Financial Disclaimer -- Portfolio Manager by PluriFin

Version: 1.0.0 Last update: 2026-07-14 Original language: Italian (binding version for jurisdiction)

IMPORTANT NOTICE -- READ BEFORE USING THE APP

The Portfolio Manager App by PluriFin is a personal informational

tool. The information, data, charts, rebalancing suggestions and AI

analyses shown **DO NOT in any way constitute financial advice,

investment recommendation, public solicitation of savings or

investment service** under the Italian Consolidated Law on Finance

(TUF, D.Lgs. 58/1998) and the EU MiFID II Directive (2014/65/EU). The

User assumes sole responsibility for their investment decisions.

1. Informational nature of the App

Everything the App shows the User -- positions, market prices, historical performance, allocation, AI analyses, rebalancing suggestions -- has purely informational, descriptive and educational purpose.

The App does not:

• Provide personalized investment advice
• Recommend specific financial instruments or specific trades
• Express opinions on the suitability of an investment for the User's

patrimonial situation, goals or risk tolerance

• Execute orders, nor have relationships with brokers or intermediaries
• Hold User funds or financial instruments

2. Regulatory references

In particular:

• Art. 1 paragraph 5-septies TUF (D.Lgs. 24 February 1998 no. 58):

defines "investment advice" as a personalized recommendation regarding a specific financial-instrument transaction, given on the provider's initiative or at the client's request. The App does not fall within this definition.

• Art. 18-bis and 18-ter TUF: reservation to natural persons enrolled

in the OCF Register and to authorized financial advisors. PluriFin / Filippo Salemi is not enrolled in the OCF Register and does not act in that capacity.

• Art. 1 paragraph 5(d) TUF: portfolio management. **The App does

not manage portfolios; it only shows User-entered data.**

• MiFID II (Directive 2014/65/EU) and **MiFIR (Regulation EU

600/2014)**: the App provides no reserved investment services.

• Regulation (EU) 2017/565: the App is not subject to suitability

or appropriateness assessment, since it offers no investment services.

3. AI analyses -- specific warnings

When the User uses the "AI Analysis" or "AI Chat" feature (powered by Google Gemini), the User must be aware that:

3.1 Probabilistic, not deterministic model

Large language models (LLMs) generate text probabilistically. The same question can produce different answers. Answers are not the result of rigorous quantitative analysis but of plausible textual generation based on the training corpus statistics.

3.2 Hallucinations

AI models may produce false but plausible statements ("hallucinations"), particularly regarding:

• Names of financial instruments, tickers, ISINs
• Historical performance, dividends, maturities
• Tax rules (rates, brackets, deadlines, exemptions)
• Composition of indices, ETFs, funds
• Ex-dividend dates, corporate events

The User must verify every model statement against official sources (KIID, prospectuses, broker sites, Borsa Italiana, EDGAR SEC, ESMA) before any decision.

3.3 Knowledge cutoff

The AI model has a "cutoff" date beyond which it does not know recent events. It cannot know current prices, recent central bank decisions or intraday market events.

3.4 No personalized recommendations

Even when the prompt includes the User's portfolio, AI responses are not personalized advice: the model does not know the User's overall patrimonial situation, income, liquidity needs, time horizon, risk tolerance, specific tax situation, retirement goals. Even when phrasing sounds advisory, the output remains generic text, not a professional opinion.

3.5 No "Know Your Customer"

The App does not collect the User's risk profile, investment experience, financial situation or goals: it does not fall under MiFID II suitability/appropriateness because it provides no investment service. A fortiori, AI analyses cannot be considered suitable or appropriate for the individual User.

4. Rebalancing suggestions

The App automatically computes the difference between current portfolio allocation and User-defined target allocation, displaying the "deltas" needed to bring the portfolio back to target.

These calculations are not buy/sell recommendations. They are simple arithmetic operations on User-chosen parameters. The App does not evaluate:

• Market timing
• Tax impact (capital gains, losses, holding period)
• Broker transaction costs
• Instrument liquidity
• Impact on client / sector / country / currency concentration risk

The User must consult an authorized financial advisor before executing any transaction based on the displayed deltas.

5. Market data

Prices, performance and historical data shown come from public sources or third-party providers (EODHD, FMP) activated by the User with their own API keys. Such data:

• May be delayed 15-20 minutes vs. live market (delayed quotes), unless

real-time subscriptions paid directly to the provider

• May contain errors, gaps, mismatches on splits, dividends,

consolidations, ticker changes

• Are valid only at the time of display and constitute no legal proof of

any transaction

The App accepts no responsibility for third-party data errors or delays.

6. Tax calculations

The App does not compute the User's taxes. Any gain/loss shown is a raw arithmetic calculation (current price - average price) * quantity that does not consider:

• Capital-gain taxation (26%, 12.5% for Italian government bonds and

similar, etc.)

• Stamp duty on securities (0.2% per year)
• IVAFE on assets held abroad
• Deductions, loss carry-forward (4 years in Italy)
• Holding period for special regimes (PIR, pension funds, etc.)
• UCITS vs non-UCITS ETF treatment, "harmonized" vs "non-harmonized"
• Inheritance, gift tax

For tax declarations, the User must consult an accountant or authorized fiscal assistance center (CAF).

7. Foreign markets and currencies

For investments in foreign markets or non-EUR currency, the User must consider:

• Exchange-rate risk
• Broker conversion fees
• Double taxation (Italy treaties, W-8BEN form for US)
• Reporting of assets abroad (Quadro RW)
• Tax-residence regulations

The App models none of these aspects.

8. Personal security

The User is warned that:

• API keys entered for AI or real-time prices are saved in the OS

keystore but accessible to whoever has physical access to the unlocked device

• A lost or stolen device if locked is protected by platform measures;

unlocked it could expose portfolio data

• Google Drive backups are disabled by default but the user might

accidentally enable them

PluriFin is not responsible for losses or unauthorized access from:

• Theft / loss of unlocked device
• Lock-screen misconfiguration
• Device compromise (root, jailbreak, malware)
• Sharing your API keys with third parties
• Manual data export and subsequent uncontrolled distribution

9. Regulatory updates

Italian and EU tax / regulatory rules change frequently. The App does not guarantee that calculations, examples shown or AI responses are up-to-date with the latest changes.

The User must verify the regulation in force at the time of any transaction.

10. User decisions -- liability waiver

The User declares and accepts that:

1. Use of the App, data and analyses shown is at the User's exclusive

initiative and risk

1. Investment decisions are and remain exclusively the User's
2. PluriFin is not liable, within legal limits, for capital losses,

missed gains, missed opportunities or tax consequences from App use

1. For any significant investment decision the User will consult an

authorized financial advisor registered with the OCF Register (<https://www.organismocf.it>) or a supervised intermediary

11. Minors

The App is not intended for users under 18. Play Store content rating is "Everyone / 18+" as recommended for financial apps. Parents and guardians are responsible for any access by minors; PluriFin cannot verify the actual user's age.

12. Geolocation and markets

The App is designed for the Italian and Eurozone markets. Users in other jurisdictions:

• Must verify that App use complies with local rules on personal financial

services

• Must verify the applicable tax regime
• Assume full risk of divergent interpretations

PluriFin is not responsible for compliance with non-Italian / non-EU rules.

13. Explicit acceptance

By accepting this Financial Disclaimer at first launch (or first launch after a version bump), the User declares to:

• Have read and understood this Disclaimer in full
• Accept the App's informational nature
• Understand AI analyses are subject to errors and hallucinations
• Release PluriFin / Filippo Salemi from liability within the limits set

out, to the maximum extent permitted by applicable law

Acceptance is recorded in the encrypted local consent_box (see ConsentService) with UTC timestamp, document version and SHA-256 hash of the accepted text.

Without acceptance, the App will not enable rebalancing, AI and import features: only legal-document viewing and settings remain available.

14. Jurisdiction and applicable law

This Disclaimer is governed by Italian law. For disputes, the provisions of the Terms of Service (legal/terms_of_service.md) apply.

15. Contacts

For clarification on this Disclaimer:

• Email: [email protected]

PluriFin cannot provide financial advice via email nor answer queries about specific financial instruments. For that, an authorized advisor is required (OCF Register: <https://www.organismocf.it>).