Privacy, Legal, Policies, & Additional Resources

LupoToro Group take a strong stance against Modern Slavery and Human Trafficking. The LupoToro Group is a registered and highly regulated company. In order to uphold our high standards both from an internal perspective, as well as from a governmental perspective, we actively adhere to a modern policy to protect our employees, partners, networks, and associates.

Modern Slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

LupoToro Group is a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery. We have a zero-tolerance approach to modern slavery in our organisation, within our private networks of colleagues, conduits, partners, and within any of our supply chains.

The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Employees, contractors, workers, and partners must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy. We are committed to engaging with our stakeholders and networks to address the risk of modern slavery in our operations. We take a risk based, approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Consistent with our risk-based approach we may require; employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our policy and suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the policy.

As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our policy. If we find that individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated, and whether that might represent the best outcome for those individuals impacted by the breach, to terminating such relationships.

Any supplier of works, services, or support to LupoToro Group may be asked to complete a questionnaire on Anti-Slavery. The LupoToro Group will then decide whether to carry out an on-site, in-person audit of the particular party. The results of the questionnaire will also contribute a particular parties’ overall score rating at LupoToro Group and could affect future business. Any suspected breaches of our policy will be reported to relevant authorities.

The LupoToro Group are proud to strongly uphold a no-compromise and zero-tolerance approach to modern slavery, human trafficking, and exploitation of any sort. Any concerns should be immediately raised to legal@lupotoro.com.

Additional Information Regarding The European Economic Area, the United Kingdom, Singapore, Switzerland, Hong Kong, Japan, Australia and New Zealand :

(This section applies only if your information is processed by LupoToro Group in a Member State of the European Economic Area (EEA), the United Kingdom, Singapore, Switzerland, Hong Kong, Japan, Australia or New Zealand).

You are entitled to access any personal data about you held by LupoToro Group by sending a written request to legal@lupotoro.com. You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorised disclosure of your personal information. We will process your request within the time provided by applicable law. You are also entitled to have LupoToro Group modify or delete any information that you believe is incorrect or out of date.

LupoToro Group may occasionally contact you by post, telephone, electronic mail, facsimile, etc., with details of products and services that we believe may be of interest to you. If you do not wish to be contacted in this way, if you wish to exercise your rights of correction and access, or if you require further information regarding our privacy policies and practices in the above-referenced regions, please reach out to us.

1. Website Language Policy Note:

The primary language of our website is English; this is the language we intend the website to be viewed in, and information to be comprehended. The secondary language is French and is automatically translated from English to French using custom coded Artificial Intelligence Language Models (AILM). As a result of this translation, there may be spelling, grammatical, or other errors, omissions, or mistranslations found on our website (www.LupoToro.com) whilst in the French translation mode. Therefore, there is risk that whilst viewing in the French language mode, some information may change or be altered from its original intended meaning(s).

The LupoToro Group endeavour to ensure that minimum errors related to spelling, language, grammar, or similar, are on our website and web hosted content. We strive to make continuous, ongoing corrections in secondary languages offered on our site routinely. We reserve the right to remove additional languages at any time, make necessary updates and changes to the language models (auto translation plugins) used at any time, without notice. We take no responsibility for any errors, spelling or grammatical mistakes, mistranslations, omissions, glitches, or any other errors stemming from automatically translated content on our website. To reduce the risk of this, please view the website in its primary language, English.

2. Advice

It is herein informed that LupoToro Group do not provide financial, legal, or other advice anywhere on our official websites, blogs, news articles (‘News’ and ‘News Feed’) pages, promotional material, emails, notifications or any other digital or printed materials, or formats. All information displayed on official LupoToro Group platforms are intended as general information only.

Our general information excludes ‘advice’, and includes any information provided to anyone through not only LupoToro.com, but directly or indirectly, through messages (text, email, social media, link, or otherwise), by any LupoToro Group employee, representative, consultant, contractor, or any other formally associated party. All information is to be used for information and educational purposes only. It is not intended to provide investment, financial, accounting, legal, tax or other professional advice and should not be relied upon or regarded as a substitute for such advice. We recommend that you seek advice from a qualified professional advisor before acting on any information or other content appearing on this website, the LupoToro Group social media sites or any website to which they may be linked. We do not provide you with advice and by using anything displayed on this website, you are aware of this and hereby indemnify us from any financial or other responsibility.

3. Terms of Service and Disclaimers

Capitalised terms, unless otherwise defined, have the meaning specified within the Definitions section below. This Terms of Service, along with our Privacy Policy, any mobile license agreement, and other posted guidelines within our Website, collectively “Legal Terms”, constitute the entire and only agreement between you and LupoToro Group, and supersede all other agreements, representations, warranties and understandings with respect to our Website and the subject matter contained herein. We may amend our Legal Terms at any time without specific notice to you. The latest copies of our Legal Terms will be posted on our Website, and you should review all Legal Terms prior to using our Website. After any revisions to our Legal Terms are posted, you agree to be bound to any such changes to them. Therefore, it is important for you to periodically review our Legal Terms to make sure you still agree to them.

4. Disclaimers, Policies and Terms of Service Update Date

The last update to our policies and terms of service was posted on 2 January 2024.

5. Definitions

By accessing this website, you are agreeing to be bound by these Website Terms and Conditions of Use, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this Website are protected by applicable copyright and trademark law.

a) The terms “us” or “we” or “our” refers to LupoToro Group the owner of the Website.

b) A “Visitor” is someone who merely browses our Website, but has not registered as Member.

c) A “Member” is an individual that has registered with us to use our Service.

d) Our “Service” represents the collective functionality and features as offered through our Website to our Members.

e) A “User” is a collective identifier that refers to either a Visitor or a Member.

f) All text, information, graphics, audio, video, and data offered through our Website are collectively known as our “Content”.

6. Use License

Permission is granted to temporarily download one copy of the materials (information or software) on LupoToro Group’s Website for personal, non-commercial transitory viewing only. This is the grant of a license, not a transfer of title, and under this license you may not:

a. modify or copy the materials;

b. use the materials for any commercial purpose, or for any public display (commercial or non-commercial);

c. attempt to decompile or reverse engineer any software contained on LupoToro Group’s website;

d. remove any copyright or other proprietary notations from the materials; or

e. transfer the materials to another person or “mirror” the materials on any other server.

This license shall automatically terminate if you violate any of these restrictions and may be terminated by LupoToro Group at any time. Upon terminating your viewing of these materials or upon the termination of this license, you must destroy any downloaded materials in your possession whether in electronic or printed format.

7. Restricted Uses

Listing of offered products on the Website could be used only for lawful purposes by Users of the Website. You could not frame or utilize framing techniques to enclose any hallmark, logo, copyrighted image, or most proprietary details (consisting of images, text, page layout, or type) of LupoToro Group without express composed consent. You might not use any meta tags or any various other “unseen text” utilizing LupoToro Group’s name or trademarks without the express written consent of LupoToro Group. You agree not to offer or modify any content found on the Website consisting of, however not limited to, names of Users and Content, or to recreate, display, openly perform, distribute, or otherwise make use of the Material, in any way for any public function, in connection with services or products that are not those of LupoToro Group, in other way that is likely to trigger confusion among consumers, that disparages or challenges LupoToro Group or its licensors, that dilutes the strength of LupoToro Group’s or its licensor’s residential property, or that otherwise infringes LupoToro Group’s or its licensor’s copyright rights. You also agree to abstain from abusing any of the material that appears on the Site. The use of the Material on any other website or in a networked computer system environment for any purpose is prohibited. Any code that LupoToro Group develops to generate or show any Material of the pages making up the Website is likewise secured by LupoToro Group’s copyright, and you may not copy or adjust such code.

LupoToro Group has no duty to keep track of any products published, transferred, or connected to or with the Site. If you think that something on the Website breaches these Terms please contact us at legal@lupotoro.com.

If alerted by a User of any products which allegedly do not conform to these Terms, LupoToro Group could in its single discernment explore the allegation and figure out whether to take other actions or ask for the removal or get rid of the Content. LupoToro Group has no liability or duty to Individuals for efficiency or nonperformance of such activities.

8. Electronic Communication

You are connecting with us electronically when you go to the Website or send out emails to us. You consent to get interactions from us online. We will connect with you by email or by uploading notifications on the Site.

9. Your Account

If you utilize the Website, you are accountable for maintaining the confidentiality of your account and password and you accept responsibility for all activities that happen under your account and password. You also accept not to reveal any personally identifiable information, consisting of, however not limited to, first and last names, credentials, or various other details of a personal nature (“Personal Data”) from the Site. Your disclosure of any Personal Data on the website might result in the immediate termination of your account. LupoToro Group additionally reserves the right to refuse service, terminate accounts, and remove or edit Content at its sole discernment. LupoToro Group does not guarantee the truthfulness, precision, or dependability of Content on the site, consisting of Personal Data. Each Individual is accountable for upgrading and changing any pertinent account info when essential to preserve the truthfulness, precision, or reliability of the details.

10. Reviews, Comments, and Other Material

Registered Users of the Website might post evaluations and remarks of a product and services purchased by means of the Website, so long as the Material is not unlawful, profane, threatening, defamatory, an invasive of privacy, infringing of intellectual property rights, or otherwise injurious to third parties or objectionable and does not include industrial solicitation, mass mailings, or any type of “spam.” You may not use another User’s account to impersonate a User or entity, or otherwise deceive as to the origin of the opinions. LupoToro Group reserves the right (however is not bound) to eliminate or modify such Material, but does not regularly examine posted Material. If you post an evaluation or send comments, and unless LupoToro Group suggests otherwise, you grant LupoToro Group a nonexclusive, royalty-free, permanent, irrevocable, and completely sublicensable right to utilize, recreate, modify, adjust, release, equate, create derivative works from, distribute, and screen such content throughout the world, in any media. You grant LupoToro Group and sublicenses the right to utilize your name in connection with such Material, if they choose. You represent and require that You own or otherwise control all the rights to the content that You post; that the content is accurate; that use of the content You supply does not violate this policy and will not trigger injury to anyone or entity; which You will indemnify LupoToro Group for all claims resulting from Content You supply. LupoToro Group has the right but not the commitment to edit and keep track of or eliminate any task or Material. LupoToro Group takes no duty and assumes no liability for any content published by You or any 3rd party.

11. LupoToro News Feed and Media on the Website

The News Feed and any news articles on the LupoToro.com website is published for informative purposes only. Whilst many articles are original works, some are reshared articles, and will be credited and referenced accordingly, if, where, and when applicable. If a credit is missing, please contact teams@lupotoro.com to report it.

12. Legal Compliance

You agree to comply with all applicable domestic and international laws, statutes, ordinances, and regulations regarding your use of our website. LupoToro Group reserves the right to investigate complaints or reported violations of our Legal Terms and to take any action we deem appropriate, including but not limited to cancelling your Member account, reporting any suspected unlawful activity to law enforcement officials, regulators, or other third parties and disclosing any information necessary or appropriate to such persons or entities relating to your profile, email addresses, usage history, posted materials, IP addresses and traffic information, as allowed under our Privacy Policy.

13. Intellectual Property

Our Website may contain our service marks or trademarks as well as those of our affiliates or other companies, in the form of words, graphics, and logos. Your use of our Website does not constitute any right or license for you to use such service marks/trademarks, without the prior written permission of the corresponding service mark/trademark owner. Our Website is also protected under international copyright laws. The copying, redistribution, use or publication by you of any portion of our Website is strictly prohibited. Your use of our Website does not grant you ownership rights of any kind in our Website.

14. Revisions and Errata

The materials appearing on LupoToro Group’s website could include technical, typographical, or photographic errors. LupoToro Group does not warrant that any of the materials on its website are accurate, complete, or current. LupoToro Group may make changes to the materials contained on its website at any time without notice. LupoToro Group does not, however, make any commitment to update the materials.

15. Disclaimer

The materials on LupoToro Group’s website are provided “as is” LupoToro Group makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties, including without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights. Furthermore, LupoToro Group does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its Internet Website or otherwise relating to such materials or on any sites linked to this site. The Website serves as a venue for Individuals to purchase distinct service or products. Neither LupoToro Group nor the Website has control over the quality or fitness for a particular function of a product. LupoToro Group likewise has no control over the accuracy, reliability, completeness, or timeliness of the User-submitted details and makes no representations or warranties about any info on the Site. The website and all details, content, materials, products (including software application) and services listed on or otherwise made available to you through this website are provided by LupoToro group on an “as is” and “as available” basis, unless otherwise specified in writing. LupoToro group makes no representations or warranties of any kind, express or implied, about the operation of this website or the info, materials, products (including software) or services listed on or otherwise made available to you through this site, unless otherwise pointed out in writing. You expressly agree that your use of this website is at your own risk. To the complete extent permissible by applicable law, LupoToro group disclaims all warranties, express or implied, including, but not limited to, implied warranties of merchantability and physical fitness for a particular purpose. LupoToro group does not warrant that this website; details, content, materials, products (including software application) or services consisted of on or otherwise made available to you through the site; its servers; or email sent from LupoToro group are without viruses or other harmful elements. LupoToro group will not be liable for any damages of any kind arising from the use of the website or from any details, content, materials, products (including software application) or services listed on or otherwise made available to you with this site, including, but not limited to direct, indirect, incidental, punitive, and consequential damages, unless otherwise pointed out in writing. Under no scenario shall LupoToro group’s liability developing from or in connection with the website or your use of the website, despite the reason for action (whether in agreement, tort, breach of service warranty or otherwise), go beyond $100.

16. Links to Other Websites

Our website may contain links to third party websites. These links are provided solely as a convenience to you. By linking to these websites, we do not create or have an affiliation with, or sponsor such third-party websites. The inclusion of links within our website does not constitute any endorsement, guarantee, warranty, or recommendation of such third-party websites. LupoToro Group has no control over the legal documents and privacy practices of third-party websites; as such, you access any such third-party websites at your own risk.

17. Site Terms of Service Modifications

LupoToro Group may revise these Terms of Service for its Website at any time without notice. By using this website, you are agreeing to be bound by the then current version of these Terms and Conditions of Use.

18. Group Assets

Group Assets are entities on our website who the LupoToro Group either have an ownership stake in (part or in full) or have agreed to host any particular entity on our website (such as a third-party company) which is wholly owned and controlled by a third-party, of who we may have potential mutual benefits. Working example: Placement of a third-party accounting firm on our website, and promoting their services, in exchange for that third-party firm providing LupoToro Group discounted or additional services for our private use. Unless specified specifically, any Group Asset on our website is a third-party entity that we reserve the right to add, remove, or update at any time without notice. We do not take responsibility for any third-party asset on our website, the information they disclose, communication they provide, works they complete or works they are subcontracted to (if any), and are hereby indemnified from responsibility pertaining to any third-party controlled asset on our website. Any person or company will be informed of this specific clause should any Group Asset be or form part of any discussion, agreement, or other exchange with the LupoToro Group. Any non-third party entity or asset which the LupoToro Group are currently building, testing, incubating (concept stage and not fully active or in operation), or pending official active release (active operation) will be listed under the Group Asset tab. This includes: DangerPretty and LupoTek at the time of inclusion within this disclaimer.

19. The Reach Foundation and LupoToro Group

The Reach Foundation is currently undergoing internal planning, strategy, and research development in expectation for a potential future launch and is not operational. Any works or services it would otherwise assist in or provide are not operating in any capacity and detailed online for informative purposes only. We reserve the right to maintain its addition on the LupoToro.com website for its sole purpose as a funnel, to push any interested party in the direction of registered, compliant, third-party non-profit organisation (some of which may be listed on the Reach Foundation page). The Reach Foundation and LupoToro Group have never and do not make any implied or direct suggestions that they are affiliated with, in any way shape or form, with any listed third-party non-profit groups. The Reach Foundation and LupoToro Group have never and do not accept any charitable donations of any sort, financial or other, nor make any direct or indirect assertions that we are a registered non-profit or charitable organisation. The Reach Foundation is an internal initiative concept only. The LupoToro Group are currently in the process of a wider business relaunch and the Reach Foundation may at a future date apply for the legally required licences and compliances, which may allow it to transition from an internal concept into a legally registered and operating entity (pending necessary and relevant compliance and registrations obtained). We reiterate that the Reach Foundation is an incubation zone concept only, and not an operating entity in any other form, other than acting as a funnel; this is publicly available information here on our website. The Reach Foundation does not allude to or certify to be anything other than a non-functioning concept. Any and all communication of offers of potential charitable assistance or similar, which may be sent to the Reach Foundation or LupoToro Group, will be forwarded to non-related registered, compliant, and operating third-party non-profit organisations. The Reach Foundation and LupoToro Group never have and do not require, request, or want, any credit for charitable donations, or similar, in any way. The Reach Foundation is part of the LupoToro Group’s ongoing development of commitment, in which we wish to provide positive influences on our wider communities.

20. Governing Law

Any claim relating to LupoToro Group’s website shall be governed by the laws of The United Arab Emirates, without regard to its conflict of law provisions, and You consent to exclusive jurisdiction and venue in such courts.

21. Indemnity

You accept defend, indemnify, and hold safe LupoToro Group, its affiliates, and their corresponding officers, directors, agents and workers, from and against any claims, actions or demands, including without limitation affordable legal, accounting, and other provider charges, affirming or resulting from (i) any Content of most material You offer to the Site, (ii) Your use of any Content, or (iii) Your breach of the terms of these Terms. LupoToro Group will provide notice to You promptly of any such claim, match, or case.

22. General Terms

Our Legal Terms shall be treated as though it were executed and performed in the United Arab Emirates and shall be governed by and construed in accordance with the laws of the UAE without regard to conflict of law principles. In addition, you agree to submit to the personal jurisdiction and venue of such courts. Any cause of action by you with respect to our Website, must be instituted within one (1) year after the cause of action arose or be forever waived and barred. Should any part of our Legal Terms be held invalid or unenforceable, that portion shall be construed consistent with applicable law and the remaining portions shall remain in full force and effect. To the extent that any Content in our Website conflicts or is inconsistent with our Legal Terms, our Legal Terms shall take precedence. Our failure to enforce any provision of our Legal Terms shall not be deemed a waiver of such provision nor of the right to enforce such provision. The rights of LupoToro Group under our Legal Terms shall survive the termination of our Legal Terms.

23. Investible Services or Work: General Terms

Any works presented to the LupoToro Group for investment, which are accepted as potential investible projects, are handled with care by the LupoToro Group. In accordance with our internal governing rules, any third-party investor(s), affiliates, or potential partners will first need to be vetted and verified in full (100 points of identification) prior to formally signing onto any project or investment or potential project or investment. The LupoToro Group hereby is indemnified from any responsibility should any potential outside party (investor, partner, or similar) are unable to be verified by the LupoToro Group, or if their identity, financing, or character is suspected or proven to be, false, misleading, or incorrect at any point. The LupoToro Group cannot guarantee or safeguard against third-party bad actors in business and therefore makes no promise to do so. Any third-party investor who may be known in any capacity to any official employee of LupoToro Group, and who may be engaged, is also required to be reverified or verified to the same extent of any third-party who does not fit that depiction. For more information, please contact legal@lupotoro.com.

24. General Social Media

LupoToro Group does not maintain official social media accounts, outside of an Instagram page (www.instagram.com/lupotoro); any other social media page claiming to be the LupoToro Group is not an authorised platform.

25. M&A and Licensing

The LupoToro Group, outside of any deal brokerage not requiring additional licences, will engage a third-party license holder accordingly to remain compliant prior to engaging in any deal or similar, including M&A, which requires appropriate licence holders. The LupoToro Group will not commence or engage in any works that require specific licences or guarantees, that it does not currently hold.

26. Disclaimer on third-party conduits and outside of the LupoToro Group provided information

The LupoToro Group shall not be held liable for any inaccuracies, errors, omissions, or misrepresentations in the information or guarantees provided by third-party conduits, including but not limited to vendors, suppliers, contractors, consultants, or agents. The LupoToro Group hereby indemnifies and holds harmless from any claims, damages, losses, liabilities, costs, or expenses arising directly or indirectly from reliance on such information or guarantees. The LupoToro Group acknowledges that any information or guarantees provided by third-party conduits are provided on an 'as-is' basis, without any warranty or representation of accuracy or completeness. The LupoToro Group agrees to conduct its own due diligence and assessments before relying on any information or guarantees provided by third-party conduits, after a signed and agreed mandate with any potential client or investor is in place.

27. Director, Partner, Owner Indemnity: Overview

This is an overview of our Director, Partner, Owner Indemnity Policy, and Indemnity Clause for Employee Wrongdoing. No Director, Partner, or Owner of the LupoToro Group will be held liable for any wrongdoing act undertaken by any employee, third-party operating under the name of LupoToro Group, contractor, conduit, or other, in any way. We note:

a) Indemnification: LupoToro Group (‘The Company’) agrees to indemnify and hold harmless all active Partners, Owners or Directors (hereinafter referred to as the "Indemnified Party"), to the fullest extent permitted by law, from and against any and all claims, losses, liabilities, damages, expenses, including reasonable attorney's fees, and judgments arising out of or relating to any act (including gross negligence or criminal actions) or omission of employee(s) in the performance of their duties.

Conditions of Indemnification: The Indemnified Party's right to indemnification under this clause is contingent upon:

i. The Indemnified Party cooperating fully with the Company in the defence of any such claim, lawsuit, or proceeding.

ii. The Company having sole control over the defence and settlement of any such claim, lawsuit, or proceeding; provided, however, that the Indemnified Party shall have the right to participate in the defence of any such claim, lawsuit, or proceeding with counsel of its own choosing at its own expense.

b) Limitation of Liability: Notwithstanding anything to the contrary contained herein, the Company's aggregate liability under this indemnity clause shall not exceed the total amount of compensation paid by the Company to the employee(s) during the twelve (12) month period immediately preceding the event giving rise to the claim for indemnification.

c) Exclusions: The Company may (but is not obligated to) indemnify the Indemnified Party for any claims, losses, liabilities, damages, expenses, or judgments arising out of or relating to the Indemnified Party's breach of this Agreement, gross negligence, wilful misconduct, or criminal actions.

d) Severability: If any provision of this indemnity clause is held to be invalid, illegal, or unenforceable under any applicable law, the validity, legality, and enforceability of the remaining provisions shall not in any way be affected or impaired thereby.

28. Media Releases (Press Releases)

As with all media releases on the LupoToro.com website, the information contained is for informational purposes only and does not constitute financial, legal, or professional advice. While every effort has been made to ensure the accuracy and reliability of the information provided, LupoToro Group makes no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability, or availability with respect to the content contained herein. Readers are advised to conduct their own research and consult with appropriate professionals before making any decisions or taking any actions based on the information provided in this media release. LupoToro Group shall not be liable for any loss or damage, including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from the use of or reliance on any information contained in this media release. Furthermore, the views and opinions expressed in this media release are those of the individual spokesperson(s) that published them and do not necessarily reflect the official policy or position of LupoToro Group. All media releases may be subject to change without notice. The LupoToro Group maintain hard-copies (i.e. original physical printed copies) of all media releases. Some media releases have been consolidated, scanned, or copied directly from their original hard-copy source and digitally uploaded (or transcribed) onto the LupoToro.com website under the “Media Releases” subheading. No changes are made to the digital copies of any media release from the original hardcopy versions. As the LupoToro.com website continues to grow (with changes to page layouts, formats, typography, coding, and other ongoing and routine changes) and be refined, there is a risk content is affected unintentionally. There is also a risk that any content transcribed from an original hard-copy source may have errors, omissions, or grammatical or spelling errors. Therefore, all uploaded media releases will be routinely checked for accuracy against their corresponding original hard-copy versions. Any errors, omissions, or similar, made during any transcribing or uploading process of any media releases is hereby considered a clerical error, and the LupoToro Group are indemnified from any potential issue or miscommunication which may result from this. The LupoToro Group offer any person a scanned copy of any original media release sent to them for private comparison reasons (i.e. not for public use, legal use, without prior express written permission), should they so wish; to obtain a copy of any media release published on our website, please email a request for this through to admin@lupotoro.com.

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Privacy Policy

At LupoToro Group, our privacy policy is a statement of our commitment to protecting personal information provided to us and to ensure it is only used for the purpose for which it was intended and provided. This Policy applies to all customers (including clients, applicants, and registrants), whether past, present or future, of LupoToro Group.

We apply the definition of personal information contained within the The Data Protection Act 2003. The LupoToro Group Group is protected by the governing laws and associated policies outlined by the The Privacy Commissioner, including the data protection authority in The United Arab Emirates.

When providing us with information, individuals have a right to know:

· type of personal information collected and held;

· purposes for which the information is collected;

· how the information is collected;

· how the information is held;

· access and correction;

· who may the information be disclosed to;

· complaints procedure

Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.

We will collect and use personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.

We will only retain personal information as long as necessary for the fulfilment of those purposes.

We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.

Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.

We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

We will make readily available to customers information about our policies and practices relating to the management of personal information.

Your Privacy

LupoToro Group follows all legal requirements to protect your privacy. Our Privacy Policy is a legal statement that explains how we may collect information from you, how we may share your information, and how you can limit our sharing of your information. We utilize the Personal Data you offer in a way that is consistent with this Personal privacy Policy. If you provide Personal Data for a particular reason, we could make use of the Personal Data in connection with the reason for which it was provided. For example, registration info sent when developing your account, might be used to suggest products to you based on past acquisitions. We might use your Personal Data to offer access to services on the Website and monitor your use of such services. LupoToro Group may also utilize your Personal Data and various other personally non-identifiable info gathered through the Website to assist us with improving the material and functionality of the Website, to much better comprehend our users, and to improve our services. You will see terms in our Privacy Policy that are capitalized. These terms have meanings as described in the Definitions section below.

Definitions

“Non Personal Information” is information that is not personally identifiable to you and that we automatically collect when you access our Website with a web browser. It may also include publicly available information that is shared between you and others.

“Personally Identifiable Information” is non-public information that is personally identifiable to you and obtained in order for us to provide you within our Website. Personally Identifiable Information may include information such as your name, email address, and other related information that you provide to us or that we obtain about you.

Information We Collect

Generally, you control the amount and type of information you provide to us when using our Website.

As a Visitor, you can browse our website to find out more about our Website. You are not required to provide us with any Personally Identifiable Information as a Visitor.

Computer Information Collected

When you use our Website, we automatically collect certain computer information by the interaction of your mobile phone or web browser with our Website. Such information is typically considered Non Personal Information. We also collect the following:

Cookies

Our Website uses “Cookies” to identify the areas of our Website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We use Cookies to personalize the Content that you see on our Website. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our Website correctly or at all. We never place Personally Identifiable Information in Cookies.

Geographical Information

When you use the mobile application, we may use GPS technology (or other similar technology) to determine your current location in order to determine the city you are located in and display information with relevant data or advertisements. We will not share your current location with other users or partners. If you do not want us to use your location for the purposes set forth above, you should turn off the location services for the mobile application located in your account settings or in your mobile phone settings and/or within the mobile application.

Automatic Information

We automatically receive information from your web browser or mobile device. This information includes the name of the website from which you entered our Website, if any, as well as the name of the website to which you’re headed when you leave our website. This information also includes the IP address of your computer/proxy server that you use to access the Internet, your Internet Website provider name, web browser type, type of mobile device, and computer operating system. We use all of this information to analyze trends among our Users to help improve our Website.

Log Data

Like many Website operators, we collect information that your browser sends whenever you visit our Website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages and other statistics.

Under the Child’s Online Privacy Security Act, no Website operator can require, as a condition to involvement in an activity, that a child younger than 13 years of age divulge more details than is reasonably required. LupoToro Group abides by this demand. LupoToro Group just collects information willingly offered; no information is gathered passively. children under 13 can submit only their email address when sending us an email in our “Contact Us” area. LupoToro Group makes use of the email address to respond to a one-time demand from a child under 13 and afterwards deletes the email address. In case LupoToro Group collects and maintains personal information relating to a child under 13, the parent may send out an email to us to review, alter and/or erase such info as well as to decline to enable any additional collection or use of the child’s information.

A Note on Advice

At LupoToro Group, we do not provide financial advice to Clients, we only provide general information. Information provided on LupoToro.com or by any of our LupoToro Group Consultants or provided in a link on the website is to be used for information and educational purposes only. It is not intended to provide investment, financial, accounting, legal, tax or other professional advice and should not be relied upon or regarded as a substitute for such advice. We recommend that you seek advice from a qualified professional advisor before acting on any information or other content appearing on this website, the LupoToro Group social media sites or any website to which they may be linked.

How We Use Your Information:

We use the information we receive from you as follows:

Customizing Our Website

We may use the Personally Identifiable information you provide to us along with any computer information we receive to customize our Website.

Sharing Information with Affiliates and Other Third Parties

We do not sell, rent, or otherwise provide your Personally Identifiable Information to third parties for marketing purposes. We may provide your Personally Identifiable Information to affiliates that provide services to us with regards to our Website (i.e. payment processors, Website hosting companies, etc.); such affiliates will only receive information necessary to provide the respective services and will be bound by confidentiality agreements limiting the use of such information.

Data Aggregation

We retain the right to collect and use any Non Personal Information collected from your use of our Website and aggregate such data for internal analytics that improve our Website and Service as well as for use or resale to others. At no time is your Personally Identifiable Information included in such data aggregations.

Legally Required Releases of Information

We may be legally required to disclose your Personally Identifiable Information, if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Legal Terms; (d) necessary to protect us from legal action or claims from third parties including you and/or other Members; and/or (e) necessary to protect the legal rights, personal/real property, or personal safety of LupoToro Group, our Users, employees, and affiliates.

Opt-Out

We offer you the chance to “opt-out” from having your personally identifiable information used for particular functions, when we ask you for this detail. When you register for the website, if you do not want to receive any additional material or notifications from us, you can show your preference on our registration form.

Links to Other Websites

Our Website may contain links to other websites that are not under our direct control. These websites may have their own policies regarding privacy. We have no control of or responsibility for linked websites and provide these links solely for the convenience and information of our visitors. You access such linked Websites at your own risk. These websites are not subject to this Privacy Policy. You should check the privacy policies, if any, of those individual websites to see how the operators of those third-party websites will utilize your personal information. In addition, these websites may contain a link to Websites of our affiliates. The websites of our affiliates are not subject to this Privacy Policy, and you should check their individual privacy policies to see how the operators of such websites will utilize your personal information.

Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. We utilize practical protection measures to safeguard against the loss, abuse, and modification of the individual Data under our control. Personal Data is kept in a secured database and always sent out by means of an encrypted SSL method when supported by your web browser. No Web or email transmission is ever totally protected or mistake cost-free. For example, email sent out to or from the Website may not be protected. You must take unique care in deciding what info you send to us by means of email.

Privacy Policy Updates

We reserve the right to modify this Privacy Policy at any time. You should review this Privacy Policy frequently. If we make material changes to this policy, we may notify you on our Website, by a blog post, by email, or by any method we determine. The method we chose is at our sole discretion. We will also change the “Last Updated” date at the beginning of this Privacy Policy. Any changes we make to our Privacy Policy are effective as of this Last Updated date and replace any prior Privacy Policies.

Questions About Our Privacy Practices or This Privacy Policy

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained. If you have any questions about our Privacy Practices or this Policy, please contact us.

For a copy of this document please email legal@lupotoro.com

For a copy of our comprehensive list of operational internal governing rules, please email legal@lupotoro.com.

All legal disclaimers and policies online are subject to change at any time without notice.

Our business, our reputation, and the success of our clients depend on our people safeguarding client, proprietary and other confidential information. This includes any information our people create, develop, receive, or have access to in connection with their work at LupoToro Group, such as information about the firm, our clients, or prospective clients, or confidential supervisory information created by or for our regulators.

Access to information should only be provided to those with appropriate authorisation and information should only be shared, even internally, with those who have a valid business reason for receiving it. Sharing confidential information by forwarding it to personal email accounts or through other unauthorized messaging systems is strictly prohibited. Notwithstanding our obligation to safeguard information, our people may escalate concerns under the Business Integrity Program and report conduct they believe to be in violation of the law to the government or regulators.

As our reliance on the internet and digital devices for business and personal use increases, so do opportunities for criminals seeking to steal information for financial gain. Cyber criminals and fraudsters are also becoming more savvy in their attempts to lure people into clicking suspicious links, downloading email attachments, or “connecting” on social media, which are often gateways to stealing sensitive information. Fraudsters may pose as legitimate organisations and create fraudulent websites, send emails, or make phone calls to solicit monetary payments. These scams are complex as the perpetrators often use genuine real employee names and replicate proprietary documentation.

LupoToro Group places great importance on cybersecurity and fraud prevention and has programs and technical controls in place to protect client accounts and information. To help improve your personal cybersecurity posture, we offer the following information about cyber threats and guidance to help protect you, your family, and your employer from falling victim to a cyber-attack or fraud scam.

Understanding Cybersecurity Threats

Any organisation or individual can be a target of cyber criminals. Here are some of the most common tactics and types of attacks employed by these actors:

1. Malicious Emails and Websites
   An unsuspecting e-mail from your bank or favourite retailer may secretly be an attempt to steal your identity or personal information. “Phishing” is a common tactic of cyber criminals that relies on “spoofed” e-mails or fraudulent websites (that look and feel like a well-known website) to collect personal and financial information or infect your machine with malware and viruses. Criminals use this stolen information to commit identity theft, credit card fraud and other crimes. Phishing can also occur by telephone and is becoming increasingly prevalent on social media and professional networking sites.
   
   When you click a malicious link, you may unknowingly install malware on your device. Malware refers to software that is intentionally designed to cause damage to a digital device. The most common form of malware is a virus, which is typically designed to give the criminals who create it some sort of access to the infected devices. Ransomware is another type of malware that is becoming increasingly prevalent. Ransomware accesses a victim’s files, locks and encrypts them and then demands the victim to pay a ransom to get them back. Ransomware is like the “digital kidnapping” of valuable data – from personal photos and memories to client information, financial records and intellectual property. Any individual or organisation could be a potential ransomware target.

2. Credential-based Attacks
   If you use the same username and password combination across different websites or services, you are particularly susceptible to this cybercrime technique where stolen account credentials are used to gain unauthorised access to a user’s various other online accounts. Credential stuffing attacks can often go unnoticed until funds are transferred.

3. Social Media Impersonation
   Criminals are increasingly using social media to build relationships with victims and ultimately steal data. Typically, these actors create fake accounts that appear (and claim) to be official accounts for an individual or organisation. Social media impersonation can also refer to the takeover of real accounts. These accounts can be used for phishing activities or causing an individual or a company reputational damage.

How You Can Protect Yourself

• Establish Secure Email Protocols: Emails continue to be a common entry point for hackers for performing online fraud. Do not click on links or open attachments from suspicious-looking emails. Expand your communication protocol to verify sensitive information, such as wire instructions, in person or by telephone. Generally, LupoToro Group will never send wiring instructions via email.

• Employ Password Management: Use lengthy, unique, and complex passwords — a great first step toward stopping bad actors. In fact, cybersecurity best practices suggest utilising long, memorable, and hard-to guess passwords such as a favourite song lyric. Avoid reusing passwords. Consider using a password application, such as LastPass, Password or Dashlane to help manage multiple complex passwords.

• Enable 2-Step Authentication Measures: Where available, use 2-factor authentication for account login (2FA) a.k.a. two-step verification or multi-factor authentication, commonly done via a PIN sent over text message or email and done most securely when a hardware token or phone application is used. At a minimum, enable this capability for your email, cellular provider, financial websites, password manager, cloud file storage and social media.

• Lock Down Social Media: Periodically review and adjust social media account settings to better control who can view the content posted. Hackers and social engineers frequently obtain critical information about a target from social media sources. When posting, always consider how that information can be used against you.

• Reduce Your Public Online Footprint: Periodically review all your online accounts. Reduce and/ or obfuscate personal information on the internet, remove unnecessary data, delete unused accounts, and avoid sharing or reusing passwords across accounts to minimise exposure.

• Protect Critical Data: Know where all your sensitive personal information is stored. Ensure that your sensitive data is always stored encrypted, to prevent someone from viewing it if your device gets lost or stolen. Also consider having a second encrypted backup of your sensitive data, whether on a flash drive stored in a safety deposit box or in the cloud using a reputable service such as Dropbox, iCloud, or Google Drive.

• Protect Your Personal Devices: Configure devices securely, considering what your risks would be if your device were stolen. Use a difficult to guess passcode as a backup to biometric security such as a thumb print or Face ID, and be sure your device is encrypted. Ensure that sensitive data, such as email, does not display on the lock screen.

• Update Your Software: Keep all of your software up to date. Apply software updates as soon as possible once they become available. Consider enabling automatic updates where available.

• Secure Wi-Fi Access: Be aware that using public Wi-Fi can expose your communications and devices to risk. If you must use public Wi-Fi, consider a virtual private network (VPN) solution to protect your communications — particularly when traveling and using public Wi-Fi at the airport or hotel. Alternatively, consider using a mobile hotspot, to protect sensitive information. At home, use a guest network for visitors.

• Freeze Credit Lines: Thwart identity theft and minimise fraud risk with a call to major credit-reporting bureaus Experian, TransUnion and Equifax, as well as Innovis, the unofficial fourth credit bureau, to set a security freeze on your credit reports. Considering signing up for an identity theft protection service such as LifeLock, Kroll, or Experian, which also offers credit monitoring. These suggestions apply to all family members.

Understanding Financial Fraud

Financial fraud occurs when someone takes money or other assets from you through deception or criminal activity. Here are some common examples of financial fraud:

1. Investment Scams
   Investment scams involve getting you or your business to agree to a financial transaction on the promise of a questionable financial opportunity. To perpetrate these scams, fraudsters typically present the opportunity by making contact by email, through a website, or by phone, often going through great lengths to gain the victim’s trust and even that they may be in a genuine relationship. These offers are typically low risk –high reward investments that typically sound “too good to be true”— because they are! To evaluate whether you are the target of an investment scam, you should consider:

1. How were you contacted? Any contact with LupoToro Group will come from an @lupotoro.com e-mail address (not from a free email account such as Yahoo, Gmail or any other domain outside of “@lupotoro.com”) and/or be found on the lupotoro.com website

2. Did I find the investment opportunity through a website not associated with LupoToro Group? E.g. a comparison website

3. Have I provided my personal information on a website not associated with LupoToro Group?

4. Have I been contacted by cold call or e-mail offering a low risk – high return investment opportunity?

5. Does the e-mail or documentation contain numerous spelling errors or misprints?

6. Have I provided photo ID or proof of address documentation? If you have, consider notifying the organisation that issued them and contacting your regional fraud prevention service

7. Was I pressured into making a money transfer to avoid missing an opportunity?

2. Identity Theft
   Identity theft occurs when someone steals your personal information and uses it without your permission. Examples of how your information could be used include opening bank accounts, taking out credit cards and loans or applying for government benefits and documents in your name.
   
   There is no definite rule on how to protect yourself from identity theft however, in addition to the cybersecurity good practices listed above, you can protect yourself by:

   1. Not sharing your personal data with anyone/any site you’re not familiar with.

   2. Safely disposing of unwanted documents such as utility bills or bank statements.

3. Business Email Compromise
   Business Email Compromise (BEC) scams are carried out when a cybercriminal compromises legitimate business or personal email accounts to intercept the communication between the victim and their business partner or to conduct unauthorised transfers of funds. Fraudsters commonly tend to intercept email wire instructions from investments firms, real estate agencies, and art dealers to then impersonate a trusted source.
   
   In addition to the cybersecurity good practices listed above, protect yourself by:

   1. Confirming the payment instructions with the recipient verbally, not by email

   2. Watching for irregularities when receiving transfer instructions or sudden change of payment information via email

If you receive a cold call or e-mail from LupoToro Group that you are uncertain about, or which you believe to be fraudulent, please forward it to legal@lupotoro.com. The LupoToro Group will investigate the e-mail and respond back to you. If you are a client of the firm, please notify your sales representative or investment professional, as well.

For further information on staying safe, the following resources provide helpful information:

United Kingdom

• Take Five to Stop Fraud – Impartial advice to help everyone in the UK protect themselves against financial fraud

• Action Fraud – The National Fraud & Cyber Crime Reporting Centre

• FCA Scam Smart – Check an investment opportunity and avoid scams

• Money Advice Service – How to spot an investment scam

Greater China

• Hong Kong Anti-Deception Coordination Centre

• Hong Kong Securities and Futures Commission

• Financial Supervisory Commission R.O.C. (Taiwan)

• Chinese Securities Regulatory Commission

• Securities Association of China

• China Investor Website (under China Securities Regulatory Commission)

Singapore

• Singapore Police Force – Scam Advisory

• Singapore Scam Alert – Spot the signs, stop the crime

United States

• Federal Trade Commission – Identity Theft

• Federal Bureau of Investigation – Scams and Safety

• United States Secret Service – Protecting Yourself

• United States Government – Scams and Frauds

Specific Data Protection Code

The firm is subject to various privacy laws in the jurisdictions in which it operates. The definition of “personal data” can vary widely, but generally includes information that relates to an identified or identifiable individual (e.g., name and address, government identification number). The relevant data protection laws require the firm to be transparent about how it collects, uses, and discloses personal data. These laws also mandate security controls to protect personal data, and they contemplate taking appropriate steps in situations where personal data may have been improperly disclosed or subject to unauthorised access or misuse. Several laws grant individuals some degree of control over how the firm processes their personal data. Our people and agents are required to: comply with applicable data protection laws and the privacy policies of the businesses of which they are a part; keep personal data secure; and escalate incidents involving the potential misuse of personal data.

Anti-Bribery Code

We are committed to seeking and retaining business based on merit and the excellence of our performance. The firm does not tolerate bribery or corruption of or by our people, agents, vendors, or other business partners. Our people are strictly prohibited from improperly providing anything of value to anyone in order to obtain or retain business or any improper business advantage. This includes: public officials, candidates for office, employees, or officers of state-owned enterprises; employees or officers of counterparties; clients/customers or suppliers; any agent of the aforementioned parties; or any other person with whom the firm does or anticipates doing business. Our people are also prohibited from receiving or accepting bribes. “Anything of value” includes obvious improper payments, such as cash bribes or kickbacks, but also may include other direct or indirect benefits and advantages, such as inappropriate gifts, meals, travel, entertainment, charitable and political contributions, and offers of employment or internships. Some specific activities, such as interacting with government officials, can present increased bribery and corruption risk, and therefore, pre-approval is required before anything of value is provided to such “Restricted Recipients.” Restricted Recipients include employees or representatives of governments, government agencies, public international organisations (e.g., World Bank), state-owned enterprises, and public pension funds. The firm also prohibits facilitation payments, as well as the use of third parties or intermediaries/finders to route any inappropriate payments. In retaining any third parties, we must adhere to our processes and procedures concerning the diligence and oversight of third-party relationships. We must each remain vigilant about potential bribery concerns and escalate them immediately.

Anti-Money Laundering

The firm is committed to ensuring that its people and services are not used to facilitate the flow of, or conceal the origin of, criminally-derived funds or the financing of terrorism (collectively “money laundering”). Our dedication to integrity requires strict compliance with all applicable anti-money laundering laws and regulations. To comply with these procedures, we must adhere to all “know your customer” requirements and be alert for, and promptly report, any unusual or potentially suspicious activity that could involve money laundering, terrorist financing, violations of law or regulation, or any other activity that has no apparent legitimate business purpose or is outside of the ordinary course of a client’s business activity.