Terms and Conditions

Last updated: 8 September 2026

1. Acceptance of the Terms

These Terms and Conditions govern access to and use of the portal, website and digital services provided by Carlo International, hereinafter referred to as "Carlo International" or the "Platform".

By creating an account or using Platform features that require registration, the user declares that they have read and accepted these Terms and Conditions.

The user further declares that they have been made aware of the Privacy Policy applicable to the processing of their personal data.

The use of cookies or other non-essential technologies depends on the choices made by the user through the consent management mechanism provided on the Platform and does not follow from acceptance of these Terms and Conditions.

If the user does not agree with these Terms, they should refrain from creating an account or from using the Platform features that depend on them.

Certain features or services may be subject to additional commercial or specific terms, presented to the user before they are contracted or used. In the event of conflict, those specific terms prevail only as regards the matters they expressly govern, without altering the nature of Carlo International as the operator of a technology platform.

2. About Carlo International and the Nature of the Platform

Carlo International provides and operates a digital platform intended to create a technological environment in which buyers, investors, investor representatives, agencies, agents and other authorised professionals can make information available, identify potential opportunities and interact with one another.

Carlo International's role consists essentially of providing technological infrastructure and digital features for searching, organising and presenting information, communication, account management, matching between criteria and opportunities, document management, administrative processing and other services associated with the operation of the Platform.

Within the scope of the services governed by these Terms, Carlo International does not act on behalf of users in the negotiation or conclusion of property transactions.

In particular, Carlo International:

does not negotiate property prices on behalf of buyers, investors, owners, agencies or other users;
does not present, accept, reject or amend offers on behalf of any of the parties;
does not represent buyers, investors, sellers, owners, agencies or other users in the negotiation of a transaction;
does not decide whether an offer should be presented, accepted, rejected or amended;
does not enter into sale and purchase agreements, promissory contracts or other property transactions on behalf of users;
does not receive deposits, down payments, purchase prices or other sums intended for the completion of a property transaction;
does not determine the legal or commercial terms on which a transaction is to be carried out;
does not guarantee that an interaction started through the Platform will result in a negotiation or transaction;
does not act as buyer, seller, owner or counterparty in the transactions presented on the Platform.

The provision of tools that allow properties and opportunities to be searched, filtered, sorted, saved, compared or viewed does not mean that Carlo International represents any of the parties.

Likewise, the provision of technological mechanisms intended to put users in contact, to transmit requests or to match criteria with opportunities does not, in itself, mean that Carlo International takes part in any negotiation that may subsequently occur between those users.

The offers, counter-offers, checks, decisions, negotiations and contracts relating to any property or transaction are conducted directly between the interested parties and, where applicable, by the legally qualified professionals they choose to engage.

2.1. No Relationship of Representation or Mandate

Creating an account, viewing a property, submitting a request, defining investment criteria, using a restricted area or interacting through the Platform does not, in itself, create:

any mandate conferred on Carlo International;
any relationship of representation;
any agency relationship;
any real estate mediation contract between the user and Carlo International;
any partnership or joint venture;
any fiduciary relationship;
any obligation on Carlo International to negotiate or conclude a transaction on the user's behalf.

No user is authorised to make commitments, give guarantees or make statements on behalf of Carlo International without written authorisation to that effect.

Carlo International does not assume powers to bind any buyer, investor, investor representative, agency, agent, owner or other user.

Where the Platform uses the term "investor mandate" or an equivalent expression, that term identifies a feature through which the investor or their representative may record criteria, preferences and parameters for seeking opportunities.

That feature does not, in itself, constitute a legal mandate conferred on Carlo International, nor does it give Carlo International powers to negotiate, represent the investor or enter into transactions on their behalf.

3. User Accounts, Registration and Validation

The Platform provides different account types and functional profiles, with their own journeys, permissions and access conditions, including, as applicable:

Buyer or Private Client;
Investor;
Investor Representative;
Agency;
Estate Agent;
Legal Support;
Financing Support.

The Platform also has internal profiles for administration, accounting, security and compliance functions, which do not correspond to professional services offered to external users.

Access by invitation

Access to certain account types is restricted.

As at the date of these Terms, registration as an Investor, Investor Representative or Agency requires an invitation code issued or validated by Carlo International.

Buyer registration is open, without prejudice to the checks applicable to certain features.

The invitation code is personal to the purpose for which it was issued and must not be shared, transferred, sold or used by third parties without authorisation.

Validation

Creating an account does not necessarily grant immediate access to all features.

Depending on the type of user, different validation steps may be carried out and information may be requested in order to verify, in particular:

identity;
contact information;
professional capacity or standing;
licences or qualifications;
powers of representation;
validity of documents;
information necessary for security, risk or compliance procedures;
other elements legally required or reasonably necessary for the provision of the service.

Carlo International may refuse, restrict or hold a registration pending until the conditions necessary for its activation are met.

Wherever possible and appropriate, the user will be informed of the reason for the pending status or rejection, and may be allowed to correct or resubmit the missing elements.

Investors

Investors' access to their restricted areas is subject to the applicable validation steps, including the prior conclusion of the Confidentiality Agreement where required.

Investor Representatives

The Investor Representative must demonstrate that they hold sufficient powers to act in that capacity.

Carlo International may request documentation evidencing those powers and their validity, and may restrict or suspend representation features where the documents expire, are revoked or cease to evidence sufficient powers.

Agencies

The activation of an Agency account intended for carrying on real estate mediation activity in Portugal depends on the submission of proof of the applicable AMI licence and its validation by Carlo International.

The agency is responsible for keeping its authorisation valid and for notifying any suspension, expiry, cancellation or other relevant change.

User obligations

The user undertakes to:

provide true, complete and up-to-date information;
keep their registration details up to date;
keep valid the documents necessary for the use of their account;
protect the confidentiality of their credentials;
not allow unauthorised use of their account;
not share invitation codes outside the authorised conditions;
notify Carlo International of any suspected unauthorised access or use.

The user is responsible for the activity carried out through their account to the extent that such activity is legally attributable to them.

4. Confidentiality Agreement

Access by Investors and Investor Representatives to non-public or restricted-circulation opportunities depends on the prior conclusion of the applicable Confidentiality Agreement.

The document is made available through the Platform and must be signed or accepted through the procedure provided there.

The conclusion and validation of the Confidentiality Agreement are recorded by the Platform.

Until the required Confidentiality Agreement has been duly concluded and validated, access to information subject to confidentiality remains restricted.

The Agreement may cover, in particular:

unpublished opportunities;
restricted-circulation information;
documentation made available in restricted areas;
non-public financial or commercial information;
other elements expressly identified as confidential.

The confidentiality obligations remain in force for the period and on the terms set out in the relevant Agreement.

5. Information, Properties and Opportunities

The Platform allows agencies, agents and other duly authorised users to make available information relating to properties or opportunities.

Depending on the feature used, that information may include:

advertised price;
location;
areas;
layout;
number of bedrooms and bathrooms;
garage;
state of repair;
intended use;
photographs;
energy certificate;
description;
availability;
indicative financial or economic information;
other elements provided by the relevant user.

The entity or professional making the information available is responsible for ensuring that:

they are entitled to make it available;
they hold the necessary authorisations;
the information is true and not misleading;
the relevant elements are kept sufficiently up to date;
the content used does not infringe third-party rights;
the applicable legal and professional obligations are complied with.

Carlo International may adopt reasonable validation, security, moderation and quality control measures.

Those measures do not mean that Carlo International carries out a complete legal, technical, planning, land registry, tax, financial or commercial audit of each property or opportunity.

Except where a particular element is expressly identified as verified by Carlo International itself, Carlo International does not guarantee that information provided by third parties is, at any given time:

entirely correct;
complete;
up to date;
free from errors or omissions;
permanently available.

The presentation of a property or opportunity on the Platform does not constitute a binding contractual offer by Carlo International and does not guarantee its availability.

Before entering into any transaction, the interested party should carry out, directly or through duly qualified professionals, the legal, land registry, planning, technical, tax, financial and commercial checks they consider appropriate.

Properties made available through the Platform's commercial mechanisms are subject to the applicable eligibility conditions. As at the date of these Terms, the applicable minimum advertised value is 500,000 euros per property, unless otherwise expressly set out in the commercial terms presented before use of the service.

6. Acquisition and Investment Decisions and Matching of Opportunities

The information, tools, filters, indicators, comparisons, matches and other content made available through the Platform are intended to facilitate the consultation, organisation and understanding of the information available.

These elements do not constitute personalised legal, tax, financial or investment advice provided by Carlo International.

Carlo International does not decide on the user's behalf whether they should acquire, sell, finance, hold or carry out any operation in relation to a given property.

No information made available through the Platform constitutes a guarantee of:

future appreciation;
income;
profitability;
liquidity;
financing approval;
obtaining a visa or residence permit;
obtaining a tax benefit;
the conclusion of a transaction;
any particular legal, tax, financial or commercial outcome.

References to "investor", "investment" or "investment opportunity" used on the Platform in relation to properties refer, unless expressly stated otherwise, to the acquisition, holding, development or operation of real estate assets and do not, in themselves, constitute a recommendation relating to financial instruments.

Matching with investment criteria

The Platform may automatically compare the criteria defined by an Investor or Investor Representative with the elements recorded in the available opportunities and present potentially relevant matches.

The existence of a match does not constitute a recommendation, a suitability assessment, a guarantee of interest, a guarantee of profitability or an indication that the user should carry out the transaction.

The decision to review, contact, negotiate or carry out a given transaction belongs exclusively to the user concerned.

7. Agencies and Estate Agents

Agencies and agents who use the Platform to make properties available, respond to requests or carry on their activity are responsible for complying with the legal and professional obligations applicable to them.

An entity carrying on real estate mediation activity in Portugal must hold the AMI licence required by law.

Agents, collaborators or other associated professionals must act, where legally required, within the scope of a duly qualified entity.

Agencies and agents are responsible for ensuring that:

they are entitled to promote the properties made available;
the information published is true and sufficiently up to date;
they hold the necessary authorisations to use photographs, floor plans, descriptions and other content;
they comply with the applicable professional and legal rules;
they use data and contacts obtained through the Platform only for legitimate and authorised purposes;
they respect the confidentiality of restricted-circulation opportunities;
they conduct directly the negotiations for which they are responsible;
they keep their professional details and licensing documentation up to date.

Carlo International may verify professional documentation and suspend access where the necessary documentation is missing, expired or invalid, or where there are reasonable doubts as to its authenticity or sufficiency.

The validation of an account does not constitute an absolute guarantee, permanent certification or recommendation of the solvency, competence, integrity or conduct of the professional concerned.

8. Subscriptions, Plans, Credits and Payments

Certain Platform features are subject to a subscription, the use of credits or another payment presented to the user in advance.

Plans

The Platform provides, for Agencies, Investors and Investor Representatives, different subscription tiers, including:

Free;
Basic;
Professional;
Premium.

Each plan may set specific limits as to:

number of properties;
number of agents or users;
access to features;
use of restricted areas;
digital services included;
duration;
other limits presented before contracting.

The prices, limits, duration, renewal terms and other characteristics applicable to each plan are set out in the applicable commercial terms before it is contracted.

Certain plans allow properties to be marked as featured. Properties marked as featured are presented first in the Platform's listings and search results, ahead of the others, which are then ordered by publication date. The availability of this feature depends on the plan contracted, so subscribing to a higher plan may influence the position in which a professional user's properties are presented.

Carlo International may change plan prices or characteristics for future contracts or renewals, respecting the applicable contractual and legal rights.

Payments

The prices, frequency, taxes, invoicing and other commercial terms are presented to the user before they complete payment.

Payments may be processed by independent payment service providers.

Carlo International does not receive, through these payments, any deposit, down payment or price relating to the acquisition of a property.

Payments made to Carlo International are intended exclusively for the digital services it provides.

In the event of non-payment, cancellation or expiry of the subscription, Carlo International may suspend or restrict the features that depend on the relevant plan.

Wherever automatic renewal applies, its terms will be presented before contracting.

Consumer users

Where a user acts, in legal terms, as a consumer and enters into a contract with Carlo International to which mandatory consumer protection rights apply, those rights are not prejudiced by these Terms.

Where a right of withdrawal is legally applicable, information on its period, manner of exercise and consequences will be provided before contracting.

Where the consumer requests that provision of a service begin during the statutory withdrawal period, the declarations or consents required by applicable legislation will be collected.

9. Requests, Classification of Opportunities and Access Price

The Platform allows buyers to submit requests relating to properties, including requests for information, contact or viewings.

Where a request is associated with a property made available through the Platform, it may be handled through the digital mechanisms applicable to that property and to eligible professional users.

Carlo International provides the technological infrastructure through which the request is processed and transmitted, and does not take part in any property negotiation that may subsequently occur.

9.1. Automatic classification of requests

For the purposes of organising, prioritising and operating the Platform's routing mechanisms, certain buyer requests are classified automatically on the basis of the information provided by the buyer themselves.

The classification takes seven criteria into account:

the timeframe envisaged for the purchase;
whether the budget indicated covers the advertised value of the property;
the financing situation or need;
a request for a viewing;
the buyer's presence in Portugal;
the provision of a telephone number;
an indication as to whether the buyer is handling the request exclusively through the Platform.

The combination of these criteria produces a score between 0 and 100 and the corresponding classification of the request in one of the following levels:

Contact;
Lead;
Qualified lead;
Hot lead.

The classification is intended for the operation of the Platform and does not constitute an assessment of creditworthiness, financial capacity, integrity, investment quality, nor a guarantee that the buyer will carry out a transaction.

A request classified as Contact is not made available through the paid access commercial mechanisms and is not placed in the global panel of paid opportunities.

Further information about this classification, including information on the associated automated processing of personal data, is available in the Privacy Policy.

9.2. Paid access to opportunities

Certain opportunities classified as Lead, Qualified lead or Hot lead may be subject to an access price payable by the Agency.

This payment remunerates exclusively Carlo International's own digital services, including, as applicable:

provision and operation of the Platform;
processing and organisation of the request;
classification and categorisation of the opportunity;
matching with eligible professional users;
technological assignment of the opportunity;
access to the data and features associated with the request on the authorised terms.

The payment does not constitute the purchase or sale of personal data.

Access to personal data is limited to the authorised purposes and to the conditions set out in the Privacy Policy and in applicable legislation.

9.3. Calculation of the access price

The access price is calculated from the advertised value of the property and the level assigned to the request, using the following formula:

advertised value of the property × 0.0001 × level multiplier

The multipliers are:

Lead: 0.5;
Qualified lead: 1;
Hot lead: 2.

The result is subject to a minimum price of 10 euros and a maximum price of 400 euros per access.

Where the Platform uses credits as an internal means of payment, the number or value of credits required for access will correspond to the applicable price under the commercial terms in force.

The access price:

is consideration for digital services and for access to the opportunity;
does not constitute a real estate mediation commission;
is payable irrespective of any subsequent commercial outcome;
does not depend on the conclusion of a promissory contract, deed or other property transaction;
does not depend on the final price that may be agreed between buyer and seller;
does not correspond to a percentage of the price actually agreed in the transaction;
does not guarantee that the buyer will reply;
does not guarantee that a negotiation will begin;
does not guarantee the conclusion of any transaction.

9.4. Alternative routing and global panel

Where the agency associated with the property does not follow up the request, the opportunity may only be routed to other agencies through the global panel if the buyer has consented to that routing.

Without that consent, the opportunity will not be made available to other agencies through this mechanism.

Where the conditions for routing are met:

only limited or not directly identifying information may initially be presented;
the opportunity may be made available for the equivalent of 40% of the access price originally calculated;
if it is classified as Hot lead, it may remain available for 72 hours;
at the other eligible levels, it may remain available for 168 hours;
the opportunity ceases to be available once it is validly taken on by an agency or once the relevant period ends.

The first eligible Agency to validly complete the taking on of the opportunity through the Platform's mechanism obtains its exclusive assignment.

The system uses technical mechanisms designed to prevent the same opportunity from being assigned simultaneously to more than one agency.

After assignment, the negotiation and any resulting transaction take place directly between the interested parties and professionals, without Carlo International taking part in the negotiation.

9.5. Use of the data received

An Agency or professional receiving contact details through an opportunity may use them only:

to follow up the request made by the user;
for communications reasonably related to that request;
for other purposes that have an independent legal basis and are compatible with applicable legislation.

Obtaining access to an opportunity does not confer any right to unrestricted use, resale, transfer or exploitation of the associated personal data.

10. User Conduct

The user undertakes to use the Platform lawfully, responsibly and in a manner compatible with its purpose.

It is prohibited, in particular, to:

provide false, fraudulent or materially misleading information;
impersonate another person or entity;
use forged or invalid documents;
publish unlawful, fraudulent, abusive or defamatory content;
infringe intellectual property, privacy, data protection or other third-party rights;
use personal data or contacts obtained through the Platform for unauthorised purposes;
send unsolicited commercial communications in breach of applicable legislation;
disclose confidential or restricted-circulation information outside the authorised conditions;
carry out automated data collection, scraping or bulk extraction without authorisation;
circumvent security, access control, subscription or payment mechanisms;
attempt to access accounts, systems or restricted areas without authorisation;
interfere with the operation of the Platform;
introduce viruses, malicious code or other elements liable to compromise security;
use the Platform for fraud, money laundering, financing of unlawful activities or other acts contrary to law;
use the Platform to harass, threaten or harm third parties.

11. Communications, Deal Rooms and Negotiations between Users

The Platform may provide features intended to facilitate communication and the controlled sharing of information between users, including messages and restricted document areas or deal rooms.

Communications between users are the responsibility of the parties involved.

Where a communication develops into a negotiation, that negotiation takes place directly between the parties and, where applicable, through the professionals they engage.

Carlo International does not take part in that negotiation, does not represent any of the parties and does not assume powers to accept or reject offers on their behalf.

Carlo International does not:

set the final price of a transaction;
propose amounts on behalf of the parties;
accept or reject offers;
convey counter-offers as a representative;
decide whether a party should accept or reject a given condition;
agree payment terms between the parties;
set completion dates on behalf of the parties;
receive deposits or down payments relating to the property;
enter into property contracts on behalf of the parties.

Deal rooms

Deal rooms are technological features for organising, providing, communicating and sharing documents between authorised users.

Making a document available in a deal room:

does not mean that Carlo International has legally validated the document;
does not constitute certification of its authenticity;
does not replace appropriate legal, technical, tax or financial due diligence;
does not turn Carlo International into a depositary, agent or representative of the parties.

Any offers, statements, commitments or agreements established between users take effect exclusively between the parties involved, without prejudice to Carlo International's own responsibilities in relation to the operation of its digital services.

12. Intellectual Property

Unless otherwise stated, the Platform's own elements, including visual identity, structure, design, institutional texts, software, proprietary databases, trade marks, logos and original content, belong to Carlo International or are used with the authorisation of their respective owners.

Access to the Platform does not confer on the user any intellectual property right over those elements.

The reproduction, distribution, modification, commercial exploitation or unauthorised use of protected content is not permitted, except in the cases allowed by law or with prior written authorisation.

The rights relating to photographs, descriptions, floor plans, trade marks and other materials provided by users remain with their respective owners.

By making content available on the Platform, the user declares that they hold the necessary rights and authorisations and grants Carlo International, for the period during which that content is to be presented or processed through the service, a non-exclusive authorisation limited to what is necessary to host, technically reproduce, present, format and make available that content within the operation of the Platform.

This authorisation does not transfer ownership of the user's content to Carlo International.

13. Third-Party Services, Professionals and Content

The Platform may include links to, integrations with or references to websites, systems, payment providers, professionals or other third-party services.

Those third parties are responsible for their own services, policies, content, security and contractual terms.

Use of their services may be subject to the terms, conditions and policies set by the providers themselves.

External professionals

The Platform may provide features through which the user may request contact with or support from lawyers, legal professionals, professionals or entities relating to financing, or other independent providers.

Carlo International's role in these situations is limited to the technological and administrative features that are legally permissible, intended to facilitate the expression of interest, the administrative organisation of the request or contact between the user and the independent professional.

Carlo International does not provide directly, through the mere use of the Platform:

legal services reserved to legally qualified professionals;
legal representation;
individualised legal advice;
accounting services reserved to legally qualified professionals;
credit intermediation;
the presentation or offering of credit agreements;
personalised recommendation of credit agreements;
regulated financial advice.

The use of a contact or support feature does not, in itself, create a lawyer-client relationship, a credit intermediation contract, an accounting relationship or any other professional mandate between the user and Carlo International.

Where an independent professional agrees to provide a service, the professional relationship is established directly between the user and that professional or entity.

The scope of the service, fees, professional duties, liability and other contracting terms will be determined directly between those parties.

In the area of financing, the Platform's features must not be used to allow Carlo International to carry on activities legally reserved to credit intermediaries, nor to allow a credit intermediary to delegate to Carlo International, in whole or in part, the carrying on of that activity.

Carlo International is not liable for the professional acts or omissions of independent providers that are not legally attributable to it, without prejudice to Carlo International's liability for the operation of its own digital services.

The existence of a link, integration, contact feature or reference to a third party does not, in itself, constitute a guarantee or recommendation by Carlo International in relation to that third party.

14. Availability, Security and Technical Changes to the Platform

Carlo International will adopt reasonable measures to ensure the operation, maintenance and security of the Platform.

It is not, however, guaranteed that the service will be permanently available, entirely free from errors or immune to technical or security incidents.

Temporary interruptions or limitations may occur for reasons such as:

maintenance;
technical updates;
security fixes;
failures of external suppliers;
telecommunications problems;
cybersecurity incidents;
force majeure;
events beyond Carlo International's reasonable control.

Wherever reasonably possible, measures will be adopted to reduce the impact of such situations.

Carlo International may modify, replace or discontinue features where there is a reasonable technical, operational, security, commercial or legal reason, respecting the rights applicable to users and contracts in force.

15. Liability

Carlo International is liable for the obligations legally or contractually attributable to it as operator of the Platform.

Carlo International is not a party to the property contracts entered into directly between buyers, investors, owners, agencies or other users.

To the extent permitted by applicable law, Carlo International is not liable for damage resulting exclusively from:

incorrect, incomplete or out-of-date information provided by third parties;
the withdrawal or amendment of a property by the person responsible for it;
negotiations conducted directly between users;
failure to perform obligations assumed directly between users;
independent professional acts of agencies, agents, lawyers, professionals relating to financing, accountants or other providers;
acquisition, investment, financing or contracting decisions taken by the user;
the absence of a reply from another user;
the absence of a commercial outcome associated with a given opportunity;
temporary unavailability caused by circumstances beyond Carlo International's reasonable control;
use of the Platform in breach of these Terms.

The classification of requests, the matching of criteria with opportunities and other automatic features do not constitute a guarantee of suitability, creditworthiness, successful negotiation or the conclusion of a transaction.

Nothing in these Terms excludes or limits:

liability that cannot lawfully be excluded;
liability arising from obligations expressly assumed by Carlo International;
mandatory consumer rights;
other liabilities whose exclusion or limitation is prohibited by law.

16. Personal Data Protection

The processing of personal data carried out in the context of the Platform is subject to applicable data protection legislation, including the General Data Protection Regulation.

The conditions relating to collection, use, sharing, retention, security and the exercise of data subject rights are described in Carlo International's Privacy Policy.

The Privacy Policy includes, in particular, information relating to:

the automatic classification of buyers' requests;
the seven criteria used in that classification;
the use of the score to organise and route requests;
the sharing of contact details with professional users;
the consent mechanisms applicable to alternative routing;
security, activity and compliance records;
the applicable retention periods.

Carlo International keeps certain records of the relevant operations and decisions carried out on the Platform for the periods necessary for their purposes and for the applicable legal obligations.

Obtaining access to data through the Platform does not confer on the recipient the right to use it for purposes incompatible with those that justified its being made available.

17. Moderation, Reports, Suspension and Account Closure

Carlo International may apply moderation measures intended to protect the lawfulness, security, trust and proper operation of the Platform.

Those measures may include:

human review of content or conduct;
automated checks intended to identify risk or non-compliance situations;
requests for information or documentation;
removal or restriction of content;
warnings;
temporary restriction of features;
account suspension;
account closure.

Reports

The Platform provides a mechanism through which facts considered contrary to these Terms or to applicable legislation may be reported, including:

false information;
fraud;
abusive conduct;
misuse of data;
improper disclosure of confidential information;
potentially unlawful content.

Submitting a report does not, in itself, produce any automatic restriction on the person or entity concerned. Reports will be reviewed proportionately to the circumstances and clarifications or additional evidence may be requested.

The Platform provides separate communication channels for the person submitting the report and for the person or entity concerned. The identity of the person submitting a report is not disclosed to the person concerned, except where this is necessary or legally required.

Wherever compatible with the nature of the situation, the safety of users and the applicable legal obligations, the person or entity concerned will have a reasonable opportunity to provide explanations or evidence before an adverse final decision is taken.

That hearing may be limited or deferred where:

an urgent protective measure is necessary;
there is a serious risk to security;
notification could compromise an investigation;
there is a risk of destruction or manipulation of evidence;
Carlo International is legally prevented from disclosing certain information.

Suspension, restriction or closure

Carlo International may restrict, suspend or close an account where there are reasonable grounds, in particular where:

these Terms are breached;
there is fraudulent or unlawful use;
the security of the Platform or of third parties is at risk;
there is a failure to meet payment obligations;
necessary documentation has not been provided;
documentation has expired or has ceased to evidence the necessary qualification;
valid powers of representation have ceased to exist;
there is repeated failure to comply with obligations;
it is necessary in order to comply with a legal obligation or an order of a competent authority.

Wherever the circumstances and applicable legislation permit, the user will be informed of the measure and of the essential reasons on which it is based.

The user may provide explanations or contest the measure through the contact channels indicated in section 22.

Where a specific notice period or duty to give reasons is legally applicable in relation to professional users, Carlo International will comply with that regime. In particular, where Regulation (EU) 2019/1150 applies, the restriction, suspension or termination of the service will be notified and reasoned as required by that regime, without prejudice to its legal exceptions.

Users may request the closure of their account through the channels provided by the Platform, without prejudice to the retention of information where necessary to comply with a legal obligation, exercise rights, ensure security, prevent fraud or for other legitimate purposes described in the Privacy Policy.

18. Changes to the Terms and Conditions

Carlo International may update these Terms and Conditions where necessary, in particular as a result of changes:

legal or regulatory;
technical;
operational;
security-related;
commercial;
relating to new features or services.

The version in force and its update date will be permanently available on the Platform.

Changes will not have retroactive effect on situations already concluded, except where this results from law or is expressly agreed on legally permissible terms.

Where a change is materially relevant, Carlo International will adopt reasonable means to inform the affected users.

In relation to professional users covered by the legal regime applicable to online intermediation services, proposed changes will be notified on a durable medium with the legally applicable notice. Where the minimum period provided for in Regulation (EU) 2019/1150 applies, that period will be at least 15 days, and may be longer where the nature of the change requires significant technical or commercial adaptations by the professional user.

The legally provided exceptions may apply, in particular where an immediate change is necessary to comply with a legal obligation or to respond to an unforeseen and imminent risk relating to fraud, malware, data breaches or other cybersecurity risks.

The professional user may exercise the termination rights conferred on them by applicable legislation as a result of those changes.

For other users, the entry into force of changes will respect any mandatory rights that may apply, including consumer rights.

19. Partial Invalidity

If any provision of these Terms and Conditions is held to be invalid, unlawful or unenforceable, that circumstance does not, in itself, render the remaining provisions invalid.

The remaining clauses remain in force to the fullest extent permitted by applicable law.

Wherever possible, the affected provision will be interpreted or replaced so as to approximate legitimately its original purpose without breaching applicable legislation.

20. Governing Law, Consumers and Dispute Resolution

These Terms and Conditions are governed by Portuguese law.

The choice of Portuguese law is without prejudice to the mandatory rights that may be conferred on a consumer by the legislation applicable to them under the rules of private international law.

Jurisdiction for the resolution of disputes will be determined in accordance with applicable legislation, including the mandatory consumer protection rules.

Alternative consumer dispute resolution

Where Carlo International enters into a contract with a user having the legal status of a consumer, that user may have recourse to the competent alternative consumer dispute resolution body, in accordance with applicable legislation.

The competent body will be determined in accordance with the legal and territorial rules applicable to the specific case.

Carlo International will provide the consumer, by the legally required means, with the identification of the applicable alternative dispute resolution body or bodies and their websites.

The up-to-date list of alternative dispute resolution bodies recognised in Portugal is made available by the competent authorities.

The use of alternative dispute resolution mechanisms is without prejudice to the right of access to the courts under applicable legislation.

21. Language Versions

These Terms and Conditions are made available in:

Portuguese;
English;
German;
French;
Italian;
Spanish.

Carlo International will seek to ensure the material equivalence of the different language versions.

In the event of divergence, doubt or contradiction between translations, the Portuguese version will serve as the interpretative reference, without prejudice to the mandatory rights conferred on the user by applicable legislation, in particular on the consumer, in relation to the language in which the contractual information was provided to them.

22. Contact and Identification

For questions relating to these Terms and Conditions, to the use of the Platform, to a measure adopted in relation to an account or to the exercise of rights, the user may contact:

Carlo International
Email: info@carlointernational.pt

The official contact page available on the Platform may also be used.

The full legal identification of the entity, including company name, legal person identification number, registered office and commercial registry details, is available on the Platform's legal information page.