Privacy Policy

Effective Date: 19 October 2025

Last Updated: 19 October 2025

This Privacy Policy outlines how Open Software Solutions LTD ("we", "our", "us") collect, utilize, store, and keep personal data in connection with the use of the Averion Transport Management System ("Averion TMS") and the Averion Mobile Application ("Mobile App"). We take an obligation to the processing of personal data under the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and the Data Protection Act 2018.

1. Data Controller

The data controller processing personal data under this Privacy Policy is:

Open Software Solutions LTD

Registered in England and Wales, Company Number 16553509

Registered Office: 124 City Road, London, EC1V 2NX, United Kingdom

VAT Number: GB498 0965 29

Email: support@averion.co.uk

2. Scope

This Privacy Policy applies to all processing of personal data that results from use of the Averion TMS web platform and Averion Mobile App by business users, employees, contractors, or representatives. The system is designed to be used solely within a business-to-business (B2B) setting.

3. Types of Personal Data

We may process the following types of personal data:

• Identification information including full name, business email address, and telephone number.

• Business information like company name, VAT number, and invoice details.

• Operations information like trip details, vehicle information, drivers' info, and associated documents (like proof of delivery, invoices, or CMRs).

• GPS-calculated location information for real-time tracking of current trips and proof of delivery.

• User-uploaded images and documents through the Mobile App.

• Technical information like IP address, device identifiers, and system logs.

• Billing and invoicing metadata managed by Stripe.

4. Purpose and Legal Bases for Processing

Personal data is processed on the following purposes and legal bases:

(a) To establish user accounts, administer, and authenticate and provide access to Averion services – processing is necessary for contract performance.

(b) For the supply of transport management functionality like trip management, route calculation, driver communication, and document handling – there is processing for the purpose of the performance of a contract.

(c) For making payments, issuing invoices, and maintaining financial records – processing for the purpose of the performance of a contract and for complying with legal obligations.

(d) For purposes of user support, for user communication, and for continuity of service – processing is on legitimate interests grounds.

(e) For system security, fraud prevention, and to comply with the law – processing is on legitimate interests and legal obligations grounds.

5. Data Retention

Personal details will be retained only for so long as it is required to fulfill the purposes for which they were collected. Dormant accounts will be deleted on request or automatically after three years of inactivity, except for retention under legal or regulatory obligations. Financial and accounting records will be held for longer to fulfill statutory obligations.

6. Storage of and transfers of data

All data is stored in the European Union within infrastructure hosted by Supabase in Frankfurt, Germany. Transactional emails are delivered by Resend (United States) under Standard Contractual Clauses granting equivalent protection. Payment details are handled by Stripe in the United Kingdom and European Economic Area. Future accounting integration with Xero will occur within EU and UK data centres.

7. Data Sharing

We do not sell, rent, or otherwise profit from personal information. Data can be disclosed to our approved service providers and data processors only for the purposes of delivering services, making payments, and technical infrastructure. They are Supabase (hosting and authentication), Stripe (payment processing), Resend (email delivery), and Xero (accounting integration, when live). Each processor is bound under a GDPR Article 28 compliant data processing agreement.

8. International Transfers

Where data is transferred outside the United Kingdom or the European Economic Area, such transfers are conducted in accordance with applicable data protection law using legally accepted safeguards like the Standard Contractual Clauses (SCCs) and other appropriate technical and organisational measures.

9. Data Security

We employ appropriate technical and organizational measures to protect personal data against unauthorized disclosure, modification, access, or destruction. Such measures include encryption in transit and at rest, role-based access control, Row-Level Security in Supabase, and system monitoring and patching on a regular schedule.

10. Tracking and Cookies

Cookies that are essential for session management and authentication are used by the Averion TMS web application. No advertising, marketing, or analytics cookies are utilized within the Averion TMS or Averion Mobile App. Our public marketing website (landing page) is on Vercel and utilizes Vercel Analytics to measure anonymous aggregated visitor traffic. This service does not retain cookies, does not keep IP addresses, and does not measure individual visitors. The scope of such analytics is limited to capturing website performance and interest in our services only.

11. Data Subject Rights

Under the UK GDPR and EU GDPR, users shall have the right of access, rectification, erasure, or restriction of processing of their personal data, as well as data portability. Users will also have the right to lodge a complaint with the Information Commissioner's Office (ICO) or relevant supervisory authority. Enquiries may be directed to support@averion.co.uk. We will respond within 30 calendar days.

12. Business Use and Children's Data

Averion is intended for business use only. We don't provide services to consumers who are not business users or gather information from consumers who are under 16.

13. Changes to This Policy

We reserve the right to modify this Privacy Policy periodically to accommodate changes in our processing operations, technology, or law. Any changes will be made available on our website and on the Averion Mobile App. Periodic review of this policy is recommended to users.

14. Contact

In case of questions, requests, or issues related to this Privacy Policy or personal data processing, please contact:

Igor Montkiewicz

Open Software Solutions LTD

124 City Road

London EC1V 2NX

United Kingdom

Email: support@averion.co.uk

Terms of Service

Effective Date: 19 October 2025

Last Updated: 19 October 2025

These Terms of Service ("Terms") govern the access to and use of the Averion Transport Management System ("Averion TMS") and Averion Mobile Application ("Mobile App") operated by Open Software Solutions Ltd ("we", "us", "our"). By accessing or using the Averion platform, all business users ("Customer", "you", "your") agree to be bound by these Terms.

1. Company Information

Open Software Solutions Ltd is a company registered in England and Wales with Company Number 16553509 and registered office at 124 City Road, London EC1V 2NX, United Kingdom (VAT No. GB498 0965 29). All services provided under these Terms are business-to-business (B2B) only.

2. Scope of Service

Averion TMS and the Mobile App are software-as-a-service (SaaS) solutions for transport, logistics, and fleet management. The Service includes trip planning, vehicle tracking, document storage, driver management, and other such functionality as may be provided from time to time. We reserve the right to introduce new features, modify existing features, or make improvements to the Service, provided that any modification does not decrease the features or level of functionality for which the Customer has paid.

3. Account Registration and Access

Customers must register for an account to utilize Averion TMS. It is the responsibility of every Customer to make sure all account details are accurate and updated and maintain confidential log-in credentials. The Customer will be responsible for all activities carried out under its account.

4. Subscription and Billing

Access to Averion TMS is provided on a subscription basis. Fees are due on usage basis, either billed per invoiced payment, monthly or yearly by Stripe or other payment processor as we may specify. Subscriptions renew automatically unless cancelled prior to the renewal date. We reserve the right to suspend use of the Service until full payment is received if payment is not received within fourteen (14) days of the due date. There is no minimum term of contract, and Customers may cancel their subscription at any time via their account options. Fees paid are non-refundable except where required by law.

5. Ownership of Customer Data

All data posted or generated by the Customer in utilizing Averion TMS, including but not limited to trip data, invoices, vehicle data, and documentation ("Customer Data"), is and will remain the property of the Customer. We are simply a data processor and host such data on behalf of the Customer. We will not view, modify, or disclose Customer Data except as required to deliver the Service, to abide by the law, or with the prior written approval of the Customer.

6. Availability of Service

We use reasonable efforts to make the Service available, but uptime is not guaranteed. The Service may be temporarily unavailable or interrupted for maintenance, upgrades, or other technical purposes without notice. We are not liable for any loss, delay, or failure to deliver arising from such interruptions.

7. Obligations of Customer

The Customer will use the Service exclusively for lawful business purposes and in accordance with these Terms. The Customer will not:

• use the Service to transmit illegal or infringing material;

• interfere with the normal operation or security of the Service;

• reverse engineer, decompile, or attempt to obtain the source code of the Service; or

• allow unauthorized third parties to access or utilize the Service.

8. Changes and Updates

We may change or update the Service at any time to improve functionality, performance, or security. The changes will not materially reduce the major features or functionality that existed at the time of subscription.

9. Termination

We reserve the right to terminate or suspend immediately and without notice a Customer's account if the Customer breaches these Terms, is using the Service for illegal purposes, or compromises the integrity of the Service. On termination, access to the Service will cease, and we will destroy Customer Data after three (3) years of inactivity or upon written request from the Customer.

10. Intellectual Property

All right, title, and interest in and to the intellectual property rights in the Averion platform, Mobile App, and documentation shall be and remain the sole and exclusive property of Open Software Solutions Ltd. These Terms grant the Customer a limited, non-exclusive, non-transferable license to access and use the Service for internal business purposes only. No right is granted to copy, modify, distribute, or create derivative works of the Service.

11. Publicity Rights

The Customer here grants us a permission to list its company name and logo as a client in our website, presentations, and marketing materials, without suggesting endorsement. The Customer may cancel this consent at any time upon written notice.

12. Limitation of Liability

To the fullest extent permitted by law, we exclude all implied representations, conditions, and warranties. The Service is provided "as is" and "as available." We will not be liable for any direct, indirect, incidental, special, or consequential damages, including but not limited to loss of profits, data, business, or goodwill, arising in contract, tort, or otherwise, even if advised of the possibility of such damages. Our total cumulative liability for any claim regarding the Service will not exceed the amount paid by the Customer to us in the twelve (12) months immediately prior to the event giving rise to the claim.

13. Indemnity

The Customer shall indemnify and hold Open Software Solutions Ltd, its directors, employees, and affiliates harmless from any claim, loss, or damage arising from the Customer's use of the Service, violation of these Terms, or infringement of any third party's rights.

14. Data Protection and Confidentiality

We process personal data in accordance with our Privacy Policy and the applicable data protection law, including the UK GDPR and Data Protection Act 2018. The parties shall keep all non-public information exchanged in connection with the Service confidential and shall not disclose it to third parties without the other party's prior written consent, except as required by law.

15. Force Majeure

We will not be responsible for any failure or delay in the performance of our commitments under these Terms where such failure or delay is caused by events beyond our reasonable control, including but not limited to acts of nature, internet outages, labor disputes, or governmental measures.

16. Governing Law and Jurisdiction

These Terms and any dispute or claim arising out of or in relation to them shall be governed by and construed in accordance with English and Welsh law. The courts of England and Wales shall have exclusive jurisdiction in relation to all disputes arising out of or in connection with these Terms.

17. Severability

If any provision of these Terms is found invalid or unenforceable, the other provisions will remain in full force and effect.

18. Entire Agreement

These Terms, together with the Privacy Policy and any applicable Data Processing Agreement, constitute the whole agreement between the Customer and Open Software Solutions Ltd in relation to the use of the Service and supersede all prior agreements or understandings, both written and oral.

Data Processing Agreement

Effective Date: 19 October 2025

Last Updated: 19 October 2025

This Data Processing Agreement ("Agreement") forms part of the Terms of Service between the Data Controller and Open Software Solutions Ltd (Data Processor). It governs the processing of personal data by the Data Processor on behalf of the Data Controller under Article 28 of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Parties

1.1 The Data Controller is the Customer using the Averion Transport Management System ("Averion TMS") and Mobile Application ("Mobile App").

1.2 Open Software Solutions Ltd, being registered in England and Wales under Company Number 16553509 and with its registered office at 124 City Road, London EC1V 2NX, United Kingdom (VAT No. GB498 0965 29), is the Data Processor.

2. Subject Matter and Duration

2.1 The purpose of this Agreement is to process the personal data necessary for providing Averion TMS and the Averion Mobile App.

2.2 Processing shall commence on the date of acceptance of the Terms of Service and shall proceed for such duration as the Data Processor provides services to the Data Controller.

3. Nature and Purpose of Processing

3.1 The Data Processor will only process personal data for the purpose of providing, maintaining, and supporting the Averion TMS and Mobile App, such as fleet management, trip tracking, document storage, and related operating services.

3.2 The Data Processor will not process personal data for any other purpose except those explicitly directed by the Data Controller or as otherwise mandated by law.

4. Categories of Data and Data Subjects

4.1 Personal data types are, inter alia: names, business email addresses, phone numbers, trip and route data, GPS location data, vehicle and driver history, uploaded documents or photographs, and metadata.

4.2 Personal data subject types are: the employees, drivers, dispatchers, and representatives authorized by the Customer.

5. Duty of the Data Processor

5.1 The Data Processor will:

(a) process personal data on documented instructions only from the Data Controller;

(b) subject those who are entitled to process personal data to duties of confidence;

(c) implement adequate technical and organisational measures to safeguard personal data against unauthorised or unlawful processing and against accidental loss, destruction, or damage;

(d) assist the Data Controller in fulfilling data protection obligations and responding to data subject requests.

(e) notify the Data Controller of any breach of personal data as soon as possible and at least in forty-eight (48) hours after learning of it;

(f) furnish information necessary for verification of compliance with this Agreement and, on reasonable notice, allow or facilitate audits or inspections conducted by the Data Controller or its accountants.

(g) delete or send back to the Data Controller all personal data upon the cessation of the services except where storage is necessary by law.

6. Responsibilities of the Data Controller

6.1 The Data Controller will ensure that all personal data passed to the Data Processor has been acquired in a lawful manner and all notices and consents required are obtained.

6.2 The Data Controller shall at all times be responsible for the quality, accuracy, and validity of the personal data and the manner in which it was collected.

7. Sub-Processors

7.1 The Data Controller authorizes the Data Processor to utilize the following sub-processors to deliver the Service:

• Supabase – database hosting, authentication, and file storage (AWS EU West - London).

• Stripe – invoicing and payment processing (UK/EU).

• Resend – transactional email delivery (United States, subject to Standard Contractual Clauses).

7.2 Prior notice shall be given by the Data Processor to the Data Controller for any scheduled changes in sub-processors, thereby providing the Data Controller with an opportunity to object to the same.

8. Data Retention

8.1 The Data Processor shall retain personal data for no longer than is necessary to provide the services or as the law requires. Inactive accounts and their information will be deleted after three (3) years of inactivity or earlier upon written request of the Data Controller.

9. Security Measures

9.1 The Data Processor shall implement and maintain technical and organisational security measures, including but not limited to in-transit and at-rest encryption, access controls, role-based authorizations, and continuous system monitoring and patching.

10. International Data Transfers

10.1 Where the personal data is exported outside the United Kingdom or European Economic Area, the Data Processor will make sure that transfer of data outside the country or area is made in accordance with suitable protection measures like the Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner's Office (ICO) or other similar mechanisms.

11. Liability and Indemnity

11.1 Liability of both parties under this Agreement is subject to limitations in the Terms of Service. The Data Controller will indemnify and keep the Data Processor free from any damages, claims, or losses arising out of breach by the Data Controller of any data protection legislation.

12. Governing Law and Jurisdiction

12.1 This Agreement shall be interpreted in accordance with and governed by the laws of England and Wales. English and Welsh courts shall have exclusive jurisdiction to determine any dispute or controversy arising under or in connection with this Agreement.

13. Acceptance

13.1 By opening an Averion account or following the checkout process online, the Customer consents to this Data Processing Agreement and consents that such agreement is binding on the parties under law.

Cookie Policy

Effective Date: 19 October 2025

Last Updated: 19 October 2025

This Cookie Policy explains how Open Software Solutions Ltd ("we", "our", "us") uses cookies and other similar technologies on the Averion website (www.averion.co.uk) and associated online services. This policy is to be read alongside our Privacy Policy, which explains how we handle personal data.

1. What Are Cookies?

Cookies are small text files stored on your device when you access a website. They are utilized routinely to enable websites to function, to enable them to function more effectively, and to provide information to the owners of websites. Cookies can be 'session cookies', which are deleted when you close your browser, or 'persistent cookies', which remain on your device for a specified period of time or until deletion.

2. Our Use of Cookies

We only use cookies as necessary to operate and protect our services. Specifically:

• Authentication cookies – used to enable secure sign-in and maintain session of users in Averion TMS.

• Security cookies – used to protect accounts and prevent fraudulent use.

• Preference cookies – used to remember users' settings like language and plan type.

• Anonymous analytics – our marketing website (averion.co.uk) uses Vercel Analytics to monitor aggregate visitor traffic and performance. This service does not use cookies that identify individuals, does not log IP addresses, and only captures anonymous metrics for statistical analysis.

3. Legal Basis for Use of Cookies

Under the UK Privacy and Electronic Communications Regulations (PECR) and UK GDPR, we can store cookies on your device where they are strictly necessary for the site to work. We will obtain your consent before we store any other type of cookies, including optional analytics. As Averion's core services utilize anonymous and cookieless analytics, a consent banner is not required.

4. Third-Party Cookies

We do not use third-party advertising, tracking, or profiling cookies. Our only third-party analytics service is Vercel Analytics, which processes anonymous, non-identifiable data for performance monitoring.

5. Managing Cookies

You can manage or delete cookies using settings in your internet browser. Most browsers accept cookies automatically, but you can normally change your browser setting to prevent cookies, delete existing cookies, or prompt you before accepting cookies. Please be aware that if you disable essential cookies, some functionality of the website will not work, including secure login to Averion TMS.

6. Data Retention

Session cookies are deleted automatically when the browser is closed. Persistent cookies, if any, are saved only for as long as necessary to fulfill their function and are automatically deleted after twelve (12) months.

7. Updates to This Policy

We reserve the right to update this Cookie Policy at any time to conform to changing technology, legal obligations, or business practices. The latest version will always be available on our website.

8. Contact

If you have any questions or would like to talk to us about our use of cookies, please contact:

Open Software Solutions Ltd

124 City Road

London EC1V 2NX

United Kingdom

Email: support@averion.co.uk

End User Licence Agreement (EULA)

Effective Date: 19 October 2025

Last Updated: 19 October 2025

This End User Licence Agreement ("Agreement") governs the use of the Averion Mobile Application ("App") provided by Open Software Solutions Ltd ("we", "us", "our"). By downloading, installing, or using the App, you ("User") agree that you are subject to the terms and conditions of this Agreement. If you do not, you should not install or use the App.

1. Company Information

Open Software Solutions Ltd is a limited company in England and Wales with Company Number 16553509, whose registered office address is 124 City Road, London EC1V 2NX, United Kingdom (VAT No. GB498 0965 29).

2. Licence Grant

We grant you a limited, non-exclusive, non-transferable, revocable license to download, install, and use the App solely for your internal business purposes with respect to your Averion account. This license does not provide you with any ownership of the App or any intellectual property rights with respect to the App.

3. Restrictions

You are not allowed to:

• copy, reproduce, distribute, or modify the App or any part of it;

• decompile, reverse engineer, or attempt to get the source code of the App;

• sell, sublicense, lend, rent, lease, or otherwise transfer the App to any third party;

• use the App for any criminal use or otherwise in a manner that is incompatible with this Agreement or the law.

4. Ownership and Intellectual Property

All rights in the App, its content, design, and code belong to Open Software Solutions Ltd.Nothing in this Agreement is intended to grant any rights in trademarks, logos, or other proprietary marks held by us.

5. App Store Terms

If you've downloaded the App from Apple App Store or Google Play Store, then the use of the App by you is also governed by their respective policies and terms. If there is a clash between those terms and this Agreement, then the terms of the App Store or the Play Store will prevail only to the extent required by their policies.

6. Data Protection

Your use of the App is subject to the processing of some personal data. All personal data processed or collected using the App shall be treated in accordance with our Privacy Policy, which can be found at www.averion.co.uk/privacy-policy.

7. Updates and Maintenance

We can, from time to time, provide updates, upgrades, or patches to improve the security and performance of the App. These updates may be automatic or require manual installation. We are not under an obligation to provide ongoing support or maintenance except as a matter of law.

8. Termination

We may stop or suspend your use of the App at any time, with or without notice, if you breach any term of this Agreement, use the App illegally, or your Averion account has been terminated. On termination, you shall cease all use of the App and delete all copies from your devices.

9. Disclaimer of Warranties

To the fullest extent legally permissible, the App is provided "as is" and "as available" without any kind of warranty, express or implied, including but not limited to merchantability, fitness for a particular purpose, or non-infringement. We provide no guarantee that the App shall be error-free, uninterrupted, or compatible with all systems or devices.

10. Limitation of Liability

To the fullest extent permissible by law, Open Software Solutions Ltd will not be liable for any indirect, incidental, consequential, or special damages resulting from or in connection with your access to the App, including loss of business opportunities, data, or profits. Our total liability for any claim under this Agreement will not exceed the amount you paid for use of the App in the twelve (12) months immediately preceding the claim.

11. Indemnification

You agree to defend and indemnify Open Software Solutions Ltd, its officers, employees, and affiliates from any claim, loss, or damage arising from your violation of this Agreement or improper use of the App.

12. Governing Law and Jurisdiction

This Agreement and any dispute that may arise out of or in connection with it shall be governed by and construed in accordance with the laws of England and Wales. The courts of England and Wales shall have exclusive jurisdiction over all disputes arising out of or in connection with this Agreement.

13. Entire Agreement

This Agreement, and our Terms of Service and Privacy Policy, constitute the entire agreement between you and us regarding your use of the App and supersedes any prior agreements or representations.

14. Acceptance

By downloading, installing, or using the App, you confirm that you have read, understood, and agree to be bound by this End User Licence Agreement. If you do not agree with such terms, you should uninstall and cease use of the App forthwith.

Refund and Cancellation Policy

Effective Date: 31 October 2025

Last Updated: 31 October 2025

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This Refund and Cancellation Policy ("Policy") forms part of the Terms of Service between Open Software Solutions Ltd ("we", "us", "our") and our customers ("Customer", "you"). It covers all payments, refunds, and cancellations for the Averion Transport Management System ("Averion TMS") and Averion Mobile Application ("Mobile App").

1. General

All Averion subscriptions are paid monthly or annually in advance through our payment processor, Stripe. The Customer is accepting payment terms by entering a subscription according to this Policy and the Terms of Service.

2. 7-Day Refund Window

2.1 We give a seven (7) day refund period from the date of the original purchase of the subscription. Refunds will be issued only where the Customer has not made extensive use of the Averion TMS or Mobile App during that period.

2.2 In order to request a refund, the Customer must write to us at support@averion.co.uk within seven (7) days of the initial payment. Refund requests must include the company name, subscription plan, and payment reference.

2.3 Refunds, once processed, will be credited to the initial payment method within fourteen (14) business days from validation. We reserve the right to refuse refunds in cases of abusive use, account exploitation, or past refund history.

2.4 Refunds can only be granted for licence subscription costs for the first billing period. Any fees (e.g. Platform fees) are not eligible for refunds.

3. Renewals and Recurring Payments

3.1 Subscriptions automatically renew at the end of the billing cycle unless cancelled before the date of renewal.

3.2 The renewal fee will be billed on record using the stored payment method. The Customer is responsible for having current valid payment details.

4. Cancellation Policy

4.1 Customers may cancel their subscription at any time from their Averion account settings or by sending an email to support@averion.co.uk.

4.2 Cancellations will be effective at the end of the current billing period. Use of the Service will remain available until that period ends.

4.3 Once a billing cycle has been initiated, charges will be non-refundable, and no refunds of unused time in kind shall be issued.

5. Refunds for Misuse or Breach

5.1 Refunds will be refused when an account has been suspended or terminated due to a breach of the Terms of Service or use in violation of law.

5.2 Charges for any such cost incurred due to chargebacks, payment disputes, or fraudulent transactions may be credited against future refunds or charged separately.

6. Technical Issues

6.1 If there are technical issues that substantially interfere with the Customer from utilizing the Service for an uninterrupted period of over seventy-two (72) hours, we may, at our sole discretion, provide partial credit or subscription term extension.

6.2 Credits are not automatic and are only provided as a matter of goodwill.

7. Business Use Disclaimer

7.1 We are a business-to-business (B2B) company. As a result, consumer rights to refund under the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 do not apply. We nevertheless do so voluntarily give the seven (7) day refund window outlined in Section 2 as a policy of goodwill.

8. Amendments to This Policy

8.1 We may update this Policy at any time to reflect changes in business practice or changes to legal requirements. The up-to-date version will always be accessible on www.averion.co.uk/refund-policy.

9. Contact

If you have any question about this Policy or wish to return a product or cancel an order, please contact us at:

Open Software Solutions Ltd

124 City Road

London EC1V 2NX

United Kingdom

Email: support@averion.co.uk