Lórien
FINANCIAL

Terms of Use & Legal Notice

Aviso Legal y Condiciones de Uso · Last updated: [DATE] · Version: interim draft
Interim demonstration draft. Lórien Financial is currently a pre-commercial demonstration. This tool is provided for evaluation only; do not submit real client or personal data. These terms are an interim draft pending review by qualified Spanish counsel and will be finalised before any commercial launch. English is the interim reference version; a Spanish (Castilian) version will be published before commercial use.

A. Legal Notice (Aviso Legal — LSSI Art. 10)

In accordance with Article 10 of Law 34/2002 (LSSI-CE), the provider of this service is:

No supervisory authorisation. Lórien Financial is not authorised, registered with, or supervised by the Comisión Nacional del Mercado de Valores (CNMV), the Dirección General de Seguros y Fondos de Pensiones (DGSFP), or any other financial supervisor, and does not hold itself out as such. It is not an investment firm, EAF/EAFN financial adviser, credit institution, insurer, or insurance distributor.

B. Definitions & Scope

Lórien Financial provides software and analytics that produce illustrative hedging analysis, historical correlations, scenarios, and coverage estimates for use by financial professionals. It is intended solely for CNMV-authorised advisers (EAF/EAFN/ESI) or otherwise duly entitled professionals ("you", the "Customer"). The tool is decision-support only; it does not make decisions.

C. Nature of the Service — No Investment Advice

The service does not constitute investment advice or a personal recommendation within the meaning of Article 4(1)(4) of Directive 2014/65/EU (MiFID II) or Article 125 of Law 6/2023 (LMVSI). Outputs are generic, methodology-driven and illustrative; they are not tailored as suitable for any specific investor and are delivered to the adviser, not to any end-investor. The authorised adviser is solely responsible for any recommendation and for assessing suitability and appropriateness. Outputs are not a suitability or appropriateness assessment.

D. No Investment Recommendation (MAR)

Outputs are not an "investment recommendation" under Article 3(1)(34)-(35) of Regulation (EU) 596/2014 (MAR). Where the tool surfaces candidate instruments, it does so illustratively and on a neutral, methodology-driven basis for the adviser's independent evaluation. Any issuer or commercial relationships relevant to instruments shown will be disclosed. Nothing here should be read as an objective recommendation to buy, sell, or hold any instrument.

E. Not Insurance

Lórien Financial is not insurance and does not provide an insurance product, contract, cover, indemnity, guarantee, or payout. It is not an insurer, reinsurer, or insurance distributor and is not authorised or supervised by the DGSFP under Law 20/2015 (LOSSEAR). Any comparison to "insurance" is an explanatory analogy only.

F. Eligibility & Customer Warranties

You warrant that you are a CNMV-authorised EAF/EAFN/ESI, a credit institution, or are otherwise entitled to carry on your activity, and that you will comply with your own regulatory obligations (including any outsourcing requirements under MiFID Art. 16(5)). You will only submit data you are entitled to process and will not use the tool to advise end-clients as Lórien.

G. Acceptable Use

H. Intellectual Property & Licence

All intellectual property in the tool and its outputs is reserved by Lórien Financial. You receive a limited, non-exclusive, non-transferable licence to use the outputs for your own professional purposes. You may not copy, resell, or reverse-engineer the tool. Lórien may use aggregated and anonymised usage data to operate and improve the service.

I. Fees, Subscription & Term

Interim / beta. The tool is currently provided free of charge for demonstration and is offered "as is" with no service-level commitment. Commercial fees, IVA, renewal, and term will be set out in a commercial agreement before any paid use. [commercial terms TBD]

J. Warranties Disclaimer

The tool is provided "as is" and "as available", without warranty of accuracy, completeness, fitness for a particular purpose, or any particular outcome. Models and figures are estimates, not guarantees. Market data may be delayed, incomplete, or sourced from third parties. You must independently verify outputs and meet your own regulatory duties before acting.

K. Limitation of Liability

To the fullest extent permitted by Spanish law: Lórien Financial excludes liability for indirect or consequential loss and loss of profits; and its aggregate liability is limited to the fees you paid in the twelve (12) months before the event (or, where no fees were paid, a modest fixed amount [TBD]). Nothing in these terms excludes or limits liability for wilful misconduct (dolo), gross negligence, death or personal injury, or any liability that cannot be limited under mandatory Spanish law (Civil Code Arts. 1102-1103).

L. Data Protection

Personal data is handled as described in our Privacy Policy. Where you submit client portfolio data, you act as controller and Lórien as processor; a data processing agreement (GDPR Art. 28) will govern that relationship before any real client data is processed.

M. Governing Law & Jurisdiction

These terms are governed by Spanish law, with the courts of Barcelona having jurisdiction, without prejudice to any mandatory consumer protections that may apply to non-professional users.

N. Changes

We may update these terms; the current version is always the one published here with its date.