legal notice

Terms and Conditions of Use

Please read these terms of use carefully before you start to use the site. By using our site, you indicate that you accept these terms of use and that you agree to abide by them. If you do not agree to these terms of use, please refrain from using our site.

Definitions and interpretations
In these Terms and Conditions, references to “Consfly”, “us” or “our(s)” are references to Consfly Management SÀRL. The company details can be in ‘Information about us’ in these Terms and Conditions.

References to “you” or “your” are references to you, the user of the site.

References to “the site” are references to the website at References to “Intellectual Property Rights” are references to any copyright, trademarks, design rights or other intellectual property rights existing from time to time.

Information about us is a site operated by Consfly Management SÀRL; we are a company registered in Luxembourg under registration number B224006. Our registered office is 11-13, Boulevard de la Foire, L-1528 Luxembourg, Luxembourg. Our VAT number is LU30555114. We are an unregulated organisation.

Access to our site
Access to our Consfly site is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on our site without notice (see below). We will not be liable if for any reason our site is unavailable at any time or for any period.

As a user of this site you warrant to Consfly that you will not use this site for any purpose that is unlawful or prohibited by these terms and conditions.

In accessing this site, you agree not to use this website in such a way that:

  1. Disrupts, interferes with or restricts the use of this website by other users;
  2. Not to upload, display or transmit any materials through this website which are false, offensive, defamatory, threatening, or otherwise violate the legal rights (such as rights of privacy and publicity) of others;
  3. Not to reverse engineer, decompile, copy or adapt any software or other code or scripts forming part of this website or attempt to transmit to or via this website any information that contains a virus or other harmful or disruptive component; and not to change, modify, delete, interfere with or misuse data contained on this website and entered by or relating to any third-party user of this website;
  4. Harvest or otherwise collect information about others, including e-mail addresses, without their consent;
  5. Violate any applicable laws or regulations.
Your account and password
If you choose to join us through our site, or you are provided with a password or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party.

You are responsible for any use of the site using your email address and password, whether chosen by you or allocated by us.

We have the right to disable any user password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion, you have failed to comply with any of the provisions of these terms and conditions.

If you know or suspect that anyone other than you, knows your password, you must promptly notify us at

Intellectual property rights
Throughout this site you may find links to third party websites. The provision of a link to such a website does not mean that we endorse that website. If you visit any website via a link on this site you do so at your own risk.

Links to and from other websites
Any party wishing to link to this site is entitled to do so provided-that the conditions below are observed:

  1. You do not seek to imply that we are endorsing the services or products of another party unless this has been agreed with us in writing;
  2. You do not misrepresent your relationship with this site; and
  3. The website from which you link to this site does not contain offensive or otherwise controversial content or, content that infringes any intellectual property rights or other rights of a third party.
  4. By linking to this site you shall indemnify us for any loss or damage suffered to this site as a result of such linking.
Reliance on information posted & disclaimer
The materials contained on our site are provided for general information purposes only and do not claim to be or constitute legal or other professional advice and shall not be relied upon as such.

We do not accept any responsibility for any loss which may arise from accessing or reliance on the information on this site and to the fullest extent permitted by Luxemburgish law, we exclude all liability for loss or damages direct or indirect arising from use of this site.

Regulatory Disclosures
The material displayed on our Consfly site is provided without any guarantees, conditions or warranties as to its accuracy. To the extent permitted by law, we, and third parties connected to us hereby expressly exclude:

  1. Any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our site or in connection with the use, inability to use, or results of the use of our site, any websites linked to it and any materials posted on it, including, without limitation any liability for:
  2. Loss of income or revenue;
  3. Loss of business;
  4. Loss of profits or contracts;
  5. Loss of anticipated savings;
  6. Loss of data;
  7. Loss of goodwill;
  8. Wasted management or office time; and for any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above.

This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.

Viruses, Malware and Security
We exercise all reasonable skill and care to ensure that our site is secure and free from viruses and other-malware. We do not, however, guarantee that our site is secure or free from viruses or other malware and accept no liability in respect of the same. Expressly you:

  1. are responsible for protecting your hardware, software, data and other material from viruses, malware, and other internet security risks.
  2. must not deliberately introduce viruses or other malware, or any other material which is malicious or technologically harmful either to or via our site.
  3. must not attempt to gain unauthorised access to any part of our site, the server on which our site is stored, or any other server, computer, or database connected to our site.
  4. must not attack our site by means of a denial of service attack, a distributed denial of service attack, or by any other means.

By breaching the provisions of the above you may be committing a criminal offence. Any breaches will be reported to the relevant law enforcement authorities and we will cooperate fully with those authorities by disclosing your identity to them. Your right to use our site will cease immediately in the event of such a breach.

Acceptable usage policy
You may print off one copy, and may download extracts, of any page(s) from our site for your personal reference and you may draw the attention of others within your organisation to material posted on our site.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of material on our site must always be acknowledged.

You must not use any part of the materials on our site for commercial purposes without obtaining a licence to do so from us or our licensors.

If you print off, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

Privacy and cookies
The Consfly site collects personal identifiable information, such as your e-mail address, name, home or work address or telephone number. There is also information about your computer that is automatically collected from the Consfly site. This information can include your email address, browser or domain name. This information is used by the Consfly site for the operation of service, to maintain a quality service and provide general statistics regarding use of this site.

We are not responsible for the privacy statements or other content on websites outside of the Consfly site or related sites.

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

We use tracking software on to monitor visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the site, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information

Our full Privacy Policy can be accessed here.

Our site changes regularly
We aim to update our Consfly site regularly, and may change the content at any time. If the need arises, we may suspend access to our site, or close it indefinitely. Any of the material on our site may be out of date at any given time, and we are under no obligation to update such material.

Electronic communications from us
For contractual purposes, you consent to receiving communications from us electronically and you agree that all agreements, notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing. For every email message sent in connection with your use of our site, you acknowledge and agree that the recipient has agreed to receive such communication and that you shall not engage in the act of sending unsolicited emails.

Data protection
For the purposes of General Data Protection Regulation within the EU you hereby consent to our processing of “personal data” (as defined by the regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, entered into force on 25 May 2018) by submission of your personal information on the site and we agree that we will treat the personal data as confidential.

You acknowledge and agree to be bound by the terms of our Privacy Policy. Our full Privacy Policy can be accessed below.

Law and jurisdiction
These terms and conditions of use are governed by Luxembourgish law. Any dispute arising in connection with these terms of use shall be subject to the exclusive jurisdiction of the Courts of Luxembourg.

Contacting us
If you have any concerns or queries about material which appears on this site or you have questions about using this site or these terms and conditions, please email us at

If you have any suggestions for improvements or additions that you would like to see on this site, please email us at

Our postal address is:
11-13 Boulevard de la Foire
L-1528 Luxembourg

Privacy Policy

Consfly is committed to preserving the privacy of all visitors to its website ("website"). Please read the following privacy policy to understand how we use and protect the information that you provide to us. By accessing this website, you consent the collection, use and transfer of your information under the terms of this privacy policy and the terms of use of this website.

  1. What information will be collected from you;
  2. Who exactly collects that information;
  3. How that information is used and by whom;
  4. What security measures are in place to protect this information;
  5. Your rights in relation to this information;
  6. How this policy may change and how we will notify you of any changes; and
  7. How to contact us if you have any queries about this policy.

We have an obligation under the regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 to abide by our Privacy Policy. If you believe that we are not meeting the commitments set out in this document, please contact us using the details provided below.

  1. Your name, address, telephone number and email address. Additional information may be requested if you advance with the purchase of shares.
  2. Your Personal information
  1. Cookies and System Logging

A cookie is a file that is placed on your computer by another computer on the internet to enable that computer to know when you are using a particular website. For example, if you had a cookie on your home PC, you may be greeted by your name when you log on to a particular website. We do use cookies on this Site.

WHO COLLECTS THE INFORMATION? The information is collected by:

11-13 Boulevard de la Foire
L-1528 Luxembourg


The above information will be used by us for the following purposes only:

  1. To process and maintain your investment
  2. Provide updates on the ongoing investments you hold

To protect your privacy, your financial information is sent to us through a secure server which encrypts it before it is sent to us. The system uses a secure mode using 256-bit SSL encryption. We also use our best efforts to protect your information off-line: it is only given to those of our employees who genuinely need to have access to it in order to perform their job. Furthermore, our security procedures for storing and disclosing customer details conform with the regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 so as to prevent unauthorised access to it.

The Site may, from time to time, contain links to other web sites. We are not responsible for the privacy practices of the owners and operators of these sites. We therefore encourage you to read the privacy statements and policies on each site to which you are asked to submit personal information.


If you wish to change any of your personal information, please contact us by sending an email to us at

You also have the right to request that this information is removed from our system at any time.


Please note that we reserve the right to change this policy at any time in the future, with or without notice.

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