Article 6 of Directive 2009/24/EC) expressly prohibits the foregoing restriction notwithstanding this limitation;

▪ circumvent any Plan limit, paywall, role check, rate limit, audit log or other technical protection measure;

▪ scrape, bulk-extract, reproduce or commercialise the App’s interface, outputs, datasets, catalogues or claim-pack templates outside personal or licensed use;

▪ interfere with the integrity, performance or security of the App, attempt unauthorised access to other users’ data or transmit malicious code;

▪ use the App in any way that may damage our reputation, Apple’s platform or other users.

5.3. Reservation of rights. All rights not expressly granted under this Agreement are reserved by ML Consulting and its licensors. No title, ownership or intellectual-property right in the App or in the Services is transferred.

What the App Does, and What It Does Not Do

Estimates and operational records — not legal, regulatory or financial determinations.

6.1. Purpose. The App’s purpose is described in Schedule A, clause A2. Schedule A sets out what the App actually does.

6.2. Estimates, not guarantees. Where the App produces estimates, suggestions, scores, confidence bands, customer-leakage rankings, audit-pack outputs, scorecards, claim-pack PDFs or any similar derived output, those outputs are probabilistic and operational and are not legal, regulatory, financial, insurance, tax or professional advice.

6.3. The App is not, and shall not be relied on as:

▪ a regulatory-compliance certification or substitute for legal review;

▪ a transport management system (TMS), route planner, navigation product, payroll system, accounting system or telematics / continuous driver-monitoring system;

▪ a substitute for tachograph data under Regulation (EC) 561/2006 or Directive 2002/15/EC, or for official inspection records, or any other regulated record-keeping that the user is required by law to maintain;

▪ a legal claim platform, debt-collection service, court-filing tool or substitute for the advice of a qualified lawyer;

▪ an offline-first product, save where Schedule A expressly states otherwise;

▪ an automated decision-making system within the meaning of Article 22 GDPR — see section 13.

6.4. Best-effort availability. The App is provided on a best-effort basis. Where Schedule A or an Order Form sets a specific service-level commitment, that commitment governs and the corresponding remedies (typically service credits) are your exclusive remedy for unavailability, save for liability that cannot be excluded under mandatory law.

Accounts and Security

Authentication, credentials and account security.

7.1. Account creation. You must provide accurate and current information when creating an account. You are responsible for keeping your account information up to date.

7.2. Credentials. You are responsible for safeguarding your device, your Apple ID, any Google account used to sign in, your email account and any password you set within the App. We will not be liable for any loss arising from your failure to keep credentials secure, save where such loss results from our gross negligence or wilful misconduct, or where mandatory law provides otherwise.

7.3. Suspected unauthorised access. If you believe your account or device has been compromised, contact us at support+truckdelay@mlconsulting.lt without undue delay.

7.4. One account per authorised user. Unless we agree otherwise in writing or Schedule A expressly permits, each authorised user holds one account. Accounts are personal and not transferable.

7.5. Third-party authentication services. Where the App relies on Apple, Google, iCloud, CloudKit or other third-party services for authentication or storage, your access depends on those services and your settings. We are not responsible for third-party outages or restrictions outside our control.

Your Data and Permitted Use by Us

You own your data. We use it only to operate the Services.

8.1. Ownership. As between the parties, the Workspace Owner retains ownership of all Customer Data submitted to or generated through the App.

8.2. Limited operational licence. You grant ML Consulting a worldwide, royalty-free, non-exclusive, non-transferable licence (with a sub-licence to our hosting and infrastructure providers, including Apple Inc. for iCloud / CloudKit where used, strictly to provide the Services) to host, copy, transmit, display and process Customer Data solely to operate, secure, support and improve the Services and to comply with applicable law.

8.3. No sale; no AI training. We do not sell Customer Data. We do not use Customer Data for third-party advertising. We do not use Customer Data to train any third-party machine-learning model, except where you have given valid prior consent for a specific feature that is clearly described in the App and Schedule A.

8.4. On-device storage and backups. Some App features store Customer Data only on your device or in your private iCloud / CloudKit container. If you delete the App, reset your device, disable iCloud or fail to maintain a backup, that data may be lost. You are responsible for maintaining exports and backups that matter to you, using the in-App export controls.

8.5. Accuracy and provenance of inputs. You are responsible for the accuracy, lawfulness and provenance of data you input, import or upload, including CSV files, photographs, voice notes, free-text commentary and any data you copy from third-party sources. Schedule A imposes specific accuracy and integrity warranties for evidence captured in the App.

Privacy and Data Protection

GDPR-aligned. Two roles — controller and processor. See the Privacy Policy.

9.1. Privacy Policy. Our processing of personal data is described in the Privacy Policy, which is incorporated into this Agreement by reference for the purpose of describing data processing.

9.2. Two roles. Depending on the data category:

(a) in respect of Account Data, Telemetry, Communications and Billing Data, ML Consulting acts as data controller under the GDPR. The Privacy Policy describes that processing.

(b) in respect of Customer Data within Workspaces (including Driver Personal Data — see Schedule A, clause A8), the Workspace Owner is the data controller and ML Consulting is the data processor under a Master Data Processing Agreement (“Master DPA”).

9.3. Apple’s role. Apple acts independently for App Store transactions, Apple ID services, App Store IAP processing and iCloud / CloudKit storage. Apple’s processing is governed by Apple’s Privacy Policy, not by this Agreement or our Privacy Policy.

9.4. Your rights. Subject to applicable law, you may exercise rights of access, rectification, erasure, restriction, portability and objection, and withdraw consent where processing is based on consent. The Privacy Policy explains how. Workspace-controlled requests should generally be directed to the relevant Workspace Owner first.

9.5. Permissions. The App may request access to camera, photos, microphone, notifications, location and iCloud only for the relevant feature. You can manage permissions in iOS settings. Certain features may not work if permissions are refused or withdrawn.

9.6. Data Protection Officer. ML Consulting is not currently required to designate a DPO under Article 37 GDPR. Privacy enquiries may be sent to support+truckdelay@mlconsulting.lt.

9.7. Lithuanian supervisory authority. Our lead supervisory authority is the Lithuanian State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija, VDAI), L. Sapiegos g. 17, LT-10312 Vilnius, vdai.lrv.lt.

Subscriptions, Billing and App Store Rules

TruckDelay Evidence is sold via the Direct Channel (Order Form). App Store auto-renewable subscriptions are not the default channel.

10.1. Plans. TruckDelay Evidence is sold as a B2B subscription under an Order Form. Plan features, limits, prices, currencies and renewal periods are set out in the Order Form and Schedule A. Where ML Consulting separately offers an App Store paywall sheet for any feature, the paywall sheet at the moment of confirmation governs that transaction.

10.2. Apple as merchant of record (where used). Any App Store Subscription, if offered, is sold by Apple via your Apple ID using StoreKit. Your contract for that purchase is concluded between you and Apple at the moment you confirm in the App Store sheet. ML Consulting sets the price and product configuration; Apple is the merchant of record.

10.3. Auto-renewable subscriptions — Apple-required disclosures (where used). Where an App Store auto-renewable Subscription is offered, it is governed by the following terms, which are also displayed in the App Store paywall sheet before purchase:

▪ title and length of the subscription (presented in the paywall sheet);

▪ price per period (presented in the paywall sheet, including local currency and applicable taxes);

▪ any free trial or introductory offer (where offered, the duration and conversion mechanics are presented in the paywall sheet; any unused portion of a free trial is forfeited when a Subscription is purchased, where applicable law permits);

▪ auto-renewal — payment is charged to your Apple ID account at confirmation of purchase. The Subscription automatically renews for an identical period at the then-current price, unless you cancel auto-renewal at least 24 hours before the end of the current period. Your account will be charged for renewal within 24 hours prior to the end of the current period;

▪ how to manage and cancel — you can manage your Subscriptions and turn off auto-renewal in your Apple ID account settings (Settings → [your Apple ID] → Subscriptions) on your device after purchase;

▪ links to the Privacy Policy and to this Agreement appear in the paywall sheet and in the App’s Settings → Legal (or equivalent).

10.4. Local price, currency and tax. Actual prices, local taxes, currency, renewal period and available offers are controlled by the App Store at the time of purchase and may vary by country. Where there is any inconsistency, the App Store paywall sheet at the moment of confirmation controls the transaction.

10.5. Cancellation, deletion and continued access. You may cancel auto-renewal at any time as described in clause 10.3. Cancellation takes effect at the end of the current paid period; you retain access until then. Deleting the App or your account does not cancel an active App Store Subscription — you must cancel separately in your Apple ID settings.

10.6. Refunds. Refunds for App Store purchases are governed by Apple’s policies and may be requested at reportaproblem.apple.com. We cannot directly refund App Store purchases unless Apple provides a mechanism for us to do so. Mandatory consumer rights remain unaffected (sections 17 and 18).

10.7. Price changes. Price changes for active subscriptions are handled through Apple’s App Store process and, where required by law or by Apple’s policies, are subject to your consent. We will notify you of material changes at least thirty (30) days in advance where the law requires it.

Direct Billing for the App

Order Form path — the primary billing channel for TruckDelay Evidence.

11.1. Direct Channel as primary path. TruckDelay Evidence is primarily sold via the Direct Channel. The Workspace Owner subscribes under a written or electronic Order Form with ML Consulting.

11.2. Order Form mechanics. The Order Form sets out the Plan, term, fees, currency, truck / seat / block limits, any onboarding or professional services and any service-level commitment. Subscription Fees are stated exclusive of value-added tax or equivalent indirect taxes, which are payable in addition where applicable. Currency is EUR unless otherwise stated.

11.3. Payment terms. Direct-Channel invoices are payable as set out in the Order Form (typically thirty (30) days net). Late-payment interest accrues at the statutory rate. If an undisputed invoice is unpaid when due, ML Consulting may, on at least seven (7) days’ written notice, suspend access until payment is received. Suspension does not relieve the Business User of payment obligations.

11.4. Renewal. Direct-Channel Plans renew at the end of the Subscription Term in accordance with the Order Form (typically automatic renewal unless the Business User gives written notice of non-renewal at least thirty (30) days before the end of the current Term).

11.5. Apple App Store policies preserved. Direct Channel arrangements do not circumvent Apple’s policies. Where Apple requires that a particular paid feature be sold via App Store IAP, ML Consulting will route that feature through StoreKit; the Direct Channel applies only to features that may lawfully be sold outside the App Store under Apple’s policies (typically enterprise / business-account access).

Acceptable Use

What you must not do with the App.

You must not, and must not permit any third party to:

12.1. Universal prohibitions.

▪ use the App for any unlawful purpose or in any way that infringes the rights of any third party;

▪ use the App to provide a paid service to third parties (for example, valuation, brokerage, regulatory-compliance certification, debt-collection, legal-claim filing) without our prior written agreement and the agreement of Schedule A;

▪ fabricate, alter or backdate evidence, timestamps, photographs, audit events, location data or override records, or attempt to remove or modify watermarks or audit trails on any export, claim pack or scorecard;

▪ import content that infringes third-party intellectual property, privacy, publicity, confidentiality or database rights;

▪ circumvent any Plan limit, paywall, role check, rate limit, audit log or other technical protection;

▪ scrape, bulk-extract, reproduce or commercialise the App’s interface, datasets, catalogues, calculation rules or derived outputs outside personal or licensed use;

▪ interfere with the integrity, performance or security of the App, attempt unauthorised access to data of other users or transmit malicious code;

▪ use the App to make material decisions affecting individuals (for example, employment, contractor renewal, disciplinary action) in reliance solely on App output without meaningful human review and an independent assessment.

12.2. App-specific additions. Schedule A (clauses A5 and A9) adds App-specific acceptable-use rules, including evidence-integrity discipline, worker-transparency rules and prohibitions against covert driver surveillance.

AI / ML Features and Probabilistic Outputs

Optional, opt-in, never autonomous, no third-party model training on your data.

13.1. Where the App offers AI features. The App may include optional AI-assisted helpers (for example, drafting assistants for follow-up emails, summary text for a delay event, OCR helpers, structured-note suggestions). Where present, those features are off by default and are activated only by an explicit configuration choice by an admin of the Workspace Owner.

13.2. Always reviewable; never autonomous. AI output is assistive only. It must be reviewed, edited or rejected by a human user before it is finalised in any record, communication, claim pack, audit pack, customer-facing output or evidentiary document. Schedule A (clause A7) sets specific prohibitions for AI helpers in TruckDelay Evidence.

13.3. No solely-automated decisions with legal or significant effects. ML Consulting does not subject you to decisions producing legal or similarly significant effects based solely on automated processing within the meaning of Article 22 GDPR.

13.4. Estimates only. AI output is a probabilistic suggestion. It is not legal, regulatory, medical, financial, insurance, tax, investment or other professional advice.

13.5. Sub-processor. Where AI text generation is enabled, it is performed by a third-party language-model provider acting as a sub-processor on the terms of the Master DPA. Inputs and outputs are not used by ML Consulting to train any third-party model. Customer-identifying free-text and third-party personal data are redacted before transmission where Schedule A requires redaction.

13.6. EU AI Act readiness. ML Consulting will keep AI features aligned with applicable obligations under Regulation (EU) 2024/1689 (AI Act), including transparency, logging and human-oversight requirements appropriate to the risk classification of the relevant feature.

Intellectual Property

Who owns what.

14.1. Our IP. The App, the Services, the underlying code, the design system, the workflow logic, deterministic engines, datasets, catalogues, claim-pack templates, calculation rules, the ML Consulting and TruckDelay Evidence word and figurative marks, the documentation and all related creative materials are the exclusive property of ML Consulting and its licensors, protected by copyright, database, trade-mark and other intellectual-property laws.

14.2. Your IP. As between the parties, you retain all rights in Customer Data and any branding you upload (for example, report logos on claim packs). The operational licence in clause 8.2 applies.

14.3. Personal use of outputs. You may use outputs generated for your own management, decision-support and recordkeeping purposes within the licensed scope of the App. You may not reproduce, publish, sell, licence, benchmark, train models on or commercially exploit App outputs except as expressly allowed by this Agreement, Schedule A or our written agreement.

14.4. Feedback. If you send us suggestions or feedback, ML Consulting is granted a perpetual, irrevocable, worldwide, royalty-free, sub-licensable licence to use, modify and incorporate them into the Services, without obligation to you. We will not identify you as the source unless you ask us to.

14.5. Third-party trademarks. Customer names, port, depot, carrier, vehicle, plate and similar references appearing in Customer Data may be the trademarks or other protected designations of their respective owners; their appearance is for descriptive purposes and does not imply sponsorship, endorsement or affiliation.

Updates, Availability and Support

Best-effort availability; we may evolve the App.

15.1. Updates. We may release updates, fixes, security patches, new features or modifications. Some updates may be required for security, compatibility, App Store compliance or continued operation. Where a modification materially and adversely affects the App in respect of a paid Subscription mid-term, we will give reasonable advance notice and (subject to mandatory law) the right to terminate the affected Subscription Term and receive a pro-rata refund of pre-paid Subscription Fees attributable to the unused portion.

15.2. Availability. We aim to support the App with reasonable care, but we do not promise uninterrupted availability, permanent compatibility with every iOS or iPadOS version or device, or indefinite availability of any specific feature. Where an Order Form sets a specific service-level commitment, that commitment governs (clause 6.4).

15.3. Support. Support requests may be sent to support+truckdelay@mlconsulting.lt. We may prioritise issues affecting security, access, purchases, data export and data deletion.

15.4. Beta features. Features marked “beta”, “preview” or similar are provided “as is”, may be discontinued and may carry additional terms presented at the point of access.

Suspension and Termination

How and when access can end.

16.1. Termination by you. You may stop using the App at any time. You may delete your account or local data through in-App controls where available. Deleting the App or your account does not automatically cancel an active App Store Subscription (clause 10.5).

16.2. Suspension and termination by us. We may suspend or terminate access to the App, immediately and without refund (subject to mandatory law), where:

▪ you materially breach this Agreement or Schedule A (including the Acceptable Use rules in section 12 and Schedule A clauses A5 and A9);

▪ we are required to do so by law, court order or competent authority;

▪ we have reasonable grounds to believe an account is being used to harm us, other users or third parties (for example, fraudulent purchases, security attacks, evidence fabrication or scraping);

▪ non-payment of an undisputed Direct-Channel invoice continues for more than seven (7) days after notice (clause 11.3).

16.3. Notice and cure. Where the alleged breach is capable of being remedied and where it is reasonable in the circumstances, we will give you notice and a reasonable opportunity to remedy before suspending or terminating.

16.4. Effect of termination. On termination, the licence in section 5 ends. Your data is treated in accordance with the data-export / retention provisions in Schedule A (clauses A5 and A8). Provisions intended to survive termination (including sections 8, 13, 14, 16, 17, 18, 19, 20, 21, 24 and 25, and Schedule A clauses A5, A6, A8, A9 and A10) survive.

Consumer Rights

Mandatory protections preserved where applicable. TruckDelay Evidence is offered to Business Users only (clause 3.3).

17.1. Mandatory rights preserved. If any provision of this Agreement is interpreted as excluding a right that cannot lawfully be limited, excluded or modified under applicable consumer-protection law, that provision is read down to the minimum extent necessary to preserve that right.

17.2. Withdrawal and conformity (Directives 2011/83/EU and 2019/770). Statutory rights of withdrawal (where applicable), digital-content conformity, remedies for defective digital content and protection against unfair contract terms apply where mandatory law grants them.

17.3. Apple as merchant of record. Because any App Store Subscriptions would be purchased from Apple as merchant of record, cancellation and refund requests should normally be made through Apple. We will cooperate reasonably where a legal issue requires our involvement.

17.4. EU Online Dispute Resolution. Consumers resident in the EU may lodge a complaint via the European Commission’s Online Dispute Resolution platform: ec.europa.eu/consumers/odr. Lithuanian Consumers may also contact the Valstybinė vartotojų teisių apsaugos tarnyba (Vilniaus g. 25, LT-01402 Vilnius, www.vvtat.lt).

Disclaimers

What we do not warrant — to the maximum extent permitted by law.

18.1. As-is. Subject to mandatory consumer protection (section 17) and to any express service-level commitment in an Order Form, the App is provided “as is” and “as available” to the maximum extent permitted by applicable law. We expressly disclaim all implied warranties of merchantability, satisfactory quality, fitness for a particular purpose, accuracy, quiet enjoyment and non-infringement.

18.2. Specifically and without limitation, we do not warrant that:

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

▪ all defects will be corrected;

▪ any output (including waiting-time calculations, claim-pack PDFs, audit-pack exports, customer scorecards, OCR results, AI-assisted drafts and similar) will be accurate, complete, reliable, admissible, persuasive, sufficient or accepted in any forum (including by any customer, court, arbitrator, regulator, insurer or counterparty);

▪ use of the App will prevent any commercial dispute, regulatory finding, certification finding, worker injury, illness or environmental incident, or that it will result in any recovery, payment or favourable outcome;

▪ third-party services on which the Services rely (Apple App Store, iCloud, Sign in with Apple, Google sign-in, file-storage, email, AI text APIs, payment processor, PDF rendering) will be available at any specific time.

18.3. Not professional advice. The App does not provide legal, regulatory, medical, financial, accounting, tax, insurance, investment or debt-collection advice. Schedule A sets out the App-specific disclaimers that apply to TruckDelay Evidence.

Limitation of Liability

What may, and may not, be recovered. Read together with Schedule A, clause A10.

19.1. Mandatory carve-outs. Nothing in this Agreement excludes or limits liability for:

(a) death or personal injury caused by negligence;

(b) fraud or fraudulent misrepresentation;

(d) breach by ML Consulting of the Master DPA insofar as such breach gives rise to liability that cannot be limited under Article 82 GDPR; or

(e) any other liability that cannot be excluded or limited under mandatory applicable law (including Lithuanian Civil Code, Articles 6.252 and 6.253; Directive (EU) 2019/770; Directive 2011/83/EU as transposed into Lithuanian law).

19.2. Indirect loss excluded. Subject to clause 19.1, neither party is liable to the other for indirect, consequential, special, incidental, punitive or exemplary loss; loss of profits; loss of revenue; loss of goodwill; loss of data caused by your failure to back up; loss of anticipated savings; loss of opportunity; loss of contract; or business interruption — however arising.

19.3. Floor cap. Subject to clause 19.1 and to the App-specific cap in Schedule A, clause A10.3, our aggregate liability for any and all claims arising out of or relating to this Agreement is limited to the total Subscription Fees paid by you under this Agreement in the twelve-month period preceding the event giving rise to the claim. Where Schedule A specifies a higher cap, the App-specific cap prevails.

19.4. App-specific carve-outs. Schedule A (clause A10.4) adds App-specific carve-outs reflecting the evidence, operational and dispute-outcome exposure profile of TruckDelay Evidence.

19.5. Allocation of risk. The allocation of risk in this section reflects the Subscription Fees and is an essential basis for ML Consulting’s willingness to make the Services available.

Indemnity for Business Users

Reciprocal indemnities applicable to all use of TruckDelay Evidence, which is a B2B App.

20.1. Indemnity by the Business User. The Workspace Owner shall defend, indemnify and hold harmless ML Consulting and its officers, directors, employees and agents from and against any third-party claim, demand, damage, liability, loss or expense (including reasonable legal fees) arising out of or related to:

▪ the Workspace Owner’s (or any of its authorised users’) breach of this Agreement, Schedule A or applicable law;

▪ Customer Data, including any claim that Customer Data infringes a third party’s intellectual property, privacy, publicity or other rights, or that the Workspace Owner failed to provide a required notice or obtain a required consent (including driver privacy notices and works-council consultations under Schedule A clause A8);

▪ the Workspace Owner’s commercial exploitation of any output of the App (including any defamation, competition-law or unfair-commercial-practices claim arising from the use, sharing or publication of customer scorecards, claim correspondence or audit packs);

▪ the Workspace Owner’s relationship with its authorised users, drivers, workers, clients, customers, port operators, depots or other counterparties.

20.2. Indemnity by ML Consulting (IP). ML Consulting shall defend the Workspace Owner against any third-party claim alleging that the App, as supplied by ML Consulting and used in accordance with this Agreement, infringes that third party’s intellectual property rights, and shall pay damages and reasonable legal fees finally awarded against the Workspace Owner. This indemnity does not apply to claims arising from Customer Data, modifications not made by ML Consulting, combinations with materials not provided by ML Consulting where the claim would not have arisen but for the combination, or use of the App after ML Consulting has provided modified or non-infringing functionality and informed the Workspace Owner.

20.3. Conditions. Each indemnity is conditional on the indemnified party (i) giving prompt written notice of the claim, (ii) granting the indemnifying party sole control of the defence and settlement (provided that no settlement may impose any non-indemnifiable obligation on the indemnified party without its written consent), and (iii) providing reasonable assistance at the indemnifying party’s expense.

Governing Law and Disputes

Lithuanian law. EU consumer protections preserved.

21.1. Governing law. This 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 (CISG).

21.2. Consumer protection carve-out. If any individual ever uses the App as a Consumer notwithstanding clause 3.3, that Consumer also benefits from the mandatory consumer-protection rules of their country of habitual residence (Article 6 of Regulation (EC) 593/2008 — Rome I); nothing in this section deprives that person of that protection.

21.3. Jurisdiction (Business Users). For disputes between us and a Business User, the courts of Vilnius, Republic of Lithuania, have exclusive jurisdiction. The parties may agree in an Order Form to refer disputes to confidential arbitration under the rules of the Republic of Lithuania, seated in Vilnius, in Lithuanian; where so agreed, that arbitration is the exclusive forum subject to the carve-outs for injunctive relief and IP disputes.

21.4. Jurisdiction (Consumers). For disputes with Consumers, jurisdiction is determined under Articles 17–19 of Regulation (EU) 1215/2012 (Brussels I bis); a Consumer may bring proceedings in the courts of their country of habitual residence or in the Lithuanian courts; we may bring proceedings only in the courts of the Consumer’s country of habitual residence.

Changes to this Agreement

How updates take effect, and what we tell you.

22.1. Routine updates. We may update this Agreement, Schedule A and the Privacy Policy from time to time, for example to reflect new features, regulatory change or operational change.

22.2. Material changes. Where a change is material and adverse to you, we will give reasonable advance notice (at least thirty (30) days unless a shorter period is required by law) by in-App notice and, where we have your email address, by email. If you do not agree, you may terminate the affected Subscription without penalty before the change takes effect, with a pro-rata refund of pre-paid Subscription Fees attributable to the unused portion.

22.3. Non-material changes (typographical fixes, clarifications, contact details, sub-processor list updates) take effect on posting.

22.4. App-specific updates. Schedule A may be amended independently of these Master Terms. A material adverse change to Schedule A triggers the same notice and termination rights as a change to these Master Terms.

22.5. Versioning. Each version of this Agreement and Schedule A is dated and archived. The version in force at the time of the relevant use governs that use.

General

Severability, assignment, force majeure, notices, language.

23.1. Severability. If any provision of this Agreement is held invalid or unenforceable, the remaining provisions continue in full force, and the invalid provision is replaced by a valid provision that most closely reflects the parties’ intent, consistent with mandatory law.

23.2. Assignment. You may not assign or transfer this Agreement or your account without our prior written consent. We may assign this Agreement in connection with a merger, acquisition, reorganisation, sale of assets or by operation of law, provided the assignee assumes the obligations and your statutory rights are preserved.

23.3. Force majeure. Neither party is liable for failure or delay caused by events beyond its reasonable control (war, civil unrest, natural disaster, pandemic, governmental action, internet or major third-party-platform failure including the Apple App Store), provided notice is given and reasonable mitigation is attempted.

23.4. No waiver. Failure or delay in enforcing any right does not waive that right. A waiver is effective only in writing and signed by us.

23.5. Entire agreement. This Agreement (with Schedule A, the Apple-Required Terms in section 24, the Privacy Policy and any signed Order Form) constitutes the entire agreement between you and ML Consulting in respect of the App and supersedes all prior or contemporaneous communications, save for any pre-contractual statements that cannot be excluded under mandatory law.

23.6. Notices. Notices to ML Consulting must be sent to support+truckdelay@mlconsulting.lt and, where required by law, by registered post to our registered address. Notices to you are sent in-App, by email to the address associated with your account, or by postal mail where reasonably required.

23.7. Language. This Agreement is concluded in English. Translations may be provided for convenience; in case of discrepancy, the English version prevails, save where mandatory consumer law of your country of habitual residence requires otherwise.

23.8. Headings. Headings are for convenience only and do not affect interpretation.

23.9. No agency. Nothing in this Agreement creates any agency, partnership, joint venture or employment relationship between us.

Apple-Required Terms

Apple’s standard licensee provisions, applicable because the App is a Licensed Application distributed via the Apple App Store.

The following provisions apply because the App is a “Licensed Application” distributed via the Apple App Store. Apple Inc. and its subsidiaries are third-party beneficiaries of this section and may enforce its terms against you.

24.1. Acknowledgement. This Agreement is concluded between you and ML Consulting only, and not with Apple. ML Consulting, not Apple, is solely responsible for the App and the content thereof.

24.2. Scope of Licence. The licence granted in section 5 is limited to a non-transferable licence to use the App on any Apple-branded products that you own or control and as permitted by the Usage Rules in the Apple Media Services Terms and Conditions, except that the App may be accessed and used by other accounts associated with you via Family Sharing or volume purchasing.

24.3. Maintenance and Support. ML Consulting is solely responsible for providing any maintenance and support services with respect to the App, as specified in this Agreement or as required under applicable law. Apple has no obligation whatsoever to furnish any maintenance and support services with respect to the App.

24.4. Warranty. ML Consulting is solely responsible for any product warranties, whether express or implied by law, to the extent not effectively disclaimed. In the event of any failure of the App to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price for the App (if any) to you. To the maximum extent permitted by applicable law, Apple will have no other warranty obligation whatsoever with respect to the App, and any other claims, losses, liabilities, damages, costs or expenses attributable to any failure to conform to any warranty will be ML Consulting’s sole responsibility.

24.5. Product Claims. ML Consulting, not Apple, is responsible for addressing any claims of you or any third party relating to the App or your possession and/or use of the App, including: (i) product liability claims; (ii) any claim that the App fails to conform to any applicable legal or regulatory requirement; and (iii) claims arising under consumer protection, privacy or similar legislation, including in connection with the App’s use of HealthKit and HomeKit (where applicable).

24.6. Intellectual Property Rights. 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, not Apple, will be solely responsible for the investigation, defence, settlement and discharge of any such intellectual-property-infringement claim.

24.7. Legal Compliance. You represent and warrant that (i) 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 (ii) you are not listed on any U.S. Government list of prohibited or restricted parties.

24.8. Developer Name and Address. ML Consulting MB, legal entity code 306991112, email support+truckdelay@mlconsulting.lt, is the licensor and the contact point for any user complaint, query or claim with respect to the App.

24.9. Third-Party Terms of Agreement. You must comply with applicable third-party terms of agreement when using the App.

24.10. Third-Party Beneficiary. You and ML Consulting acknowledge and agree that Apple, and Apple’s subsidiaries, are third-party beneficiaries of these Master Terms (and Schedule A which incorporates them), and that, upon your acceptance of this Agreement, Apple will have the right (and will be deemed to have accepted the right) to enforce this Agreement against you as a third-party beneficiary.

Precedence — Schedules and Order Forms

How conflicts between the Master Terms, Schedule A and an Order Form are resolved.

25.1. Order of precedence. In case of conflict between documents forming this Agreement, the order of precedence is:

(i) the Apple-Required Terms in section 24 (in respect of Apple’s role and Apple-required clauses);

(ii) the relevant Order Form (in respect of commercial terms specifically agreed between ML Consulting and the Workspace Owner for the relevant Subscription Term);

(iii) Schedule A (in respect of TruckDelay Evidence-specific provisions); and

(iv) these Master Terms.

25.2. Schedule A applies only to TruckDelay Evidence. A reference in Schedule A to a particular regulatory regime, evidentiary standard, data warranty or liability cap applies only in respect of TruckDelay Evidence. Cross-App contagion is excluded.

25.3. No silent override. Schedule A modifies these Master Terms only where it expressly says so. Where Schedule A is silent on a matter addressed in these Master Terms, the Master Terms apply unmodified.

PART II

Schedule A — TruckDelay Evidence

HOW THIS SCHEDULE IS READ

This Schedule supplements the Master Terms in respect of TruckDelay Evidence only. Where this Schedule expressly modifies a provision of the Master Terms, this Schedule prevails for TruckDelay Evidence and that App only. Where this Schedule is silent, the Master Terms apply unmodified.

VERSION

1.0

EFFECTIVE

2026-05-20

APP

TruckDelay Evidence — waiting-time evidence (iOS)

USER PROFILE

Business User (B2B) — haulage & drayage operators

BILLING CHANNEL

Direct Channel (Order Form)

READ WITH

Master Terms (Part I) v1.0

App-Specific Definitions

Terms additional to section 4 of the Master Terms.

“Claim Pack” — A watermarked PDF generated by TruckDelay Evidence that combines a delay event, its evidence, a frozen snapshot of the applicable customer waiting terms and the audit history at freeze time.

“Driver Personal Data” — Personal data relating to a driver processed through TruckDelay Evidence, including identification and contact data, work-time records, event-based location data and any photograph or audio file in which the driver is identifiable.

“Customer Scorecard” — A customer-leakage ranking generated from reviewed records, naming a commercial counterparty of the Workspace Owner.

“Terms Snapshot” — A frozen, time-stamped record of the waiting-time rates, grace periods, rounding rules, currencies, customer terms, claim windows and chargeability rules in force at the moment a Claim Pack is generated or frozen.

“Event-Based Location” — Location data captured only in connection with a user-initiated or system-linked delay event, evidence submission, or related operational record — not continuous GPS tracking.

Description of TruckDelay Evidence

Evidence chain — but not a legal-outcome guarantee.

A2.1. Purpose. TruckDelay Evidence is a B2B mobile evidence and Claim-Pack platform that helps haulage, drayage, road transport and logistics operators record waiting time, capture supporting evidence, generate Claim Packs, prepare audit packs, track claim outcomes and analyse customer or location-related leakage.

A2.2. Core functions. Driver evidence capture (photographs, documents, voice notes, Event-Based Location data); dispatcher review queue; Claim Pack generation with watermark and Terms Snapshot; Customer Scorecards and analytics from reviewed records; rules-based automations (missing-evidence warnings, repeated-issue detection, stale-PDF detection, claim follow-up reminders); CSV exports; append-only audit logging; optional opt-in AI helpers (clause A7).

A2.3. What TruckDelay Evidence is not. TruckDelay Evidence is not, and shall not be relied on as, a transport management system (TMS), route planner, navigation product, tachograph product, payroll system, accounting system, legal claim platform, court-filing tool, debt-collection service, regulatory-compliance certification or telematics / continuous driver-monitoring system. Claim Packs, scorecards, exports and calculated amounts are supporting materials only.

A2.4. No legal-outcome guarantee. TruckDelay Evidence supports the Workspace Owner’s commercial position but does not guarantee the admissibility, evidential weight, recoverability or legal validity of any Claim Pack, scorecard or export. The Workspace Owner is responsible for the accuracy, lawfulness and use of every record, including whether any underlying customer terms are legally valid, contractually agreed or commercially enforceable.

Organisation, Employer and Driver Responsibilities

What the Workspace Owner must do before granting access.

A3.1. Customer responsibility. The Workspace Owner is responsible for ensuring that use of the App is lawful in its operating jurisdictions and consistent with employment law, transport law, privacy law, customer contracts, union or works-council obligations, internal policies and driver notices.

A3.2. Driver notices. Before inviting drivers or field personnel, the Workspace Owner must provide clear notice explaining: (i) what data is collected; (ii) why it is collected; (iii) who can access it; (iv) how long it is retained; and (v) that the App is designed for event-based evidence capture rather than continuous surveillance. The App records the timestamp of each driver’s acknowledgment of that notice.

A3.3. Driver access. Drivers should only see their own assigned jobs, delay submissions, evidence status and any information required to perform the capture workflow, unless the Workspace Owner configures broader access lawfully and with appropriate notice and legal basis.

A3.4. Authorised users. The Workspace Owner is responsible for the conduct of its authorised users (drivers, dispatchers, admins, finance users) and for any third party with whom they share App outputs.

Location, Evidence and Privacy-Sensitive Data

Event-based location only. No covert surveillance.

A4.1. Event-based location only. TruckDelay Evidence captures driver location at the moment of evidence capture (not continuously). The App does not perform continuous GPS tracking and does not provide a fleet-tracking telematics function.

A4.2. No hidden surveillance. The Workspace Owner must not configure, describe or use TruckDelay Evidence as a hidden employee-surveillance tool. Any use involving workers, contractors or drivers must be transparent and supported by an appropriate legal basis under Article 6(1) GDPR and applicable national worker-monitoring rules.

A4.3. Evidence data. The App may process job references, customer / location details, timestamps, reason codes, driver identity, notes, photos, files, optional voice notes, optional event location, review history, claim amounts, claim status and audit logs.

A4.4. Photographs at third-party premises. The Workspace Owner is responsible for ensuring it has all necessary rights, consents and notices to capture and upload photographs taken at customer, port, depot, warehouse, customs or third-party premises, including any photographs in which third parties (other drivers, port workers, customers’ staff), vehicle registration plates or premises are identifiable, and for any required redaction before external sharing.

Evidence Integrity and Acceptable Use Additions

Specific to TruckDelay Evidence. Additional to section 12 of the Master Terms.

A5.1. Acceptable use additions. In addition to section 12 of the Master Terms, no user shall: fabricate, alter or backdate delay events, Claim Packs, evidence attachments, audit events, timestamps, location data or override records, or attempt to remove or modify the watermark or audit trail on a Claim Pack, export or scorecard.

A5.2. Customer Scorecards. The Workspace Owner uses Customer Scorecards on its own responsibility. ML Consulting does not warrant the accuracy of any conclusion drawn from Customer Scorecard data and is not liable for any defamation, competition-law or unfair-commercial-practices claim arising from the Workspace Owner’s use, sharing or publication of Customer Scorecards.

A5.3. Evidence integrity discipline. ML Consulting will: (i) preserve append-only audit history (capture, edit, status change, snapshot freeze, export, claim send) for the retention period set in the Workspace’s settings (default thirty-six (36) months); (ii) watermark Claim Packs and freeze Terms Snapshots at freeze time; (iii) scope evidence file access through signed URLs with time-to-live no greater than fifteen (15) minutes; and (iv) not destructively delete claim-critical history except through a privileged workflow logged in the audit trail. ML Consulting does not review, validate, certify or authenticate the substance of any evidence.

A5.4. Watermarking and export. All Claim Packs and audit exports generated by the App carry a watermark and an audit-trail block. Removal, modification or obscuring of either is a material breach of this Agreement and may result in immediate suspension or termination under section 16 of the Master Terms.

Claim Packs, Terms Snapshots and Calculations

Workspace-configured terms. Reproducibility — not legal validity.

A6.1. User-configured commercial terms. Waiting-time rates, grace periods, rounding rules, currencies, customer terms, claim windows and chargeability rules are configured or confirmed by the Workspace Owner. ML Consulting is not responsible for verifying whether those terms are legally valid, contractually agreed or commercially enforceable.

A6.2. Frozen snapshots. A Claim Pack may preserve a Terms Snapshot of evidence, terms and calculation inputs at the time of generation or freeze. This supports reproducibility but does not make the underlying claim legally valid if the source data, customer terms or user assumptions are incorrect.

A6.3. Review gates. Missing-evidence warnings, claim-readiness checks, stale-PDF warnings and review states are operational controls only. They reduce weak submissions but do not replace legal, contractual, finance or management review. The Workspace Owner remains responsible for the substantive review of each Claim Pack before it is sent to any third party.

A6.4. Calculated amounts. Calculated waiting-time amounts, charges and claim values produced by the App are derived from inputs the Workspace Owner provides. ML Consulting does not warrant that any calculation will be accepted by a customer, insurer, court, arbitrator or regulator, or that any amount will be recovered.

AI-Assisted Features and Redaction Discipline

Optional, opt-in, rules-first, human-reviewed, redaction-bounded.

A7.1. Rules-first. Rules-based warnings and scorecards may highlight repeated issues, missing evidence, stale Claim Packs, follow-up reminders or customer-leakage patterns. These rules-based features operate without third-party AI providers and run on data within the Workspace Owner’s tenancy.

A7.2. AI assistance is optional and opt-in. AI-assisted drafting helpers (for example, summary text for a delay event, follow-up email drafts, note structuring, wording, translation or monthly summary) are off by default and are activated only when an admin of the Workspace Owner explicitly enables them in Settings. Section 13 of the Master Terms applies.

A7.3. Human review mandatory. Any AI-assisted output is optional, reviewable, editable and must not be sent to a customer, regulator, insurer or court, or relied on for any operational decision, without meaningful human review by an authorised user of the Workspace Owner.

A7.4. Redaction discipline. Where AI helpers are enabled, ML Consulting will not silently send customer-identifying free-text or third-party personal data to a third-party language-model provider. Inputs are redacted in accordance with the rules disclosed in the in-App AI settings, and the Workspace Owner controls whether identifying fields are included.

A7.5. Sub-processor. AI text generation is performed by [INSERT_LLM_PROVIDER] as a sub-processor on the terms of the Master DPA. Inputs and outputs are not used by ML Consulting to train any third-party model.

A7.6. No automated legal action. The App does not automatically issue legal demands, commence proceedings, collect debts, submit regulatory filings or bind customers to payment obligations. All such steps require the Workspace Owner’s separate, informed, manual action outside the App.

Driver Personal Data and Worker Monitoring

Event-based location only. Article 88 GDPR obligations on the Workspace Owner.

A8.1. Event-based location only. TruckDelay Evidence captures driver location at the moment of evidence capture (not continuously). The App does not perform continuous GPS tracking and does not provide a fleet-tracking telematics function.

A8.2. Worker-monitoring obligations of the Workspace Owner. Because driver evidence capture and event-based location processing constitute employee monitoring in many EU jurisdictions, the Workspace Owner shall, before granting any driver access to TruckDelay Evidence:

(i) provide each driver with a privacy notice meeting Articles 13–14 GDPR and the worker-information rules of the country where the driver normally works (in particular under national rules implementing Article 88 GDPR and applicable employment law);

(ii) obtain the driver’s acknowledgment of that notice (the App records the timestamp);

(iii) where required by national law or collective agreement, consult the works council, employee representatives or trade union and obtain any required co-determination or authorisation; and

(iv) establish and document an appropriate lawful basis under Article 6(1) GDPR.

A8.3. No tachograph substitute. TruckDelay Evidence is not a substitute for tachograph data under Regulation (EC) 561/2006 or Directive 2002/15/EC. The Workspace Owner shall not use TruckDelay Evidence to replace, falsify or work around tachograph obligations.

A8.4. Proportionality. The Workspace Owner must use the App’s monitoring features (location capture, photo capture, voice notes) proportionately and only for the legitimate operational purposes described in the driver privacy notice. Use of the App to monitor, discipline or profile workers unlawfully or disproportionately is prohibited.

Specific Prohibited Uses

In addition to section 12 of the Master Terms and clause A5.

The Workspace Owner and its authorised users must not:

▪ use the App for covert employee or driver surveillance, or describe the App to any worker as anything other than an event-based evidence tool;

▪ use Claim Packs as legal filings, court pleadings, statutory demands or debt-collection instruments without independent legal review;

▪ enter false timestamps, fabricated evidence, misleading photos, fake location data or knowingly incorrect customer terms into the App;

▪ use the service to monitor, discipline or profile workers unlawfully or disproportionately;

▪ remove, modify, obscure or attempt to forge the watermark or audit trail on any Claim Pack, scorecard or export;

▪ use Customer Scorecards in a way that breaches competition law, defames a counterparty, or constitutes an unfair commercial practice;

▪ use the App as a substitute for tachograph data, regulated record-keeping, official inspection records, statutory work-time records or any other regulated record the user is required by law to maintain;

▪ integrate the App with, or build into the App, any system that performs continuous GPS tracking, continuous driver-behaviour scoring or automated worker decisions, except as expressly enabled by ML Consulting in writing.

A10

Billing

A10.1. Plans. TruckDelay Evidence is sold as a premium B2B subscription. Plans currently start at the Single Fleet tier and rise to Group / Multi-Site. Plan tiers, truck and seat limits and any service-level commitment are set out in the Order Form.

A10.2. Direct Channel. All paid TruckDelay Evidence Plans are billed through the Direct Channel under clause 11 of the Master Terms. No App Store auto-renewable subscription is offered by default.

A10.4. Operational and dispute-outcome limitation. Without prejudice to clause 19.1 of the Master Terms, ML Consulting is not liable for: (i) the outcome of any commercial dispute, customer renegotiation, regulatory investigation, court or arbitration proceeding; (ii) the value of any unrecovered or written-off claim; (iii) the actual condition or behaviour of any third-party customer, port, depot, warehouse or other counterparty; or (iv) any decision the Workspace Owner takes in reliance on App output.

A10.5. Pre-paid Subscription Fees. Where a Subscription Term is terminated for cause attributable to ML Consulting under clause 22.2 of the Master Terms, ML Consulting will refund pre-paid Subscription Fees attributable to the unused portion of the affected term on a pro-rata basis.