Terms & Conditions

GLACIER LOCATION LDA

Terms & Conditions and Service Agreement

Version: 1.0

Effective date: 1 May 2026

Jurisdiction: Portugal, European Union

Languages of original: English, Portuguese and Russian

Table of Contents

1. General Provisions

2. Definitions

3. Real Estate Agency Services

4. Relocation Services

5. Registration and Account

6. Fees and Payment

7. Cancellation and Refunds

8. Privacy and GDPR

9. Limitation of Liability

10. Intellectual Property

11. Prohibited Activities

12. Amendments

13. Governing Law

14. Contact Information

1. General Provisions

1.1 These Terms and Conditions ("Terms") govern the relationship between Glacier Location LDA ("Company", "we", "us"), registered in Portugal (NIF: 516344412), and any individual or legal entity ("User", "you") accessing the website [website address] ("Website") or using its services.

1.2 By using the Website, you confirm that you have read, understood and unconditionally accepted these Terms. If you do not agree with any provision, you must discontinue use of the Website.

1.3 The Company is a licensed real estate intermediary in Portugal, holding AMI licence No. 22212 issued by the Associação dos Profissionais e Empresas de Mediação Imobiliária de Portugal (APEMIP), and operates in accordance with Decreto-Lei n.º 15/2013 de 8 de fevereiro.

1.4 These Terms are drawn up in Russian, English and Portuguese and are legally binding under the laws of Portugal.

2. Definitions

"Real Estate Services" — intermediary and advisory services for the purchase, sale and rental of real estate in Portugal.

"Relocation Services" — a package of services assisting with relocation to Portugal, including legal support, assistance with visas, NIF registration, bank account opening and settlement.

"Client" — a User who has entered into an agreement with the Company for any of the services.

"Property" — a specific unit of real property offered for sale or rent.

"Personal Account" — the personal section of the Website accessible after registration.

3. Real Estate Agency Services

3.1 The Company acts as a real estate intermediary and is not a party to any purchase, sale or rental transaction. All transactions are concluded directly between the buyer/tenant and the seller/landlord, with notarial certification as required under Portuguese law.

3.2 Property descriptions on the Website are for informational purposes only. The Company endeavours to keep information up to date but does not guarantee its completeness or accuracy. Final specifications are confirmed by cadastral documents (Caderneta Predial, Certidão de Registo Predial).

3.3 Property prices are quoted in euros (€) and may change without prior notice. The binding price is fixed at the time of signing the preliminary contract (CPCV — Contrato de Promessa de Compra e Venda).

3.4 The Company does not provide financial, tax or investment advice. Clients wishing to assess the investment value of a property should consult independent specialists.

3.5 Real estate transactions are subject to Portuguese taxes (IMT, Imposto de Selo, IMI, etc.). The Client is responsible for compliance with tax legislation, independently or with the assistance of a tax adviser.

The Golden Visa (ARI) and other immigration programmes are not guaranteed and depend solely on the decisions of the SEF/AIMA authorities. The Company assists with document preparation but accepts no responsibility for the outcome of any applications.

4. Relocation Services

4.1 Within the scope of relocation services, the Company may assist with the following: finding short-term and long-term rental accommodation; obtaining a NIF (número de identificação fiscal); opening a bank account; registration with SEF/AIMA; advice on the NHR (Non-Habitual Resident) programme; arranging school enrolment, health insurance and other related matters.

4.2 The specific scope and cost of services are set out in an individual Service Agreement or proforma invoice accepted by the Client prior to commencement of services.

4.3 The Company acts as a consultant and coordinator and is not an immigration lawyer. For legal representation in matters of visas and residence permits, the Client is advised to engage a licensed Advogado or Solicitador.

4.4 Timelines for services involving government authorities (AIMA, AT, Finanças, Câmaras Municipais) are indicative only and depend on administrative queues beyond the Company's control.

Providing the Company with false, incomplete or misleading information about oneself or one's circumstances constitutes grounds for immediate termination of the agreement without refund of amounts paid, where this has resulted in additional costs or losses for the Company.

5. Registration and Account

5.1 Access to certain services requires registration on the Website. Upon registration, you must provide only accurate and up-to-date information and keep it current.

5.2 You are responsible for maintaining the confidentiality of your login credentials and for all actions performed under your account. If you suspect unauthorised access, you must notify the Company immediately.

5.3 Registration on the Website is available to individuals aged 18 or over with full legal capacity. Legal entities act through an authorised representative.

5.4 The Company reserves the right to block or delete an account in the event of a breach of these Terms or on reasonable security grounds.

6. Fees and Payment

6.1 The agency commission for purchase and sale services ranges from 3% to 5% of the transaction price (plus VAT at 23%) and is payable by the seller/buyer in accordance with the terms of the mediation agreement (Contrato de Mediação Imobiliária). Specific rates are stated in the individual agreement.

6.2 Prices for relocation packages and individual services are set out in the price list on the Website or determined upon request. All prices are in euros and include VAT unless otherwise stated.

6.3 Payment is accepted by bank transfer (MB Way, SEPA), Visa/Mastercard card, or other methods indicated on the Website. Bank transaction fees are borne by the Client.

6.4 Certain service packages may require an advance payment (retainer). The balance is payable according to an agreed schedule or upon completion of the service.

6.5 In the event of a payment overdue by more than 15 days, the Company reserves the right to suspend services and charge statutory interest (juros de mora) in accordance with Decreto-Lei n.º 32/2021.

7. Cancellation and Refunds

7.1 A consumer (an individual acting for personal purposes) has the right to withdraw from the agreement within 14 calendar days of its conclusion without giving any reason (right of withdrawal, direito de livre resolução) in accordance with Decreto-Lei n.º 24/2014.

7.2 The right of withdrawal does not apply to services fully performed with the consumer's express consent before the expiry of the 14-day period, nor to real estate transactions in which the Company acts as an intermediary.

7.3 Refunds for partially performed services are made on a pro-rata basis for the unperformed portion, less the Company's documented expenses incurred prior to receipt of the cancellation notice.

7.4 All refund requests must be submitted in writing to glacierlocation@glacierlocation.com with reference to the agreement/invoice number. Processing time is 14 business days.

8. Privacy and GDPR

8.1 Personal data is processed in accordance with EU Regulation 2016/679 (GDPR) and Portuguese Law No. 58/2019. Further details are set out in the Privacy Policy, which forms an integral part of these Terms.

8.2 The Company collects personal data only to the extent necessary to provide the services and does not transfer it to third parties without the data subject's consent, except where required by law (notary, AIMA, Finanças, banks, for AML purposes).

8.3 Users may at any time request access, rectification, erasure or portability of their data by contacting alc@glacierlocation.com. Complaints may be submitted to the CNPD (Comissão Nacional de Proteção de Dados).

8.4 For anti-money-laundering (AML/KYC) purposes under Lei n.º 83/2017, the Company is required to verify the identity of clients and retain the relevant documents for the period prescribed by law.

9. Limitation of Liability

9.1 The Website is provided "as is". The Company accepts no liability for interruptions to the Website's operation, technical errors, temporary unavailability or loss of data due to force majeure.

9.2 The Company's aggregate liability to the Client on any grounds is limited to the amount of fees actually paid by the Client for the relevant service during the preceding 12 months.

9.3 The Company is not liable for decisions of government authorities (AIMA, AT, câmaras municipais), actions of third parties (sellers, landlords, banks, notaries), or changes in legislation affecting the availability of visas or residency.

9.4 Nothing in this section limits the Company's liability for wilful misconduct or gross negligence, nor does it prejudice consumer rights guaranteed under Portuguese and European law.

10. Intellectual Property

10.1 All materials on the Website — texts, photographs, logos, graphics, databases — are the intellectual property of the Company or its licensors and are protected under Portuguese and EU copyright law.

10.2 Reproduction, distribution or creation of derivative works without the Company's written consent is prohibited. Personal, non-commercial use of information with mandatory attribution of the source is permitted.

10.3 By posting any materials on the Website (reviews, photographs), the User grants the Company a non-exclusive licence to use such materials for marketing purposes, while retaining the right of authorship.

11. Prohibited Activities

Users are prohibited from:

a) using the Website for unlawful activities, including money laundering, fraud and tax evasion;

b) automated data collection (scraping, crawling) without written permission;

c) publishing false, misleading or defamatory information;

d) attempting unauthorised access to the Company's systems;

e) circumventing the agency to enter into direct transactions with sellers represented by the Company, during the term of the mediation agreement and for 12 months following its termination.

12. Amendments

12.1 The Company reserves the right to amend these Terms unilaterally. Notice of material amendments will be sent to registered users by email and/or published on the Website at least 30 days before the amendments take effect.

12.2 Continued use of the Website after the amendments take effect constitutes acceptance of the revised Terms. If you do not agree with the amendments, you may terminate your service agreement in accordance with section 7.

13. Governing Law and Dispute Resolution

13.1 These Terms are governed by and construed in accordance with the laws of the Portuguese Republic.

13.2 The parties will endeavour to resolve disputes by negotiation. If no agreement is reached within 30 days, the dispute will be referred to the competent court at the Company's registered place of business.

13.3 Consumers may also refer disputes to alternative dispute resolution bodies (RAL/ADR), in particular the Centro de Arbitragem de Conflitos de Consumo (CACCL), or use the ODR platform (ec.europa.eu/odr).

13.4 If the Client is domiciled in another country, the parties may agree on an alternative dispute resolution procedure within the individual agreement.

14. Contact Information

Company: Glacier Location LDA, NIF 516344412

Address: Av. do Atlântico, nº 16, 14º Piso, Escritório 8, 1990-019, Lisbon

Email: glacierlocation@glacierlocation.com

Phone: +351 214 093 629

AMI Licence: No. 22212, APEMIP

Data Protection Officer (DPO): alc@glacierlocation.com

Glacier Location LDA · NIF 516344412 · AMI No. 22212 · glacierlocation@glacierlocation.com · +351 214 093 629