TERMS OF SERVICE

WEBSITE

Effective Date: January 1, 2026

These Terms of Service (“Terms”) govern your access to and use of advisorsportugal.com and any related services, features, content, or applications (collectively, the “Services”) provided by

[APLAUSO DOURADO UNIPESSOAL LDA] (“Advisors Portugal”, “we”, “us”, or “our”). By accessing or using the Services, you (“you” or “User”) agree to these Terms in full. If you do not agree, you must not use the Services.

1. Definitions

Account: A unique account created for you to access our Services.

Content: All text, graphics, images, data, software, and other materials available through the Services.

Personal Data: Any information relating to an identified or identifiable individual.

Services: The website advisorsportugal.com and any related advisory, coordination, and information services provided by our team.

Website: The website located at https://advisorsportugal.com.

You/User: The individual or entity accessing or using the Services.

2. Scope of Services

Advisors Portugal provides independent advisory, fund analysis, coordination, and related services for Portugal’s Golden Visa investment fund route. We analyze CMVM-regulated investment funds and provide inputs on application processes, US tax compliance structuring (including PFIC, IRA, 401(k), and SDIRA considerations), and coordination with legal counsel and other service providers.

We may modify, suspend, or discontinue any aspect of the Services at any time, with or without notice, and we will not be liable for any such modification, suspension, or discontinuance.

2.1 No Investment Advice and Risk Acknowledgment

[APLAUSO DOURADO UNIPESSOAL LDA] IS NOT A REGISTERED INVESTMENT ADVISER, BROKER-DEALER, OR FIDUCIARY.
The Services, including any guidance or information provided related to Golden Visa investment funds, fund performance, or investment opportunities, are offered purely for informational and educational purposes and DO NOT constitute:

Investment advice
Financial advice
Legal advice
Tax advice
A recommendation, solicitation, or offer to invest in any specific fund or product
You acknowledge and agree that:
All investment decisions are made at your own risk and sole discretion
You should consult with licensed investment advisers, legal counsel, and tax professionals before making investment decisions
Past performance of investment funds does not guarantee future results

[APLAUSO DOURADO UNIPESSOAL LDA] shall not be responsible or liable for any losses, damages, or expenses arising from your investment decisions, including without limitation any loss of capital, loss of expected returns, opportunity costs, or consequential damages.

3. Account Registration and Security

You must be at least 18 years old and have legal capacity to enter into binding contracts.
You agree to provide accurate, complete, and current information during registration and to update it to keep it accurate.
You are responsible for maintaining the confidentiality of your account credentials and for all activities under your account.
You agree to notify us immediately of any unauthorized use.

4. User Conduct and Obligations

You shall NOT:

Use the Services for any unlawful purpose or to violate any local, national, or international law
Attempt to gain unauthorized access to any portion of the Services or other accounts, systems, or networks
Reverse engineer, decompile, or disassemble any portion of the Services
Interfere with or disrupt the integrity or performance of the Services
Transmit any viruses, worms, malware, or any items of a destructive nature
Use automated means (e.g., bots, scrapers) to access or collect data from the Services
Impersonate any person or entity
Submit false, misleading, or fraudulent information

5. Fees, Billing, and Payments

Fees for Services (if any) are set forth in separate engagement agreements or invoices.
Advisors Portugal operates on a zero-fee buy-side advisory model for fund recommendations, receiving compensation through broker fees from fund managers.

6. Intellectual Property

All rights, title, and interest in and to the Services, including Content, fund analysis reports, trademarks, and logos, are owned by [APLAUSO DOURADO UNIPESSOAL LDA] or its licensors. Nothing in these Terms grants you any ownership rights to the Services or Content.

7. License to Use Content

We grant you a limited, non-exclusive, non-transferable, revocable license to access and use the Services for your personal or internal business purposes.
You may NOT republish, redistribute, or commercially exploit Service content.
Your license terminates immediately upon termination of these Terms.

8. User Content

By submitting any content, information, or materials to us (including through inquiry forms, consultations, or communications), you:

Grant us a worldwide, royalty-free, sublicensable license to use such content in connection with providing the Services
Represent and warrant that you own or have all necessary rights to grant this license
Acknowledge that your content does not infringe any third party rights
Understand we may remove or refuse to display any content at our sole discretion

9. Disclaimers

THE SERVICES ARE PROVIDED “AS IS” AND “AS AVAILABLE,” WITHOUT WARRANTY OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE.

To the fullest extent permitted by law, [APLAUSO DOURADO UNIPESSOAL LDA] disclaims any implied warranties of merchantability, fitness for a particular purpose, title, and non-infringement.

10. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY PORTUGUESE AND EU LAW, IN NO EVENT SHALL [APLAUSO DOURADO UNIPESSOAL LDA], ITS OFFICERS, DIRECTORS, EMPLOYEES, OR AGENTS BE LIABLE FOR:

Any indirect, incidental, special, consequential, or punitive damages
Any loss of capital, investment losses, or fund underperformance
Loss of profits, revenue, savings, or expected returns
Business interruption or opportunity costs
Data loss or reputational harm
Legal, regulatory, or tax consequences

arising from:

Your use of the Services
Your investment decisions
Your reliance on any information provided

11. Indemnification

You agree to indemnify, defend, and hold harmless [APLAUSO DOURADO UNIPESSOAL LDA], its officers, directors, employees, agents, and affiliates from any claim, demand, liability, loss, damages, or expenses (including reasonable attorneys’ fees) arising from:

Your breach of these Terms
Your use of the Services or investment decisions
Your violation of any law or third party right
Any information or content you provide
Your violation of Portuguese immigration or tax law

12. Force Majeure

Neither party shall be liable for any delay or failure to perform due to circumstances beyond its reasonable control, including but not limited to:

Portuguese government regulatory changes to the Golden Visa program
AIMA (Portuguese immigration authority) processing delays or backlogs
Changes to CMVM fund regulations
Acts of war, terrorism, strikes, pandemics
Government orders or changes to immigration law

13. Dispute Resolution and Arbitration

Any disputes arising under these Terms shall be resolved as follows:

Informal Resolution: Contact us first to attempt informal resolution within 30 days
Arbitration: If informal resolution fails, disputes shall be resolved by binding arbitration in Lisbon, Portugal administered by [APLAUSO DOURADO UNIPESSOAL LDA]
Class Action Waiver: You and Advisors Portugal waive the right to a jury trial and any right to participate in a class or representative action.
Exceptions: Either party may seek injunctive relief in Portuguese courts for intellectual property infringement or violation of confidentiality obligations.

14. Governing Law and Jurisdiction

These Terms shall be governed by and construed in accordance with the laws of Portugal and applicable European Union regulations, without regard to conflict of law principles.

15. Termination

[APLAUSO DOURADO UNIPESSOAL LDA] may suspend or terminate your access to the Services at any time, with or without cause or notice, for reasons including but not limited to:

Breach of these Terms
Suspected fraudulent or illegal activity
Request by law enforcement or government agencies
Extended periods of inactivity

Upon termination, your right to use the Services immediately ceases. Provisions that by their nature should survive (including intellectual property, disclaimers, limitation of liability, and indemnification) shall remain in effect.

16. Changes to Terms

We may revise these Terms at our discretion. We will post updated Terms with a new Effective Date and, if required by law, notify you by email. Your continued use of the Services after changes constitutes acceptance.

17. Severability

If any provision of these Terms is held invalid or unenforceable, that provision shall be struck and the remaining provisions shall remain in full force and effect.

18. Contact Information

For questions about these Terms, please contact:

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