Disclaimer

PLEASE READ THIS DISCLAIMER CAREFULLY. BY USING RETURNOLIO YOU ACKNOWLEDGE AND AGREE TO IT IN FULL.

1. What Returnolio is

Returnolio is a financial publisher and educational research platform. We produce data, scores, models, written commentary, rankings, watchlists and email digests for the general investing public. Every output of the Service is a piece of published commentary of regular and general circulation, prepared without regard to the financial situation, objectives or needs of any particular reader.

Our mission is to help you learn how to make investment and personal-finance decisions for yourself. Returnolio is not in the business of rendering personalised investment advice and never will be.

Returnolio is, and operates as, a bona fide financial publication within the meaning of Lowe v. SEC, 472 U.S. 181 (1985), and the publisher's exclusion from the definition of "investment adviser" set out in Section 202(a)(11)(D) of the U.S. Investment Advisers Act of 1940 (15 U.S.C. § 80b-2(a)(11)(D)) and the equivalent state statutes. Specifically, the Service is:

1. Bona fide - genuine in its offering of disinterested commentary and analysis, not as a tool to sell or promote any specific transaction;
2. Of regular and general circulation - published on a recurring schedule and made available to all subscribers on the same terms;
3. Impersonal - not based on, and not tailored to, the financial situation, investment objectives, or risk profile of any particular subscriber; and
4. Not in the nature of a tip-sheet or hot-tip service promoting the purchase of specific securities at specific times for the benefit of identifiable subscribers.

2. What Returnolio is NOT

Returnolio, its operator Bodri Tamás EV, and all contractors and editorial contributors (collectively, the "Returnolio Parties") are not:

• a registered investment adviser, investment counsel, financial planner, wealth manager or fiduciary, with the U.S. Securities and Exchange Commission, FINRA, or any U.S. state securities authority, nor with any equivalent regulator in any other jurisdiction;
• a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor or money manager;
• a bank, trust company, insurance company, qualified custodian, or money-services business;
• a tax adviser, accountant, attorney, or licensed legal professional;
• a fiduciary of any kind to any user of the Service.

We do not need to be any of the above because the Service is a publication, not an advisory service. Use of the Service does not create any investment-adviser/client, broker/customer, fiduciary, agency, partnership, or trust relationship between you and any Returnolio Party.

3. Not investment, financial, tax, accounting or legal advice

Nothing in or accessible through the Service - including, without limitation, all data, fair-value estimates, RTEP scores, quality scores, sub-scores, Top-10 editions, smart-money data, position disclosures, ticker pages, macro and event commentary, blog posts, email digests, screenshots, diagrams, AI-generated summaries, replies in support tickets, and any other content - constitutes or should be construed as:

• investment advice, financial advice, securities advice, or trading advice;
• a recommendation, endorsement, solicitation or offer to buy, sell, hold or refrain from buying, selling or holding any security, asset, or financial product;
• a representation that any security, asset or strategy is suitable for any specific person;
• tax, accounting, legal, retirement, insurance, or estate-planning advice.

We do not know, and do not collect for the purpose of advising on, your investment objectives, risk tolerance, time horizon, tax situation, liquidity needs, family circumstances, employment status, or any other factor relevant to a personalised investment recommendation. You alone are responsible for evaluating whether any information from the Service is appropriate for your own circumstances.

4. No personalised recommendations

No output of the Service is a personal recommendation. The scores, the Top 10, and the model outputs are impersonal — the same figures are produced for, and shown to, every subscriber within a given tier. Some features present those impersonal outputs alongside information you have entered (see the My Portfolio note below), but even then the Service does not, will not, and has no capacity to:

• review your portfolio and tell you what to do with it;
• tell you whether a specific security is right for you;
• tell you what percentage of your assets to allocate to anything;
• place, route, recommend or facilitate any trade on your behalf;
• act as your agent or representative with any broker, custodian, exchange, or counterparty.

Features that let you input your own holdings (such as the My Portfolio module and its Portfolio Summary) describe what you have entered — for example your sector breakdown, the impersonal Returnolio Score already assigned to each holding, and which of your holdings appear on the published Top 10. This is descriptive information for your own reference. It is not investment advice and not a recommendation tailored to your personal circumstances, financial situation, objectives, or risk tolerance, and the scores and Top 10 it references are the same impersonal outputs shown to every user.

5. Educational and informational purposes only

All content is provided strictly for general educational, informational and journalistic purposes. The Service is intended to help you become a better-informed reader and decision-maker - it is not a substitute for the personalised advice of a qualified, licensed professional in your jurisdiction.

6. Risk of loss

Investing in securities and other financial instruments carries substantial risk, including the possible loss of your entire principal. Past performance is not indicative of, and does not guarantee, future results. Hypothetical, modelled or forward-looking results have inherent limitations: they do not represent actual trading and may differ materially from results that would have been achieved.

7. Forward-looking statements

The Service contains forward-looking statements - including, without limitation, fair-value estimates, RTEP scores, growth assumptions, scenario projections, ranking changes and editorial commentary about future outcomes.

Such statements are opinions and estimates based on current publicly-available information and modelling assumptions. They are not predictions of fact and are subject to numerous risks and uncertainties, many of which are outside our control. Actual results may differ materially. We undertake no obligation to update any forward-looking statement to reflect events occurring after the date of publication.

8. Data accuracy and third-party sources

We make reasonable efforts to keep our data accurate and up-to-date, sourcing fundamentals from licensed professional data providers and free public sources, and cross-validating where feasible. We do not warrant that any data is accurate, complete, current, reliable, or free from delay, omission or error. Errors are inevitable in any large-scale data product. Always verify against primary sources (issuer filings, regulatory filings) before acting.

9. Conflicts of interest & trading restrictions

Returnolio Parties and their immediate family members may hold, buy, sell, or otherwise transact in any security or asset discussed in the Service. To preserve editorial integrity and the bona-fide character of our publication, we operate under the following self-imposed trading restrictions:

• Pre-publication blackout - Returnolio Parties may not initiate a transaction in any security during the period beginning two (2) U.S. trading days before the publication of any piece referencing that security and ending two (2) trading days after.
• No front-running - Returnolio Parties may not use advance knowledge of forthcoming editorial decisions, ranking changes, Top-10 list adjustments, or RTEP-score updates to trade ahead of publication.
• Position transparency - Where a piece focuses on an individual security and the principal author holds a material position, the piece will carry a position-disclosure footer (e.g. "Author is long XYZ at the time of writing"). Aggregate Returnolio Party holdings are not disclosed at the position level.

Beyond these self-imposed rules, you should assume that any name discussed in the Service may be a position held by a Returnolio Party.

10. How we make money

Returnolio is funded primarily by direct subscription fees paid by users. We also earn affiliate commissions from a small number of partner links: a Top 10 edition carries links to tools we use ourselves, currently a broker and a charting service, and we may earn a commission if you sign up through them, at no extra cost to you. Those links carry an affiliate disclosure wherever they appear.

We do not sell user data, and we do not run display or programmatic advertising on the Service. We do not accept payment from any issuer to feature, rank, or rate its security, and we do not receive payment-for-order-flow. No partner has any say in which securities we discuss or recommend. Our affiliate links attach to a Top 10 edition as a whole, never to an individual pick, and the picks are chosen first, on the methodology alone. One of our affiliate partners, Interactive Brokers, is itself a listed company in our universe: its score is produced by the same methodology as every other name, and the referral relationship has no bearing on it and cannot. Sub-processors (hosting, payments, email) are paid for service, not for influence.

11. Hypothetical, modelled and backtested results

Some content references the historical performance of our scores, rankings or thesis ideas (e.g. "the Top-10 list outperformed the S&P 500 by X% over the past 12 months") or modelled fair-value projections. These are hypothetical, backtested or modelled results and:

• do not represent actual trading or actual subscriber returns;
• are computed with the benefit of hindsight and survivorship-free lists where possible, but cannot be perfectly reconstructed without residual look-ahead bias;
• do not reflect transaction costs, taxes, slippage, dividends not timed to actual ex-dividend dates, or other real-world frictions unless explicitly stated;
• have inherent limitations and may differ materially from results that would have been achieved by any actual investor.

Hypothetical results are not, and should not be construed as, a promise or guarantee of future results.

12. Testimonials and quotes

Where the marketing site features quotes from named or anonymised readers, those quotes reflect the views of those individuals and arenot necessarily representative of the experience of all subscribers. No subscriber received compensation in exchange for a testimonial. Testimonials do not represent any guarantee of outcomes you may experience.

13. Material non-public information (MNPI)

We do not knowingly publish, or invite our readers to act on, material non-public information within the meaning of U.S. securities laws or equivalent regulations elsewhere. All content is based on publicly-available information at the time of writing. If you believe a piece contains MNPI, please contact support@returnolio.com immediately so we can investigate and, where appropriate, retract.

14. AI-generated content

Some narrative summaries, news digests and explanatory content may be generated, in whole or in part, by large-language-model systems. Such content is reviewed editorially but may still contain errors, omissions or hallucinations. Do not rely on any AI-generated content as the sole basis for any decision.

15. Jurisdiction-specific notices

11.1 United States - federal

The Service is offered only as a bona fide publication of regular and general circulation, in reliance on the publisher's exclusion under Section 202(a)(11)(D) of the Investment Advisers Act of 1940. We are not registered with the U.S. Securities and Exchange Commission as an investment adviser, broker-dealer or any other regulated entity, and no such registration is required for the activities carried out through the Service.

Nothing in the Service is intended as, or should be construed as, an offer to sell or a solicitation of an offer to buy any security in any jurisdiction in which such offer or solicitation would be unlawful.

11.2 United States - state law

Each U.S. state regulates investment advice independently. The Service is offered as a publication and not as personalised investment advice in any state. To the extent any state's investment-adviser laws contain a publisher's or substantively similar exemption (most do), we rely on that exemption. We do not and will not provide individualised investment advice to residents of any state without first becoming properly registered or qualifying for an applicable exemption.

California, New York, Texas and other states impose anti-fraud rules regardless of registration status. Nothing in the Service is intended to defraud, mislead, or deceive any reader; if you believe any content is materially misleading, please contact support@returnolio.com.

11.3 European Economic Area & United Kingdom

The Service is an impersonal publication addressed to the public at large. It does not provide personalised recommendations, does not take account of any individual reader's circumstances, and is not intended as "investment advice" or "investment research" within the meaning of MiFID II (Directive 2014/65/EU) or any implementing national legislation.

11.4 Canada, Australia, and other jurisdictions

Where local law requires registration to publish investment commentary for compensation, we rely on the equivalent of the U.S. publisher's exclusion or, where no such exemption exists, restrict access from that jurisdiction. By accessing the Service you confirm that doing so is lawful in your place of residence.

16. No reliance / hold harmless

You acknowledge that you are not relying on any Returnolio Party in making any investment, financial or other decision. To the maximum extent permitted by applicable law, you release, hold harmless and agree to indemnify the Returnolio Parties from any and all losses, damages, claims, costs and expenses (including reasonable attorneys' fees) arising from or relating to your use of the Service or any action you take, or fail to take, based on any information from the Service.

17. Limitation of liability

This Disclaimer is supplemental to, and is incorporated into, our Terms of Service. The limitation-of-liability, warranty-disclaimer, indemnification and dispute-resolution provisions in those Terms apply equally to this Disclaimer.

18. Updates

We may update this Disclaimer from time to time. The "Last updated" date above is always current. Material changes will be notified by email or in-app notice.

19. Contact

Questions: support@returnolio.com.