Version 20241217

Introduction

The Terms of Use described below apply to all transactions and activities engaged by the users of vaultoro.com and with its subsidiaries and to all data gathered by Vaultoro and the support system (3rd party).

Acceptance of the terms of use

By using the Vaultoro website ("site, "us", "we", "our", "trading system", the trading engine"), signing up and creating a Vaultoro Account ("Account"), or using any other NATIONAL VAULTING SERVICES LTD service, you ("yourself", "you", "your") are accepting and agreeing on the terms and conditions of use outlined and documented below ("Terms of Use", "terms and conditions"). You must read the whole terms of use in its entirety carefully and fully understand it before you use this site, any of the subdomains or services run or owned by NATIONAL VAULTING SERVICES LTD.

The word "Vaultoro" as used in this Terms of Use document refers to the company platform vaultoro.com owned by NATIONAL VAULTING SERVICES LTD, its subsidiaries, including and without limitation, its employees, Directors, Investors, or directly related parties substantially important for the business activity and 3rd parties.

The Service that Vaultoro offers allows buyers ("buyers") and sellers ("sellers"), to buy and sell cryptocurrencies, tokens and physically vaulted precious metals through its portal.

Contextually speaking "Vaultoro" may also refer to the website, content, services, products or other materials and media (collectively, "Vaultoro Services") provided by Vaultoro.

Some functions of the site might be restricted depending on the country in which you reside or your legal status within or outside of your jurisdiction. The responsibility resides on you to follow the rules, laws and regulations of the country in which you reside and/or the country in which you access Vaultoro and its services.

By agreeing to and complying with these Terms of Use, Vaultoro grants to you a personal, non-sublicensable, non-exclusive, non-transferable and limited right to become a member, enter and use the site and the services it offers. We may, at any time, and at our sole discretion, modify these Terms and Conditions of Use, including our Privacy Policy, with or without reasonable (in time) notice to the user. Any such modification will be effective immediately upon public posting. Your continued use of our Service and this site following any such change constitutes your acceptance of these modified Terms.

The purpose of our business relationship

You must become a Vaultoro member to benefit from Vaultoro's Terms of Use for trading in cryptocurrencies, tokens and precious metals, and storing precious metals. Vaultoro members expect to enjoy a transparent, efficient trading experience while paying low commission rates and low charges in comparison to alternative services for trading cryptocurrencies and tokens or holding precious metals. For Vaultoro to deliver these expectations Vaultoro's platform, engine, payment input and output, graphing engine are all highly automated across the internet to keep costs as low as possible.

Data about you - Privacy Policy

For Vaultoro to provide its services to you, Vaultoro needs to retain certain information about its members.

Please find all information in our Privacy Policy.

Passwords

Vaultoro makes all efforts to store your passwords encrypted with industry standards to protect your personal and financial data from unauthorised access. You must keep your passwords and access credentials secret.

Vaultoro or its staff will never ask you for your password.

To provide reliable customer access to accounts, Vaultoro employs a procedure for re-issuing forgotten passwords. By accepting these Terms of Use, you accept the form of the password reset procedure.

Data Transmission

All data which passes between you and Vaultoro servers during a logged-in session, in both directions, are transmitted across the internet using the SSL protocol, which is an industry-standard. SSL is widely accepted as an extremely reliable way to transfer data while maintaining privacy and accuracy between 2 parties. Vaultoro is not responsible for any existing or future bugs or exploits that could be used for frauds within the SSL software.

Communication

To communicate with Vaultoro, you may use the following channels.

Visit https://vaultoro.com/support

Email: [email protected]

Email

By registering with Vaultoro you accept and agree to receive occasional emails to the email address associated with your user account. These emails include information about but are not limited to statements, confirmations of changes to your account settings, login notifications, order confirmations, security advice, monthly statements, critical news about and changes to terms and conditions. These emails will be written in an easy to comprehend, open format feedback to the email address you have on record. By accepting these Terms of Use, you agree that you cannot unsubscribe from emails that relate to the administration of your account and or emergency emails. You do, however, have the option to unsubscribe from general updates. To do this simply follow the instructions at the end of these types of emails.

You agree that the email address you have on file is appropriate for receiving reports on your completed business with Vaultoro, offline and after the fact.

Once an email is sent from Vaultoro servers, it is your responsibility to make sure you have a working and reliable email service provider that delivers the email to you in a timely manner.

Emails sent from Vaultoro are not encrypted and like any regular email is susceptible to a man in the middle attack by, for example, but not limited to, network engineers at your ISP or government agencies.

Vaultoro will never ask for your password via email. If you receive an email from Vaultoro asking you to log in, we always recommend logging in by typing https://vaultoro.com into a browser and not by clicking links in emails. This is because fraudulent emails can look as though they come from Vaultoro and link to a site that looks exactly like our homepage, hoping for you to log in. We also always recommend activating 2-factor authentication.

You agree that Vaultoro is able to reply to your receipt and acceptance of emails and its content. If we receive no response from you within three calendar days of the emails' transmission, then we will assume that you have received the communication. You agree that if we receive communication about an issue with the content of a Vaultoro email more than three calendar days after transmission, that any resolution will be considered within the context of the delay of communication and may influence the outcome of the resolution.

Mail (post)

You agree to give Vaultoro the right to contact you via traditional Mail ("post", "snail mail") delivered to the address you have entered into your Vaultoro account. If we receive no response from you within ten calendar days of the mail being sent, then we will assume that you have received the communication. You agree that if we receive a communication about an issue with the content of a Vaultoro mail more than ten calendar days after postage, that any resolution will be considered within the context of the delay of communication and may influence the outcome of the resolution.

Contact details

As a Vaultoro member, you agree to have an email on file that works and that you check regularly. You may also enter

• a mobile telephone number

• a landline telephone number

• a home or work address

It is your responsibility to keep your contact details, held by Vaultoro, up to date and accurate, which you can easily do via the account settings page once you log into vaultoro.com

You acknowledge that Vaultoro is entitled to rely on the accuracy of any contact details you have entered.

By accepting these Terms of Use you accept that your failure to maintain correct and up to date contact details may invalidate some of the protections Vaultoro offers. You hereby agree that Vaultoro will not be held responsible in any way for losses which arise out of your failure to maintain your correct contact details.

Retention of account information

Vaultoro will hold your personal account information only as long as it is necessary to protect the user and/or Vaultoro from damages. In accordance with our record-keeping obligations, we will keep accounts and personal information for at least a period of five years after a member's account is closed. We may be requested by the relevant authorities to hold your details for longer periods, if such request is received, we will ensure that personal details are stored and used only for legitimate purposes according to the relevant regulations.

Risks for the User

Trading carries a high degree of risk and may not be suitable for all investors. Before you decide to trade, you should always consider proper education and risk analysis. By trading, the possibility exists of both substantial losses and gains of your investments. You might lose some or all of initial deposit and investments, and therefore, you should not day trade cryptocurrencies, tokens or precious metals that you cannot afford to lose.

There are also risks of online deal execution due to any number of factors. Some examples include, but not limited to, server lag, internet lag, server downtime, software glitches, user browser crashes, software or hardware failure and internet disconnection. Vaultoro is not responsible for any losses or failures.

In case of any fault in the Vaultoro pricing calculations and process, typing errors and quoting errors, Vaultoro has full right to make any necessary modifications to the member's account in which mistakes took place.

Vaultoro shall not be held responsible for any losses that arise from trading decisions based on any forecast, recommendation or other information provided by Vaultoro on the site, social media, blogs or any other information aggregation service.

Any conflicts regarding pricing will be solved by checking the actual prices in the market history at the specific time that the error was thought to have occurred. Members should check their trading history and are solely responsible for reporting any mistakes found on their account. All perceived errors must be reported within 24 hours after the execution of the trade.

If you do not understand the risks involved in exchanging cryptocurrencies or tokens to precious metals, then you should not execute such trade. For any questions or clarification, please feel free to contact our support.

Vaultoro does not take any responsibility for either the precious metals prices or the cryptocurrencies and tokens prices at any given moment in time.

From time to time, governments try to tax precious metals or cryptocurrencies or tokens. Vaultoro takes no responsibility for either the price of precious metals or cryptocurrencies or tokens in the geographical location where taxes might arise.

You are responsible for depositing your cryptocurrencies and/or tokens in the correct wallet. Cryptocurrencies and tokens which are sent to the wrong wallet will be lost.

To comply with Swiss AML/KYC (anti-money laundering and know your customer guidelines), you need to be verified with your name, address, birth date and country of residence before you can buy and sell precious metals on Vaultoro.

Verifying yourself

Verification ensures that all precious metals purchased is your legal property.

Users voluntarily perform the verification of their account using the automated authentication process from our service provider Onfido Limited (3 Finsbury Avenue, London EC2M 2PA).

With this verification method, in addition to the actual verification data (e.g. screenshots of ID documents and identification data from these, residence, status of politically exposed persons, video data, etc.), biometric data (e.g. personal data resulting from specific technical processing in connection with the physical, physiological or behavioural characteristics of a person and enabling the unique identification of a person, e.g. facial images, dactyloscopic data) is also collected.

Such processing of biometric data takes place exclusively on the basis of your express consent, which you may revoke at any time.

Users are required to perform the verification of their account using the automated authentication process from our service provider Onfido Limited (3 Finsbury Avenue, London EC2M 2PA), Vaultoro reserves the right to choose another provider, clients may not be advised of such change.

With this verification method, in addition to the actual verification data (e.g., screenshots of ID documents and identification data from these, residence, status of politically exposed persons, video data, etc.), biometric data (e.g., personal data resulting from specific technical processing in connection with the physical, physiological or behavioural characteristics of a person and enabling the unique identification of a person, e.g., facial images, dactyloscopic data) is also collected.

The biometric data will be processed solely by our processor Onfido Limited (or other of our choosing) for the purpose of verification and will be erased completely within 30 days after performing the identification. Vaultoro only receives the positive or negative verification result with other verification data and does not process biometric data from Clients itself at any time.

Taxes

All local taxes and/or associated charges that may be applied to purchases, sales of, and/or custody of precious metals bullion are the responsibility of the user ("you") to research, understand and pay in full.

It is your sole responsibility to determine whether, and to what extent, any taxes apply to any transactions you conduct through the Vaultoro Services, and to withhold, collect, report and remit the correct amount of tax to the appropriate tax authorities. Your transaction history is available through your Vaultoro Account.

Force Majeure, acts of God or vis major.

Vaultoro will not be responsible for any delay or failure in any performance due to, and not limited to, acts of God, war, blockade, embargoes, riots, governmental restriction, labour disturbances, unavailability of anticipated usual means of supplies, transportation or loading facilities, wrecks, epidemics, quarantine, fire, flood, earthquake, explosion, any unforeseen change in circumstances, or any other causes beyond its reasonable control.

Any of the risks described under Force Majeure are not the responsibility of Vaultoro.

A lack of liquidity

Enough market liquidity is in the interest of both Vaultoro and the user. Vaultoro will do its best to promote or provide liquidity. Vaultoro is not responsible for any risk or losses that may arise from a lack of liquidity on the Vaultoro order book.

Identity theft

Vaultoro employs multiple levels of industry-standard best practice used to secure, encrypt all personal user data.

In Vaultoro it is mandatory to enable 2-factor authentication to protect your account from unauthorised access

You agree to and acknowledge that any loss of private data or funds as a result of a compromised account due to the user using a weak password, compromised email accounts or not setting up 2 factor authentication and other reasons where Vaultoro is not at fault is NOT the responsibility of Vaultoro.

Trading in cryptos and precious metals warning

The trading of precious metals and cryptocurrencies involves a significant amount of risk. Prices can fluctuate on any given day. Because of such price fluctuations, you may gain or lose value of your assets at any given moment. Any cryptocurrency or precious metal may be subject to large swings in value and its value may become zero. There is always an inherent risk that losses will occur as a result of buying, selling or trading anything on the market.

Cryptocurrencies trading has specific risks, which are not shared with other official currencies, goods or commodities in a market.

Unlike fiat currencies, which are supported by government reserves or other legal entities, as well as commodities such as silver and gold, most cryptocurrencies are "flat" currencies, which are only backed by mathematics, technology and trust. Any of these currencies is absolutely decentralized, which means there is no authority that can take corrective measure to protect their value in a crisis or issue more currency.

Cryptocurrencies are an autonomous and mostly unregulated worldwide payment system. When using them - traders put their trust in the digital, decentralized and mostly anonymous system, which relies on p2p networking and cryptography to maintain its integrity.

Trading in cryptos is susceptible to irrational or rational bubbles or absolute loss of confidence, which could collapse demand/supply. Any actions, even remotely connected to such currency can crash confidence in this currency, such as unexpected changes imposed by the currency developers, a government crackdown, the creation of a superior competing alternative, or even a deflation or inflation spiral. Confidence might also collapse because of various technical problems: if the anonymity of the system can be compromised, funds lost or stolen, or in the event that hackers or governments become able to prevent any transactions from settling.

There may be additional risks, which have not been foreseen or identified in the current Terms of Use.

Every user has to carefully assess whether his/her financial situation and tolerance for risk is suitable for buying/selling/trading cryptocurrencies.

Fees and Commissions

Vaultoros business model is based around trading fees and a percentage on the purchase or sale price of precious metals.

Vaultoro has the right to change these fees, including adding additional fees, at any time and with no notice to you due to quick market fluctuations, although Vaultoro will try to make all efforts possible to notify users of any fee changes including, but not limited to, email and notices on the site when a user logs in. All prices and fees will always be visible to the user before the user can buy or sell precious metals.

Vaultoro sometimes offers discounts such as vouchers, promotions or giveaways. These discounts may be the totality of the trading fee or some other discount.

Precious metals storage fees are charged by a percentage of holdings per year. This is calculated every day. .

Vaultoro uses a secure custodian for the custody of cryptocurrencies and tokens. Fees arising from such service will be paid in full/partially by the client. Transacional fees will be charged to withdraw the funds through the Vaultoro interface according to our fee schedule.

Intellectual Property Rights

Unless otherwise specified, all contents of the Vaultoro website including, but not limited to, text, images, names, graphics, data, logos, icons, code, prices, charts, methods, techniques, models, video, audio and the underlying software (the "Components"), are proprietary to Vaultoro and are protected by the patent, copyright, trademark and other applicable laws of the UK legal justice system.

You may view, download and / or print a copy of the materials from this site solely for your personal records, interests, educational, non-commercial use, provided that you keep all copyright and other proprietary notices intact.

Vaultoro utilises some graphics and icons which come with a creative commons licence, for example, but not limited to, awesome font icons. These may be used as per the licence agreements of the providers.

Publicly visible data

To create a transparent and vibrant marketplace, Vaultoro makes certain information freely available to the public.

• Every user is given a random string of letters and numbers ("Client ID") which only the user knows is attached to them and their account. This number is shown in the public audit PDF along with how much precious metals and how many cryptocurrencies or tokens that account had at the end of that day. To the public, there is no way to link this number to an actual user unless that user reveals their Client ID outside of Vaultoro. This is necessary for transparency's sake to prove to the world that Vaultoro is equal to, or above, 100% reserve for cryptocurrencies, tokens holdings and precious metals holdings without compromising user privacy.

  It is the member's responsibility to keep their Client ID secret and not connect it with their person and or account.

• A list of transactions and an order book is visible on the Vaultoro website as well as broadcast out through the API and price feed. This contains prices and sizes of trades which are pending and/or have been executed. Through this, your orders and transactions are visible to others but in no way traceable or attributable to you.

• Vaultoro may be requested or subpoenaed by government law enforcement agencies to hand over records. If a government agency chooses to or accidentally releases this information publicly, Vaultoro will not be held liable.

Jurisdiction and Law

Availability of Service

Due to international and European trade embargoes and sanctions Vaultoro is not able to do business with people based in embargoed countries. Vaultoro reserves its right to stop providing all or part of the Vaultoro services to any country, anytime or any user at any time if after a certain time the user is identified later as a politically exposed person or bad actor.

Death or incapacity

The procedure for the collecting of assets held by a deceased person is different depending on the jurisdiction of the deceased person(s). You agree to and allow Vaultoro management to seek legal advice in the territory of your estate's administration at the expense of your account. These expenses are limited to any charges outlined on our Fees and Charges page

Please refer to our procedures for handling deceased accounts for further details.

Your cryptocurrencies and tokens Holdings

Security

Security is our top priority. Vaultoro has partnered with a first tier company to be the custodian of our client's cryptocurrencies and tokens.

Cryptocurrencies and tokens withdrawals

Under no circumstances should you attempt to use your Cryptocurrency Wallet to store, send, request, or receive cryptocurrencies in any form that we do not support (although we will use reasonable efforts to help you move or sell Digital Currency that we no longer support). We assume no responsibility or liability in connection with any attempt to use your cryptocurrency Wallet for cryptocurrencies that we do not support.

Daily withdrawal limits

There may be times where you can not instantly withdraw your desired cryptocurrencies and/or token amount.

Vaultoro is not responsible or liable for any losses of opportunity due to the time taken to securely deliver your cryptocurrencies and token withdrawal.

Your responsibilities on withdrawal and deposit addresses.

Although Vaultoro has checks in place to validate correct cryptocurrencies and token withdrawal addresses, Vaultoro does not guarantee this to work 100% of the time. It is your responsibility to enter a correct and valid withdrawal address to which you (or your beneficiary ) control the private keys or have access to the funds once withdrawn.

You are responsible for depositing your cryptocurrencies and/or tokens in the correct wallet. Cryptocurrencies and tokens which are sent to the wrong wallet will be lost.

Your precious metals holdings

100% full reserves

Your precious metals holdings are held by professional vaulting operators. The only access to your precious metals holdings is through the Vaultoro platform.

In certain high volume times, Vaultoro and its subsidiaries reserve the right to sell precious metals to its users that have not yet been acquired by Vaultoro or its subsidiaries. This creates a contract that Vaultoro and its subsidiaries need to buy the precious metals as soon as possible from a precious metals provider. This is to ensure the possibility of customers to buy or sell precious metals on days and times when the precious metal markets are closed (weekends or holidays, or after 6pm CET).

Vaultoro and its subsidiaries will never use customers' assets as collateral, lend out, hypothecate, or create a derivative transaction of any type. All precious metals holdings are stored by the vault operator. NATIONAL VAULTING SERVICES LTD is the only party that has a vaulting contract with the vault operator. By law, the vault operator is informed of the holdings of each user, but a user can not contact the vault directly to access its holdings or get information about Vaultoro or its subsidiaries due to data protection laws. Vaultoro and its subsidiaries reserve the right to change vault operators and places of precious metals holdings anytime. The vault operators have contracts with a third party to ensure the precious metals and to audit the precious metals.

Insurance

All user's precious metals are 100% insured against theft and damages through the precious metals insurance contract the vault operator has with its insuring company.

The insurance meets generally accepted bullion industry insurance standards, the cost of which is included in the small vaulting fee charged to Vaultoro members that have a precious metals holding on Vaultoro. (please see the section on Fees and Charges)

Vaultoro and its subsidiaries ensure to comply with the vault operators legal obligations (know your customer and anti-money-laundering laws and other laws) so the contract with the vault operator can be maintained by each party.

Locations

Your precious metals are currently physically stored in a Brink's vault at the Zurich Airport Google Map

Address:

Brink's Switzerland Ltd.
Tor 105
Fracht Ost
CH-8058 Zurich Airport
Switzerland

Other storages

For staying able to buy and sell physical precious metals very quickly, a small amount of precious metals is stored at the precious metals trading companies we are cooperating with

philoro SCHWEIZ AG
St. Gallerstraße 7
CH-9300 Wittenbach, Switzerland

philoro EDELMETALLHANDEL AG
Wirtschaftspark 25
LI-9492 Eschen, Liechtenstein

pro aurum SCHWEIZ AG
Zürcher Freilager AG GVZ
CH-8424 Embrach, Switzerland

Vaultoro and its subsidiaries reserve the right to change the locations of the user's holdings.

Form

All precious metals bars held by Vaultoro clients have a purity of no less than 999,9 / 1000 (gold) and 999 / 1000 (silver). This is the highest quality grade which is globally accepted by bullion markets.

The bullion is held in a form generally accepted in settlements of physical bullion markets around the world. This is usually 1-kilo bars or 500 gr bars in gold or 1.000 Oz or 15-kilo bars in silver.

Bullion content

Vaultoro guarantees that all gold purchased by Vaultoro is of a 999,9 / 1000 and all silver of 999 / 1000 minimum purity.

If there is any breach found in this guarantee, Vaultoro will hold the seller accountable if faulty precious metal bars are discovered.

Vault Operators

Vaultoro employs the services of professional vault operators of the highest reputation. Vault operators are in the business of managing the logistics and storage of bullion bars. By accepting this Terms of Use Agreement, you agree and accept that Vaultoro and its subsidiaries have a contract with a vault operator(s). The storage agreement(s) between Vaultoro / its subsidiaries and vault operator is between Vaultoro/its subsidiaries and the vault operator only. The agreement to manage customers precious metals is only between Vaultoro/and its subsidiaries and the user ("you")

Your precious metals are held in bailment

Bailment describes a legal relationship in common law where physical possession of the personal property, or a chattel, is transferred from one person (the 'bailor') to another person (the 'bailee') who subsequently has possession of the property.

Vaultoro's chosen Vault Operators store your precious metals pursuant to a storage agreement between Vaultoro and the vault operator. By accepting these terms of use, you acknowledge that your precious metals are only accessible to you through the Vaultoro platform.

The reason for structuring your precious metals' safekeeping as a bailment is purely to arrange the est and easiest legal framework and protections for your precious metals to be held within a professional vault at the lowest possible price to you.

Bailments within Vaultoro

By purchasing precious metals within the Vaultoro markets, you agree that the ownership of the bullion purchased is transferred by the seller to the buyer within Vaultoro's system and becomes a bailment of the buyer's property, through the agreement between the buyer and Vaultoro.

You agree that once you have purchased the precious metals on Vaultoro, Vaultoro stores your precious metals within the vault operators storage facilities.

By agreeing to these Terms of Use, you acknowledge that Vaultoro will be responsible for all record-keeping in terms of the creation and termination of the bailment according to these Terms of Use

By using, buying, selling and storing precious metals on Vaultoro, you agree and acknowledge that any precious metals that you own do not relate to any specific bar but rather to portions of bars that when added up are equal to the full reserves of all Vaultoro customers. By the method of measurably subdividing ownership of whole bars among multiple Vaultoro members.

Contractual rules for physical precious metals withdrawal

Physical delivery is possible under certain circumstances but is not guaranteed. The possibilities depend on your geographical location and geopolitical situation within your area. You acknowledge the possibility that the precious metals might be delivered from a precious metals merchant in your country.

Vault operators Storage Agreement termination

In the event that a Vault Operator wants to terminate a Storage Agreement, Vaultoro confirms that the Vault Operator must give Vaultoro 1 months notice prior to termination. In the event of such a termination notice, Vaultoro will find a suitable alternative storage solution for all precious metals held in bailment at the Vault Operator's premises in question.

We hereby confirm that Vaultoro will notify all users with a minimum of 1 month prior to the termination of the Storage Agreement if an alternative cannot be found so that members have the ability to sell, organise for physical delivery and/or arrange an alternative mechanism for securing their precious metals bullion assets.

Record keeping and database security

Vaultoro maintains and controls the master copy of the precious metals and cryptocurrencies and tokens ownership database. The only way Vaultoro can modify this database of records is by the execution of a members trade order made in accordance to these Terms of Use.

At Vaultoro we strive for as much transparency as possible without revealing personal information. This is to prove 100%+ precious metals and cryptocurrencies and tokens reserves to its creditors.

Every 24 hours, Vaultoro will reconcile and anonymise ("Client ID") customer records of cryptocurrencies, tokens and precious metals ownership and publish the entire list on its website for constant public scrutiny. This will let users personally audit the Vaultoro holdings against the statement of all precious metals held in bailment for Vaultoro users by the Vault Operator as well as cryptocurrencies and tokens held in the Proxy hot and cold wallets.

To ensure the safety of records, Vaultoro has multiple backups of the full database.

Dormant accounts with small amounts of precious metals

If an account exists that has less than 1 gram of precious metals and the member has not logged into the site for 5 years or more, does not respond to post, emails or telephone calls, then Vaultoro reserves the right to take over ownership of and liquidate the remaining precious metals. This is because with some promotional fees we take a % for the storage fee, so the holdings of the precious metal can never reach zero if we do not take ownership and liquidate.

If Vaultoro manages to contact the owner, then no action will be taken, and the precious metals will remain in possession of the member.

Sometimes Vaultoro may run promotions, wherein we give away small amounts of precious metals for people to get started with trading. Vaultoro reserves the right to reclaim the promotional precious metals balance if it becomes evident that the account has been abandoned, or that the account was set up to abuse the Terms of Service for a particular promotion.

Vaultoro reserves the right to terminate any promotion without prior notice or warning to the public or the users.

User bullion withdrawal rights

Although Vaultoro is not primarily designed as a physical bullion precious metals delivery system but rather a trading platform, Vaultoro offers the Service of physical delivery for but not limited to

• Clients that wish to take physical possession of their precious metals holdings for any reason

• To highlight that we run at or above full precious metals reserves at all time

The minimum amounts and fees for the delivery of precious metals can be seen here (link to "Fees ")

By requesting the delivery of physical gold, you accept and agree to pay Vaultoro any of the fees and charges associated with it and that these fees may vary depending on the type and amount of precious metals. You acknowledge that all fees and charges needed for a physical delivery must be paid before delivery can be set in motion.

You acknowledge and agree that all fees and charges are denominated in precious metals, and must be paid for in precious metals.

Vaultoro acknowledges, and the user agrees that, Vaultoro has been set up primarily as a trading and savings platform and that most users will find it more economical to simply sell their precious metals on Vaultoro for cryptocurrencies, transfer the cryptocurrencies to themselves and buy precious metals locally, rather than paying the fees for physical delivery or physical withdrawal. This is a result of the cheap, fast and liquid way the cryptocurrency network works.

The user agrees that because of the nature of physical metals, the user must round delivery amounts to the nearest 100 grams (in accordance to and within the balance of the precious metal of the user). Any precious metals funds left over may be kept as precious metals on the user's account or be sold for cryptocurrencies and tokens and withdrawn using the standard selling mechanisms on the Vaultoro market.

You acknowledge that the precious metals which will be delivered must not have the same origin as the precious metals that are stored by Vaultoro.

To facilitate physical delivery, Vaultoro requires appropriate user identification and address verification. This is needed for multiple reasons:

• Vaultoro follows strict KYC and AML regulations as set out by British and International Law.

• Vaultoro needs to ensure customers precious metals is withdrawn by the owner of the precious metals and not a thief.

• Vaultoro ships with insurance and needs a verified user for the insurance to be effective

You acknowledge that you cannot request physical precious metals withdrawal from the Vault Operator itself. The right to withdraw your precious metals is only effective through the mechanisms of Vaultoro or an associated law firm who hold the responsibility for Identifying and verifying you correctly, as well as in a timely manner.

You acknowledge, by withdrawing precious metals bullion from Vaultoro that you may become liable to new taxes that you would not have to pay when your precious metals are held in bailment by Vaultoro. By withdrawing you agree to and permit Vaultoro to charge you or deduct any taxes that apply to you.

You acknowledge that by withdrawing precious metals, your privacy may be lost due to transactions being monitored by appropriate organisations and or authorities.

You acknowledge that if a physical precious metals withdrawal is too large in quantity, you may be asked to provide the address of local bank or equivalent, this is to ensure safe delivery and only for very large amounts of precious metals bullion.

Logistics and delivery of precious physical metals

The withdrawing party ("you") acknowledge that

• you must inspect any package before signing for receipt.

• if any person at the delivery address you specify signs for receipt or omission of your delivery, that this will be fairly deemed by Vaultoro to be acts or omissions by you.

• It is your responsibility to be available at the address you specify to receive and sign for the goods.

• Government or customs agencies who have the authority by law to open and inspect packages might do so and then reseal the package in question. If the package has been tampered with by any other party, it is your obligation to refuse to sign and receive the package.

Vaultoro acknowledges that it will pay for all courier charges from the delivery charges paid by you when initiating the physical precious metals delivery. In some cases, depending on the jurisdiction, you may be liable to pay extra taxes including, but not limited to, customs, delivery company taxes, local government tax, and release charges. By withdrawing physical precious metals bullion from Vaultoro, you agree to educate yourself on all local tariffs that you are liable for and pay them.

You acknowledge and accept that:

• a signature of receipt by anyone at your selected delivery address is regarded as evidence and confirmation that you have received the package and that everything in the package is in appropriate condition.

• there may be delays in delivery time due to actions or duties from government agencies

• you have an obligation to sign a proof of receipt when you receive the package and contents in an appropriate condition.

• If you, or someone else at the delivery address specified at Vaultoro, signs for the receipt of the package and its contents, any returns to Vaultoro for whatever reason shall be at your expense. This excludes your refusal to sign for receipt of the package.

Trading

Risk when trading

By creating an account on Vaultoro, you agree:

• To trade at your own risk.

• That trading comes at a risk of losing some, or all, of your initial deposit.

• That you have educated yourself appropriately on how to trade safely.

• That Vaultoro is not liable for any losses due to your trading activity or decisions on Vaultoro.

• That the internet could slow down or crash during an important trade and that Vaultoro is never liable for any losses for any technical reason.

• To take full responsibility for any losses due to information you might have read on the Vaultoro site, on social network accounts run by Vaultoro, or anywhere else online or offline.

You acknowledge that :

• Vaultoro will do its best to always keep the site online and responsive but can not guarantee a responsive service all of the time.

• Vaultoro is not liable for any losses due to, but not limited to, site bugs, internet lag, server lag, browser crashes, incompatible browser versions, denial of service attacks (DDOS attacks), countrywide firewalling and or site censorship from a government authority.

• Vaultoro makes no claim of being 100% reliable and that the technology of the internet and Vaultoro can and will sometimes act unexpectedly, leading to losses.

Order book

When you place an order on Vaultoro's platform, you may place two types of orders:

A limit order

A limit order is an order to buy precious metals at no more than a specific price, or to sell precious metals at no less than a specific price (called "or better" for either direction). This gives the trader (user) control over the price at which the trade is executed; however, the order may never be executed ("filled") if the price never reaches the limit because it was set for lower than the current price on the buy side, and higher than the current sell price on the sell-side. Limit orders are used when the trader wishes to control price rather than the certainty of execution.

A buy limit order can only be executed at the limit price or lower. For example, if an investor wants to buy precious metals, but doesn't want to pay more than 0.1BTC for it, the investor can place a limit order to buy the precious metals at 0.1BTC. By entering a limit order rather than a market order, the investor will not buy the stock at a higher price but may get less precious metals than he wants or not get any precious metals at all.

A sell limit order is analogous; it can only be executed at the limit price or higher.

A market order

A market order is a buy or sell order to be executed immediately at current market prices. As long as there are willing sellers and buyers, market orders are filled. Market orders are therefore used when certainty of execution is a priority over the price of execution.

A market order is the simplest of the order types. This order type does not allow any control over the price received. The order is filled at the best price available at the relevant time. In fast-moving markets, the price paid or received may be quite different from the last price quoted before the order was entered.

A market order may be split across multiple participants on the other side of the transaction, resulting in different prices for some of the shares.

Your Orders

All orders on our platform are limited to the balance on your account

You may cancel an unfulfilled order at any time.

Timing Risks

You acknowledge and accept that the Vaultoro markets work very fast. This means that if you were to cancel your limit order, Vaultoro might receive a matching order milliseconds before we receive your cancellation request. In this case, your order may be fulfilled before we cancel the order. If however the order is only partially matched then the cancel request will cancel the remainder of your open order.

Vaultoro's right to remove orders at its discretion

You agree that Vaultoro reserves the rights to remove any orders from the order book at any time and for any reason.

Vaultoro's right to pause trading for single users or all users.

You agree that Vaultoro may pause trading for you and/or for every user across the platform at its discretion and is not liable for any losses due to this pause.

You acknowledge that if for any reason trading is paused for more than 1 hour, that some or all open orders may be cancelled by Vaultoro to keep the market fair and minimise loss for its customers.

If Vaultoro removes one or more of your orders from the Vaultoro order book, then we accept the responsibility to inform you via the email address registered by us.

Communications about orders

You authorise Vaultoro to send you emails to do with your orders for the following reasons:

• To acknowledge that an order has been placed

• To acknowledge that an order has been filled

• To acknowledge that an order has been cancelled

You may, at any time, turn these emails off in the preferences. By doing so, you do not void any deals that have been or will be filled on the Vaultoro marketplace.

You acknowledge that emails from Vaultoro only act to keep you informed and not as a contract.

Settlement

By trading on Vaultoro's platform, you accept and authorise Vaultoro's counterparties to settle any order you submit as soon your order becomes matched with another parties' order, partially or in full. Vaultoro accepts full responsibility for the ability to execute and settle all orders according to your instructions, either by 3rd party API call or through the vaultoro.com website.

Vaultoro acts as a guarantor behind every order. Vaultoro ensures that the buyer and seller in any transaction have the funds.

You acknowledge and agree that:

• Vaultoro settles all order book transactions, partially filled or in full, instantaneously and at the point of trade

• No physical changes happen to the precious metals stored at the Vault as a result of a trade settlement.

• It is possible to trade with yourself by putting a buy and sell order in at the same time at a matching price point.

Trades

As soon as a trade is settled, a seller is credited with cryptocurrencies or tokens held in trust, and a buyer becomes the owner of the precious metals held in bailment by Vaultoro. The Vaultoro trading fee is automatically deducted from both parties' accounts at the time of the trade.

Settlement of delivered precious metals bullion is achieved through a Vaultoro book entry. Your precious metals balance (as shown when logged in on the website), shows your precious metals bullion custody balance and represents outright ownership of precious metals bullion held in bailment by Vaultoro, in a professionally secured and insured vault.

You acknowledge that any trade done on the Vaultoro trading platform is settled simultaneously and immediately with the delivery of precious metals, minus the trading fee from both parties.

All precious metals which have been settled on Vaultoro are held for you in custody by the Vault Operators.

Any unsettled balances are immediately added and represented in your balance as soon as a trade settles.

Vaultoro endeavours to publish every 24 hours a reconciled and anonymised list of all precious metals, cryptocurrencies and tokens held by all customers as well as a precious metals holdings list from the Vault Operators

Limitations of liability

Vaultoro will not be held liable for any damages to the extent permitted by UK Law, this includes, but is not limited to, loss of opportunity, loss of revenue, loss of profit, loss of data, indirect or consequential loss, loss of business.

Vaultoro will only be liable if the loss suffered arose from wilful deceit or fraud on behalf of Vaultoro.

You agree and acknowledge that Vaultoro is not liable for any harm, self-harm or suicide arising from trades or losses in any way. You take full responsibility for your trading activity.

If you feel you have a problem with gambling you agree to seek help, and that Vaultoro and or any promotion is not responsible for your continued use in any capacity.

Subject to this Terms of Use document, Vaultoro's collective liability in respect of claims that arise out of any single user's use of the Vaultoro site and/or platform, in contract, wrongful conduct, negligence or anything else, shall in no circumstances exceed the greater of either:

1. The total amount of precious metals, cryptocurrencies and tokens held on account for the member making a claim, minus any fees or charges owed to Vaultoro for the transactions needed to release the funds; or

2. 100% of the amount of any transaction(s) that are subject of the claim, minus any fees or charges owed to Vaultoro for the transactions needed to release the funds

Trading bots and API access

You acknowledge that the API on api.vaultoro.com is used by you or 3rd parties at your own risk. Vaultoro is not responsible for proper implementation, can not offer technical support and is not liable for any damage that arises by using the Vaultoro API at any capacity.

Custody of cryptocurrencies

Vaultoro has partnered with Bitgo inc. All cryptocurrencies that you have not traded in precious metals, will be securely stored in a Bitgos wallet.

Fees and Charges

All Vaultoro fees and charges are described and published on its website here

By agreeing to these terms and conditions you agree to let Vaultoro automatically deduct the appropriate fees and charges, both from your precious metals holdings and your cryptocurrencies and tokens holdings, for any activity on the Vaultoro platform that attracts its fees or charges.

Downtime and Availability

Vaultoro is designed to run 24/7 under normal circumstances. Sometimes Vaultoro will have planned software upgrades or maintenance where trading will need to be halted. These outages will generally happen on low traffic times,

In an emergency outage, Vaultoro reserves the right to pause, cancel or restart all trading at its discretion.

Vaultoro takes outages extremely seriously and will do anything in its power to minimise these happenings.

You acknowledge that Vaultoro will not be held liable for any loss of opportunity, loss of revenue, loss of profit, loss of data, indirect or consequential loss, loss of business due to outages by the Vaultoro system.

Vaultoro will do its best to keep you informed during an outage if you have open orders on the order book. You accept that during an unscheduled service interruption or downtime emails may not be sent due to the system being down or out.

You accept that an interruption of Service is an inevitable and unavoidable eventuality with networked computer systems. You accept our method of dealing with your open trades during an outage or before trading resumes. You accept and understand the risks of leaving open orders on the Vaultoro system can expose you to risks that are increased during times of maintenance, outages or DDOS attacks to the website, and you accept these risks as your own.

Computer Viruses

You agree that any damage or interruptions caused by computer viruses, scareware, spyware, Trojan horses, worms or other malware that may affect your computer or other equipment is your responsibility in full and that Vaultoro does not bear any liability, whatsoever, for any losses of moneys, assets, personal identities, opportunities.

This is also the case for any phishing, spoofing or other attacks.

Vaultoro recommends the regular use of reputable malware and antivirus software.

Vaultoro also recommends that you never click a link in an email from Vaultoro. Instead, you should open a browser and log into vaultoro.com manually to make sure you are not dealing with a phishing attack email purporting to come from vaultoro.com and made to look like an official Vaultoro email.

If you have any doubt whatsoever about communication from Vaultoro, please don't hesitate to contact us

Trading errors or corrections

If a trading engine error is found by you it is your responsibility to report the error as soon as you have found it to [email protected]. It is not within your or Vaultoro's rights to profit from any trading system vulnerability or error.

Vaultoro has algorithms in place that check for trades that have happened far out of the price range of the wider global markets and will halt all trading if such an error was to arise. In the unlikely event that these protections in the Vaultoro trading system were to fail in any way then you and Vaultoro agree that Vaultoro may make reasonable adjustments to user balances.

Regulations and Vaultoro

You acknowledge that The Financial Services industry is regulated very differently from Vaultoro's regulatory status.

Throughout America, Europe and Australia, financial service companies or schemes tend to deal in paper-based instruments ("securities"). These are regulated very differently to what Vaultoro offers its clients, which is absolute ownership of physical precious metals. Like the rest of the physical precious metals industry in the UK, Vaultoro falls outside any definitions of the formal financial services regulations.

Vaultoro enables its users to trade in the absolute ownership of physical metal ("precious metals"), cryptocurrencies and tokens. Vaultoro does not offer credit or paper-backed securities.

Vaultoro like the rest of the London physical precious metals bullion markets are not regulated by the UK's Financial Services Authority but by traditional English property law.

No financial advice

Vaultoro is not your broker, intermediary, agent, or advisor and has no fiduciary relationship or obligation to you in connection with any trades or other decisions or activities affected by you using the Services. No communication or information provided to you by Vaultoro is intended as or shall be considered or construed as, investment advice, financial advice, trading advice, or any other sort of advice. All trades are executed automatically, based on the parameters of your order instructions and in accordance with posted trade execution procedures, and you are solely responsible for determining whether any investment, investment strategy or related transaction is appropriate for you based on your personal investment objectives, financial circumstances and risk tolerance. You should consult your legal or tax professional regarding your specific situation.

Vaultoro does not recommend that any precious metal, cryptocurrency or token should be bought, earned, sold, or held by you. Before making the decision to buy, sell or hold any precious metal, cryptocurrency or token, you should conduct your own due diligence and consult your financial advisors before making any investment decision. Vaultoro will not be held responsible for the decisions you make to buy, sell, or hold precious metal, cryptocurrency or token based on the information provided by Vaultoro.

Limited and exclusions of liability

1. The financial liability for the acts and omissions of Vaultoro and/or its subcontractors, agents, freelancers or employees are laid out below in the following provisions:

   1. any breach of these Terms of Use

   2. any representation, statement, tortious act or omission (including negligence), arising under or in connection with these Terms of Use

2. Subject to the clauses above on Inspection and Acceptance and Risk and Title, all warranties, conditions or other terms implied by statute or common law (save for those implied by Section 12 of the Sale of Goods Act 1979) are excluded to the fullest extent permitted by law.

3. Nothing in these Terms and Conditions shall exclude or limit our liability for fraud, or death or personal injury caused by our negligence, or for any other liability which cannot be excluded or limited under applicable law.

4. Subject to the 2nd and 3rd Paragraphs above:

   1. Vaultoro's total liability in contract, tort (including negligence or breach of statutory duty), misrepresentation, restitution or otherwise, arising in connection with the performance or contemplated performance of these Terms of Use shall be limited to the value of your cryptocurrencies and tokens balance and/or precious metals from time to time deposited with or by Vaultoro; and

   2. Vaultoro shall not be liable to you for

      1. any pure economic loss,

      2. loss of corruption of data or information;

      3. fall in the value of your precious metals or cryptocurrencies or tokens,

      4. loss of anticipated savings

      5. loss of business,

      6. loss of profit,

      7. loss of goods

      8. depletion of goodwill or otherwise,

      9. loss of contract

      10. in each case whether indirect,

      11. loss of use

      12. direct or consequential,

      13. or any claims for consequential compensation whatsoever (howsoever caused) which arise out of or in connection with these Terms of Use.

5. If Vaultoro's performance of its obligations under these Terms of Use is prevented or delayed by any act or omission of the Customer or any agent, subcontractor or employee of the Customer, Vaultoro will not be liable for any costs, charges or losses whatsoever sustained or incurred by the Customer arising directly or indirectly from such prevention or delay.

6. No legal proceedings (including any counterclaim) may be brought against Vaultoro unless they are issued and served within nine months of the event giving rise to the claim.

KYC/AML Policy

Vaultoro will do all it can to prevent the company and its staff being exposed to money laundering, to identify the potential areas where it may occur, and to comply with all legal and regulatory requirements.

Vaultoro's management and whole team are committed to prevent criminal activities and money laundering on vaultoro.com and so we comply with the underlying spirit of the legislation and regulations and have in place internal procedures to prevent the use of their services for money laundering.

Scope

This policy aims to maintain a high standard of conduct. The policy applies to all employees and clients and exists to prevent criminals worldwide from laundering money through NATIONAL VAULTING SERVICES LTD's services.

The Policy sets out the procedures which must be followed.

What is money laundering

Money laundering is concealing the transformation of profits from illegal activities into ostensibly "legitimate" assets.

The following actions constitute money laundering activities as outlined in the proceeds of Crime Act 2002 :

• Acquiring, possessing and using criminal property (section 329)

• Enters into or becomes concerned in an arrangement which he/she knows or suspects facilitates (by whatever means) the acquisition, retention, use or control of criminal property by or on behalf of another person. (section 328)

• If a person conceals, converts, disguises or transfers criminal property or removes it from the UK. (Section 327)

Applicable legal framework

• Fifth Anti-money Laundering Directive (AMLD5)

• The Proceeds of Crime Act 2002 (POCA), and its amendments.

• The Terrorism Act 2000 and its amendments.

• The Terrorism Act 2006.

• The Money Laundering Regulations 2017.

AML Policy

Our AML Policy is designed to prevent money laundering and includes control systems to mitigate the risk of Vaultoro being used to facilitate financial crime.

Vaultoro's AML policies are as follows:

• Tracking and identifying suspicious transactions, with the power to suspend, return or decline suspicious funds/transactions.

• Reporting suspicious activities to law enforcement authorities' official request.

• Keeping records for over the recommended periods.

• Provide targeted training where it has been identified staff are most likely to encounter money laundering

International Sanctions Policy

Vaultoro is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists. We screen against United Nations, UK and European Union sanctions lists in all jurisdictions in which we operate.

Know Your Customer Procedures

KYC refers to a process that banks and other financial institutions use to gather identifying data and contact information from current and potential customers. Its purpose is to prevent fraud, money laundering, and other illicit activity, as well as the misuse of financial accounts.

Reasonable steps must be taken to check the client's identity to show that they are who they claim to be and if applicable that they are trading for a legitimate purpose. All new clients must provide sufficient information for verifying their identity before any transactions are undertaken. Non-verified accounts present limited functionality which only allows users to view the platform.

Vaultoro requires the submission of two documents: a government issued photo ID and a proof of address.

Valid forms of ID include:

• passport,

• national ID

• driving licence

The Proof of address is not only compliant with regulatory guidelines, it also ensures the security of our clients and their allocated funds as well as their digital and physical assets. When all customers onboard into the Vaultoro platform they complete our KYC (Know Your Customer) and AML (Anti Money Laundering) verification process.

The customer's address must be verified in the following process.

Proof of address documents must:

• State the client's full name clearly

• State the client's home address clearly

• The document must not be older than three months or in the future (date of issue)

Accepted documents for Proof of Address are:

• Bank Account Statement

• Utility bill

  • Water

  • Electricity

  • Gas

  • Heating

  • Cable television

  • Internet

• Phone bill

• Land taxes payment

No other documents will be accepted.

Governing Law

This Agreement ("Terms of Use") shall be governed, construed, and enforced in accordance with the laws of The United Kingdom, without regard to its conflict of laws rules. All disputes in hereof shall be governed exclusively by courts within the jurisdiction of The United Kingdom.

Company Details

NATIONAL VAULTING SERVICES LTD
308 High Street
Croydon, Surrey
England, CR0 1NG
Company number: 09369786

Standard Token Sale Terms

Terms related to the sale of Standard Tokens can be found here.

Fiat Purchase in Fiat Currencies

From time to time Vaultoro may offer You the ability to purchase Cryptographic Tokens and Cryptocurrencies using Fiat purchase systems.

These Fiat purchase systems are offered by third party vendors providing a POS (Point of Sale) Service. As such, Vaultoro holds no liability for the service provision and any/all complaints regarding the use of fiat based purchases should be handled by the third party.

Any and all service provisions and terms of service are provided by the third party service provider.

When Purchasing Cryptocurrencies with Fiat, you hereby warrant and understand that You are aware of the associated risks.

From time to time these risks include:

• Uncleared funds being held up in the payment network causing the payment to become incomplete.
• Uncleared funds being held up in the payment network causing the transaction to become incomplete.
• Delay in service provision between cleared funds reaching Vaultoro and the distribution of Cryptocurrencies or Tokens to your account.
• The variance of price between the time of purchase and the time of delivery of any Cryptocurrencies or Tokens.

You must only use a card that belongs to you and is registered to your name. You should not use any card belonging to a third party including any company that you may own or operate. Each user will be required to prove their identification and payment identification should match any identification taken by Vaultoro during the sign up process.

Vaultoro is not and shall not be liable for any use of your card by a third party without your permission. Any fraud, or illegal activity on your account should be reported to your financial institution and to Vaultoro.

In the event that You are found to have used a third party card, or any other payment method, without their express permission any and all Cryptocurrencies or Tokens purchased using that payment method shall be immediately forfeited and returned to The Company, including any additional Tokens held within your account.

The Company also reserve the right to retain the amounts paid by you including any fees paid. In using any Fiat based payment services You agree to indemnify the Company for any fraudulent or criminal activity undertaken by you. This includes activity which was done with or without your knowledge. The recovery of any funds from a third party shall be covered exclusively by you without the need for Vaultoro to pay any funds to the victim.

Any and all questions regarding the use of Fiat based Services should be directed to the third party provider.

Transfers in Euro and exchange

Vaultoro ltd. is a highly secure service that works in a transparent and solid way, maintaining contractual relations with an electronic money institutions and entities based in European Union countries.

For the storage and holding of cryptocurrencies and exchange with precious metals and vice versa Vaultoro has partnered with Sequoyah Vaulting

Sequoyah Vaulting is authorised and regulated in Denmark, Østerbrogade 137, DK-2100 Copenhagen, Kingdom of Denmark

Part of cryptocurrencies owned by customers might be held for exchange purpses on third party crypto currency exchnages like Kraken, Binance or Bitstamp

Inactivity Fee

The platform reserves the right to request re-verification of customer identification at any time. If the customer does not complete the re-verification process within two years, the platform reserves the right to charge an inactivity fee to the customer.

The following customers are affected by the inactivity fee:

• Customers who have funds in their account and have never completed the identification procedure at least once
• Customers who are due to re-verify their account and have not fulfilled their duty within a two year period

Fee schedule:

• The inactivity fee will be applied at the first of every month until the customer completes the identification
• The inactivity fee will be either 10$ monthly worth of assets or 0.2% monthly of customers' funds, whichever is greater.
• The platform will not be responsible for any losses incurred by the customer due to the inactivity fee.

These changes are coming into effect 20th of April 2023