CSR & ESG Policy
Effective Date: 23 August 2025
Entity: Qont (owned by Vigilshore Group Holdings) (“Qont,” “we,” “us,” “our”).
Scope: This Policy applies worldwide across Qont operations, subsidiaries, controlled affiliates, suppliers, contractors, and partners engaged in producing, sourcing, or delivering Qont products and services, including physical goods (e.g.,
hardware, components, apparel/merchandise).
0) Policy Status, Interpretation, and Liability Safe-Harbor
0.1 Purpose. This Policy sets out Qont’s corporate commitments and standards for Environmental, Social, and Governance (“ESG”) responsibilities.
0.2 Aspirational Commitments. Targets and commitments in this Policy are goals, not warranties, guarantees, or representations of future performance.
0.3 Operational Primacy. Qont prioritizes consumer-first product quality, reliability, and safety. Responsible sourcing and stewardship are pursued where feasible and commercially reasonable and will not prevent us from meeting
essential quality, safety, reliability, or delivery requirements.
0.4 No Liability for Target Shortfalls. To the maximum extent permitted by law, Qont disclaims liability for any failure to achieve, by any date, any aspirational objective, initiative, or metric referenced in this Policy.
0.5 No Contract / No Third-Party Rights. This Policy is not a contract and does not create third-party beneficiary rights. It may be updated at Qont’s discretion.
0.6 Local Law Prevails Where Mandatory. Mandatory local law governs in case of conflict. Regional Variations (AU, EU, US, UK) below explain how we align with local frameworks.
1) Our Commitments at a Glance
• Environmental: Responsible physical sourcing (e.g., chips, components, textiles) without compromising quality; efficient operations; reduction of waste; practical stewardship in logistics and packaging.
• Social: High-performance professionalism, safe and fair workplaces, merit-based opportunity, community engagement, career creation, and discreet charitable activity.
• Governance: Transparent leadership; user-first data and privacy posture; strong internal controls; anti-bribery and anti-corruption compliance; ethical conduct across the value chain.
• Enforcement: A tiered supplier enforcement program (warning → remediation plan → audit/monitoring → termination).
• Reporting: Annual, concise CSR/ESG reports highlighting progress, actions, and areas for improvement.
2) Definitions
2.1 Physical Goods means hardware, components, peripherals, apparel/merchandise, packaging, and printed materials produced for Qont.
2.2 Supplier means any third party that provides goods or services incorporated into Qont offerings.
2.3 Responsible Sourcing means sourcing that respects applicable laws and Qont standards on safety, labor, and environmental practices, balanced against operational viability, quality, reliability, and delivery requirements.
2.4 High-Performance Professionalism means a culture of excellence, compliance discipline, and leadership standards consistent with a global enterprise.
3) Environmental Responsibility (E)
Position: We pursue responsible sourcing and environmental stewardship in practical balance with our non-negotiable commitments to product quality, safety, reliability, and delivery.
3.1 Responsible Sourcing of Physical Goods.
• We seek suppliers who comply with applicable environmental, product safety, chemical, and waste regulations.
• For chips, components, and textiles, we expect traceability appropriate to risk, adherence to hazardous substances restrictions, and product-safety certifications where required.
• We strengthen packaging and logistics practices to reduce unnecessary materials and transportation inefficiencies where commercially reasonable.
3.2 Manufacturing Standards.
• Facilities producing Qont goods should operate with legally required permits, emissions controls, and safe waste handling.
• Cooling, power, and process chemical management must align with applicable regulations and industry norms.
3.3 Materials and Substances.
• We prohibit the use of banned substances in Physical Goods and require conformance with relevant restricted substances lists where applicable.
• Where conflict-mineral or high-risk materials diligence is required by law, we expect suppliers to implement reasonable due diligence programs.
3.4 Product Lifecycle & Waste.
• Where feasible, we encourage design choices that support durability and responsible end-of-life handling (e.g., recyclability, repairability subject to safety).
• We will explore feasible take-back or recycling pathways where they add real value, subject to operational constraints.
No Net-Zero Claim. Qont does not adopt or market a “net zero” target. Our environmental approach is responsibility-first, quality-first, and practically implementable.
4) Social Responsibility (S)
Position: Qont builds a high-performance, compliant workforce and engages communities with professionalism and respect.
4.1 People & Workplace.
• Safe, healthy, respectful workplaces; compliance with wage, hour, and working-conditions laws.
• No forced, child, or trafficked labor; no unlawful discrimination or harassment.
• Merit-based opportunity, performance development, and leadership training consistent with high-performance professionalism.
4.2 Suppliers & Labor Standards.
• Suppliers must provide safe working conditions, comply with labor laws, and prohibit prohibited forms of labor.
• We may require evidence of labor compliance as part of our tiered enforcement (see §7).
4.3 Community & Opportunity.
• Career Creation: We invest in skills, training, and professional pathways that expand opportunity in the regions where we operate.
• Community Engagement: We participate in responsible local engagement and quiet, private charitable activity without commercializing philanthropy.
5) Governance (G)
Position: We prioritize transparency, user-first ethics, data protection, and anti-corruption compliance.
5.1 Leadership Accountability & Transparency.
• Clear executive ownership for CSR/ESG; periodic reporting to senior leadership and the board (or a delegated committee).
• Internal policies mapped to risk, audited on a cadence appropriate to the risk profile.
5.2 User-First Data & Privacy.
• Data is handled under strict privacy, security, and access controls.
• We implement technical and administrative safeguards designed to prevent unauthorized access, misuse, or disclosure.
5.3 Anti-Bribery & Anti-Corruption.
• Zero tolerance for bribery and corruption.
• Compliance with applicable anti-corruption laws and trade controls/sanctions.
• Training for relevant personnel and consequences for violations.
5.4 Ethics & Speak-Up.
• Code of Conduct expectations for employees and suppliers.
• Confidential reporting channels and non-retaliation for good-faith reports.
6) Product & Market Conduct
6.1 Quality First. Our supply, manufacturing, and logistics decisions must not compromise product safety, reliability, or consumer quality.
6.2 Truthful Statements. Public claims about environmental or social performance must be supportable, specific, and not misleading.
6.3 Marketing and Procurement. Vendor selection and marketing practices must align with this Policy and applicable law.
7) Supplier & Partner Enforcement Framework (Tiered)
We apply a documented, fair, and escalating process:
Stage 1 — Notice & Review. Formal notice of concern; meeting with supplier leadership to discuss issues and corrective expectations.
Stage 2 — Remediation Plan. Written corrective plan with clear actions, owners, and deadlines; periodic status checks.
Stage 3 — Audit & Monitoring. Verification through audit or third-party review; intensified monitoring. Costs may be allocated to supplier where permitted.
Stage 4 — Termination. If remediation fails or risk is severe, we terminate the relationship and may report the conduct where required by law.
We reserve discretion to accelerate stages for severe non-compliance (e.g., safety risks, illegal labor practices, corruption).
8) Reporting, Transparency & Continuous Improvement
8.1 Annual CSR/ESG Report (Concise). We publish a short annual report summarizing material actions, progress, and next steps.
8.2 Independent Review. We may engage independent reviewers where appropriate or required.
8.3 Stakeholder Engagement. We maintain channels for regulators, customers, and trusted partners to raise responsible sourcing or compliance concerns.
9) Implementation & Oversight
9.1 Responsibility. Day-to-day ownership resides with Qont’s executive sponsors for Operations, Supply Chain, People, Security/Privacy, and Legal/Compliance.
9.2 Training. Role-appropriate training is provided to personnel who influence sourcing, manufacturing, logistics, privacy/security, and supplier oversight.
9.3 Records. We maintain records reasonably necessary to evidence actions under this Policy, subject to privacy and confidentiality obligations.
10) Changes to this Policy
We may update this Policy to reflect operational, legal, or market developments. The effective date above indicates when updates take effect.
Regional Variations (AU, EU, US, UK)
The following apply in addition to the Global Policy and prevail where required by local law.
A) Australia (AU)
• We align with Australian requirements on workplace safety, environmental compliance, consumer protection, and modern slavery obligations applicable to qualifying entities and supply chains.
• Claims and disclosures will be consistent with ACCC guidance on truthful environmental representations.
• Where local law mandates specific remediation, reporting, or contractual terms, those requirements will control.
B) European Union (EU)
• We align with applicable EU directives and national implementations on sustainability reporting, product safety, labor standards, and environmental compliance; privacy practices align with EU data protection law.
• Environmental or social claims will follow EU rules on substantiation and unfair commercial practices.
• Where certain disclosures or due-diligence processes are mandated for covered entities, we will implement controls appropriate to scope and risk.
C) United States (US)
• We align with applicable federal and state requirements on product safety, truthful marketing, privacy/security, labor, and environmental compliance.
• Anti-bribery/anti-corruption compliance and internal controls are maintained consistent with applicable U.S. laws and industry norms.
• Where regulators prescribe ESG disclosures for covered entities, we will provide concise reporting appropriate to our footprint.
D) United Kingdom (UK)
• We align with UK requirements on modern slavery statements for qualifying organizations, product safety, and fair trading standards.
• Governance expectations follow applicable UK corporate governance and reporting norms as relevant to our structure and listings (if any).
• Environmental/social claims will be clear, specific, and supportable under UK consumer-protection rules.
E) Conflict Rule
Where a Regional Variation conflicts with the Global Policy due to mandatory local law, the Regional Variation prevails to the extent required. Otherwise, the Global Policy applies.
Product Quality & Service Status Disclaimer — Store
Effective Date: 23 August 2025
Entity: Qont (owned by Vigilshore Group Holdings) (“Qont,” “we,” “us,” “our”).
Scope: This document applies to all products, subscriptions, and services purchased through the Qont Store (the “Store”). It governs quality commitments, service availability representations, and downtime remedies. It does not apply to
products purchased outside the Store unless expressly stated in writing.
1) Definitions
1.1 Model: An eligible Qont product or subscription offered for sale in the Store that is expressly identified as a “Model” at the time of purchase. For clarity, merchandise, accessories, and promotional items are not Models.
1.2 Downtime Event: A period during which a Qont-managed service essential to a Model is unavailable to an affected customer, other than during Excluded Events (defined below).
1.3 Excluded Events: (a) scheduled maintenance announced in advance; (b) emergency security maintenance; (c) failures, outages, or degradations of third-party systems (including hosting, cloud infrastructure, telecommunications,
internet service providers, app stores, payment processors, or integrator platforms); (d) force majeure events; (e) customer-side or local network/device issues; (f) misuse, unauthorised modifications, or use contrary to documentation.
1.4 Billing Cycle: The recurring billing period applicable to a subscription Model, or, for one-time purchases, the thirty (30) day period following the transaction date.
2) Quality and Delivery Assurance
2.1 Delivery/Access Assurance. Qont will provide the Model purchased, including associated service access where applicable. If delivery or initial access is not provided, Qont will, at its option, fulfil the order, replace with an equivalent
offering, issue a Store credit, or provide a refund consistent with Store policies and applicable law.
2.2 Conformity. Qont’s obligation is that Models will materially conform to the descriptions and specifications presented in the Store at the time of purchase, subject to reasonable updates, improvements, and version changes.
3) Service Availability (Status)
3.1 Estimated Availability. Qont targets an estimated 99% availability for Qont-managed services essential to Models, measured on a monthly basis. This is an estimate and not a guarantee of uninterrupted 24/7 service.
3.2 Dependencies. Availability may be affected by third-party systems and networks outside Qont’s control. Qont is not liable for outages or degradations caused by such third parties (see §7 and §9).
3.3 Measurement. Availability and Downtime Events are assessed using Qont’s production monitoring and service logs, excluding Excluded Events.
4) Downtime Remedy (Store Discount)
4.1 Trigger. If a single Downtime Event exceeds thirty (30) consecutive minutes and directly affects a customer’s ability to use an essential service component of a Model, the customer becomes eligible for a Store discount under §4.2,
subject to §5.
4.2 Discount. Qont will provide a Store discount between thirty percent (30%) and forty percent (40%) toward the customer’s next Model purchase. The precise percentage within that range will be determined by Qont, taking into
account scope, duration, and impact of the incident.
4.3 Exclusions. Merchandise, accessories, and promotional items are excluded from this discount.
4.4 Form. The discount is non-transferable, has no cash alternative, and applies only at checkout for the eligible next Model purchase.
Taxes, duties, shipping, and third-party fees are excluded from discount calculations unless required
by law.
5) Eligibility and Process
5.1 Automatic Eligibility Upon Report. Eligibility is automatic if the customer is affected and reports the incident to Qont Support. Qont may request reasonable information to verify impact.
5.2 Verification. Issuance of a discount is subject to Qont’s verification against its monitoring and service logs.
5.3 One Claim Per Billing Cycle. A customer may receive no more than one (1) discount per Billing Cycle.
5.4 Value Cap. The discount cannot exceed the value of the customer’s future Model purchase to which it is applied.
5.5 Sole Remedy for Downtime. The §4 discount is the sole and exclusive remedy for qualifying Downtime Events, without prejudice to any non-excludable statutory rights (see Jurisdictional Variations).
6) Third-Party Systems and Integrations
6.1 No Liability for Third Parties. Qont is not liable for failures, outages, or degradations attributable to third-party systems, networks, or platforms not operated by Qont.
6.2 Coordination Efforts. Qont will act with reasonable commercial efforts to coordinate with third-party providers to restore service, but such coordination does not create liability beyond the remedies stated herein.
7) Limitations and Exclusions (General)
7.1 Use Requirements. Remedies do not apply where an issue arises from unauthorised use, misuse, or use contrary to documentation.
7.2 Changes and Maintenance. Reasonable updates, feature changes, or scheduled maintenance are not Downtime Events.
7.3 No Stacking. Discounts under §4 may not be combined or stacked across incidents within the same Billing Cycle.
8) Disclaimers of Warranties
8.1 As-Is/As-Available (to the extent permitted by law). Except for the specific assurances in §2 and the discount remedy in §4, the Store, Models, and related services are provided on an “as is” and “as available” basis.
8.2 No Additional Warranties. Qont disclaims all implied warranties (including merchantability, fitness for a particular purpose, and non-infringement) to the maximum extent permitted by law.
8.3 Statutory Rights Preserved. Nothing in this document excludes or limits non-waivable statutory rights (see Jurisdictional Variations).
9) Limitation of Liability
9.1 No Indirect Damages. To the maximum extent permitted by law, Qont will not be liable for any indirect, incidental, special, exemplary, punitive, or consequential damages, including lost profits, lost revenues, lost data, business
interruption, or loss of goodwill.
9.2 Exclusive Remedy for Downtime. For qualifying Downtime Events, the exclusive remedy is the Store discount described in §4.
9.3 Aggregate Limit (if enforceable). Where permitted by law and unless expressly stated otherwise in a separate agreement, Qont’s aggregate liability for claims arising from or related to a Model purchased through the Store will not
exceed the amount paid to Qont for that Model, excluding taxes and third-party fees.
10) Changes to this Disclaimer
Qont may update this document from time to time. Material changes will be posted in the Store or communicated through reasonable channels. Updated terms apply prospectively from the stated effective date.
11) Contact
Questions or incident reports: the Support channel identified in your order confirmation or within the Store account portal.
Jurisdictional Variations
The following variations apply in addition to the Global Principles above and prevail to the extent of any conflict. They do not reduce or remove non-waivable consumer rights.
A) Australia (AU)
A.1 Australian Consumer Law (ACL). Nothing in this document excludes, restricts, or modifies any rights or remedies conferred by the Competition and Consumer Act 2010 (Cth) and the Australian Consumer Law that cannot be
excluded.
A.2 Non-Excludable Guarantees. Where the ACL implies guarantees that cannot be excluded, Qont’s liability is limited, to the extent permitted, to repair or replacement, re-supply of the services, or payment of the cost of doing so, at
Qont’s election.
A.3 Availability & Credits. The §4 discount remedy operates in addition to any ACL remedies.
A.4 Governing Law. For purchases by Australian residents, the laws of Australia and the laws of your State or Territory of residence apply, subject to any mandatory forum requirements.
B) European Union (EU)
B.1 Consumer Rights Preserved. Nothing limits consumers’ rights under Directive (EU) 2019/770 (digital content and services), Directive (EU) 2019/771 (sale of goods), or applicable national implementations, including rights to
conformity and remedies.
B.2 Withdrawal and Local Rules. If applicable law grants a right of withdrawal for certain consumer purchases made at a distance, the Store’s Returns/Withdrawal Policy will apply in accordance with EU and national law.
B.3 Data & Reporting. Incident reports may involve processing of personal data; processing is performed in accordance with the Store Privacy Policy and applicable EU data protection law.
B.4 Governing Law. Mandatory consumer protection laws of the EU Member State of residence apply. Any choice of law in Store terms will not deprive you of those protections.
C) United States (US)
C.1 Warranty Disclaimers and Limitations. To the fullest extent permitted under applicable state and federal law (including the UCC where applicable), Qont disclaims implied warranties beyond those that cannot be disclaimed.
C.2 State Variations. Some states do not allow limitations on implied warranties or exclusion of incidental or consequential damages, so certain limitations may not apply to you.
C.3 Remedies. The §4 discount remedy is supplemental to any non-waivable statutory rights.
C.4 Governing Law. Mandatory consumer protection laws of the state of your residence apply to the extent required by law. Any broader choice-of-law clause in the Store terms is subject to those protections.
D) United Kingdom (UK)
D.1 Consumer Rights Act 2015. Nothing in this document excludes or limits rights under the Consumer Rights Act 2015, including rights relating to goods’ satisfactory quality and services’ reasonable care and skill.
D.2 Fairness. Terms are intended to be fair, transparent, and prominent; they will be interpreted in accordance with UK consumer law and the Consumer Contracts Regulations where applicable.
D.3 Governing Law. Mandatory UK consumer protection laws apply for UK residents. Any choice-of-law in Store terms will not deprive you of those protections.
E) Conflict Rule
If a jurisdictional variation conflicts with a Global Principle, the variation prevails to the extent required by applicable law. Otherwise, the Global Principles apply.
IP Protection & Anti-Impersonation Policy
Effective Date: 23 August 2025
Entity: Qont (owned by Vigilshore Group Holdings) (“Qont,” “we,” “us,” “our”).
Scope: This public policy applies worldwide to all Qont intellectual property and brand assets, including systems, models, LLMs, formulas, frameworks, features, software, data, designs, documentation, user interfaces, names, logos, and
trade dress.
1) Ownership & Reservation of Rights
1.1 Ownership. Qont exclusively owns all rights in and to its technology and brand. This includes our style of Portable Risk Management, all LLMs developed or customized by Qont, all proprietary formulas (including scoring and mitigation
frameworks), all systems and software, and all Qont-exclusive features and methods.
1.2 No License. Nothing in any Qont website, product, service, Store page, publication, or communication grants you any license or right to copy, reproduce, modify, train, fine-tune, distribute, sell, or otherwise use Qont IP, except where
expressly permitted in a written agreement signed by Qont.
1.3 All Rights Reserved. Qont reserves all rights not expressly granted. Any unauthorized use is prohibited.
2) Definitions
2.1 Qont IP means all intellectual property owned or controlled by Qont, including technology, content, data, documentation, know-how, trade secrets, source code, object code, models, LLM weights/configurations, prompts, formulas,
schemas, and designs.
2.2 Impersonation means any act that falsely suggests you are Qont or affiliated with Qont, including use of confusingly similar names, brands, domains, handles, profiles, visuals, or product descriptors.
2.3 Brand Assets means QONT, QONT-form marks, logotypes, icons, product names, and associated trade dress.
3) Prohibited Conduct (Non-Exhaustive)
You must not do any of the following without Qont’s prior written permission:
(a) Copy, reproduce, mirror, scrape, or data-mine Qont IP or Brand Assets.
(b) Reverse engineer, decompile, disassemble, derive source code, model weights, or formulas, or attempt to do so.
(c) Train, fine-tune, or otherwise develop any model or system using Qont data, outputs, interfaces, or code to replicate or approximate Qont functionality or features.
(d) Create derivative works, competing systems, “look-alikes,” or confusion as to source, sponsorship, or affiliation.
(e) Sell, license, sublicense, rent, lease, time-share, or otherwise commercialize Qont IP or outputs.
(f) Remove, alter, or obscure any copyright, trademark, confidentiality, or other proprietary notices.
(g) Register or use domains, social handles, application names, package names, or marketplace listings containing or imitating Qont’s names, marks, or product identifiers.
(h) Use Qont Brand Assets in advertising, packaging, UI, or materials to imply partnership, certification, or endorsement.
4) Anti-Impersonation & Brand Misuse (Zero Tolerance)
4.1 No Impersonation. Do not present yourself, your product, or your organization as Qont or as affiliated with Qont.
4.2 No Brand Misuse. Do not use Qont names, logos, or trade dress, or confusingly similar variations, in any medium, including domains, apps, plug-ins, social profiles, marketing assets, marketplace listings, or documentation.
4.3 Takedowns. Qont will act swiftly to remove infringing or impersonating materials from websites, app stores, code repositories, social platforms, clouds/hosts, and marketplaces.
5) Enforcement & Remedies
5.1 Immediate Action. Qont will take immediate action against theft, copying, misappropriation, or impersonation of Qont IP or Brand Assets.
5.2 Lawful Recovery. Depending on jurisdiction and facts, actions may include injunctive relief, removal/takedown requests, claims for damages, account of profits, delivery-up or destruction of infringing materials, and seizure
where lawful.
5.3 Civil & Criminal Pathways. Where conduct amounts to fraud, deception, computer misuse, trade-secret theft, or related offenses, Qont may refer matters to law enforcement and regulatory authorities domestically and
internationally.
5.4 Costs. Qont will seek recovery of legal fees and enforcement costs where permitted by law.
5.5 No Waiver. Failure to act immediately is not a waiver of rights.
6) Third-Party Platforms & Partners
6.1 Platforms. Qont will pursue enforcement on hosting providers, CDNs, app stores, social networks, marketplaces, package registries, and code repositories to remove infringing or impersonating content.
6.2 Partners. Authorized partners must comply with written brand and integration terms. Any use outside written permission is unauthorized.
7) Notice, Reporting & Cooperation
7.1 Report Violations. Report suspected infringement or impersonation via the Support/Legal contact provided in your Store account or on our website. Provide URLs, screenshots, account names, and any evidence available.
7.2 Preservation. Qont may preserve and collect evidence, including logs and public records, to support enforcement.
7.3 Counterfeit & Fraud. Qont will notify affected customers and relevant platforms where counterfeit or fraudulent listings are detected.
8) Changes
Qont may update this Policy periodically. Updated versions apply prospectively from the stated effective date.
Jurisdictional Variations
These variations apply in addition to the global policy and prevail where required by local law.
A) Australia (AU)
• This Policy operates alongside Australian law, including copyright, trademark, and Australian Consumer Law (ACL).
• Qont will seek all remedies available under Australian law, including injunctions, damages or an account of profits, delivery-up, and costs.
• Nothing in this Policy excludes rights you cannot lawfully waive.
B) European Union (EU)
• This Policy operates alongside EU and Member State IP laws, including copyright, trademark, trade secrets, database rights, and unfair competition/passing-off equivalents.
• Qont will seek injunctions, damages, and delivery-up/destruction of infringing goods where available, and will use platform notice-and-action mechanisms under applicable EU rules.
• Mandatory consumer protections remain unaffected.
C) United States (US)
• This Policy operates alongside US IP, trade secret, unfair competition, and anti-impersonation laws.
• For willful infringement or misappropriation, Qont may seek enhanced damages and attorneys’ fees where permitted, plus injunctions and lawful seizure/destruction of infringing materials.
• Some limitations or remedies vary by state; applicable state law controls where required.
D) United Kingdom (UK)
• This Policy operates alongside UK IP laws, including copyright, trademarks, trade secrets/confidential information, and passing off.
• Qont will seek interim and final injunctions, damages or an account of profits, delivery-up/destruction, and costs where available.
• Mandatory consumer protections under UK law remain unaffected.
E) Conflict Rule
If a jurisdictional variation conflicts with the global Policy, the variation prevails to the extent required by local law. Otherwise, the global Policy applies.
Qont Global No Advice & No Liability Disclaimer
Effective Date: 23 August 2025
Entity: Qont (owned by Vigilshore Group Holdings) (“Qont,” “we,” “us,” “our”).
Scope: This disclaimer applies globally to all Qont products, services, systems, simulations, risk assessments, outputs, publications, and Store content.
1) No Advice of Any Kind
Qont does not provide financial advice, legal advice, medical advice, investment advice, professional advice, or any other form of advice. All outputs, reports, tools, communications, and Store content are provided strictly as risk
assessment and mitigation resources, and nothing contained in them should be construed as advice.
2) Risk Assessment & Mitigation Only
Qont products and services are designed to identify, map, and present potential risks and mitigation strategies. They are not intended to, and do not, constitute recommendations, endorsements, or guidance on whether a risk should be
accepted, rejected, or mitigated.
3) User Responsibility
All decisions regarding whether to act, not act, or take mitigation steps remain solely with the customer or user. Qont does not assume responsibility for any outcome resulting from reliance on or disregard of its risk outputs.
4) No Liability
To the maximum extent permitted by law, Qont is not liable for any losses, damages, costs, or consequences arising from:
• choosing to take a risk,
• choosing to reject a risk, or
• attempting to mitigate a risk.
The user accepts full responsibility for all decisions and consequences.
5) Changes
Qont may update this disclaimer from time to time. Updated terms will apply from the effective date stated.
Jurisdictional Variations
The following variations apply in addition to the Global Principles above and prevail where required by law.
A) Australia (AU)
• Nothing in this disclaimer excludes, restricts, or modifies any rights under the Australian Consumer Law (ACL) that cannot be excluded.
• To the extent permitted, Qont’s liability is limited to the remedies provided under the ACL: repair, replacement, re-supply, or payment of the cost of doing so, at Qont’s election.
B) European Union (EU)
• Nothing in this disclaimer removes or limits non-waivable consumer rights under EU law, including Directive (EU) 2019/770 and Directive (EU) 2019/771.
• Qont’s role is expressly limited to risk assessment and mitigation, and no advisory relationship of any kind is created.
C) United States (US)
• To the fullest extent permitted by law, Qont disclaims all warranties, express or implied, including merchantability and fitness for a particular purpose.
• Qont is not liable for indirect, incidental, special, or consequential damages.
• Some states do not allow certain limitations, so these disclaimers may not apply to all users.
D) United Kingdom (UK)
• Nothing in this disclaimer excludes rights under the Consumer Rights Act 2015, including satisfactory quality and reasonable skill.
• Qont provides no advice of any kind and assumes no advisory duty. Liability is excluded to the maximum extent permitted by UK law.
E) Conflict Rule
If a jurisdictional variation conflicts with a Global Principle, the variation prevails to the extent required by applicable law. Otherwise, the Global Principles apply.
Anti-Money Laundering (AML) & Corporate Social Responsibility (CSR) Policy
Effective Date: July 9, 2025
Entity Covered: Vigilshore Group and its sub-brands, including Qont and affiliated systems
Policy Purpose
This document outlines the Anti-Money Laundering (AML) and Corporate Social Responsibility (CSR) commitments of Vigilshore Group and all its subsidiaries and brands, including Qont. It affirms our commitment to compliance, ethical operation, anti-abuse enforcement, and the responsible development of technologies across regulated and sensitive sectors.
Applicability
This policy applies to all:
-
Corporate operations and digital platforms owned by Vigilshore Group
-
Users, employees, vendors, and contractors
-
Systems operating under the Qont brand, including QontVision, QontMedical, QontLogix, and any future entities
Anti-Money Laundering (AML) Framework
Risk-Based Approach
While we do not hold customer balances, offer tokens, or provide wallet functionality, we recognize our operational exposure in AML-flagged industries such as fintech, gaming, medical, and logistics.
We adopt a risk-based framework to detect and prevent:
-
Account fraud or identity theft
-
Misuse of payment platforms
-
Abusive automated activity or suspicious access behavior
-
Attempts to use our systems to facilitate illegal or unethical activity
Know Your User (KYU) Protocols
We do not currently require formal KYC (Know Your Customer) identity procedures for general users. However, we retain the right to:
-
Request identity verification in the event of suspected abuse or fraud
-
Restrict or suspend accounts exhibiting suspicious behavior
-
Investigate transaction patterns, access behavior, or IP-level anomalies
For high-risk modules (e.g., QontGaming or medical validation), enhanced due diligence may be introduced at any time and governed by this policy.
Third-Party Payment Compliance
All financial transactions are processed exclusively through established payment platforms including:
-
Stripe
-
Google Pay
-
Apple Pay
-
PayPal
-
Wix Payments
These platforms are responsible for the AML compliance of payment flow. We do not store, process, or transmit raw card data.
AML Incident Monitoring and Reporting
We maintain automated systems and internal protocols for:
-
Monitoring suspicious login, purchase, or system behavior
-
Logging access metadata for review
-
Internally flagging accounts or sessions for escalation
If required by law or legal process, we will cooperate with regulatory bodies, law enforcement, or financial intelligence units (FIUs) regarding AML concerns.
Corporate Social Responsibility (CSR) Commitments
We believe technology carries a duty of care. Vigilshore Group commits to responsible, transparent, and ethical operations across the following CSR pillars:
Environmental Responsibility
-
We seek to reduce our carbon footprint through efficient infrastructure, data center optimization, and responsible development of physical systems (e.g., Cloud A7).
-
We favor low-impact digital deployment and responsible energy use where possible.
Supply Chain and Ethical Sourcing
-
All hardware components, partnerships, and services undergo ethical review.
-
We commit to avoiding suppliers or vendors involved in forced labor, environmental harm, or human rights violations.
Anti-Corruption and Fair Conduct
-
Vigilshore Group enforces a zero-tolerance policy toward bribery, fraud, collusion, and unethical influence.
-
We maintain internal compliance reviews and contractual restrictions with vendors and executives.
Equity, Diversity, and Inclusion
-
Our global hiring framework respects and promotes diversity across gender, background, and belief.
-
We actively cultivate inclusive leadership and hiring pipelines across all branches.
Responsibility in High-Risk Sectors
We acknowledge the serious nature of operating in sectors such as:
-
Gambling (via NedStake)
-
Medical systems (via Ralphen)
-
Military logic systems (via QontRisk/MissionSim)
We commit to:
-
Transparent use-case disclosure
-
Age and access restrictions where required
-
Responsible marketing and product design that avoids manipulation or harm
Policy Enforcement and Disclosures
-
Violations of this policy may result in account restriction, termination, or legal reporting.
-
All employees and contractors are required to uphold the principles set forth herein.
-
Users may contact our compliance team to report abuse or request review of any flagged behavior.
Policy Updates
This policy is reviewed annually or as required by law. Updates will be posted with an updated effective date.
Contact Information
Vigilshore Group – Compliance & Ethics Division
Whistleblower Protection & Government Cooperation Policy
Effective Date: July 9, 2025
Issued by: Vigilshore Group
Applies to: All subsidiaries, brands, and platforms (including Qont, NedStake)
Purpose and Commitment
Vigilshore Group is committed to the highest standards of ethics, integrity, legal compliance, and operational transparency. This policy affirms our dual responsibility to:
-
Protect individuals who report misconduct in good faith (whistleblowers), and
-
Actively engage with law enforcement and regulatory authorities in identifying and preventing illegal activity.
This approach is central to our role as a global operator in regulated sectors including fintech, logistics, gaming, and medical systems.
Scope of Protection
This policy applies to:
-
Employees (full-time, part-time, and probationary)
-
Independent contractors and freelancers
-
External stakeholders (vendors, clients, and partners)
-
Anonymous individuals making good-faith disclosures
Whistleblowing protections apply regardless of position, relationship, or geographic location.
Protected Categories for Reporting
Vigilshore Group protects individuals who report the following, provided the report is made in good faith:
-
Fraud, bribery, or corruption
-
Financial misreporting or manipulation
-
Misuse or unauthorized access to personal data
-
Harassment, discrimination, or abuse of authority
-
Violations of AML, export controls, labor laws, or compliance obligations
-
Safety, environmental, or health risks
-
Misconduct related to government interactions, favoritism, or unethical partnerships
Anti-Retaliation Guarantee
We strictly prohibit retaliation against any whistleblower. This includes:
-
Termination, demotion, or reassignment
-
Harassment, intimidation, or social isolation
-
Withholding of promotions, contracts, or benefits
-
Legal threats or informal punitive conduct
Any confirmed retaliation will result in disciplinary action, up to and including termination or legal remedy.
Reporting Channels
Whistleblowers may file reports through any of the following confidential and secure channels:
-
Email: Compliance@vigilshore.com
Reports will be reviewed promptly, fairly, and without prejudice.
Investigation and Review Process
All reports are:
-
Logged and time-stamped upon receipt
-
Reviewed by an independent internal compliance team or third-party advisor
-
Handled with strict confidentiality and need-to-know access control
-
Investigated using factual evidence and in compliance with local law
Whistleblowers may be contacted, protected, or updated throughout the process depending on legal circumstances.
Cooperation with Law Enforcement and Regulatory Authorities
Vigilshore Group is committed to actively upholding legal and ethical standards by engaging with law enforcement and regulators when illegal activity is identified.
We maintain:
-
Internal systems to detect fraud, identity abuse, or suspicious activity
-
A policy of voluntary cooperation with law enforcement when criminal activity is suspected
-
Procedures to proactively notify authorities where threats, breaches, or abuse are substantiated
-
Logging and forensic audit tools to support investigative efforts
-
Strict verification of all legal requests (e.g., warrants, subpoenas) prior to data release
Our goal is to act as a responsible steward of digital systems while ensuring platform integrity and public trust.
Policy Oversight and Revisions
This policy is maintained by the Office of Ethics & Legal Affairs and reviewed annually. It may be updated to reflect changes in law, corporate structure, or operational risk.
Updates will be made public via our website or official communication channels.
Contact Information
Vigilshore Group – Compliance & Ethics Division
Data Processing Addendum (DPA)
Effective Date: July 9, 2025
Issued by: Vigilshore Group
Applies to: All business clients, partners, and platform users
Purpose
This Data Processing Addendum (DPA) supplements our Terms of Use and applies to any business or institutional client (“Client”) using Vigilshore Group platforms, including Qont, Ralphen, NedStake, and affiliated services.
This DPA is issued to meet the obligations under applicable data protection laws, including the General Data Protection Regulation (GDPR), UK GDPR, CCPA, and equivalent global laws.
Data Relationship
-
Vigilshore Group acts as a data controller for user registration data (e.g., name, email) collected at checkout or during account setup.
-
For any operational data entered into our platforms (e.g., medical or risk assessment inputs), we do not act as a data processor.
-
That data is:
-
Encrypted and stored locally on user devices
-
Not collected, viewed, transmitted, or accessed by Vigilshore Group servers
-
Processed entirely within the user’s device or infrastructure under their sole control
-
Data Handling and Protection
Where limited data (e.g., email, name, IP metadata) is stored:
-
We implement appropriate technical and organizational safeguards
-
Access is restricted based on role
-
No personal data is sold, profiled, or processed beyond functional platform use
We maintain a lawful basis under GDPR Art. 6(1)(b) (contractual necessity) and provide data subject rights in accordance with our Privacy Policy.
Sub-Processors
We use secure sub-processors to provide core infrastructure:
-
Wix Cloud (site operations)
-
Google Analytics
-
Stripe, PayPal, Apple Pay, and Google Pay (payment gateways)
All vendors are contractually bound to comply with equivalent data protection standards.
Breach Notification
In the unlikely event of a data breach involving controller-level data, Vigilshore Group will:
-
Notify affected Clients and authorities without undue delay
-
Provide details and steps taken for containment, investigation, and mitigation
Termination and Deletion
Upon request or termination of services, we will delete account data (email/name) in accordance with our data retention policy and applicable law.
Export Control & Sanctions Policy
Effective Date: July 9, 2025
Issued by: Vigilshore Group
Applies to: All clients, users, and partners globally
Purpose
This Export Control & Sanctions Policy outlines Vigilshore Group’s compliance with global trade, export, and embargo laws in all countries where we operate. As a provider of technology solutions—including defense-adjacent risk systems, medical platforms, and logistics tools—we recognize our legal duty to prevent unauthorized use or distribution of our services.
Jurisdictional Compliance
We comply with:
-
U.S. Export Administration Regulations (EAR)
-
UK Export Control Order
-
EU Dual-Use Regulations
-
UN Security Council Sanctions
-
Australian Defence Export Controls (DEC)
Embargoed & Restricted Regions
We prohibit the use of our platforms by individuals or entities:
-
Located in or affiliated with embargoed jurisdictions (e.g., North Korea, Iran, Syria, Crimea, Cuba)
-
Listed on U.S. OFAC, UK HMT, or EU consolidated sanctions lists
-
Engaging in activities that support military, surveillance, or dual-use applications without written authorization
Customer Screening & Responsibility
Clients and users must:
-
Not export, re-export, or transfer our software to prohibited parties or regions
-
Notify us immediately if they suspect unauthorized use of our technology
-
Agree to indemnify Vigilshore Group for any violation of applicable export laws
We reserve the right to block, suspend, or terminate access if a user or organization is found to be in breach of these provisions.
Internal Access Control Policy
Effective Date: July 9, 2025
Issued by: Vigilshore Group
Applies to: All employees, contractors, and internal users
Purpose
This Internal Access Control Policy defines how data access is managed, secured, and monitored within Vigilshore Group systems, ensuring compliance with international security standards and protecting client trust.
Role-Based Access
Access to any sensitive or personal data is granted based on:
-
Business role and function
-
Need-to-know principle
-
Security clearance, where applicable
No employee, contractor, or third party may access protected data without authorization.
Data Handling Rules
Personnel must:
-
Access data only for authorized operational reasons
-
Not copy, export, or transmit sensitive data without written approval
-
Avoid using unencrypted personal devices to view or store company data
-
Comply with security awareness training and audits
Logging and Monitoring
All access to protected systems is:
-
Logged and timestamped
-
Subject to periodic audit and investigation
-
Retained in accordance with industry best practices
Breaches, misuse, or suspicious activity will be escalated to compliance and may lead to suspension or legal action.
Enforcement
Violation of this policy may result in:
-
Access restriction or revocation
-
Disciplinary measures up to termination
-
Legal action, including civil or criminal penalties if laws are broken
Acceptable Use Policy (AUP)
Effective Date: July 9, 2025
This Acceptable Use Policy outlines the rules and prohibited conduct for all users of Vigilshore Group platforms, including Qont, NedStake, and any affiliated systems.
Users may not:
-
Use any platform or product for illegal, unethical, or unauthorized purposes
-
Reverse-engineer, tamper with, or probe the systems’ architecture or logic
-
Upload, generate, or transmit false, defamatory, or harmful content
-
Launch denial-of-service attacks, data scraping, auto-bots, or brute force actions
-
Circumvent geo-restrictions, access controls, or sandbox limitations
-
Use risk results, simulations, or scoring tools to mislead, defame, harass, or threaten others
Violations may result in access suspension, account termination, or referral to law enforcement.
End-User License Agreement (EULA)
Effective Date: July 9, 2025
This EULA governs your use of any Vigilshore Group software, including QontVision, Ralphen OS modules, Cloud A7 firmware, and downloadable risk tools.
Key Terms:
-
You are granted a license, not ownership
-
You may not modify, copy, reverse-engineer, or distribute the software
-
License is revocable upon violation of any term
-
Software is provided “as is” without warranty of uptime or result accuracy
-
Government and commercial clients may receive extended license terms via contract
Violation of this agreement may result in immediate suspension and legal action.
Refund & Cancellation Policy
Effective Date: July 9, 2025
Digital Products & Services:
-
Non-refundable once accessed, activated, or downloaded
-
Cancellations only valid before platform access or license issuance
Hardware Products (e.g., Cloud A7):
-
May be returned within 14 days if unopened or proven defective
-
Refund will be issued upon inspection and validation
Risk Systems:
-
No refunds for simulations, intelligence reports, or risk scoring modules once results are generated
Vigilshore reserves the right to deny refunds in cases of abuse, fraud, or terms violations.
Disclaimer Policy
Effective Date: July 9, 2025
Vigilshore Group provides intelligence systems, simulation tools, and risk scoring platforms intended to enhance decision-making — not replace professional, legal, medical, military, or financial advice.
Key Disclaimers:
-
Our systems are not medical devices, military chain-of-command software, or gambling outcomes providers
-
Simulations and results are for informational and mitigation support purposes only
-
Actions taken based on platform output are the responsibility of the user or client organization
-
We do not guarantee outcomes, accuracy, or legality of user-led decisions
AI Use & Transparency Policy
Effective Date: July 9, 2025
As of the effective date, Vigilshore Group does not use Artificial Intelligence (AI) in its platforms, simulations, or scoring engines.
Future Use Position:
-
We may introduce AI-enhanced modules in specific sectors (e.g., logistics, medical triage)
-
Any AI used will be supportive, advisory, and non-controlling
-
Users will be clearly informed in advance of any meaningful changes
-
We will not deploy opaque AI (“black-box decision-making”) without user opt-in and full disclosure
This ensures transparency, accountability, and ethical deployment at all stages of AI evolution.
Terms of Use
Effective Date: July 9, 2025
Issued by: Vigilshore Group
Applies to: Qont, NedStake, and all platforms, services, and sites under Vigilshore Group ownership
Acceptance of Terms
By accessing or using any of our websites, products, or services (“Services”), you agree to be legally bound by these Terms of Use (“Terms”). If you do not agree to these Terms, you may not access or use our Services.
Your agreement is confirmed at the point of checkout, registration, or continued use.
Eligibility
To use our Services, you must:
-
Be at least 14 years of age
-
Be legally permitted to enter into a binding agreement in your jurisdiction
-
Not be barred from using our Services under any applicable laws or sanctions
Note: Certain services, including those related to medical, military, or gambling modules, are restricted to users 18 years or older.
Both individuals and companies are allowed to register and create accounts under these Terms.
User Conduct and Prohibited Use
By using our Services, you agree not to:
-
Reverse-engineer, decompile, modify, or otherwise attempt to access our source code or systems
-
Attempt to gain unauthorized access to our platforms, servers, or data
-
Upload, post, transmit, or share any content that is unlawful, defamatory, harmful, abusive, or discriminatory
-
Use stolen identities, false information, or engage in payment fraud
-
Use our Services for any illegal, unethical, or malicious purpose
-
Circumvent export laws, trade controls, or operate from embargoed territories
We reserve the right to suspend or terminate any account or access found in breach of these conditions.
Privacy and Data Handling
Your use of our Services is also governed by our Security & Policy, which outlines:
-
What data we collect
-
How it is stored and used
-
Your legal rights under global privacy frameworks (e.g., GDPR, CCPA)
By using our Services, you consent to our handling of your data as described therein.
Intellectual Property
All content, software, technology, systems, brand marks, and documentation provided by us remain the exclusive property of Vigilshore Group or its licensors.
You may not:
-
Reproduce, redistribute, or create derivative works
-
Sell, license, rent, or commercially exploit any part of our platform
-
Use our trademarks or brand elements without prior written consent
Account Access and Security
You are responsible for:
-
Keeping your login credentials confidential
-
All activity that occurs under your account, even if unauthorized
-
Promptly notifying us of any suspected security breaches or unauthorized access
Disclaimer of Warranties
Our Services are provided on an “as-is” and “as-available” basis. We do not guarantee:
-
That services will be uninterrupted, secure, or error-free
-
That results will be accurate, timely, or suitable for any specific purpose
To the fullest extent allowed by law, we disclaim all warranties, express or implied, including fitness for a particular purpose and non-infringement.
Limitation of Liability
To the maximum extent permitted by applicable law, Vigilshore Group shall not be liable for:
-
Indirect, incidental, special, consequential, or punitive damages
-
Data loss, system failure, or service interruption
-
Unauthorized access, breach, or misuse of your information
In jurisdictions that do not allow such exclusions, our liability is limited to the amount you paid (if any) in the 12 months preceding the event.
Legal Compliance
You are responsible for complying with all laws, regulations, and rules applicable in your jurisdiction when using our Services.
You may not use our Services in any country or region subject to embargoes, trade restrictions, or prohibited use by applicable export control laws.
Suspension and Termination
We may suspend or terminate your access, with or without notice, if we believe you have violated these Terms or pose a legal or security risk to others.
We also reserve the right to remove, restrict, or deactivate content or accounts at our sole discretion in accordance with applicable law.
Changes to These Terms
We may revise these Terms at any time. The updated version will be posted with a new “Effective Date.”
Your continued use of the Services constitutes acceptance of any changes.
Governing Law
These Terms are governed by the laws of Australia, without regard to conflict of laws principles.
Any disputes shall be resolved in the courts of Australia, unless otherwise required by applicable law.
Contact Information
Vigilshore Group – Legal Affairs
Platform Disclaimer of Results & Risk Scores
Effective Date: July 9, 2025
Vigilshore platforms provide simulation tools, intelligence systems, and risk scoring outputs designed to support high-quality mitigation efforts and decision-making. However:
Disclaimers:
-
Results are informational tools, not definitive predictions
-
Mitigation outcomes depend on correct application, context, and judgment
-
We do not accept liability for decisions made based solely on platform outputs
-
All use of simulations, scores, and insights is at the user’s discretion and risk
We provide intelligence. You apply the judgment.
Moderation & Uploaded Content Policy
Effective Date: July 9, 2025
Users may upload content (e.g., photos, data, risk scenarios) into QontVision, simulations, or platform modules.
Rules:
-
Users are fully responsible for what they upload
-
Uploads must not contain illegal, defamatory, abusive, or misleading content
-
We do not pre-screen, but reserve the right to investigate or remove content post-submission
-
Serious violations may lead to account suspension or reporting to authorities
Content freedom exists, but platform integrity will be upheld.
Encryption & Data Security Policy
Effective Date: July 9, 2025
Vigilshore Group is committed to industry-leading data security standards across all platforms, systems, and devices.
Key Security Practices:
-
Encryption at rest and in transit for all sensitive account data
-
On-device encryption for simulations, uploads, and camera-based input (e.g., QontVision)
-
User content is never decrypted, accessed, or analyzed by Vigilshore servers unless required by law
-
All unauthorized access attempts are logged, flagged, and may trigger account suspension or legal action
Your data stays encrypted. Your trust stays protected.
Service Level Agreement (SLA)
Effective Date: July 9, 2025
This SLA applies to all enterprise, B2B, and institutional clients using Vigilshore systems.
Service Commitments:
-
Target uptime: 99.9% monthly availability for all core platforms
-
Best-effort support response times, subject to global time zones and load
-
No liability for:
-
Outages caused by third-party providers (e.g., Wix, Stripe, ISP)
-
Force majeure events (e.g., war, disaster)
-
Minor latency or delays in simulation processing unless total system halt occurs
This SLA does not override negotiated contracts with specific service tiers or uptime guarantees.
Copyright & DMCA Policy
Effective Date: July 9, 2025
Vigilshore allows users to upload material as long as it is lawful and non-abusive. However, we comply with all global copyright frameworks, including the Digital Millennium Copyright Act (DMCA).
Key Terms:
-
Users may upload any material they own or have rights to
-
Uploading stolen, infringing, or pirated content is prohibited
-
Copyright owners may submit takedown requests to:
-
We will remove material promptly when properly notified
-
Repeat violators may have accounts suspended or restricted
You retain freedom. We retain the right to protect rights holders.