Legal Notice

Last updated: September 1, 2026
Effective: as of the publication date
Version: 1.0

This Legal Disclaimer is part of the Terms of Use and applies to everything we publish: site, app, newsletter, YouTube videos, Reels, social media posts and any other official channel of the project.

1. Who we are and what we are not

Rico aos Poucos is an independent financial education project, maintained by an individual, that studies public documents of the Brazilian market and publishes what it understood from them, in accessible language.

The person responsible for the project is not and does not present himself as:

• A securities analyst registered with the CVM (Brazil's securities and exchange commission) or accredited by APIMEC (Resolução CVM nº 20/2021);
• A securities consultant (Resolução CVM nº 19/2021);
• An investment advisor or tied agent (Resolução CVM nº 178/2023);
• A securities portfolio administrator or third-party asset manager (Resolução CVM nº 21/2021);
• A brokerage, bank, distributor, certified financial planner or accountant.

What we publish is personal opinion and educational material, protected by freedom of expression and of information (art. 5, IV and IX, and art. 220 of the Brazilian Federal Constitution), produced from public information and without any contractual relationship with the reader.

2. Nothing here is an investment recommendation

No content of Rico aos Poucos constitutes:

• A recommendation to buy, sell or hold any asset;
• A personalized indication — we don't know your objectives, your time frame, your income, your debts, your risk tolerance, your tax situation or your life;
• A public offering, solicitation of investment or promotional material for any financial product;
• A promise or guarantee of returns, of capital protection or of a future result;
• Legal, accounting or tax advice.

Words like "good", "cheap", "expensive", "attractive", "risky", "better" or "worse" express a value judgment about the information analyzed, within a context explained in the text itself — they are not instructions for you to act. Before investing, seek a licensed professional who can assess your specific case.

3. Scores, verdicts, fair price and "recommended portfolios"

The site publishes scores from 0 to 10, verdicts, fair price ranges and sets of funds that we call recommended portfolios. That name is a didactic convention. In practice:

• They are theoretical exercises, built by public and deterministic rules applied equally to every fund in the collection, with the aim of teaching selection criteria;
• They are not personalized. The same portfolio shows up for everyone, because no one here knows who you are;
• No one is a client. There is no contract, no suitability assessment, no follow-up, no liability for results;
• They reflect the data available on the date and change when the data changes. What held true in one month may not hold in the next;
• Fair price, ranges and trajectories are estimates derived from stated assumptions. Wrong assumption, wrong estimate — and assumptions about the future are frequently wrong;
• A high score is not an invitation to buy, and a low score is not an order to sell.

4. Projections and scenarios

Projections of dividends, price and net worth are simulations built on declared assumptions (interest rates, inflation, occupancy, default, payout). They describe possible scenarios, not the future. The market is influenced by factors that no model captures — political decisions, crises, regulatory changes, fraud, catastrophes.

Past performance is no guarantee of future performance. No return shown on the site is promised, contracted or assured.

5. The risks you take on when investing

Every investment involves risk, including the risk of losing all the capital invested. Among the main ones:

• Market risk: the asset's price fluctuates and can fall a lot, for a long time;
• Credit risk: whoever owes may not pay;
• Liquidity risk: there may be no buyer when you want to sell, or only at a bad price;
• Management risk: decisions by the manager or the administrator can destroy value;
• Concentration risk: a single property, debtor, tenant or sector can determine the outcome;
• Regulatory and tax risk: rules and exemptions change, sometimes with retroactive effect on your returns;
• Dividend risk: distributions are not guaranteed, may fall or be interrupted at any time;
• Currency and international risk, where applicable;
• Absence of guarantee: funds, stocks and most of the assets mentioned are not covered by the FGC (Brazil's deposit insurance fund) or by any other protection mechanism.

6. Data sources, delays and errors

We work with public information: B3, CVM, FNET, management reports and fund filings, the Central Bank of Brazil, IBGE, CEPEA, quote providers and the specialized press. About that:

• Quotes and indicators are displayed with a delay and are not suitable for real-time trading;
• Documents are read and interpreted by automated processes — which may extract a wrong number, attribute a document to the wrong fund or miss a data point;
• Third-party sources may be incorrect, incomplete or unavailable;
• Always confirm at the primary source any number that will weigh on your decision.

7. Content produced with AI support

A good part of the content is written, translated, narrated or illustrated with the support of artificial intelligence models, from public data and under our own checks. We say this plainly because that is how the project manages to cover hundreds of funds.

AI models make mistakes — sometimes with an air of certainty. Our filters reduce the error, they don't eliminate it. No text on the site replaces the official document.

8. Independence and conflicts of interest

• We do not receive payment from asset managers, fund administrators, brokerages or issuers to write about, praise, criticize or omit any asset;
• We are not compensated for fundraising, brokerage referrals or investment volume;
• The person responsible for the project is an individual investor and may hold a position, buy or sell any of the assets analyzed, including in the opposite direction of the tone of a published text;
• Any revenue of the project comes from advertising on video platforms, reader support and promotion of our own content — never from commission on your investment;
• If one day there is sponsored content, it will be identified as such, conspicuously, in the material itself.

9. We never ask for money — beware of scams

10. Content from other users

Comments, topics, messages and polls are the responsibility of whoever wrote them and do not represent the opinion of Rico aos Poucos. We do not endorse, do not verify and do not guarantee anything another user says — including when they present themselves as an expert.

11. Errors and corrections

We make mistakes. When that happens, we correct them and, if the error is relevant, we publish an erratum note in the content itself. Found an error in data, in a calculation or in interpretation? Use the "Contribua" button in the footer or write to galera.org@gmail.com. We look into it and reply.

12. Limitation of liability

To the maximum extent permitted by law, Rico aos Poucos and the person responsible for the project are not liable for losses, damages, lost profits, lost opportunity or any harm arising from decisions made on the basis of the published content, from errors or delays in third-party data, from technical failure or from another user's content. By using the service, you acknowledge that decisions about your money are exclusively yours.

This limitation does not set aside liability for willful misconduct or gross negligence, nor the non-waivable rights of the consumer. The complete limits are in item 16 of the Terms of Use.

13. Contact

Questions about this Disclaimer, requests for correction, complaints or notices: galera.org@gmail.com. We reply within a reasonable time and prefer to settle things by talking.