Terms of Use

Terms of Use

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Please read this important legal information regarding the use of the www.Lakefront.com.cn website (“Terms of Use”) before proceeding, as it explains certain restrictions imposed by law on the distribution of information contained within it and onthe countries in which Lakefront’s products are authorized for sale.

It is your responsibility to be aware of andto observe all applicable laws and regulations of any relevant jurisdiction. By accessing and using the www.Lakefront.com.cn website and any pages there of (the“Site”), you acknowledge that you have reviewed these Terms of Use and understand and agree to the terms and conditions contained herein. If you donot agree to the terms and conditions below, do not access or use this Site in any way.

General Provisions.This Site offers certain information about the approach of Lakefront Asset Management and its affiliates (“Lakefront”) to providing investment funds and advisory management services. The information provided on the Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution, publication or use would be contrary to local law or regulation or in which Lakefront does not hold any necessary registration or license. Individuals or legal entities in respect of whom such prohibitions apply, whether on grounds of their nationality, their place of residence or on other grounds, must not access or use the Site.

Use of Information and Material.This Site and the information herein is for general information purposes only.In addition, the information and materials contained in this Site and the terms and conditions of the access to and use of such information and materials are subject to change without notice. Not all products and advisory or management services are available in all geographic areas. Your eligibility for particular products and advisory or management services is subject to local law and regulation. Unauthorized use of the Site and Lakefront’s systems, including but   not limited to unauthorized entry into Lakefront’s system, misuse of passwords or misuse of any information posted on this Site, is strictly prohibited. Your eligibility for a particular product or service is subject to final determination by Lakefront. You acknowledge that the Site may contain audit software and that all your actions while using this Site may be recorded and analyzed for various purposes, including security, marketing and system monitoring purposes.

No Advice, Offers or Solicitations.The information and materials in this Site should not be construed as to provide tax, legal or investment advice. In addition, the information and materials herein shall not constitute an offer or solicitation, or an offer tosell, shares of any of the funds or any advisory or management service in any jurisdiction. Shares of any funds may only be made by the private placement memorandum or scheme particulars for the relevant fund, and only to investors who meet certain eligibility requirements. The type of securities mentioned maynot be suitable for everyone. USERS ARE URGED TO BASE THEIR INVESTMENTDECISIONS UPON A THOROUGH INVESTIGATION AND TO OBTAIN ALL NECESSARY PROFESSIONAL ADVICE.

US Persons. For US citizens, Lakefront is required to obtain certain information about you and to confirm your status as an “accredited investor” (as defined in Regulation Dunder the US Securities Act of 1933, as amended) before Lakefront can give you access to certain private areas of the Site. Lakefront may not allow you access to certain areas of the Site if you do not meet certain eligibility and suitability requirements.

Disclaimer of Warranties.THE SITE AND ALL INFORMATION AVAILABLE ON OR VIA THE SITE ARE PROVIDED "ASIS" AND "AS AVAILABLE," WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION: (1) ANY WARRANTIES CONCERNING THE AVAILABILITY, RELIABILITY, ACCURACY, COMPLETENESS, TIMELINESS OR SEQUENCING OF THE SITE OR THE CONTENT, PRODUCTS OR SERVICES AVAILABLE ON OR VIA THE SITE;(2) ANY WARRANTIES OF TITLE OR EXPRESS OR IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT OFINTELLECTUAL PROPERTY AND PROPRIETARY RIGHTS; (3) THE RESULTS TO BE OBTAINED BY ANY USER OF THE SITE; AND (4) ANY CONTENT (INCLUDING ANY THIRD PARTY CONTENT) ACCESSIBLE ON OR THROUGH THE SITE. LAKEFRONT DOES NOT WARRANT THAT THE SITE ORANY CONTENT WILL BE UNINTERRUPTED OR ERROR FREE, THAT DEFECTS WILL BE CORRECTED OR THAT THE SERVERS FROM WHICH IT IS AVAILABLE WILL BE FREE OF VIRUSES, TROJANHORSES, WORMS, SOFTWARE BOMBS OR SIMILAR ITEMS OR PROCESSES OR OTHER HARMFUL COMPONENTS.

ANY EXPRESSIONS OF OPINION, ESTIMATES AND PROJECTIONS ON THE SITE ARE THOSE OF THE AUTHORS AT THE DATE OF WRITING. THEY DO NOT NECESSARILY REFLECT THE VIEW OF LAKEFRONT AND ARE SUBJECT TO CHANGE AT ANY TIME WITHOUT PRIOR WARNING. LAKEFRONT AND ITS CONTRACTUAL PARTNERS MAY DISCONTINUE, OR MAKECHANGES IN, THE INFORMATION, DATA AND DOCUMENTS, AND THE PRODUCTS OR SERVICES DESCRIBED HEREIN, AT ANY TIME WITHOUT PRIOR NOTICE. ANY INFORMATION MARKED WITHA DATE IS PUBLISHED AS OF THIS DATE ONLY AND NO OBLIGATION OR RESPONSIBILITY IS UNDERTAKEN TO UPDATE OR AMEND ANY SUCH INFORMATION.

Limitation of Liability.IN NO EVENT SHALL LAKEFRONT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL,PUNITIVE OR CONSEQUENTIAL DAMAGES (INCLUDING, WITHOUT LIMITATION, DAMAGES FORLOSS OF DATA, BUSINESS OR PROFITS) ARISING OUT OF OR IN CONNECTION WITH THESETERMS OF USE , THE SITE, THE INABILITY TO USE THE SITE OR ANY PRODUCTS, SERVICES OR CONTENT PURCHASED, OBTAINED OR STORED IN OR FROM THE SITE, WHETHER BASED ON CONTRACT, TORT, STRICT LIABILITY OR OTHERWISE, EVEN IF LAKEFRONT HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, AND NOTWITHSTANDING THE FAILURE OF THE ESSENTIAL PURPOSE OF ANY REMEDY. WITHOUT LIMITING THE FOREGOING PROVISIONSOF THIS PARAGRAPH, THESE LIMITATIONS ALSO APPLY TO ANY THIRD PARTY CLAIMS AGAINST USERS.

Without limiting any exclusion specifically provided for in these Terms of Use, we shall in no event be liablefor any costs, damages or liability for any unauthorized use of the Site or breach of security relating to the Site.

We do not guarantee or assume any responsibility that and you acknowledge that we make no representation or warranty, that:

(a)the Information on the Site is accurate, adequate, current orreliable, or may be used for any purpose other than for general reference or as specified in any separate licence granted by us;

(b)the Information on the Site is free of defect, error, omission, virus or anything which may change, erase, add to or damage your software, data or equipment;

(c)messages sent through the internet will be free from interception,corruption or loss;

(d)access to the Site will be available or be uninterrupted; or

(e)defects in the Site will be corrected.

Indemnity. Youagree to indemnify, defend and hold harmless Lakefront from and against any andall suits, losses, claims, demands, liabilities, damages, costs and expenses(including reasonable attorneys' fees) arising from or relating to: (a) youruse of the Site; (b) your breach of any terms and conditions contained in theseTerms of Use or any representation, warranty or covenant made by you herein; or(c) your violation of any applicable law, statute, ordinance, regulation or anythird party's rights. This obligation survives the termination of these Termsof Use.

Ownership. AllRights Reserved. All content of the pages and in the screens displaying thepages, and in the information and material therein and in their arrangement and“look and feel” of the Site, is, unless otherwise specifically stated, owned byLakefront and is protected by copyright, database rights or other intellectualproperty rights. Lakefront will enforce such rights to the full extent of applicablelaw. Except as otherwise agreed in writing or to the extent necessary to usethe Site in accordance with these terms and conditions, you shall not: (1) copythe Site in whole or in part; (2) display, reproduce, create derivative worksfrom, transmit, sell, distribute, rent, lease, sublicense, time-share, lend ortransfer or in any way exploit the Site in whole or in part; (3) embed the Siteinto other products; (4) use the Site in any timesharing arrangement; (5)create function calls or other embedded links from any software program to theSite; (6) remove or obscure any copyright notice of Lakefront or any of itssuppliers; (7) use any trademarks, service marks, domain names, logos, or otheridentifiers of Lakefront or any of its third party suppliers; or (8) except tothe extent permitted under by law, reverse engineer, decompile, disassemble, oraccess the source code of the Site.

Nothing in the Site is designed to grant any license or right touse any image, trademark or logo. No act of downloading or otherwise copyingfrom the Site will transfer any legal entitlement to any software or materialon the Site to you. Lakefront reserves all intellectual property rights (suchas copyright and trademark rights) to all material on the Site, and will enforcesuch rights to the full extent of applicable law.

Passwords and Security.Access to any password-protected portion of the Site requires that a userobtain a username and password from Lakefront. In consideration of beinggranted a username and password and permitted access to certain portions of theSite, you hereby acknowledge having read and understood these Terms of Use andagree to be bound thereby. Subsequent use of any username and password issuedby Lakefront shall be deemed to constitute full acceptance and understanding ofthe terms and conditions in these Terms of Use. Any use of or action takenunder your password on the Site and maintaining the confidentiality andsecurity of your password is your sole responsibility. In addition, full responsibilityfor all activity conducted through your account is your sole responsibility,and you hereby release Lakefront from any and all liability concerning suchactivity. You must immediately notify Lakefront of any actual or suspectedloss, theft or unauthorized use of a user’s username or password. Lakefront hasno obligation to inquire as to the authority or propriety of any use of oraction taken under your password and will not be responsible for any loss toyou arising from any such use or action or from your failure to comply with theabove.

Please note that when using any Internet facility (such as thisSite), data is transported over an open network that is accessible to thirdparties and may not be secure and there is a risk that information may be corruptedor interrupted during transmission or that any encryption technology may notprovide complete protection. Data is also regularly transmitted acrossinternational borders. This also applies to data transfers where both thesender and recipient are located in the same country.

Investigation and Disclosure of Information.Lakefront has the right, but not the obligation, to monitor any activity andmaterial associated with the Site. Lakefront may investigate any complaint orreported violation of its policies and take any action that it deemsappropriate. Such action may include, but is not limited to, issuing warnings,suspending or terminating your use of all or any portion of the Site anddenying you access to all or any portion of the Site. Lakefront also reservesthe right to report any activity that it suspects may violate any law orregulation to appropriate law enforcement officials, regulators, or otherpersons or entities. In order to cooperate with governmental requests, toprotect Lakefront’s systems and other users, to ensure the integrity andoperation of the Site, business or systems, or otherwise to comply with the lawand legal process, Lakefront may access and disclose any information itconsiders necessary or appropriate.

Privacy Policy. We reserve the right to trackvisitors to, and usage of, this Site through “cookies” and similar techniquesand to use any resulting information as we determine in our sole discretion.

Third Party Links.The Site may contain hyperlinks (or "links") to Internet websites ofthird persons and entities. Lakefront may provide such links solely as aconvenience to its users or has no control over the content on such third partywebsite. Lakefront does not maintain and is not responsible or liable for any off-Siteweb pages accessible from or linked to the Site or any products, services orinformation contained, offered or promoted therein. Use of links to any thirdperson via the Site is at your own sole risk. No warranties, either express orimplied, concerning the content of such Site are made, including the accuracy,completeness, reliability or suitability thereof for any particular purpose,nor does Lakefront warrant that such website or content is free from any claimsof copyright, trademark or other infringement of the rights of third parties orthat such site or content is devoid of viruses or other contamination. Noguarantee as to the authenticity of documents on the Internet is given. Linksto off-Site web pages do not necessarily constitute sponsorship or affiliationof, with or by Lakefront and should not be construed as such. All opinions,recommendations, views, news, information and other content contained in anythird person sites are solely those of the third persons, and Lakefrontdisclaims all responsibility and liability for such content.

Risks in Relying on the Information and Materials Contained in the Site.Lakefront makes reasonable efforts to provide accurate information on the Site.There may be delays, omissions or inaccuracies in the information. Lakefrontdoes not endorse the opinions of, or warrant the accuracy of facts or otherinformation or materials contributed by, any third party. Lakefront has noobligation or responsibility to undertake, update or amend any suchinformation. The information contained in this Site is as of the datesexpressly stated herein, and no implication is being made that there has beenno change in such information subsequent to such dates.

Past Performance.Past performance is no indication of future performance, and nothing on thisSite should be interpreted to state or imply otherwise. The value ofinvestments may fall as well as rise and investors may not get back the fullamount invested. Changes in rates of foreign exchange may cause the value ofinvestments to go up or down.

Modifications.Lakefront reserves the right to change the terms and conditions under whichthis Site is offered without further notice to you. Your continued use of thisSite shall signify your agreement with and understanding of any additional ormodified terms or conditions applicable to this Site, which additions andmodifications can be made at any time, without notice.

Termination. ThisSite and access to it can be terminated at any time, with or without notice,and for any reason. Termination of your access to and use of the Site does notrelieve you of any obligations arising or accruing prior to such termination orlimit any liability that you otherwise may have to Lakefront.

Assignability.These Terms of Use will be binding on and will inure to the benefit of thelegal representatives, successors and assigns of the parties hereto. Lakefrontmay assign the terms and conditions under these Terms of Use in whole or inpart at any time without your consent. Your obligations contained in theseTerms of Use shall not be assigned or delegated. Any purported assignment ofthe terms and conditions contained in these Terms of Use in violation of itsterms shall be void.

No Waiver of Rights.No failure of either party to enforce any of its rights under these Terms ofUse will act as a waiver of such rights.

Enforceability.If any portion of any provision of these Terms of Use is found invalid orunenforceable, that provision shall be enforced to the maximum extent possibleand the remaining provisions of these Terms of Use shall remain in full forceand effect.

Governing Law and Jurisdiction.These Terms of Use are governed by Law of the People’s Republic of China andthe courts within China shall have exclusive jurisdiction over any matterarising out of these Terms of Use or from your accessing of the Site.


OFFICE LOCATIONS

OFFICE LOCATIONS

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HONGKONG

1103, 11/F, Nexxus Building, 41 Connaught Road Central,

Central, Hong Kong

BEIJING

3F,   A5 One Center of Lama Temple, 51 Hepingli West Street, Dongcheng District, Beijing, China

SHENZHEN

22A/F, CITIC Securities Tower, No.8 Center 3rd Road, Futian District, Shenzhen, China