Privacy, Legal, Policies, & Additional Resources

Additional provisions — 30 October 2026. Read these provisions with all existing policies, including sections 3, 6, 7, 15, 20, 21 and 22 of Legal, Data/Cookie & Disclaimers & Policies. Existing clauses remain published. These provisions clarify their application and preserve every protection, defence, indemnity and remedy that LupoToro may lawfully exercise; they do not create immunity from mandatory law.

Excluded advice and limits of service

Express service-scope clarification — 30 October 2026. LupoToro Group does not provide financial advice, financial product advice (whether general or personal), investment advice, legal advice or legal representation. These services are excluded from LupoToro's activities, including its website, publications, research, meetings, introductions, communications and client engagements. The exclusion is not limited to personalised advice.

This express exclusion controls the interpretation of any earlier wording referring to an expressly agreed scope, licence, authorisation, exemption or professional advisory relationship. Such wording does not create an exception to this exclusion or an offer to provide any of these services. An engagement, referral, partner relationship or written agreement does not authorise anyone to provide these excluded services on LupoToro's behalf.

LupoToro does not undertake any other advice or work requiring a licence, registration, practising certificate, permit or other regulatory authorisation unless it is legally entitled to undertake that specific activity and every applicable requirement has been established and satisfied. Required authority must be current and cover the actual legal entity, activity, jurisdiction and scope. LupoToro does not claim or acquire authority merely because a partner, contact, contractor or other third party holds it. Work requiring authority that LupoToro does not have must not commence or continue.

Clients and readers who need financial, investment or legal advice must obtain it from an appropriately qualified and authorised independent professional under that professional's own engagement. An introduction does not make the professional's advice LupoToro's advice or extend the professional's authority to LupoToro. These service boundaries must be observed in practice: the legal classification of actual conduct is determined by applicable law, and no disclaimer changes that classification or excludes a non-excludable obligation or liability.

Mandatory law and interpretation

Mandatory applicable law prevails over every website provision. These additional provisions control any inconsistency in the interpretation or operation of earlier website provisions to the extent expressly addressed here. A separately executed engagement agreement governs its subject matter, subject to mandatory law; website updates do not unilaterally amend it. Unaffected provisions continue to operate. An unlawful or unfair term is not made enforceable merely by a general savings statement, severability clause or acknowledgement of these Terms.

References to no liability, no duty of care, no personal recourse, no reliance, exclusive remedies, indemnification or action at a person's own risk apply only to liabilities and rights that may lawfully be excluded or allocated. They do not exclude Australian Consumer Law guarantees or remedies, liability for misleading or deceptive conduct that cannot lawfully be excluded, statutory officer duties, accessorial liability or other mandatory obligations. Nor do they bind regulators or non-consenting third-party rights holders. A third party's conduct does not automatically relieve LupoToro of its own legal responsibility.

Consumer and small-business protections

Where applicable, the Australian Consumer Law, including sections 18, 23–28, 29 and 60–64A, governs representations, unfair contract terms and consumer guarantees. Business customers can also qualify as consumers under that law. Services supplied to a consumer carry the applicable guarantees, including due care and skill; statutory remedies depend on the nature of the failure. The existing section 64A remedy limitation applies only to qualifying supplies and only where its statutory requirements are satisfied. It is not a universal cap on consumer remedies.

For any standard form consumer or small-business contract protected by unfair-contract-terms legislation, LupoToro will not propose, apply or rely on an unfair term. A discretion, indemnity, exclusion, termination right or procedural requirement must be reasonably necessary to protect legitimate interests, transparent and proportionate in its operation. A term requiring a person to bear a loss irrespective of responsibility, or preventing a lawful remedy, must not be applied in that manner. Existing proportionate-liability protections apply across the website's indemnities.

Changes, suspension and termination

Website changes operate prospectively. They do not remove accrued rights, retrospectively alter an accepted engagement or constitute consent to a new use of personal information. Material changes to continuing contractual rights require reasonable advance notice and any agreement required by law. If a protected standard form contract permits a material adverse change, the affected party may end the affected continuing service before the change takes effect without a change-related exit penalty, with payment for services properly supplied and treatment of prepaid unused services in accordance with law and the agreement.

Discretionary suspension, removal or termination under website terms must be exercised reasonably and for a legitimate purpose, such as addressing a material breach, security threat, rights claim or legal requirement. Where practicable, notice and a reasonable opportunity to remedy a remediable breach will be provided. Immediate protective action remains available where reasonably necessary to prevent harm or meet legal obligations. Such action does not extinguish accrued lawful remedies or justify retaining payments contrary to law.

Liability cap and indemnity operation

Where the existing website liability cap validly applies, its reference to the greater amount means the greater of the total amount paid by the user for services in the six months preceding the claim and US$500, or any higher amount required by applicable law. It is an aggregate cap, not a separate allowance for each claim. It does not override a separately agreed engagement liability arrangement or apply to liability that cannot lawfully be capped. The qualifications in this section apply to both the cap and the exclusions it accompanies.

Existing user, contractor and contributor indemnities protect against loss to the extent attributable to the indemnifying party's relevant breach, negligence, unlawful conduct or supplied material for which that party is legally responsible. They do not transfer loss to that party to the extent caused by an indemnified party's own wrongful conduct or failure to take reasonable mitigation steps. An allegation alone does not conclusively establish liability. Recoverable defence costs must be reasonable and properly incurred; there is no double recovery for the same loss.

Existing notification, defence, settlement-consent and cooperation provisions continue to apply. A consent or approval concerning a reasonable settlement must not be unreasonably withheld or delayed, but no indemnified party is required to accept an admission, non-monetary obligation, inadequately funded settlement or settlement that fails to provide an appropriate release. Defence and settlement rights remain subject to conflicts of interest, insurer rights and applicable law.

Governing law, dispute resolution and service

The existing UAE and Ukrainian choice-of-law and forum provisions do not displace mandatory Australian law, including territorial intellectual-property law, or prevent proceedings in an Australian court or tribunal where a person has a right that cannot lawfully be excluded. They do not require a consumer or protected small business to use an overseas forum where doing so would be unlawful or unfair. Their operation in a particular international engagement requires assessment of the actual transaction and the executed agreement; a website reference does not establish enforceable consent by a third-party claimant.

Negotiation or mediation requirements do not prevent either party seeking urgent interlocutory or protective relief, preserving a limitation period, complying with a court order, making a protected disclosure or contacting a regulator, ombudsman or statutory complaints body. No contractual period shortens a non-excludable statutory period. A party may commence protective proceedings without awaiting mediation; commencing them does not itself waive available settlement processes. Declining voluntary mediation is not automatically bad faith.

The email contact legal@lupotoro.com is available for correspondence. References to email-only contact or the absence of a public-facing office do not deny the company's registered-office obligations or restrict service by a method permitted by law, including section 109X of the Corporations Act 2001 (Cth). Website permission is not required to use material lawfully in court, respond to compulsory process, obtain legal advice or make a protected disclosure. Originals, copies, electronic records and authenticity disputes remain subject to applicable evidence law and the court's powers.

Officer protections and corporate authority

Existing company and individual protections remain subject to sections 199A–199C of the Corporations Act 2001 (Cth) and other restrictions on indemnifying or insuring liabilities, penalties and legal costs. No website statement authorises a prohibited payment or exempts an officer from a liability owed to the company. Entitlements, limits and defence control under a valid deed or insurance policy must be assessed separately; a website label does not establish insurance coverage. Titles, email addresses, partner listings and introductions do not themselves establish authority to bind another legal entity.

Legal status and duties depend on applicable law and the actual relationship. A contractor, partner, adviser or non-executive label does not by itself determine employment status, agency or director and officer duties. Required appointments, delegations, approvals and contract acceptance must be documented. No website policy itself grants shares, a board position, a licence or a right to remuneration.

LupoToro Group take a strong stance against Modern Slavery and Human Trafficking. LupoToro’s activities are subject to applicable laws and regulatory obligations. 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

The primary language of this website is English. Where a translated version is available, readers should refer to the English version if meaning is unclear and contact LupoToro for clarification.

2. Website Information and Engagement Scope

Website publications provide general information and do not take account of a reader’s circumstances. They are not personalised financial, investment, legal, tax or other regulated professional advice, and are not an offer to acquire an investment.

LupoToro’s commercial strategy, research and coordination services are provided only within an agreed engagement scope. Any regulated activity requires the relevant licence, authorisation or applicable exemption and must be assigned to an appropriately authorised provider. A service description or written agreement does not itself confer regulatory authorisation.

Clients should obtain appropriately qualified advice for decisions requiring it. Engagement responsibilities and deliverables are defined in the applicable written agreement, subject to mandatory law.

3. Terms of Service and Disclaimers

Capitalised terms, unless otherwise defined, have the meaning specified within the Definitions section below. These website Terms of Service, the Privacy Policy and applicable published notices govern use of this website. They do not replace a separately signed client engagement agreement. We may amend our Legal Terms at any time without specific notice to you. The latest copies of our Legal Terms will be posted on our Website, and you should review all Legal Terms prior to using our Website. After any revisions to our Legal Terms are posted, you agree to be bound to any such changes to them. Therefore, it is important for you to periodically review our Legal Terms to make sure you still agree to them.

4. Disclaimers, Policies and Terms of Service Update Date

Last editorial update: 12 October 2026. This update clarifies website information and engagement scope, removes duplicated and outdated wording, and preserves rights that cannot lawfully be excluded.

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. Accounts and Separate Services

The public corporate website does not require a visitor account. Any separately provided service with account access is subject to its applicable access and security terms.

10. Enquiries and Submitted Material

Submit only information you are authorised to share. Do not send classified, privileged or highly sensitive material through a general enquiry. Confidential information should be exchanged through an agreed channel and under appropriate arrangements.

11. LupoToro News Feed and Media on the Website

The News Feed [Insights] and any articles on the LupoToro.com website are 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.

Certain insights, articles, research notes, and commentary published on this website have been migrated from original online blog posts, media publications, and legacy digital platforms. Over time, the website has undergone structural changes, including name changes, server migrations, and transitions between different web hosting environments and provider platforms.

As part of these migrations, some archived content may retain residual technical artefacts. These may include, but are not limited to, formatting irregularities, character encoding issues, missing symbols, spacing anomalies, or unintended substitutions where characters were not transferred cleanly between platforms. Such artefacts are a known and occasional by-product of large-scale content migration across differing content management systems and hosting infrastructures.

While reasonable care has been taken to preserve the original substance, intent, and analytical integrity of all published material, certain legacy articles (particularly older publications) cannot be amended directly due to their archival nature or original publishing constraints. Where necessary, updated editorial notes may be added to the beginning of affected articles to alert readers to the potential presence of formatting or text inconsistencies, without altering the original analytical or historical record.

LupoToro Group remains committed to transparency, accuracy, and the ongoing maintenance of its published research and commentary. Readers are encouraged to assess archived content within its original publication context and timeframe, particularly where formatting artefacts are present.

If any technical errors, display issues, or migration-related inconsistencies are identified, please notify the LupoToro Administration team at admin@lupotoro.com, and the matter will be reviewed as part of ongoing site maintenance and content integrity processes.

Defence and Dual-Use Research

Defence clearances, contracts and third-party credentials

LupoToro Group does not purport to hold any active defence or national-security clearance, or any active defence contract directly in its own name, and makes no such claim. References to defence, intelligence, government, sovereign capability or dual-use activities describe areas of research, interest or potential application; they do not represent that LupoToro Group is a cleared, accredited, licensed or contracted defence supplier, or that it has government endorsement, sponsorship or approval.

Independent network partners, associates or contacts may hold relevant security clearances, defence contracts, licences, accreditations or other authorisations in their own capacities. Any such status belongs solely to the relevant person or entity and remains subject to its applicable scope, conditions, jurisdiction and validity. LupoToro Group neither claims those credentials or contracts as its own nor represents that a relationship, introduction, collaboration, biography, past service or website reference transfers, extends or makes them available to LupoToro Group or any other person. No current clearance, contract, licence or authority of any particular third party should be inferred from a reference on this website.

Such relationships do not, by themselves, establish an agency, legal partnership, joint venture, contractual entitlement, authority to act for a government or third party, or permission to access or disclose classified, protected or controlled information. They do not authorise LupoToro Group to perform regulated work, use another party’s licence or credentials, or perform or subcontract under another party’s contract. Any proposed engagement must identify the responsible legal entity and establish the required current authorisations, contractual permissions, security arrangements and lawful need-to-know before work or information exchange begins. Do not submit classified or controlled material through this website or general enquiry channels.

This notice clarifies the attribution and limits of the status described above. It does not exclude or restrict any right, remedy, obligation or liability that cannot lawfully be excluded or restricted, including under the Australian Consumer Law.

Public research descriptions concern analytical methods, development objectives and potential applications. They do not confer government endorsement, accreditation or authority to supply regulated defence goods, technology or services. The stage and intended scope of individual initiatives are described on their respective pages.

Any work involving controlled technology, restricted information or regulated services requires applicable authorisations, qualified participants and an agreed scope. Public research references are not permission to manufacture, export or deploy a capability.

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. Descriptions of services on this website are general introductions; any engagement requires a separately agreed scope. 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. 

Website information is general and must be assessed in context. Readers should obtain qualified advice for decisions requiring it. Client responsibilities, deliverables and reliance on engagement-specific work are governed by the relevant written agreement, subject to applicable law. The limitations in these terms do not exclude rights or obligations that cannot lawfully be excluded.

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. Website Status, Updates and External References

This is LupoToro’s public corporate website. Service descriptions, research initiatives and dated publications should be read in their stated context. Research objectives and proposed architectures are distinct from validated deployment capabilities.

External research citations, names and trademarks do not by themselves imply endorsement, affiliation or a commercial relationship. Specific relationship descriptions remain subject to the relevant agreements.

Material corrections and updates may be made as information changes. Archived announcements retain their publication date; any later editorial note is identified separately. Website information does not replace an agreed engagement scope or transaction documentation. Nothing in these terms excludes rights or obligations that cannot lawfully be excluded.

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.

Australian Registration Note: LupoToro Group Pty Ltd is an Australian-registered corporation (established 2023). The governing-law provisions above remain subject to mandatory laws and the jurisdiction of competent authorities. Nothing in these Terms excludes any statutory right, obligation or jurisdiction that cannot lawfully be excluded. The governing law and dispute arrangements for a client engagement are addressed in its written agreement, subject to applicable law.

       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)

All media releases published by LupoToro Group, including those available on the LupoToro.com website, are provided for general informational purposes only and do not constitute, and must not be relied upon as, legal, financial, investment, or other professional advice.

While LupoToro Group endeavours to ensure that information is accurate and current at the time of publication, no representations or warranties, express or implied, are made as to the completeness, accuracy, reliability, suitability, or availability of any content. Any reliance placed on such information is strictly at the reader’s own risk. Readers are encouraged to conduct their own due diligence and seek independent professional advice appropriate to their individual circumstances before making any decisions or taking any action.

To the fullest extent permitted by law, LupoToro Group disclaims all liability for any loss or damage, including indirect or consequential loss, arising from the use of or reliance on any information contained in its media releases or related communications.

The views and opinions expressed in media releases are those of the individual spokesperson(s) and do not necessarily reflect the official policy or position of LupoToro Group. All media releases are subject to change without notice.

LupoToro Group maintains original hard-copy records of its media releases (including releases which may no longer appear online for any reason). Certain releases published online may have been scanned, transcribed, or digitally reproduced from these originals. While reasonable efforts are made to ensure accuracy, there remains a risk of clerical, transcription, formatting, or typographical errors, including those arising from ongoing website updates or technical changes. Any such discrepancies are considered clerical in nature.

Where inconsistencies arise, the original hard-copy version shall prevail. LupoToro Group may, upon request, provide a scanned copy of an original media release for private comparison purposes only. Requests can be submitted to admin@lupotoro.com. Such copies are not to be used for public or legal purposes without prior written consent.

27. Website Security and Unauthorised Access Policy:

LupoToro Group is committed to maintaining the integrity, security, and reliability of its website and online publications. The organisation implements reasonable and appropriate technical, administrative, and operational measures to mitigate the risk of unauthorised access, malicious activity, and data compromise.

However, no system or platform can be guaranteed to be completely secure. LupoToro Group does not warrant or guarantee that its website, digital platforms, or published content will be free from unauthorised access, cyber intrusion, alteration, or interference at all times. This includes, but is not limited to, actions by external threat actors as well as potential misuse, error, or unauthorised conduct by current or former employees, contractors, or affiliated personnel.

While LupoToro Group maintains internal controls and governance processes designed to ensure the accuracy and integrity of its online publications, the organisation cannot guarantee that all content will remain accurate, complete, or unaltered at all times, particularly in circumstances involving unauthorised access or misuse of privileged systems.

To the fullest extent permitted by applicable law, LupoToro Group disclaims liability for any loss, damage, or consequence arising from unauthorised access, alteration, or reliance on compromised or inaccurate information published via its website or digital platforms.

LupoToro Group reserves all rights in relation to its systems, content, and enforcement of this policy, in accordance with applicable laws and regulations.

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Privacy Policy

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

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

Public website and social media content is general information, not personalised financial, investment, legal or tax advice. Commercial research, strategy and coordination work is defined in the relevant client agreement. Regulated services require the applicable licence, authorisation or exemption; see Section 2 for the distinction between website information and engagement scope.

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.

Additional Policy: Unauthorised Third-Party Content and Online Representation

As digital activity continues to expand, there has been a growing trend of third parties leveraging the names of established companies, websites, blogs and online platforms to generate traffic. This is typically undertaken to improve their own visibility through search engine optimisation (SEO) techniques, including backlink generation, keyword targeting, and the aggregation or republication of existing content. In some cases, coordinated networks of websites may influence search rankings by creating artificial link structures and amplifying selected content, enabling lower-authority sources to gain increased visibility.

In addition, misleading or inaccurate content may spread rapidly online, particularly when it is repackaged and distributed across multiple platforms to maximise engagement. This environment can result in third-party publishers reproducing, reinterpreting or misrepresenting information in a manner that is not authorised, verified or endorsed by the original source.

Accordingly, any references to or publications involving LupoToro Group that are not expressly issued or confirmed through our official channels should not be considered accurate, authorised or endorsed by LupoToro Group. We encourage individuals and organisations to seek direct confirmation from us where clarification is required as a first port of call and as soon as possible. Our contact information can be found within our online policies, and contact can also be made directly through our official website contact page. We will respond to all requests for clarification on third party media publications, releases, stories and associated questions, in a timely manner.

LupoToro Group maintains a strict policy of not soliciting, arranging, publishing, or co-publishing any news articles, public media content, or interviews through third-party platforms or external outlets. This position reflects a fundamental principle of our operations: the protection of client confidentiality through the delivery of services grounded in discretion and full regulatory compliance.

LupoToro Group takes pride in its professional reputation and operates with discretion and regulatory integrity to benefit its clients, networks, and partners. It will continue to uphold its policies, operating procedures, and standards in full compliance.

AEON Initiative and Platform Disclaimer

AEON is a proprietary software platform under development by LupoToro Group and is currently in an incubation and beta testing phase.

At this stage, AEON is not publicly available, not offered for sale, and not marketed as a commercial product or service. Access to AEON is limited to internal use and select partners of LupoToro Group, granted on a case-by-case basis for evaluation, testing, or collaborative purposes. All references to AEON on this website are provided for general informational purposes only. Any descriptions of functionality, capabilities, or use cases reflect ongoing development and may change, evolve, or be withdrawn at any time without notice. AEON is not complete, may not be fully functional, and is not intended to be relied upon for any particular purpose. No representation or warranty is made as to its performance, availability, or readiness for deployment.

Nothing on the AEON page constitutes:

- an offer to sell or license software

- a representation that AEON is commercially available

- a guarantee of functionality, performance, or outcomes

LupoToro Group makes no claim that AEON is a finished or market-ready product and makes no commitment that AEON will be completed, released, or made commercially available. Any access provided to select parties is subject to separate terms and conditions.

Nothing on the LupoToro website, any authorised LupoToro communication relating to AEON, or on the AEON platform itself constitutes financial, investment, legal, or other professional advice, nor an offer or solicitation to participate in any transaction or activity.

To the maximum extent permitted by law, LupoToro Group disclaims all liability arising from reliance on any information relating to AEON. No duty of care is owed to any person in relation to AEON or any information provided. Nothing herein creates any partnership, joint venture, agency, or advisory relationship. The AEON page on the LupoToro website is provided as a placeholder for general informational purposes, outlining potential use cases and anticipated benefits of the AEON platform. It does not constitute a representation of current functionality or availability and offers no guarantees. LupoToro does not provide any option to purchase, subscribe to, or access AEON through the website, and no such offering is being made.

By accessing or viewing information relating to AEON, you acknowledge that it is an experimental and evolving platform and that all information provided is subject to change as development continues.

The AEON Initiative, including all associated concepts, research areas, analytical frameworks, technologies, infrastructure models, commentary, strategic assessments and development initiatives presented by LupoToro Group, is provided strictly for general informational, exploratory and research-related purposes only. References to artificial intelligence, investment intelligence systems, tokenized private-market infrastructure, fintech ecosystems, defence-linked analytics, cybersecurity, strategic technologies, private capital markets or any related subject matter should not be interpreted as guarantees, promises, representations, warranties, commitments or assurances of future development, functionality, commercial deployment, operational capability, regulatory approval or investment outcome.

The AEON Initiative represents an evolving collection of strategic initiatives, exploratory concepts, technological investigations and ongoing research interests currently being examined, developed and expanded upon by LupoToro Group. Certain systems, concepts, infrastructure models, analytical environments or technological frameworks referenced throughout The AEON Initiative may remain in early-stage research, conceptual exploration, strategic analysis, prototype development or ongoing evaluation phases. As such, no representation is made that any component described within The AEON Initiative currently exists in a completed, operational, production-ready, commercially available or regulatory-approved form unless expressly stated otherwise.

LupoToro Group may continue to research, analyse, refine, expand, modify, suspend, restructure, discontinue or redevelop any aspect of The AEON Initiative at any time, without notice and without obligation. The future development, implementation or commercialisation of any concept, platform, analytical system, infrastructure model or strategic framework described under The AEON Initiative remains subject to numerous factors including, but not limited to, technological feasibility, operational capability, strategic alignment, regulatory requirements, jurisdictional restrictions, market conditions, funding considerations, infrastructure availability and commercial viability.

All information relating to The AEON Initiative is provided strictly on an “as is” and “as available” basis. To the fullest extent permitted under applicable law, LupoToro Group expressly disclaims all warranties, representations, conditions and guarantees, whether express, implied or statutory, including but not limited to warranties relating to accuracy, completeness, reliability, scalability, operational continuity, fitness for a particular purpose, merchantability, interoperability, technological capability, investment suitability, commercial performance, profitability, non-infringement, uninterrupted availability or future success. No reliance should be placed upon any statement, projection, observation, concept or forward-looking commentary presented within The AEON Initiative.

Public descriptions of Aeon research are general information, not personalised investment, legal, tax or other regulated professional advice. Any strategic assessment or analytical pilot requires an agreed scope, permitted sources and acceptance criteria. Readers remain responsible for their own due diligence and for obtaining qualified advice appropriate to the decision.

The AEON Initiative does not constitute and should not be interpreted as an offer to sell, an offer to purchase, a solicitation of investment, an invitation to invest, a securities offering, a fundraising communication, a regulated financial promotion or an inducement to enter into any financial arrangement in any jurisdiction. LupoToro Group does not publicly solicit investment into The AEON Initiative, its associated concepts, technologies, infrastructure initiatives or any related activities through the materials presented on this website or associated communications.

LupoToro Group may, where appropriate and at its sole discretion, engage in transparent exploratory discussions with prospective strategic partners, organisations, governments, sovereign entities, institutional participants, infrastructure providers, technology groups, research bodies or aligned commercial stakeholders regarding selected areas of mutual interest associated with The AEON Initiative. Any such discussions shall not constitute a commitment, partnership, investment offering, solicitation, operational undertaking or legally binding arrangement unless expressly formalised through executed written agreements between the relevant parties.

The AEON Initiative may involve subject matter connected to financial systems, digital infrastructure, artificial intelligence, strategic technologies, cybersecurity, private capital markets, defence-linked analytics and cross-border operational environments, all of which may be subject to evolving laws, regulatory frameworks, licensing obligations, export controls, jurisdictional restrictions and governmental oversight. LupoToro Group makes no representation that any concept, framework, technology or initiative referenced within The AEON Initiative is legally permissible, operationally available or suitable for use in all jurisdictions or regulatory environments.

To the fullest extent permitted by law, LupoToro Group, together with its affiliates, representatives, directors, contractors, advisors and associated parties, shall not be liable for any direct, indirect, incidental, consequential, financial, strategic, commercial, technological or reputational loss, damage, liability or claim arising from reliance upon, interpretation of, use of or inability to use any information, statement, concept, analytical framework, technology reference or forward-looking commentary contained within The AEON Initiative.

Certain statements contained within The AEON Initiative may constitute forward-looking statements, conceptual observations, strategic commentary or exploratory projections relating to future technologies, infrastructure models, analytical systems, market developments or commercial environments. Such statements inherently involve significant uncertainty and are subject to technological, regulatory, geopolitical, operational, market and strategic risks which may cause actual outcomes to differ materially from any future-oriented statement or conceptual direction described.

LupoToro Group continues to actively explore, evaluate and expand its research into next-generation intelligence systems, strategic analytical environments, digital infrastructure models and evolving capital-market technologies under The AEON Initiative. The company reserves the unrestricted right to revise, redefine, expand, remove, suspend or discontinue any aspect of The AEON Initiative at any time, without notice or obligation. The AEON Initiative should therefore be understood as an evolving strategic and research-oriented framework rather than a definitive representation of completed products, guaranteed deliverables or future commercial outcomes.

LupoToro Group operates in accordance with applicable laws, regulations, industry standards, and compliance obligations within the jurisdictions in which it conducts business activities. All information, materials, publications, research references, strategic commentary, and other content provided on this website are intended solely for general informational purposes.

Nothing contained on this website constitutes or should be construed as legal, financial, investment, tax, accounting, engineering, governmental, regulatory, operational, or professional advice of any kind.

Users should seek independent professional advice tailored to their specific circumstances before making any business, financial, investment, legal, or operational decisions.

References to research initiatives, analytical methodologies, strategic concepts, emerging technologies, infrastructure capabilities, or innovation programs are provided for informational and illustrative purposes only and do not imply governmental affiliation, official authorization, regulatory approval, operational deployment capability, certification, partnership, endorsement, or representation unless expressly stated in writing.

Any forward-looking statements, projections, simulations, estimates, market observations, or references to past or hypothetical performance are inherently subject to risks, uncertainties, and external factors and should not be relied upon as guarantees of future outcomes, performance, or results. Past performance, simulated performance, or illustrative scenarios are not reliable indicators of future performance.

Any dollar figure stated on this website is presented in good faith and is based on information and experience attributable collectively across LupoToro Group's directors, non-executive directors, members of the LupoToro Network, partners, and associates. LupoToro Group strives to ensure that such figures are current and correct; however, they may be aggregated, approximate, historical, or subject to change and should not be relied upon as independently verified financial information.

All engagements, services, collaborations, transactions, partnerships, and commercial activities undertaken with or through LupoToro Group remain subject to applicable laws, contractual agreements, internal governance requirements, regulatory approvals, compliance procedures, and jurisdiction-specific restrictions.

To the maximum extent permitted by applicable law, LupoToro Group disclaims all liability for any direct, indirect, incidental, consequential, financial, commercial, or reputational loss arising from reliance upon information contained on this website or from the use of any products, services, materials, or third-party references presented herein.

Users and clients remain solely responsible for conducting their own independent due diligence, assessments, risk evaluations, and decision-making processes in relation to any business, investment, commercial, or strategic activity. LupoToro Group does not provide regulated financial services, investment advisory services, legal representation, or professional fiduciary advice except within an expressly agreed scope and with every licence, authorisation or exemption required by applicable law. A written agreement alone does not confer authorisation.

Express service-scope clarification — 30 October 2026. LupoToro Group does not provide financial advice, financial product advice (whether general or personal), investment advice, legal advice or legal representation. These services are excluded from LupoToro's activities, including its website, publications, research, meetings, introductions, communications and client engagements. The exclusion is not limited to personalised advice.

This express exclusion controls the interpretation of any earlier wording referring to an expressly agreed scope, licence, authorisation, exemption or professional advisory relationship. Such wording does not create an exception to this exclusion or an offer to provide any of these services. An engagement, referral, partner relationship or written agreement does not authorise anyone to provide these excluded services on LupoToro's behalf.

LupoToro does not undertake any other advice or work requiring a licence, registration, practising certificate, permit or other regulatory authorisation unless it is legally entitled to undertake that specific activity and every applicable requirement has been established and satisfied. Required authority must be current and cover the actual legal entity, activity, jurisdiction and scope. LupoToro does not claim or acquire authority merely because a partner, contact, contractor or other third party holds it. Work requiring authority that LupoToro does not have must not commence or continue.

Clients and readers who need financial, investment or legal advice must obtain it from an appropriately qualified and authorised independent professional under that professional's own engagement. An introduction does not make the professional's advice LupoToro's advice or extend the professional's authority to LupoToro. These service boundaries must be observed in practice: the legal classification of actual conduct is determined by applicable law, and no disclaimer changes that classification or excludes a non-excludable obligation or liability.

For additional information, please refer to the Privacy Policy, Terms of Use, Legal Notices, and Compliance Policies available on this website.

LupoToro may use artificial intelligence-assisted tools to support aspects of website design, formatting, proofreading, content organisation and the preparation of draft material. AI assistance does not replace editorial responsibility. Website material is general information; engagement-specific advice and commitments are governed by the relevant written agreement. Suspected errors can be reported to admin@lupotoro.com.

Additional provisions — 26 October 2026. These provisions supplement the existing policies, disclaimers, restrictions, indemnities and reservations of rights on this page. They do not surrender any protection available to LupoToro under those provisions or applicable law.

Corporate identity and authority

The Australian company referred to in these policies as LupoToro Group Pty Ltd or LupoToro Group Pty Limited is THE LUPOTORO GROUP PTY LIMITED, ACN 671 189 450, ABN 36 671 189 450. Legal and privacy correspondence may be directed to legal@lupotoro.com. The entity responsible for a particular engagement must be identified in its executed agreement. References to a group, network, partner, associate or initiative do not, by themselves, establish that separate persons are jointly liable, have formed a legal partnership, or have authority to bind each other.

Before relying on a purported representative's instructions, commitments, guarantees or authority, obtain confirmation through an independently verified LupoToro contact. A biography, introduction, logo, email display name, shared project or reference on this website is not, by itself, evidence of authority to enter a contract or receive funds on another entity's behalf.

Engagement formation and permitted reliance

An enquiry, acknowledgement, meeting, proposal, estimate, demonstration or exchange of preliminary material does not by itself constitute acceptance of an engagement, a commitment to fund or deliver a project, or the creation of a fiduciary, agency or professional advisory relationship. The contracting parties, deliverables, intended use, permitted recipients, fees, assumptions, responsibilities and approval requirements must be settled in the applicable written engagement. Do not submit a proposal on the assumption that LupoToro has agreed to pay for reviewing it.

Do not send trade secrets, personal identity documents, privileged advice, classified information or controlled technology through a general enquiry channel. Agree appropriate confidentiality terms, access permissions and a suitable delivery channel before disclosure. An unsolicited submission does not itself create an exclusivity obligation, development commitment or right to remuneration.

Australian statutory protections and an additional remedy limitation

The existing reservations for rights and obligations that cannot lawfully be excluded include applicable Australian Consumer Law guarantees, prohibitions on misleading or deceptive conduct and unfair contract terms, and mandatory regulatory and court powers. Those reservations apply throughout the website's policies and disclaimers. A choice of foreign law, forum, limitation period or dispute process cannot remove a mandatory Australian protection. This paragraph records the operation of applicable law and preserves every exclusion, limitation and remedy that LupoToro may lawfully invoke.

Where LupoToro supplies services under these Terms that are not of a kind ordinarily acquired for personal, domestic or household use or consumption, and liability for failure to comply with an Australian Consumer Law guarantee may lawfully be limited under section 64A, LupoToro's liability for that failure is limited, at its option, to supplying the services again or paying the cost of having them supplied again. This additional limitation applies only where reliance on it is fair and reasonable and otherwise permitted by law. It supplements every other lawful exclusion and limitation in these Terms.

Regulated work, transactions and conflicts

Before any regulated work begins, the responsible provider, activity, jurisdiction and necessary licence, authorisation or applicable exemption must be established. Use of an independently licensed specialist does not itself authorise every other participant. A description as research, strategy, an introduction, wholesale participation, a token or a technology platform does not determine the regulatory classification of an activity.

No person may use this website or a preliminary discussion as authority to collect investor money, operate a scheme, accept deposits, provide custody, arrange a financial-product transaction, give regulated advice or undertake licensed property work on LupoToro's behalf. Any such activity requires separate lawful authority and documented arrangements. Material referral remuneration, ownership interests and other benefits must be disclosed where required by law and the applicable engagement.

Verification before commitment

Website forecasts, market estimates, technical demonstrations, awards, relationship descriptions and historical experience must be assessed against their stated date, source, scope and assumptions. Request engagement-specific substantiation before committing capital or deploying a capability. Historical or aggregated experience does not, by itself, establish current company revenue, assets under management, ownership, realised returns or a particular client's result. Neither a preliminary discussion nor a public reference creates a funding, capital-return or performance guarantee.

Administration of management protections

Company indemnities, insurance arrangements and payments for directors and officers must be administered consistently with sections 199A, 199B and 199C of the Corporations Act 2001 (Cth) and other applicable mandatory law. Any entitlement must be supported by the relevant corporate approval, deed or insurance terms where required. All lawful company and individual protections remain reserved.

Additional privacy provisions — 26 October 2026. These provisions add detail to the existing Privacy Policy, regional privacy notice and safeguarding requirements. Privacy enquiries, access or correction requests and complaints can be sent to legal@lupotoro.com.

Personal information and lawful collection

For Australian privacy compliance, personal information has its statutory meaning: information or an opinion about an identified or reasonably identifiable individual, whether true or not and whether recorded or not. Publicly available information, AI-generated inferences, IP addresses, device identifiers and information combined with other records can be personal information. Its treatment depends on context and identifiability, not simply a label such as public, technical, aggregated or non-personal.

Information collected must be reasonably necessary for the relevant functions or activities and collected lawfully and fairly. Sensitive information requires the consent or other legal basis required by applicable law. Unsolicited personal information must be assessed and, where legally required and lawful and reasonable, securely destroyed or de-identified. Please provide only information you are authorised to disclose.

Website enquiries: information, purposes and recipients

THE LUPOTORO GROUP PTY LIMITED collects the enquiry topic, first and last name, email address and message entered in the website enquiry form, together with optional telephone and organisation details. Submission records include a reference and time of receipt. These details are used to assess, route, manage and respond to the enquiry, maintain the relevant correspondence and protect the enquiry process against misuse. The form cannot be processed without its required fields; you may instead contact us by email. You can ask whether an anonymous or pseudonymous enquiry can be handled where lawful and practicable.

Website enquiries are stored through Cloudflare-hosted website infrastructure and sent through Google Workspace to the LupoToro administration mailbox. The relevant hosting, form-delivery and email providers process information to operate those services. Relevant LupoToro personnel receive the information needed to handle the enquiry. Additional disclosure to advisers, delivery participants or authorities must have an applicable lawful basis and comply with our confidentiality and privacy requirements. A general enquiry is not a secure channel for identity documents, highly sensitive records or controlled material.

For a subsequent engagement, due diligence, recruitment or other separate activity, the information needed and the purpose of collection must be explained in the relevant collection notice or engagement process. Where collection is required or authorised by a particular law, that requirement must be identified as appropriate; a general website policy is not a substitute for that explanation.

Overseas handling

Hosting, delivery, support and email arrangements can involve handling personal information outside Australia. No assurance is given that a general website enquiry is stored or accessed exclusively in Australia. Before disclosing personal information to an overseas recipient, LupoToro must assess the applicable Australian Privacy Principle 8 requirements, take the reasonable steps required to protect the information, and meet any applicable accountability obligations under section 16C of the Privacy Act 1988 (Cth).

Likely recipient countries must be identified in the relevant privacy information where practicable and reviewed when provider arrangements change. For information about the recipients and locations relevant to your enquiry, contact legal@lupotoro.com before sending sensitive material. A visitor's acceptance of website terms or consent to an enquiry response is not, by itself, informed consent to an exception from Australian cross-border privacy safeguards.

Technical information, cookies and linked services

Requests to the website and externally delivered resources can disclose technical information, including IP addresses and browser information, to infrastructure or resource providers. Personal information in technical records is subject to the same applicable privacy requirements as other personal information. Cookie, analytics or tracking functionality must be assessed for its actual collection, recipients and purposes; any legally required notice or consent must be provided before that functionality is used.

You can manage cookies through your browser and review the privacy information of external services before interacting with them. Browser settings do not prevent all server-side logging or all information transmitted when a resource loads. A link to a provider's privacy policy does not itself replace LupoToro's own privacy responsibilities.

Marketing preferences

The enquiry checkbox authorises use of the submitted details to respond to that enquiry; it is not consent to unrelated marketing. Any commercial electronic marketing must have the consent or other basis required by the Spam Act 2003 (Cth), identify the sender accurately and include a functioning unsubscribe facility. Unsubscribe requests must be actioned within five working days, and the facility must remain functional for at least 30 days after the message is sent. Unsubscribing must not require payment of a fee, logging in to or creating an account, or providing personal information beyond the address to which the marketing was sent.

You may also contact legal@lupotoro.com about direct-marketing preferences. Where applicable, telephone marketing must comply with the Do Not Call Register and relevant telemarketing rules. Public availability of a contact address is not, by itself, blanket permission to send marketing.

Security, retention and breach response

Personal information must be protected by reasonable technical and organisational measures appropriate to its sensitivity and use, including restricted access and secure handling. Access must be limited to authorised people and providers with a legitimate need. Records must not be kept indefinitely merely because storage is available. When information is no longer needed for a purpose permitted by law, reasonable steps must be taken to securely destroy or effectively de-identify it, subject to applicable retention obligations and lawful preservation requirements.

Suspected data breaches must be escalated promptly for containment, investigation and assessment. Where the Australian Notifiable Data Breaches scheme applies, LupoToro must take all reasonable steps to complete the assessment of a suspected eligible breach within 30 days of becoming aware of the relevant suspicion. When notification is required, the OAIC and affected individuals must be notified as soon as practicable in accordance with the law. The assessment period is not permission to delay a required notification.

Access, correction and complaints

To request access or correction, or make a privacy complaint, email legal@lupotoro.com with enough detail to identify the relevant information or concern. Do not attach identity documents unless a suitable verification channel has been agreed. Reasonable verification may be required to protect the information. Requests will be addressed within a reasonable period; ordinarily we aim to respond within 30 days and will explain any material delay.

No charge applies to making an access request, requesting or making a correction, or associating a statement of disagreement with a record. Any legally permissible charge for giving access will be explained beforehand and must not be excessive. Where access or correction is refused, reasons and available complaint mechanisms will be given as required by law. Where appropriate, you may request a statement of disagreement be associated with the record or ask that a correction be notified to another recipient.

Privacy complaints will be assessed and a response provided within a reasonable period, ordinarily within 30 days. If unresolved or if you are dissatisfied, you may complain to the Office of the Australian Information Commissioner or another competent authority. Existing contractual dispute provisions do not prevent a complaint that applicable law permits.

Children, AI and new purposes

Where a child's information is involved, capacity to understand the proposed handling and provide valid consent must be assessed, with an appropriate parent or guardian involved where required. No general age reference in website material determines capacity under Australian privacy law.

Personal or confidential information must not be entered into an AI service merely because it is publicly available or convenient to process. The purpose, lawful basis, provider's use and training settings, security, accuracy, overseas handling and any required consent must first be assessed. A privacy-policy update does not itself supply consent legally required for a new purpose. Additional transparency obligations for significant automated decisions must be assessed before introducing or materially changing such a process.

Additional provisions — 26 October 2026. These safeguards apply alongside the existing initiative-specific, AI-assisted content and website disclaimers.

Validation and authorised use

A research description, prototype, demonstration, simulation or reported test result does not establish suitability for every environment. Before an operational pilot or deployment, the parties must agree the permitted use, data sources, validation criteria, operating limits, security responsibilities, integrations, approval authorities and response procedures. Any changes to live systems require separate authorisation. A test result must be understood with its tested version, dataset, conditions, evaluation method and limitations.

Human review and consequential decisions

AI outputs, risk scores, forecasts and alerts may contain errors, omissions, bias, outdated information or false positives and false negatives. They require verification against relevant evidence and qualified human review appropriate to the consequence of the decision. An alert or predictive association is not a finding that a person has committed or will commit an offence, proof of causation or authority to take coercive action.

Research or evaluation access must not be used as the sole basis for decisions affecting health, safety, employment, credit, legal rights, defence operations or critical infrastructure. Any proposed use in those settings requires a specifically assessed and authorised scope, competent oversight and the applicable regulatory and safety approvals. No research, model output or website statement authorises unlawful surveillance, discrimination, interference with another person's systems or access to restricted information.

Data rights and confidentiality

Participants must establish permission to use each dataset, document, sensor feed, model and third-party system for the proposed purpose. They must not upload another person's confidential information, personal information, credentials or controlled technology without the necessary authority and safeguards. Agreed access boundaries, retention requirements and restrictions on model training must be recorded before the material is supplied.

Evidence, claims and status

Contributors must distinguish observed results from assumptions, modelled estimates and development objectives. Claims about accuracy, independence of testing, security, sovereignty, accreditation, environmental benefits or regulatory compliance require evidence relevant to the actual version and deployment. Aspirations and forecast benefits are not certifications or guarantees. The existence of a policy, benchmark or demonstration does not itself establish that an operational control has been implemented.

Additional intellectual-property restrictions

In addition to the existing use restrictions, no permission is granted to harvest restricted content, circumvent access controls, impersonate LupoToro, or incorporate LupoToro's proprietary software, confidential materials or protected content into model-training datasets or competing products beyond an express written licence or a right that applicable law makes non-excludable. Suspected unauthorised use may be reported to legal@lupotoro.com.

Additional requirements — 26 October 2026. These requirements supplement the existing contractor warranties, insurance requirements, indemnities, takedown procedures and publication disclaimers.

Rights evidence before use

Each supplier must identify original, third-party, stock, open-source and AI-assisted elements in a delivery and provide the evidence necessary to establish LupoToro's intended rights of use. This includes the source, rights holder, relevant licence or assignment, permitted media and territory, attribution requirements, duration, restrictions on modification or onward use, and required permissions or moral-rights consents. Payment to a supplier, attribution or online availability does not itself establish permission to use a work.

Suppliers must obtain corresponding rights and obligations from their subcontractors and contributors, disclose any incompatible or restrictive licence conditions before delivery, and promptly notify LupoToro of a rights dispute, expiry, revocation, insurance cancellation or other material change affecting a delivery. LupoToro reserves the right to withhold publication or approval until satisfactory evidence is provided and to exercise all existing contractual remedies.

Contractual implementation

Responsible personnel must ensure that applicable supplier requirements, intellectual-property rights, confidentiality obligations, insurance requirements and indemnities are incorporated into the relevant engagement and supported by evidence of acceptance. A public policy statement is not a substitute for obtaining a binding agreement. These requirements do not reduce any obligation already accepted by a supplier.

Copyright claims and statutory protections

Copyright concerns should identify the work, the disputed location and the rights asserted and be sent to legal@lupotoro.com through the existing reporting procedure. Relevant source, licence and correspondence records must be preserved during review. Any reliance on a statutory safe harbour requires assessment of the provider's eligibility, the actual activity and every applicable statutory condition; maintaining a policy or using a third-party supplier does not itself establish those facts. All available rights, defences and remedies are reserved.

Publications, corrections and evidence

Dated publications should be read with their original date and any separately identified editorial note. Before republishing a material statement, contributors must check its source, quotation rights, date and evidential basis. A forecast must be supported by reasonable grounds when made; a disclaimer cannot supply missing evidence. Statements about other people or organisations must distinguish verified facts, allegations and opinion and must respect confidentiality, privacy and applicable law.

Report a material factual error, privacy concern or rights claim to legal@lupotoro.com, identifying the URL, disputed statement and relevant evidence. Technical display or transcription concerns can also be sent to admin@lupotoro.com. Reviewing a report or taking protective action does not, by itself, constitute an admission of liability. Relevant records must be preserved where required for a complaint, investigation or legal proceeding.

Additional requirements — 26 October 2026. These provisions supplement the Anti-Slavery Policy, Safeguarding Information Code, Security & Fraud Awareness guidance and Specific Additional Codes & Policies.

Protected disclosures and non-retaliation

LupoToro prohibits retaliation against a person for making a disclosure protected by law. Confidentiality, non-disparagement, intellectual-property, dispute-resolution and other website provisions do not prohibit a lawful protected disclosure or require prior company permission to approach a regulator or legal adviser. Statutory protections depend on the applicable legal criteria; an ordinary complaint is not automatically a protected disclosure.

An eligible disclosure under the Corporations Act 2001 (Cth) may be made to an eligible recipient, including a company officer or senior manager, or directly to ASIC or APRA where applicable. Legal advice about the whistleblower provisions may be sought from a legal practitioner. A person may make a qualifying disclosure anonymously. Disclosures to journalists or parliamentarians have additional statutory conditions and should not be assumed to qualify automatically.

Ordinary policy concerns may be sent to legal@lupotoro.com. This general inbox is not represented as an anonymous reporting system. If anonymity or protected handling is important, use an appropriate eligible recipient or regulator directly. Identifying information and the substance of a protected report must be handled only as the law permits, with access restricted appropriately. These public provisions do not replace a dedicated statutory whistleblower policy where one is required.

Modern slavery and supplier conduct

Suppliers and intermediaries must cooperate with proportionate due diligence on labour sourcing, recruitment practices, subcontracting and supply-chain risks. They must not use forced labour, retain identity documents to coerce workers, impose exploitative recruitment debts or obstruct the reporting of exploitation. Suspected exploitation must be escalated promptly, with attention to affected people's safety, confidentiality and appropriate remediation. Any required modern slavery statement must meet its statutory reporting and approval requirements; publishing a policy alone is not that statement.

Anti-bribery and conflicts

Gifts, hospitality, commissions, introductions, donations and intermediary payments must not be used to secure an improper advantage. In addition to the existing prohibitions, relevant personnel must document the commercial purpose, recipient and approval for higher-risk benefits, disclose conflicts and conduct proportionate diligence on associates and intermediaries. False records, concealed commissions, split payments designed to evade approval and use of another person to do what is prohibited directly are not permitted. Overseas activity must be assessed against applicable Australian foreign-bribery obligations, including the corporate failure-to-prevent offence.

AML/CTF and sanctions

Before accepting a transaction-related engagement, the actual proposed services must be assessed for anti-money laundering and counter-terrorism financing obligations, including designated services covered by reforms applying from 1 July 2026. Applicable enrolment, program, customer and beneficial-owner due diligence, reporting and recordkeeping requirements must be met. A business title, website disclaimer or fixed points-based identity check does not, by itself, establish compliance.

Participants must provide accurate identity, beneficial-ownership, authority, transaction-purpose and source-of-funds information when lawfully required and must promptly disclose material changes. A transaction or instruction may be declined or suspended where necessary to avoid unlawful activity or resolve a material compliance concern, subject to applicable law and the engagement. Information about a suspicious matter or investigation must not be disclosed where prohibited.

Proposed parties, ownership and control, destinations, end users, goods, services and payments must be assessed against applicable sanctions. No one may use LupoToro, its systems or its relationships to evade sanctions, disguise ownership or route prohibited transactions through an intermediary. Any legally required permission must be obtained before the restricted activity occurs.

Defence, export controls and restricted information

Before sharing potentially controlled goods, software, technical information or services, the responsible participants must assess export, supply, brokering, publication, end-use and access restrictions, including restrictions that can apply to intangible transfers or access by foreign persons. A research collaboration, cloud upload, demonstration or domestic meeting is not automatically outside export controls. Required permits, exemptions and conditions must be established before access or transfer. Do not submit controlled material through the public enquiry form.

Fraud and security reporting

Independently verify unexpected payment requests, changed bank details, urgent funding instructions and document-signing links through a previously verified contact method. A familiar email address, domain, voice or video is not conclusive proof of identity. Do not transfer funds solely on the basis of an unsolicited message or a website reference. If funds may have been misdirected, contact the relevant financial institution promptly and consider reporting through ReportCyber or Scamwatch.

Report suspected compromise or impersonation to legal@lupotoro.com without sending passwords, private keys or unnecessary personal information. A security report does not authorise penetration testing, accessing other people's data, persistence, disruption or public disclosure of confidential material. Separate written permission is required for security testing. Existing restrictions and enforcement rights continue to apply.

Additional provisions — 30 October 2026. These provisions apply to website publications, outsourced material, archived content, research and media releases, alongside all existing rights reservations and supplier obligations.

Safe harbour and responsibility for publication

References elsewhere to carriage-service-provider status, conduit activity or copyright safe harbour are not a representation that LupoToro has established eligibility for every platform or publication. Any reliance on Division 2AA of Part V of the Copyright Act 1968 (Cth) requires the relevant provider to satisfy section 116ABA, the relevant category of activity and every applicable condition. Commissioning, selecting, editing or publishing material on a corporate website does not by itself qualify for safe harbour. Maintaining a takedown policy, paying a contractor or removing material after notice does not automatically extinguish liability.

Contractor warranties, indemnities, insurance requirements and rights of recovery remain available within their lawful scope. They allocate responsibility between the parties to a binding agreement; they do not prevent a rights holder pursuing a remedy otherwise available against LupoToro. Absence of a credit is not proof of authorship, ownership, contractor supply or permission. Attribution and public availability are not substitutes for a licence, valid exception or other lawful basis.

Claims and preservation

The existing copyright reporting particulars assist investigation. A credible Australian rights complaint will not be disregarded solely because it lacks a US-style statement under penalty of perjury, a telephone number or a preferred form. Sufficient information to identify the work, disputed use and asserted rights should be provided; further evidence may be requested reasonably. Any applicable statutory notice requirements remain relevant to the particular remedy or procedure invoked.

The existing 48-hour removal commitment for material found to be unauthorised is an outer operational commitment, not permission to delay action required sooner. Potentially harmful material may be restricted during assessment without admission of liability. Supplier objections do not conclusively establish a right to reinstate material; reinstatement requires a documented lawful basis and observance of applicable procedures. Source files, licences, publication versions and correspondence must be preserved when relevant to an actual or reasonably anticipated dispute, subject to lawful access and retention controls.

Defamation, accuracy and corrections

Research, opinion, third-party attribution and archival status do not create automatic defences to defamation, misleading conduct, privacy or confidentiality claims. Material statements about identifiable people and organisations require an appropriate evidential basis and assessment of publication risk. Opinion must be identifiable as opinion, with its factual basis considered. No statement that material came from a contractor or that its views are not LupoToro's own determines the legal responsibility for publishing it.

Send concerns about a publication to legal@lupotoro.com, identifying the location, disputed material, alleged meaning, harm and supporting information where available. Statutory concerns notices and offers to make amends, including under the Defamation Act 2005 (SA) where applicable, must be assessed promptly under their own requirements and deadlines. The website mediation process does not replace them. Corrections, clarification, restricted access or withdrawal may be appropriate even for archived material. A statement that a hard-copy version prevails does not establish that an inaccurate online representation is legally harmless.

Permissions and provenance

Publication and product teams must maintain evidence of the rights needed for each intended use, including relevant assignments, licences, performer permissions, image and voice permissions, and moral-rights consents where required. A commissioned work is not automatically owned by the payer. Software, research, patents and open-source material require assessment of their distinct rights and licence conditions. Public patent disclosure does not itself grant permission to practise a patented invention. AI-generated output does not guarantee originality, freedom from infringement or exclusive ownership. Nothing here expands an existing user licence or reduces lawful confidentiality, intellectual-property or supplier protections.

Additional provisions — 30 October 2026. These provisions explain the Australian application of the existing privacy, cookie, enquiry and research policies. They do not certify that any organisation is exempt from privacy law or that every operational requirement has been satisfied.

Scope and applicable rights

The Privacy Act 1988 (Cth), applicable Australian Privacy Principles and other applicable privacy laws determine coverage and rights. The regional notice's reference to processing within a listed country is not an exclusive territorial test; Australian obligations can apply to overseas handling where the statutory criteria are met. Turnover alone does not establish an exemption, and the employee-records exemption does not automatically cover applicants, contractors, every employment-related activity or service providers.

Publicly available information, online identifiers, location information and information inferred by AI may be personal information. Earlier labels such as non-personal, publicly available or non-public must be read accordingly. Aggregation, removal of names or use of a pseudonym does not alone establish effective de-identification. LupoToro's existing prohibition on selling personal information for marketing is retained; any proposed use or disclosure of aggregated information requires assessment of identifiability and re-identification risk. No resale permission applies to information that remains personal information without a lawful basis.

Current corporate website and separate services

The public corporate website's enquiry process collects the fields described in the Australian Privacy & Enquiry Collection Safeguards. Authorised LupoToro personnel can manage those enquiry records through the internal AEON administration environment, including routing a response to the administration mailbox. Access is for enquiry administration and authorised operational purposes, not a separate marketing consent.

The website's application-level traffic measurement records aggregate page-load counts and broad categories such as date, page, referring domain, device/browser category and country inferred by hosting infrastructure. That aggregate counter does not store raw IP addresses or use a visitor identifier or analytics cookie. Infrastructure providers can separately process request information for hosting, delivery and security. This distinction does not mean that no technical information is collected passively.

References in earlier text to mobile GPS, registration, payment processing, personalisation or other separate-service functionality describe activities only where that functionality is actually offered and used; they do not establish that the public corporate website currently provides each feature. Before a new feature or tracker is introduced, its actual data handling must be assessed and the relevant notice and any required consent provided. A statement that cookies do not contain names does not mean cookie identifiers cannot be personal information.

Lawful handling and retention

Personal information must be collected, used and disclosed for a lawful, identified purpose and in accordance with applicable Australian Privacy Principles, including the rules for sensitive information, secondary purposes and disclosure. Broad references to compatible purposes, enforcement, legal protection or law-enforcement assistance are not independent permissions to disclose information. Required or authorised disclosures must be assessed against the actual legal basis, necessity, scope and confidentiality restrictions.

Government-related identifiers must not be adopted as LupoToro's own identifiers or used or disclosed contrary to APP 9 where applicable. Due diligence must use proportionate identity verification; a fixed points-based process is not an authority to collect unnecessary identity records. Tax file numbers require their applicable statutory safeguards. Data quality, accuracy and relevance must be assessed before consequential use or disclosure, including where an AI system has generated an inference.

Retention schedules must identify each record category, business or legal purpose, retention trigger, responsible person and secure disposal method. A legal hold must preserve relevant records without becoming a reason to retain unrelated information indefinitely. Backups and service providers must be included in the process. Access restrictions and restoration procedures must prevent information due for deletion being returned to ordinary use without review. All existing access, correction, complaint and lawful deletion protections remain available.

Providers and overseas handling

Provider selection and changes must be assessed against the actual service configuration, access locations, subprocessors, contractual protections, incident obligations, retention and deletion arrangements. The company's responsibility is not displaced by a provider's privacy policy or by describing the provider as independent. Overseas recipients and likely countries must be disclosed where practicable as required by APPs 1 and 5; enquiry handling through international infrastructure is not represented as Australia-only. Obtain engagement-specific information before supplying sensitive or restricted material. Consent to an APP 8 exception must meet its specific informed-consent requirements and is not inferred from continued website use.

AI, surveillance and significant decisions

AI, profiling, sensor, biometric, location and surveillance activities require assessment of lawful authority, necessity, consent where required, security, accuracy, discrimination and the consequences for individuals. Neither public availability nor a research label authorises intrusion into seclusion or misuse of personal information. The statutory tort for serious invasions of privacy, in force from 10 June 2025, can apply beyond APP entities; an assumed small-business exemption is not a complete defence to privacy claims.

Upcoming requirement: From 10 December 2026, where APPs 1.7–1.9 apply to arrangements for computer programs using personal information to make, or do something substantially and directly related to making, decisions reasonably expected to significantly affect individuals' rights or interests, the privacy policy must describe the required kinds of personal information and decisions. Applicable disclosures must distinguish solely automated decisions from decisions substantially and directly assisted by the program. This is a future commencement date as at this notice; it is not a claim that every AI use falls within the provision or that an affected system is already compliant.

Marketing and security communications

Existing marketing consent and unsubscribe safeguards apply equally to agents, purchased lists and outsourced campaigns. Address harvesting and using prohibited harvested lists are not permitted. Records must establish the applicable consent and its scope; publication of a business address, a single enquiry or silence does not establish blanket consent. Opt-outs must reach relevant sending systems and service providers. A message seeking marketing consent may itself be a commercial electronic message requiring consent.

Additional requirements — 30 October 2026. These requirements supplement the existing compliance codes, AI and deployment safeguards, anti-slavery policy, defence notice and supplier obligations.

Activity-based licensing and due diligence

The express service-scope clarification under Australian Law, Contract Interpretation & Claims applies throughout these requirements. Financial advice, financial product advice (general or personal), investment advice, legal advice and legal representation are excluded services. The licensing and compliance requirements below do not create an exception to that exclusion or represent that LupoToro undertakes every listed activity.

Assess the substance of each activity before undertaking it. Introductions, arranging transactions, capital raising, M&A, tokenisation, pooled investment, custody, credit and property work can attract distinct licensing, disclosure, registration and conduct obligations. A professional investor label, research label, disclaimer, referral or involvement of a licensed third party is not itself an exemption. Any exemption or representative arrangement must cover the actual entity, service, client, jurisdiction and conduct. Work outside that authority must not commence.

The AML/CTF reforms applying to newly regulated designated services from 1 July 2026 require an activity-by-activity assessment, including relevant real-estate, business-transaction and company or trust services. Where applicable, maintain the required enrolment or registration, risk assessment, program, compliance responsibility, customer and beneficial-owner due diligence, ongoing monitoring, reporting and records. Identity checks alone are insufficient. The timing of each statutory requirement must be met; a website policy is not evidence of enrolment or regulatory approval.

Proposed acquisitions and investments require separate competition and foreign-investment screening before binding commitments or completion. Australia's mandatory merger regime applies from 1 January 2026 to acquisitions within its notification requirements; an applicable exemption, notification waiver or required approval must be established before proceeding. Assess the actual transaction, connected entities, cumulative acquisitions and current rules. Foreign-investment review is a separate process: investor status, interests in land, national-security businesses and other statutory triggers can require notification or approval irrespective of a general monetary assumption. Observe applicable standstill requirements, conditions and registration obligations. An introduction, confidentiality agreement or commercial timetable does not waive these requirements.

Sanctions diligence must consider actual ownership and control, intermediaries, destinations, sectors, end users and the proposed goods, technology, services and payments. A name absent from the Consolidated List is not a complete sanctions clearance. Potentially restricted dealings must be escalated before proceeding. Existing defence/export-control safeguards apply to relevant domestic access by foreign persons, electronic transfers, overseas resupply and controlled services as well as physical exports. Any exemption, including one connected with AUKUS, must be verified for the specific activity and its conditions.

Competition, conflicts and integrity

Network participation, collaboration and deal origination do not authorise price fixing, bid rigging, market sharing, output restrictions or unlawful exchange of competitively sensitive information. Joint bids, information-sharing arrangements and competitor collaborations require assessment before commitments or disclosure. Staff and intermediaries must disclose material conflicts and referral benefits, keep accurate records and avoid unauthorised use of confidential counterparty information.

The existing prohibition on facilitation payments remains unchanged. Anti-bribery controls must extend to associates and intermediaries through risk assessment, approval, training, reporting and periodic review; a written policy alone does not establish the adequate-procedures defence to failure to prevent foreign bribery. Modern-slavery diligence must include safe escalation, proportionate supplier verification and attention to remediation and affected people's safety. A zero-tolerance policy is not a representation that all supply chains have been independently verified as risk-free.

Incident escalation and reporting

Security incidents must be contained and assessed promptly, with relevant evidence preserved and authority assigned for technical, legal, insurer, provider and customer communications. Existing Notifiable Data Breaches obligations operate separately from other reporting duties. The 30-day assessment framework is not a waiting period for other notification deadlines.

Where Part 3 of the Cyber Security Act 2024 applies, a ransomware or cyber-extortion payment made by the reporting entity, or made on its behalf and brought to its attention, must be reported within the applicable 72-hour period. Coverage includes businesses above the applicable turnover threshold and relevant critical-infrastructure responsible entities. Reporting does not itself make a payment lawful or authorise it; sanctions and other restrictions must also be assessed.

Where Part 2B of the Security of Critical Infrastructure Act 2018 applies, relevant critical cyber incidents must be reported within 12 hours of awareness and other reportable incidents within 72 hours, according to the statutory impact criteria. Required written follow-up to an oral report and any additional regulator or customer notices must also be completed. Supporting a regulated customer does not by itself establish that LupoToro is the responsible entity; the actual statutory and contractual allocation must be confirmed before deployment.

People, safety and protected reporting

Employment, contractor, work health and safety, anti-discrimination and harassment obligations must be assessed for the actual relationship and activities. Non-transferable duties are not discharged merely by outsourcing or an indemnity. Required reasonable and proportionate preventive measures under the Sex Discrimination Act 1984 (Cth), and applicable safety duties including management of psychosocial risks, require implementation and review. Confidentiality and reputation protections must not obstruct lawful workplace complaints, regulator contact, legal advice or protected disclosures.

Protected reports require appropriate eligible recipients, restricted handling of identity and information that could identify a discloser, and protection against detriment. The public correspondence mailbox is not an assurance of anonymity or a replacement for a compliant dedicated whistleblower policy where required. Complaints concerning a decision-maker should be directed to an appropriately independent authorised recipient or competent regulator. Existing reporting rights are not conditional on first using an internal process where law permits an external report.

Australian fraud guidance and implementation

For Australian identity-fraud concerns, seek a credit-report ban from the relevant Australian credit reporting bodies using current OAIC guidance; the statutory initial ban is generally 21 days and can be extended when the conditions are met. Foreign credit-freeze services named in earlier general guidance do not replace that Australian process. Product names in security guidance are examples, not assurances of current suitability or security. Prefer unique passwords or passphrases, appropriate multi-factor authentication and independent verification of unexpected instructions.

Personnel responsible for an engagement must retain evidence of approvals, accepted contract terms, applicable licences, supplier rights, insurance and required compliance checks. Public policies do not substitute for those records, a binding supplier or client agreement, legal advice on an actual dispute, or implementation of required controls. Factual claims about accreditation, security, insurance, offices, operational readiness, charitable status or compliance must be supported and kept accurate for the particular entity and activity. All existing lawful protections remain reserved.