Welcome to the website of Galloway Capital Gestora de Recursos Ltda. (“Galloway”).

By accessing or using www.galloway.com.br, you agree to these Terms of Use. If you do not agree with any provision of these Terms, please do not use the website.

1. About the Website

The Galloway website is institutional and informational in nature and provides information about Galloway Capital, its team, investment strategies, funds, documents, publications and contact channels.

The content available on the website is provided for informational purposes only and does not, by itself, constitute an offer, recommendation, solicitation or individualized investment advice.

2. Investment Information

Information, materials, presentations, fact sheets, letters, reports, documents and other content available on the website should not be considered the sole basis for any investment decision.

Investments involve risks, including the possibility of partial or total loss of invested capital.

Past performance is not indicative of future results.

Before making any investment decision, investors should carefully assess the characteristics, risks, costs, liquidity and other conditions applicable to the relevant product, taking into consideration their investment objectives and risk profile, and should review the applicable official and regulatory documentation.

3. Fund Documents

Materials made available through the areas designated for Brazilian and international investors may include prospectuses, regulations, legal documents, financial statements, fact sheets, investor letters and other information related to investment funds.

These documents contain their own terms, limitations, disclosures and regulatory information and should be reviewed together with the applicable official materials.

In the event of any discrepancy between summarized information presented on the website and official fund documentation, the applicable official documentation and regulations shall prevail.

4. Brazilian and International Investors

The website provides separate areas for Brazilian and international investors.

Access to specific content or documents does not mean that any product or fund is available, suitable or may be offered to every person in every jurisdiction.

The availability of products and services is subject to applicable laws, regulations, eligibility requirements and restrictions in the investor’s relevant jurisdiction.

5. No Individualized Advice

Information provided on the website does not constitute individualized legal, tax, accounting or financial advice.

No content on the website should be interpreted as a personalized recommendation to purchase, sell or hold any financial asset or investment product.

Investors should seek independent professional advice when appropriate.

6. Accuracy of Information

Galloway seeks to keep the information available on the website accurate and up to date.

However, information may change as a result of market conditions, regulatory developments, changes to funds or updates to official documentation.

Accordingly, Galloway does not guarantee that all website content will always be complete, current or free from errors or omissions.

7. Intellectual Property

All content available on the website, including text, trademarks, logos, images, graphics, presentations, documents, visual elements, layout, code and other materials, is owned by Galloway or lawfully used by Galloway, as applicable.

Reproduction, distribution, publication, modification or commercial use of website content without prior authorization is prohibited, except where expressly permitted by applicable law.

Access to materials available on the website does not transfer any intellectual property rights to the user.

8. Acceptable Use

Users agree to use the website lawfully and in accordance with these Terms of Use and applicable laws.

Users may not, among other things:

• use the website for unlawful purposes;
• attempt to gain unauthorized access to systems or restricted areas;
• interfere with the operation of the website;
• introduce code, files or mechanisms that may compromise its security;
• use website information for fraudulent or unlawful activities;
• reproduce or commercially exploit protected content without authorization.

9. Third-Party Links and Websites

The website may contain links to third-party websites, platforms or services.

Such links are provided for convenience and do not necessarily constitute an endorsement, recommendation or assumption of responsibility by Galloway for the content, products, services, policies or practices of such third parties.

Users are responsible for reviewing the terms and policies applicable to third-party websites they access.

10. Website Availability

Galloway may modify, suspend or discontinue, temporarily or permanently, website functionalities or content, including for maintenance, updates, security or regulatory compliance purposes.

Galloway does not guarantee that the website will be continuously available or free from interruptions, failures or downtime.

11. Limitation of Liability

To the extent permitted by applicable law, Galloway shall not be liable for losses or damages arising solely from the use of information made available on the website, particularly where a user makes investment decisions without conducting their own analysis or reviewing the applicable official documentation.

Nothing in these Terms is intended to exclude or limit any liability that cannot legally be excluded or limited under applicable law.

12. Changes to These Terms

Galloway may update these Terms of Use periodically.

The current version will be available on the website and identified by its applicable update date.

Continued use of the website after changes have been published constitutes acknowledgment of the updated Terms.

13. Applicable Law

These Terms of Use shall be interpreted in accordance with Brazilian law, without prejudice to mandatory provisions that may apply to users in their respective jurisdictions.

Issues relating to investment products will also be subject to applicable regulations and the relevant official documentation.

14. Contact

For questions regarding the website or these Terms of Use, please contact:

Galloway Capital Gestora de Recursos Ltda.
CNPJ: 12.489.853/0001-18
Rua Joaquim Floriano, 960
Itaim Bibi, São Paulo – SP
04534-004, Brazil
Email: sales@galloway.com.br
Phone: +55 11 97771-7046