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.

LupoToro Group provides information for educational and informational purposes only. We do not provide financial, investment, tax, legal, or other professional advice to clients or any other parties. Any decisions based on information provided by LupoToro Group are solely the responsibility of the individual or entity making those decisions. LupoToro Group expressly disclaims any and all liability for any actions taken or not taken based on the information provided. For professional advice, please consult a qualified financial advisor, attorney, accountant, or other appropriate professional(s).

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.

LupoToro is aware that whilst some of our operations

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 (see section 20 for clarifications), 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

All content and materials available on the LupoToro website – including but not limited to text, graphics, logos, icons, images, audio clips, video, software, and documentation – are the property of LupoToro Group or its content suppliers and are protected by international copyright, trademark, and other intellectual property laws. LupoToro retains all rights, title, and interest in its website and content. Your use of the website does not grant you any ownership of or license to LupoToro’s intellectual property or that of any third party, except as expressly provided in these Terms. You may access and use the content of the site for your personal, non-commercial use only, and solely for the purpose of utilizing the services as offered by LupoToro. Any reproduction, distribution, modification, public display, public performance, or creation of derivative works from the website content is strictly prohibited unless you have obtained LupoToro’s express prior written consent. Similarly, you may not remove or alter any copyright, trademark, or other proprietary notices on the website.

The LupoToro name and logo, and all related names, logos, product and service names, designs, and slogans are trademarks or service marks of LupoToro Group or its affiliates. Our website may also display the trademarks, service marks, and logos of third parties (for example, those of partner companies or third-party services referenced on the site). Any use of LupoToro’s marks or third-party marks without the respective owner’s prior written permission is strictly prohibited. Nothing in these Terms or on the site should be construed as granting, by implication or otherwise, any license or right to use any trademark displayed on the website without the written permission of LupoToro or the third-party owner of such mark. All goodwill generated from the use of LupoToro’s trademarks inures to the benefit of LupoToro.

LupoToro respects the intellectual property rights of others and strives to use only content that is original or properly licensed on our platforms. Content and media that are created directly by LupoToro will be identified as such wherever feasible (for example, by an attribution or disclaimer indicating LupoToro’s ownership of that content). In the absence of a clear LupoToro attribution on a piece of media content, you should assume the material may have been provided by a third-party contractor or contributor engaged by LupoToro. We take care to ensure that any third-party content used (such as stock images, graphics, or media assets) is used with permission or under an appropriate license, and where required, we will credit the source or owner. However, LupoToro accepts no responsibility for any inadvertent copyright or trademark issues arising from content supplied by third parties. If you believe that any content on our site infringes your copyright or other intellectual property rights, please notify us immediately following our copyright notice-and-takedown procedure. Upon proper notice, we will promptly remove or disable access to any material found to be used without sufficient authorization. We do not guarantee that all content on our website is free from third-party rights or errors, but we will act in good faith to correct any unintentional infringement or mistake once it is brought to our attention. LupoToro’s designated contact for copyright issues is legal@lupotoro.com, as detailed in our policies.

i.                To expand on the above, some media featured on this site includes materials provided by third-party contractors for promotional use. This may include video, voice, audio, imagery, photography, and various other clips used in photo, sound, or video media - all of which have been produced and supplied to LupoToro Group for use. Footage and media produced directly by LupoToro Group will be clearly identified with a disclaimer confirming that it is LupoToro-produced, owned, and controlled. In the absence of such a disclaimer, all media content should be presumed to have been provided by third-party contractors engaged by LupoToro Group. LupoToro Group accepts no responsibility for any errors, potential claims, or copyright issues arising from materials that have been paid for and/or outsourced to third-party contractors for use.

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 (see section 20 for clarifications), 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); to the maximum extent permitted by applicable law, LupoToro Group and its affiliates, officers, employees, agents, and partners shall not be liable for any indirect, incidental, consequential, special, punitive, or exemplary damages arising out of or in connection with your use of the website or any LupoToro services or content.

Under no circumstances shall LupoToro Group’s aggregate liability arising from or in connection with this website exceed the greater of:

       i.         the total amount paid by the user for services in the six (6) months prior to the claim, or

     ii.         shall not exceed US$500, or such higher amount as required by law and applies to all claims in aggregate (not per-claim).

    iii.         Nothing in these Terms excludes liability that cannot be excluded under applicable consumer law.

A)    Intellectual Property & Third-Party Content: LupoToro respects the intellectual property rights of others and takes all reasonable steps to ensure that the content published on our website, platforms, and associated media is either original, appropriately licensed, or used in compliance with the Law of Ukraine on Copyright and Related Rights, as applicable (see section 20). If any third-party material, including images, graphics, or multimedia content, is found to have been published without the necessary authorization, such material will be removed promptly upon notice. LupoToro disclaims liability for inadvertent or unauthorized use of third-party content and reserves the right to resolve any such issues in good faith, including through removal of the material or confirmation of a valid license. Parties who believe their copyrighted work has been used in a way that constitutes infringement are encouraged to notify LupoToro immediately via our contact emails, including reference details of the alleged infringement.

B)    Copyright Notice & Takedown Procedure: We strive to ensure that all materials published on our website, social media, and associated platforms are either original, appropriately licensed, or used in compliance with applicable copyright law. All copyright related notices should be sent to legal@lupotoro.com. We do not operate a business address (physical) at this time, so direct correspondence via email.

C)    Reporting Infringement: If you believe that your copyrighted work has been used, displayed, or published by LupoToro in a manner that constitutes infringement, please notify us in writing. Your notice should include: 1) Identification of the copyrighted work claimed to have been infringed. 2) The exact location (URL or description) of the allegedly infringing material. 3) Proof of your ownership or rights to the work (or your authority to act on behalf of the rights holder). 4) Your name, company (if applicable), email address, and phone number. 5) A statement that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law. 6) A statement, made under penalty of perjury, that the information provided is accurate and that you are the copyright owner or authorized to act on the copyright owner’s behalf. All copyright-related notices should be sent to legal@lupotoro.com. LupoToro reserves the right to reject any copyright notice that is incomplete, invalid, or not made in good faith. If a third-party supplier disputes a claim of infringement and provides evidence of valid rights or licenses, LupoToro may reinstate the disputed content.

D)    Response Procedure: Upon receipt of a valid copyright notice, LupoToro will investigate the claim and, if material is found to be unauthorized, will remove or disable access to it within 48 hours. Where possible, LupoToro will also notify the party who supplied the content and provide them an opportunity to respond. LupoToro shall not be liable for any inadvertent or unauthorized use of third-party content. Our obligation in such cases is limited to promptly removing or disabling access to the material once we are made aware of it. LupoToro does not guarantee all content is free from third-party rights, and that any unintentional infringement will be corrected upon notice. Occasionally, we use contractors, freelancers, or partners who may supply content, and we shift liability to them (they warrant that their work is original or licensed), where applicable. All third-party contractors, suppliers, or contributors engaged by LupoToro warrant that the materials they provide are original or appropriately licensed. In addition, such parties shall indemnify and hold harmless LupoToro Group Pty Limited against any and all claims, liabilities, damages, costs, and expenses (including reasonable legal fees) arising out of or connected to the materials supplied.

E)     Content licensing: LupoToro may, at its discretion, require contributors or contractors to provide written evidence of licenses, permissions, or ownership rights for supplied content. Such records must be retained by the contractor and made available to LupoToro upon request.

F)     Alterative Dispute Resolution (option): Before initiating any legal proceedings, both parties agree to attempt to resolve disputes relating to intellectual property or copyright claims through good-faith negotiation or mediation. LupoToro reserves the right to treat failure to engage in ADR as evidence of unreasonable conduct by the claimant.

G)    Safe Harbour Compliance: LupoToro maintains a policy for dealing with repeat infringers. Any third-party contributor, contractor, or user found to have repeatedly supplied or published infringing content may have their access, account, or engagement with LupoToro suspended or terminated at LupoToro’s discretion. A “repeat infringer” is defined as any third-party contributor, contractor, or user subject to two (2) or more valid copyright infringement notices within a twelve (12) month period. Any party identified as a repeat infringer will be suspended or terminated from supplying content. Such parties may, however, submit an appeal with evidence of ownership, license, or lawful use, which LupoToro will review in good faith prior to final termination.

LupoToro endeavors to ensure that all content provided on its website and platforms is original or appropriately licensed. Inadvertent inclusion of third-party content may occur despite reasonable checks. In such cases, upon notification by a rights holder, LupoToro will promptly investigate and, if necessary, remove or replace the material. LupoToro disclaims liability for unintentional or incidental infringement beyond the immediate removal of disputed material. LupoToro Group Pty Limited (“LupoToro”) operates its online platforms as a carriage service provider within the meaning of the Copyright Act 1968 (Cth). To the extent that LupoToro transmits, caches, hosts, or provides access to third-party content, it does so as a conduit only and without exercising control over the content supplied by users, contractors, or external sources. In accordance with the Copyright Act 1968 safe harbour provisions, LupoToro: Does not authorize or condone infringement of copyright material made available through its services; Acts expeditiously to remove or disable access to material when properly notified by rights holders of alleged infringement; Requires representations and warranties from contributors, contractors, and partners that all material they supply is original or appropriately licensed; Provides a notice and takedown mechanism through which rights holders can submit claims of alleged infringement (see “Copyright Notice & Takedown Procedure”). LupoToro accepts no liability for infringing material stored, transmitted, or made available by third parties through its services beyond the obligations set out in the safe harbour provisions.

Disclaimer of Warranties:

i.                All materials and services on the LupoToro website are provided on an “as is” and “as available” basis, without any warranties of any kind. To the fullest extent permitted by law, LupoToro Group disclaims all warranties, express or implied, including but not limited to implied warranties of merchantability, fitness for a particular purpose, title, and non-infringement. We make no representation or guarantee that the website or any content on it will be accurate, complete, reliable, current, or error-free. 

ii.              You expressly agree that your use of the site is at your sole risk. LupoToro does not warrant that the website, its servers, or any email sent from us are free of viruses or other harmful components. Except as expressly set forth in these Terms, no advice or information (whether oral or written) obtained by you from LupoToro or through the site shall create any warranty. We expressly disclaim any responsibility for decisions you make based on information on our site. In particular, LupoToro provides general information only and does not offer financial, investment, legal, tax, or other professional advice on the website or through any communications – any decisions or actions taken by you based on our content are solely at your own risk. You should consult qualified professionals before making decisions in reliance on any information obtained from LupoToro. LupoToro Group expressly disclaims all liability for any actions taken in reliance upon site content as advice or guidance.

Third-Party Content and Links Disclaimer:

i.                LupoToro is not responsible or liable for any content posted, provided, or otherwise made available by any third party (including users, contractors, partners, or other external contributors) on our website. Any opinions, statements, services, offers, or other information or content expressed or made available by third parties (including content published in our forums, comment sections, news feeds, or as part of “Group Partner or Asset” pages) are those of the respective author(s) and not of LupoToro. We do not endorse, guarantee, or make any representations regarding the accuracy or reliability of any third-party content on our site. 

ii.              All third-party content is provided “as-is” without warranties of any kind, and you view and use such content at your own risk. 

iii.             LupoToro disclaims any liability for errors, omissions, defamation, obscenity, or illegal conduct arising from content supplied by third parties on our platform. In particular, where our website hosts information about third-party entities (Group Partners or Assets), such as independent companies in which LupoToro has an interest or with whom LupoToro has a collaboration, we do not assume responsibility for any information, products, or services those third parties provide. LupoToro will not be held liable for any claims or damages arising from the acts, omissions, or content of any third-party that is featured or referenced on our site. Your business dealings or correspondence with, or participation in promotions of, third parties other than LupoToro, and any terms, conditions, warranties, or representations associated with such dealings, are solely between you and such third party. You agree that LupoToro is indemnified and held harmless from any loss or liability arising from your interactions with third parties through our site.

iv.             Our website may also contain links to external websites or resources that are not owned or controlled by LupoToro. These links are provided for your convenience and reference only. The inclusion of any link does not imply affiliation, endorsement, or sponsorship by LupoToro of the linked website or any content therein. 

v.              LupoToro makes no warranties or representations regarding third-party websites, and assumes no responsibility for the content, privacy policies, or practices of any third-party sites. If you access a non-LupoToro website via a link on our site, you do so at your own risk. We will not be liable for any loss or damage that may arise from your use of third-party websites or resources. We strongly encourage you to review the terms and policies of any third-party sites you visit. Your use of third-party sites is subject to the terms and conditions of those sites, not these Terms.

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 and Disclaimer of Association, Endorsement, and Website Status

Site Terms of Service Modifications:

i.                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.

Disclaimer of Association, Endorsement and Website Status:

i.                LupoToro Group make no representation, express or implied, of any relationship, involvement, partnership, agency, collaboration, joint venture, investment, sponsorship, endorsement, or affiliation with any corporation (whether public or private), defense contractor, government department, research facility, or other external entity whatsoever, unless such relationship is formally executed in writing and expressly published by LupoToro through official channels.

ii.              Any appearance, reference, or incidental use of names, trademarks, images, logos, or related materials belonging to third parties is for illustrative, descriptive, or placeholder purposes only, and shall not be construed as implying any endorsement, authorization, or connection with LupoToro, and have been provided by third-party contractors (governed by separate sections of our terms, disclaimers and policies herein). Best efforts in line with our terms, disclaimers and policies are made to ensure legitimacy, correctness and compliance across all industries, sectors and jurisdictions.

iii.             This website and its contents are considered strictly conceptual in nature and are provided on an “as-is” and “as-available” basis solely for internal, illustrative, and informational purposes while the platform undergoes redevelopment. The website is not intended for reliance by the public and shall not be interpreted as a representation of active business operations, current partnerships, or official communications. Certain items contained on the site - including, without limitation, written text, images, media, documents, or other displayed materials - constitute sample, experimental, or placeholder content only. No such materials are to be relied upon as factual, current, complete, or reflective of LupoToro’s business, strategy, partnerships, or activities.

iv.             For the avoidance of doubt, the indemnification obligations in this Section 22 are in addition to, and not in limitation of, the indemnification obligations set forth in Section 21 (Indemnity), and shall survive termination or expiration of these Terms.

By accessing or viewing this website, you expressly acknowledge and agree that:

1.     No reliance of any kind may be placed on the website, its contents, or any perceived association with third parties;

2.     LupoToro disclaims all responsibility and liability for any interpretation, assumption, or reliance made by visitors, third parties, or external entities based on the website or its contents;

3.     No visitor or third party shall have any claim against LupoToro, its affiliates, directors, officers, partners, employees, or agents arising out of or relating to the website, its status, or its placeholder content; and

4.     To the fullest extent permitted by law, LupoToro excludes all liability, direct or indirect, arising from any use, reliance, or interpretation of the website or its contents, whether actual, alleged, or perceived.

18. Group Partners and Assets

Group Partners and 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 Partners and Assets 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

i.               The Reach Foundation referenced on our website is an internal, conceptual initiative only, and is not an active charitable or nonprofit organization at this time. Any information provided on our site about the Reach Foundation is for informational and illustrative purposes, reflecting LupoToro’s aspirational community and charitable goals. The Reach Foundation is not operational in any capacity: it does not have legal status as a charity, it conducts no charitable programs or services, and it does not solicit or accept any donations, grants, or contributions whatsoever. We have never represented, and will not represent, the Reach Foundation as a registered nonprofit, nor do we claim any affiliation with any external charitable organizations that might be mentioned or listed in our materials. Any references on our site to other charities or nonprofit groups (for example, charities listed on a Reach Foundation page as examples or inspirations) are for reference only. LupoToro Group and the Reach Foundation do not assert any partnership or formal association with any such third-party nonprofit entities. In summary, the Reach Foundation is currently an “incubation zone” concept within LupoToro, under development for potential future launch, but it is not a functioning or authorized charity, and no user or visitor should interpret it as such.

ii.              Because the Reach Foundation is not active, LupoToro will not accept any form of donation or fundraising on its behalf. If any individual or organization offers or attempts to make a charitable donation or contribution to the Reach Foundation or LupoToro with a charitable intent, we will neither solicit nor retain those funds. At our discretion, we may direct or refer such would-be donors to unaffiliated, registered third-party nonprofit organizations that are properly licensed to accept donations, but LupoToro and the Reach Foundation will not take custody of any charitable funds.

iii.             We also do not seek or accept any public recognition or credit for charitable donations that any person or entity may make to other organizations as a result of our referral. Maintaining the Reach Foundation information on our site is meant solely as a statement of our values and future goals in community engagement, not as a fundraising platform. We reserve the right to continue displaying information about the Reach Foundation concept on our website as a way to encourage interested parties toward legitimate, independent charities or causes (acting as a **“funnel” to direct goodwill to proper channels). We also reserve the right to remove or alter the Reach Foundation content on our site at any time.

iv.             LupoToro emphasizes that any involvement with the Reach Foundation at present is non-commercial and without any financial transactions. We will never ask for money or donations for the Reach Foundation, and any such request purportedly from LupoToro should be considered fraudulent. If LupoToro decides in the future to formally launch the Reach Foundation as an operational charitable entity, we will obtain all necessary licenses, registrations, and regulatory approvals required by law before doing so. Unless and until an official public announcement is made that the Reach Foundation has become a registered and operating non-profit (with details provided on how it will accept support legally), any activities of the Reach Foundation remain strictly exploratory and non-binding. We stress that no user, customer, or other party should rely on the Reach Foundation as a service provider or donate funds under the assumption that it is a charity, because it is not. Any inquiries about charitable efforts or community initiatives should be directed to us at our official contact email, and we will clarify the current status. By including this disclaimer, LupoToro and the Reach Foundation are protected from any misunderstanding or misrepresentation regarding our nonprofit status and avoid any compliance issues with charity laws, until such time (if ever) that the Reach Foundation is properly established in accordance with all legal requirements.

20. Governing Law and Jurisdiction

LupoToro operates internationally, and we have structured our governing law provisions to reflect our operational footprint in different regions. By using this website or any LupoToro services, you agree that the governing law and dispute resolution forum for any claims arising between you and LupoToro will be determined as set forth in this section. In general, the laws of the United Arab Emirates or of Ukraine will apply, depending on the subject matter of the dispute, and certain courts in those jurisdictions will have exclusive jurisdiction, as described below.

        i.     Commercial and General Disputes (UAE Law): For all disputes or claims arising out of your use of the website or LupoToro services other than those primarily involving intellectual property, these Terms shall be governed by and construed in accordance with the laws of the United Arab Emirates. You and LupoToro agree that any such non-IP dispute (including, for example, disputes related to purchases, contracts, or general online conduct) is subject to the exclusive jurisdiction of the courts of Dubai, UAE. You hereby consent and submit to the personal jurisdiction of the Dubai courts for the purpose of litigating any such claim, and waive any objections to such venue on the grounds of inconvenience or otherwise.

       ii.     Intellectual Property and Content Disputes (Ukrainian Law): For any disputes that involve intellectual property rights or content – including, without limitation, disputes relating to copyright, trademark, or the use/misuse of content on the website, as well as disputes arising from materials supplied by our European contractors – these Terms shall be governed by and construed in accordance with the laws of Ukraine. In such cases, you agree that the claim shall be brought in, and you submit to the exclusive jurisdiction of, the courts of Ukraine. This reflects LupoToro’s engagement of European contractors and our intent to resolve content-related matters in a jurisdiction familiar with the relevant laws (e.g., the Law of Ukraine on Copyright and Related Rights, as referenced elsewhere in our policies). As with UAE disputes, you waive any jurisdictional or venue objections to litigating in Ukraine for these specific matters.

     iii.     Overlap or Unclassified Disputes: We recognize that some disputes could involve both general contractual issues and intellectual property issues, or otherwise might not squarely fall into one of the above categories. In the event a dispute between you and LupoToro cannot reasonably be classified under one of the two categories above, or involves a combination of issues, then the parties agree that such dispute will default to the laws of the United Arab Emirates, and the courts of Dubai, UAE shall have exclusive jurisdiction. In other words, unless a dispute is clearly an IP-related dispute covered by Ukrainian law, UAE law will govern. This default also applies to any “mixed” dispute that includes both IP and non-IP claims, to the extent permissible by applicable law. (If a court of competent jurisdiction ultimately determines that a different law must apply to certain claims that by law cannot be governed by the chosen law, then those claims will be governed by the relevant law as required, but the UAE law selection will be enforced to the maximum extent possible for consistency.)

1.      Regardless of which of the above applies, these Terms are not governed by the United Nations Convention on Contracts for the International Sale of Goods (CISG); that convention is expressly excluded. Additionally, no other nation’s conflict-of-law principles will apply – the specified substantive laws of the UAE or Ukraine (as applicable) will govern, without regard to any principles that would cause the law of another jurisdiction to apply.

      iv.     Australian Registration Note: LupoToro Group Pty Ltd is an Australian-registered corporation (established 2023), but this administrative registration does not create any submission to Australian law or jurisdiction for the purposes of these Terms. LupoToro does not maintain an operational headquarters or conduct trading, revenue-generating business, or targeted services in Australia at this time. The choice of UAE or Ukrainian law as set out above remains exclusively in force and is not superseded or altered by the company’s incorporation in Australia. For the avoidance of doubt, the mere fact of LupoToro’s registration in Australia shall not give rise to Australian jurisdiction over disputes related to these Terms, and you agree not to assert any such claim. That said, LupoToro will comply with any mandatory Australian legal requirements that do apply to it (for example, Australian corporate filing obligations, or Australian privacy/data regulations to the extent applicable). Such compliance does not waive the agreed governing law or jurisdiction for dispute resolution. If you are accessing the website from a jurisdiction that provides you with certain non-waivable consumer rights or statutory protections, nothing in this section is intended to deprive you of the benefit of such protections; however, to the extent permitted, the governing law and forum for disputes will be as stated above. By entering into these Terms, you waive any right you may have, under the laws of your home jurisdiction, to claim that the governing law or forum selection provisions should not apply (subject to any statutory rights you hold that cannot lawfully be waived).

       v.     ADR/Dispute Resolution: Prior to commencing court proceedings, the parties agree to attempt to resolve any dispute arising under these terms by good-faith negotiation and, if unsuccessful, by mediation conducted in the jurisdiction applicable under Section 20. Litigation may only be commenced if such efforts fail within a reasonable period (not exceeding 30 days). Mediation shall take place under the rules of the Dubai International Arbitration Centre (DIAC) for disputes governed by UAE law, or the Ukrainian Mediation Centre for disputes governed by Ukrainian law, unless otherwise agreed in writing. Mediation shall occur within thirty (30) days of a written request, unless extended by mutual agreement. Only after mediation has failed may litigation or arbitration be commenced.

21. Indemnity

User Indemnification:

i.               You agree to defend, indemnify, and hold harmless LupoToro Group, its parent, subsidiaries and affiliates, and each of their respective officers, directors, owners, partners, employees, agents, contractors, and representatives (collectively, the “Indemnified Parties”) from and against any and all claims, demands, actions, liabilities, losses, damages, judgments, or expenses (including reasonable attorneys’ and experts’ fees) arising out of or relating to:

1.      your use of the website or any content or services obtained through the website; 

2.      any content or material you submit, post, transmit, or otherwise make available through LupoToro (including but not limited to user comments, uploads, or contributions); 

3.      your breach of these Terms or violation of any applicable law or regulation; 

4.      any actual or alleged infringement, misappropriation, or violation of any intellectual property right or other right of any third party by content you provide or actions you take; or 

5.      any fraud, willful misconduct, or negligence by you in connection with your use of the site.

                            ii.     This means that if a third party makes a claim against LupoToro related to your conduct or content, you will be responsible for all costs and damages we incur, including reasonable legal fees. For example, if you post content on our site that infringes someone’s copyright and we are sued as a result, you must indemnify us for that claim (including any damages and legal fees). The indemnification obligations in this section will apply to the fullest extent permitted by law and will survive the termination or expiration of these Terms.

1.      Director and Partner Liability Shield: No user or third party shall have any right of recourse against any director, officer, partner, or owner of LupoToro in their personal capacity. All claims must be brought solely against the company entity (LupoToro Group Pty Ltd or its affiliates). To the fullest extent permitted by law, LupoToro indemnifies its directors, partners, and officers against third-party claims arising from acts or omissions of employees, contractors, or agents acting in good faith within the scope of their duties. This indemnity shall not apply to willful misconduct, gross negligence, criminal acts, or statutory breaches by the individual concerned.

Indemnification Procedure:

i.                If any Indemnified Party receives notice of a claim or legal action to which your indemnity obligation applies, LupoToro will promptly notify you of the claim (provided that any delay in notification will not waive or reduce your indemnification obligations except to the extent you are materially prejudiced by such delay). You may elect to assume control of the defense and settlement of the claim with counsel of your choosing, provided that you give us prior written notice of your intention to do so, you conduct the defense diligently and in good faith, and you keep LupoToro informed of material developments. In any case, LupoToro reserves the right to participate in the defense of the claim, at its own expense, with counsel of its own selection, and to approve any settlement that would impose any obligation or liability on an Indemnified Party. You may not settle any claim without LupoToro’s prior written consent, unless the settlement unconditionally releases all Indemnified Parties from all liability and does not require any admission of fault or payment by any Indemnified Party. The Indemnified Parties agree to reasonably cooperate (at your expense) with your defense of the claim and to use reasonable efforts to mitigate any losses or liabilities arising from the claim. Your indemnification obligations shall survive any termination of your use of the website or these Terms and remain in effect indefinitely with respect to acts or omissions occurring before termination

No Personal Liability of Officers; Company Indemnification of Management: 

i.                You acknowledge that no director, officer, partner, or owner of LupoToro Group shall be personally liable for the acts or omissions of LupoToro, its employees, or its other agents. 

ii.              Any claims, obligations, or liabilities arising out of your use of the site or these Terms are understood to be claims against the company entity (LupoToro Group Pty Ltd or its affiliates), not against any individual associated with LupoToro. In turn, to attract and retain qualified personnel, LupoToro agrees to indemnify its directors, partners, and owners against any third-party claims or liabilities arising from actions taken by LupoToro’s employees or agents in the course of the company’s business, to the fullest extent permitted by law. However, this company indemnification of LupoToro’s management does not apply to the extent a claim is finally adjudicated to result from the individual’s own willful misconduct, gross negligence, or knowing violation of law. In other words, while LupoToro will protect its leadership from personal liability for business activities carried out in good faith, it will not indemnify any individual for that person’s personal wrongdoing. 

iii.             This clause does not limit any other protections (such as D&O insurance or statutory indemnities) that LupoToro’s officers or owners may have. It is intended primarily to clarify that users and third parties must pursue claims against the company, not its people, and that LupoToro stands behind its team members in legal matters arising from good-faith performance of their duties.

Contractor and Contributor Responsibilities:

i.                LupoToro sometimes engages independent contractors, freelancers, vendors, or other third-party contributors to assist with content creation, development, or other services. Any such third-party provider of content or services is required to adhere to strict legal and compliance obligations in their work with LupoToro. In particular, all contractors or contributors must warrant that any materials, content, or work they provide to LupoToro are original to them or fully licensed for LupoToro’s use, and that no such materials will infringe any intellectual property or proprietary rights of others. 

ii.              By submitting or providing any content or deliverables to LupoToro, the contractor represents and guarantees that they have obtained all necessary rights, permissions, consents, and licenses for LupoToro to use the materials in connection with our website or business, and that the materials do not violate any law or the rights of any person or entity. LupoToro reserves the right to request documentation or proof of such rights or licenses at any time for any third-party content supplied. Contributors and contractors are expected to cooperate promptly in providing evidence of ownership or permission for content they supply. In addition, LupoToro may require contractors to maintain appropriate insurance coverage, including (where relevant) insurance for intellectual property infringement liability, with policy limits sufficient to cover potential claims (for example, an errors & omissions or professional liability policy). 

iii.             Contractors must also comply with any professional licensing or regulatory requirements applicable to the services they provide and shall furnish copies of any such licenses or certifications upon request.

Indemnification by Contractors: 

i.                To further protect LupoToro, any third-party contractor, supplier, or contributor who provides materials or services to LupoToro agrees to defend, indemnify, and hold LupoToro harmless from any and all claims, liabilities, losses, damages, or expenses (including reasonable legal fees) arising from or related to the materials or services such third party provided. This means that if a contractor’s work, content, or actions lead to a legal claim against LupoToro (for example, an allegation that content supplied by the contractor infringes someone’s copyright or trademark, or a claim stemming from the contractor’s negligence or unlawful conduct), the contractor is financially responsible for all resulting costs, damages, and legal fees, to the fullest extent permitted by law. LupoToro’s acceptance of work from a contributor does not relieve the contributor of liability for issues arising from that work. 

ii.              LupoToro may, at its discretion, remove, suspend, or demand revisions to any third-party supplied content if we believe the content may violate these Terms, infringe rights, or expose LupoToro to risk. Contractors and contributors are independent parties and not employees or agents of LupoToro; as such, they shall not hold themselves out as having authority to bind LupoToro, and they bear sole responsibility for obeying all laws in connection with their work. Any failure by a contractor to meet the obligations in this clause may result in termination of the engagement and potential legal action by LupoToro to enforce its rights.

Additional information can be found within section 15 of these terms. Further information to the above is provided below; we continue with the following (we’ve made best efforts to avoid any overlap or repetition):

Mandatory Insurance & Licence Verification: Contractors, suppliers, or contributors must:

i.       Maintain insurance policies covering intellectual property and copyright infringement with limits of not less than US $1,000,000 (or local equivalent), issued by a reputable insurer, and Contractors, suppliers, or contributors must:

a.      Maintain insurance policies covering intellectual property and copyright infringement with limits of not less than US $1,000,000 (or local equivalent), issued by an insurer authorised in the jurisdiction where the contributor operates and recognised in the jurisdiction where LupoToro operates (failure to maintain such insurance does not limit the contractor's indemnity obligations);

b.     Ensure such policies expressly cover defence costs;

c.      When required and asked, provide documented proof of coverage prior to publication and annually upon renewal; and

d.     When required and asked, provide documented confirmation of ownership or valid licences for all materials supplied.

ii.     Ensure such policies cover defence costs and remain in effect for the duration of supply.

Claims Handling & Cooperation:

i.       The Indemnified Parties shall use reasonable efforts to mitigate losses and notify you promptly of any claim or proceeding.

ii.     You may assume control of the defence and settlement in good faith, provided you keep the Indemnified Parties informed.

iii.    The Indemnified Parties may participate in proceedings with their own counsel at their own cost.

Disclaimer on Third-Party Conduits:

LupoToro disclaims all responsibility and liability for inaccuracies, omissions, or misrepresentations in information, guarantees, or content provided by third-party conduits (including vendors, suppliers, contractors, consultants, or agents). Full liability rests with the third-party supplier of such information. All third-party content is provided strictly on an “as-is” basis without warranty as to accuracy or completeness. Third-party conduits shall indemnify and hold LupoToro harmless from any claim, loss, or liability arising out of their information or representations.

Director, Partner & Owner Indemnity:

i.                No Director, Partner, or Owner of LupoToro shall be personally liable for wrongful acts committed by employees, third parties, contractors, or conduits acting under LupoToro’s name.

ii.              To the fullest extent permitted by law, LupoToro Group shall indemnify its Directors, Partners, and Owners against claims, liabilities, damages, expenses, or judgments arising from the acts or omissions of employees in the performance of their duties.

iii.             This indemnity shall not extend to any liability arising from a Director’s, Partner’s, or Owner’s breach of statutory duties owed under applicable corporate, fiduciary, or regulatory law.

1.     No personal recourse by users: All claims by users or third parties must be brought solely against the company entity, not against any director, partner, or officer in their personal capacity.

Conditions of Indemnification:

o   The Indemnified Party must cooperate fully with the Company in defending any claim.

o   The Company retains sole control over the defence and settlement; however, the Indemnified Party may participate with counsel of its own choosing at its own cost.

Limitations & Exclusions:

i.       The Company’s aggregate liability under this indemnity shall not exceed the total compensation paid to the relevant employee(s) in the 12 months preceding the claim.

ii.     This indemnity shall not extend to the Indemnified Party’s own breach, wilful misconduct, gross negligence, or criminal acts.

Proportionate Liability:

i.        Where the Indemnified Parties are partly responsible for a claim, indemnification shall apply only to the extent of your contributory fault.

Survival & Severability:

i.        The provisions of these Terms which by their nature should survive termination (including indemnities, limitations of liability, confidentiality obligations, intellectual property provisions, and disclaimers) shall continue to apply after termination or expiry. If any provision of this clause is found invalid or unenforceable, the remainder shall remain in full force and effect.

22. General Terms

These Terms shall be read and enforced in accordance with Section 20 (Governing Law and Jurisdiction). For the avoidance of doubt, jurisdiction shall rest exclusively with the courts of the United Arab Emirates or the courts of Ukraine, depending on the nature of the dispute as set out above. You agree to submit to the personal jurisdiction and venue of such courts. No action or claim may be brought more than one (1) year after the cause of action arose, or the minimum statutory limitation period permitted by applicable law, whichever is longer. Should any part of our Legal Terms be held invalid or unenforceable, that portion shall be construed consistent with applicable law (see section 20 for clarifications) 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. 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.

* * *

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.

LupoToro Group complies with applicable data protection legislation, including the Privacy Act 1988 (Cth) (Australia), the Data Protection Act 2003 (UAE), and, where applicable, the General Data Protection Regulation (GDPR) (EU) and the Law of Ukraine on Personal Data Protection.

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.

Data Breach Notification Procedure

In the event of a data breach that is likely to result in serious harm to affected individuals, LupoToro will:

5.     Promptly notify affected individuals with information about the breach, including the type of data involved, potential consequences, and steps being taken to mitigate harm; and

6.     Notify the relevant regulatory authorities where required by law, including but not limited to the Office of the Australian Information Commissioner (OAIC), the relevant EU supervisory authority under GDPR, or equivalent authorities in other applicable jurisdictions.

LupoToro will document all breaches internally, whether or not notification is required, and will cooperate with regulators and affected individuals as legally required.

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 do our best to use reasonable and industry-standard safeguards, 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.