LEGAL DISCLAIMER

Effective Date: January 1, 2026

This Legal Disclaimer applies to the website
https://advisorsportugal.com
(the “Website”) and all services provided by [APLAUSO DOURADO UNIPESSOAL LDA] (“Advisors Portugal”, “we”, “us”, “our”).

By accessing or using the Website, you agree to the terms of this Disclaimer. If you do not agree, you must immediately stop using the Website.

1. No Financial, Investment, Legal, or Tax Advice

CRITICAL NOTICE:
[APLAUSO DOURADO UNIPESSOAL LDA] IS NOT A REGISTERED INVESTMENT ADVISER, BROKER-DEALER, FINANCIAL ADVISER, LAW FIRM, OR TAX ADVISER.

All information on this Website is provided for general informational and educational purposes only. It does NOT constitute:

Financial advice or investment advice
A recommendation, solicitation, or offer to invest in any specific fund, product, or service
Legal advice regarding immigration, contracts, or Portuguese law
Tax advice regarding US federal, state, or Portuguese taxation
Fiduciary services or duties
Guaranteed returns or performance predictions

You should NOT rely on the information on this Website as a substitute for professional advice from:

Licensed investment advisers (for investment decisions)
Immigration lawyers (for legal compliance)
Tax professionals (for US and Portuguese tax structuring)
Financial planners (for overall financial planning)

ALWAYS consult qualified professionals before making any investment or legal decisions.

2. Our Role: Independent Advisory and Coordination

Advisors Portugal provides independent advisory services, including:

Analysis of CMVM-regulated Golden Visa investment funds
Coordination with legal counsel, fund managers, and service providers
Inputs on US tax compliance considerations (PFIC, IRA, 401(k), SDIRA)
Process management and application coordination

We DO NOT:

Manage, operate, or custody any investments
Provide legal representation
Prepare or file tax returns
Guarantee fund performance or Golden Visa approval
Act as fiduciaries

3. Accuracy & Reliability of Information

We strive to keep content accurate and up to date, but we:

Make NO warranties or representations as to completeness, reliability, or accuracy
May update, change, or remove content at any time without notice
Are NOT responsible for errors, omissions, outdated information, or third-party data inaccuracies
Cannot guarantee fund information provided by fund managers is accurate or current

All content is provided on an “AS IS” and “AS AVAILABLE” basis, without warranties of any kind, express or implied.

Golden Visa regulations, CMVM fund rules, Portuguese immigration law, and tax regulations change frequently. Information that was accurate at the time of publication may become outdated.

4. Past & Future Performance

Any references to fund performance, historical returns, projections, target returns, or potential outcomes are:

Illustrative only and based on historical data or fund manager representations
NOT guarantees of future results
Subject to market risk, economic conditions, and fund management decisions

PAST PERFORMANCE IS NOT INDICATIVE OF FUTURE RESULTS.

All investments carry risk, including possible loss of capital. Fund values may decrease as well as increase.

5. No Endorsement or Verification

Listings, mentions, or discussions of funds, fund managers, lawyers, service providers, or other third parties do NOT imply endorsement, affiliation, partnership, or recommendation
They are provided strictly for informational reference
They have NOT been independently verified by us for accuracy, performance, or compliance

You are solely responsible for conducting your own due diligence on any fund, service provider, or investment opportunity.

6. Compensation Disclosure

Advisors Portugal operates on a zero-fee buy-side advisory model:

We do NOT charge clients advisory fees for fund recommendations
We receive broker fees/commissions from fund managers for completed investments
This compensation does NOT constitute an endorsement or preferential recommendation
We analyze all 65+ CMVM-regulated funds regardless of compensation structure

Our independence is maintained by:

Having NO in-house or proprietary funds
Analyzing and giving access to the entire CMVM-regulated fund market
Providing unbiased recommendations based on client criteria

7. Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY PORTUGUESE AND EU LAW, [APLAUSO DOURADO UNIPESSOAL LDA] AND ITS DIRECTORS, OFFICERS, EMPLOYEES, AND AGENTS SHALL NOT BE LIABLE FOR:

ANY DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, OR SPECIAL DAMAGES
LOSS OF PROFITS, REVENUE, SAVINGS, OR EXPECTED RETURNS
INVESTMENT OR BUSINESS LOSSES
LOSS OF CAPITAL OR FUND UNDERPERFORMANCE
BUSINESS INTERRUPTION OR OPPORTUNITY COSTS
DATA LOSS OR REPUTATIONAL HARM
LEGAL, REGULATORY, OR TAX CONSEQUENCES
GOLDEN VISA APPLICATION DELAYS OR DENIALS
CHANGES TO PORTUGUESE IMMIGRATION LAW

arising out of or in connection with:

Your use of the Website
Reliance on any information contained herein
Your investment decisions
Interactions with any fund, fund manager, lawyer, or service provider
Portuguese immigration authority (AIMA) decisions or delays
Fund performance or fund manager actions

YOU ASSUME FULL RESPONSIBILITY FOR ANY RELIANCE PLACED ON WEBSITE CONTENT.

8. Third-Party Websites and Links

This Website may contain links to:

Fund manager websites
CMVM official website
Portuguese immigration authority (AIMA) website
Law firm websites
Other third-party resources

We have NO control over their content, security, privacy practices, or accuracy. Accessing such websites is at your own risk. We do not endorse or assume responsibility for third-party content.

9. Regulatory Status

[APLAUSO DOURADO UNIPESSOAL LDA] is NOT licensed as:

A financial institution or bank
An investment adviser or registered investment adviser (RIA)
A broker-dealer
A fiduciary
A law firm or immigration law practice
A tax preparation or accounting firm

Nothing on this Website should be construed as regulated financial activity or as creating any fiduciary duty.

10. Compliance With Local Laws

Access to this Website may be restricted or unlawful in certain jurisdictions. It is YOUR responsibility to ensure that:

Your use of the Website complies with all laws applicable to you
Your investment activities comply with US federal and state securities laws
Your Golden Visa investment complies with Portuguese immigration law
Your tax reporting complies with US IRS requirements (PFIC, FBAR, FATCA)

If you are uncertain about legal compliance, consult legal counsel in your jurisdiction.

11. No Guarantee of Golden Visa Approval

Approval of your Golden Visa application
AIMA processing timelines
Specific outcome or residency permit issuance
Future changes to Portuguese immigration law
Maintenance of current Golden Visa program structure

Portuguese immigration authorities (AIMA) have sole discretion over Golden Visa approvals. Processing times, requirements, and regulations are subject to change by the Portuguese government.

12. Force Majeure and Regulatory Changes

We are NOT liable for circumstances beyond our reasonable control, including:

Portuguese government changes to Golden Visa program
CMVM regulatory changes affecting fund eligibility
AIMA processing delays or backlogs
Changes to Portuguese citizenship timelines
Elimination or modification of investment routes
EU regulatory changes
Force majeure events (pandemic, natural disasters, government actions)

13. Data & Security

We do NOT warrant that the Website will be:

Free from errors, viruses, or security vulnerabilities
Uninterrupted or available at all times
Completely secure from unauthorized access

We disclaim liability for any damages arising from security breaches, data loss, or technical issues.

14. Governing Law & Jurisdiction

This Disclaimer and any disputes arising from it shall be governed by the laws of Portugal and applicable EU regulations, without regard to conflict of law principles.

By using this Website, you submit to the jurisdiction of Portuguese courts for any legal proceedings.

15. Changes to This Disclaimer

We may modify this Disclaimer at any time. Updated versions will be posted on this page with a revised effective date. Your continued use after changes constitutes acceptance of the updated Disclaimer.

16. Contact Information

APLAUSO DOURADO UNIPESSOAL LDA
Rua Padre Américo, Número 7B, 1.º Dto, 1600-548 LISBOA
onboarding@advisorsportugal.com