Invest in Gold

Version 1.1. Effective date: July 29, 2026.

1. Important information

1.1. These Aspora Gold UK (as defined below) Terms and Conditions (hereinafter referred as “Terms”) apply when you access or use the gold purchase, sale and holding service made available through the Aspora mobile application in the United Kingdom.

1.2. At launch, Aspora Gold UK allows eligible customers to buy, sell and hold 24 carat gold (99.99% purity) through Goldwise (as defined below).

1.3. Aspora provides the digital interface, customer onboarding using its existing verification flow, technical facilitation, transaction information and first-level customer support.

1.4. Aspora does not sell gold to you, buy gold from you, store or insure gold, operate a vault, deliver gold, guarantee gold prices or provide investment, tax, legal or financial advice.

1.5. Goldwise is the seller and merchant of record for gold transactions. Goldwise is responsible for trade execution, allocation, the Goldwise merchant account, storage and vaulting arrangements, insurance arrangements, sale fulfilment and transaction-lifecycle support. Aspora remains responsible for its own app, onboarding and support obligations.

1.6. By using Aspora Gold UK, you agree to these Terms, the Aspora app terms, Aspora Privacy Policy, any risk warnings and/or disclosure shown in the Aspora App and any Goldwise terms expressly presented to you before you transact.

1.7. Gold prices may go down as well as up. You may receive less than you paid. Gold is not cash, e-money, a bank deposit or a guaranteed investment.

1.8. Unless expressly stated otherwise in a product disclosure, gold and precious metals themselves are not regulated deposits and may not be protected by the Financial Services Compensation Scheme.

2. Definitions

In these Terms:

2.1 Aspora, we, us or our means Vance Technologies Limited, trading as Aspora, which provides access to the Aspora App and the Aspora Gold UK service.

2.2 Aspora App means the mobile application or digital platform operated by Aspora or its affiliates

2.3 Aspora Privacy Policy means the privacy policy made available through the Aspora App, as updated from time to time, which explains how Aspora collects, uses, shares and otherwise processes personal data in connection with Aspora Gold UK.

2.4 Aspora Gold UK means Aspora’s digital gold product offered in partnership with Goldwise.

2.5 Customer, you or your means an eligible Aspora user who accesses or uses Aspora Gold UK.

2.6 Goldwise means Goldwise Holdings Limited, the Gold Provider for Aspora Gold UK.

2.7 Gold Services or Precious Metals Services means the gold purchase, sale, allocation, storage, vaulting, insurance, account-record and related services provided by Goldwise in relation to Gold.

2.8 Gold Holding means the quantity of gold purchased by you and recorded in the Goldwise ledger and applicable Vault Operator’s (as defined below) account or other storage record.

2.9 KYC Information means information required for identity verification, anti-money laundering, counter-terrorist financing, sanctions screening, fraud prevention, source of funds checks, source of wealth checks and customer due diligence.

2.10 Transaction means an instruction to buy or sell Gold through Aspora Gold UK.

2.11 Vault Operator means Brink’s Global Services International, Inc. (Brink), or any replacement vault, custodian, storage provider, logistics provider or similar service provider appointed by Goldwise, provided that any replacement is notified to you in accordance with these Terms.

3. Aspora’s role

3.1. Aspora’s role is limited to providing the Aspora App, onboarding, technical facilitation and first-level customer support for Aspora Gold UK. Aspora may transmit your instructions and technically initiate agreed payment, cancellation, refund and payout workflows, but does not have authority to bind Goldwise or enter into contracts on Goldwise’s behalf.

3.2. Aspora may:

(a) make Aspora Gold UK available in the Aspora App;

(b) collect and process KYC Information;

(c) share only the personal data and Transaction information needed to establish and administer your Goldwise account and process a Transaction; Aspora will not share copies of your identity-verification documents or KYC records with Goldwise unless required by law or specifically disclosed to you;

(d) display indicative precious metals prices, balances, order status and other information received from Goldwise;

(e) provide first-level customer support;

(f) escalate complaints, delivery issues, balance issues, refund issues, chargebacks, fulfilment issues and operational matters to Goldwise; and

(g) send you notices, confirmations, risk warnings, product disclosures and operational updates.

(h) unless you opt out or unsubscribe, send you marketing communications about Aspora Gold UK and other Aspora products or services by email, SMS, WhatsApp, push notification or similar electronic channels, and manage your marketing preferences in accordance with the Aspora Privacy Policy.

(i) unless you opt out or unsubscribe to personalised advertising, Aspora may use your contact information in hashed form to create, target or measure advertising audiences on social-media and other digital advertising platforms, as described in the Aspora Privacy Policy.

3.3. Aspora does not:

(a) sell precious metals to you;

(b) buy precious metals from you;

(c) provide custody or safekeeping of precious metals;

(d) operate or control any vault;

(e) insure your Gold Holding;

(f) provide delivery or logistics services;

(g) guarantee the availability, quality, purity, storage, delivery, liquidity or resale of precious metals;

(h) guarantee any price, return, yield, profit or appreciation;

(i) provide investment, financial, tax or legal advice; or

(j) act as trustee, custodian, broker, dealer or depositary in respect of your Gold Holding.

4. Goldwise’s role

4.1 Goldwise is the Gold Provider, seller and merchant of record and is your contractual counterparty for Gold Services.

4.2 Goldwise may be responsible for:

(a) accepting, rejecting, delaying or cancelling transactions;

(b) establishing and maintaining your Goldwise account, and relying on Aspora’s onboarding checks except where Goldwise is legally required to obtain further information;

(c) procuring, allocating, recording and maintaining records of precious metals;

(d) arranging storage, vaulting and insurance;

(e) appointing vault operators, logistics providers, payment providers, auditors and other third-party service providers;

(f) calculating prices, spreads, mark-ups, fees, charges and taxes;

(g) arranging sale, withdrawal and delivery where available;

(h) resolving escalated operational issues and complaints; and

(i) complying with applicable laws and regulatory requirements relating to the Precious Metals Services.

4.3 Goldwise may use affiliates, contractors and third-party providers to perform the Precious Metals Services.

4.4 Aspora is not responsible for any act, omission, delay, insolvency, breach, loss, error, failure, downtime, delivery issue, storage issue or non-performance of Goldwise or any Vault Operator, except to the extent caused directly by Aspora’s own fraud, wilful misconduct or breach of applicable law.

5. Eligibility and onboarding

5.1 You may use Aspora Gold UK only if:

(a) you are at least 18 years old and have full legal capacity to enter into a binding contract;

(b) you have an active Aspora account;

(c) you satisfy Aspora’s onboarding requirements;

(d) you satisfy Goldwise’s onboarding and customer due diligence requirements;

(e) you provide all requested KYC Information;

(f) you are not located in a restricted jurisdiction;

(g) you are not subject to sanctions or other legal restrictions;

(h) your use of Aspora Gold UK is lawful; and

(i) you satisfy any minimum age, residency, source of funds, source of wealth and transaction purpose requirements.

5.2 Aspora may request additional information where needed for identity verification, anti-money-laundering, sanctions, fraud prevention, source-of-funds, source-of-wealth, transaction-purpose or legal checks. Goldwise may request additional information only where required by law or reasonably necessary to execute, settle or fulfil a Gold Transaction.

5.3 Aspora or Goldwise may refuse, delay, reverse, cancel, suspend or limit any Transaction if:

(a) your KYC Information is incomplete, inaccurate or unacceptable;

(b) further due diligence is required;

(c) there is an AML/CTF, sanctions, fraud, tax, legal, regulatory or reputational concern;

(d) your Transaction appears suspicious, unusual or inconsistent with your profile;

(e) required payment has not been received, cleared or settled;

(f) a technical, pricing, reconciliation, system or operational error has occurred;

(g) Goldwise is unable to source, allocate, store, sell, withdraw or deliver precious metals;

(h) a payment provider, bank, card network, acquirer, payment gateway, vault operator, logistics provider, regulator, law enforcement authority or court requires or permits refusal, delay or suspension; or

(i) Aspora or Goldwise reasonably considers it necessary to protect customers, comply with law or manage risk.

5.4 Aspora or Goldwise may freeze, suspend or restrict your use of Aspora Gold UK while any review, investigation, dispute, chargeback, reversal, complaint, regulatory check or legal process is ongoing.

6. Customer consent to data sharing

6.1 Aspora will collect, use and share personal data only as described in the Aspora Privacy Policy. Aspora may share data with:

(a) Goldwise;

(b) Brink’s Global Services International, Inc. (Brink), the Vault Operator, in relation to the storage and custody of your Gold in London, United Kingdom;

(c) any payment provider, acquirer, bank, card network or payment gateway;

(d) any logistics, courier or delivery provider ;

(e) any identity verification, AML, sanctions screening, fraud prevention or compliance provider;

(f) any auditor, regulator, tax authority, law enforcement authority, court or government body; and

(g) Aspora’s affiliates, contractors and service providers.

6.2 Aspora’s existing remittance KYC flow is used for Aspora Gold UK. Goldwise relies on Aspora’s completion of that onboarding process and does not receive copies of your identity-verification documents or KYC records unless required by law or expressly disclosed to you.

6.3 The Aspora Privacy Policy explains the respective data-protection roles of Aspora and Goldwise, the categories of personal data shared, the purposes of sharing and your rights.

6.4 You must ensure that all information you provide is accurate, complete and up to date.

6.5 If you do not provide information required to provide the Gold Services or to comply with law, Aspora or Goldwise may refuse, suspend or terminate your access to Aspora Gold UK.

6.6 Gold is stored in Brink’s secure vaulting facilities in London, UK. Any change to the storage location or provider will be notified to you in accordance with clause 27 and reflected in the applicable product disclosure.

7. Purchase orders

7.1 You may place an order to purchase gold through the Aspora App, subject to eligibility, availability, limits, pricing, KYC approval, payment approval and Goldwise acceptance.

7.2 Before you confirm a purchase or sale, the Aspora App will display the exact Gold quantity, price, applicable spread and total amount. The price is locked for the period shown in the Aspora App. If the lock expires before payment is completed, the price will refresh; if payment is not completed in time, the order will be cancelled and any money received for that order will be refunded.

7.3 Precious metals prices may change at any time due to market movements, exchange rates, liquidity, spreads, mark-ups, taxes, fees, payment costs, settlement delays, technical issues or other factors.

7.4 A purchase order is not binding unless and until:

(a) you submit a valid instruction;

(b) payment has been authorised, received, cleared and/or settled as required;

(c) Aspora has completed the required onboarding, AML/CTF, sanctions and fraud checks and Goldwise has accepted the order;

(d) Goldwise accepts the order; and

(e) Goldwise records or confirms the relevant Gold Holding in your account, wallet, ledger or sub-account.

7.5 Goldwise may reject an order after submission if the order cannot be processed, payment fails, checks are not completed, gold is unavailable, a pricing error occurs, or the order creates legal, regulatory, operational or risk concerns.

7.6 If a purchase order is rejected after payment has been received, Goldwise will return the relevant amount to the verified bank account used for the payment as soon as reasonably practicable, subject to any lawful hold, investigation or deduction disclosed to you before you transact.

7.7 Once a purchase order is accepted and completed, you may not cancel it unless required by applicable law or expressly permitted by Goldwise.

8. Cancellation rights

8.1 Because the price of Gold depends on fluctuations in the financial markets which neither Aspora nor Goldwise can control, you do not have a right to cancel a transaction under the Consumer Contracts (Information, Cancellation and Additional Payments) Regulations 2013, in accordance with the exemption in Regulation 28(1)(b) of those Regulations, once your order has been accepted.

8.2 Where your Gold Holding is placed into storage with a Vault Operator immediately upon purchase, and to the extent any cancellation right could otherwise apply, that right (if any) ends on the day Goldwise or the Vault Operator takes possession of the gold on your behalf, on the basis that you have asked us to do so before any cancellation period would otherwise expire.

8.3 Nothing in this Section 8 affects any right you have to a remedy where a transaction has been carried out incorrectly, or where gold delivered to you does not match its description, is not of satisfactory quality, or is not fit for purpose, under the Consumer Rights Act 2015.

9. Ownership and nature of Gold Holdings

9.1 Goldwise records your Gold Holding on an allocated basis. Goldwise’s and Vault Operator’s records must identify the quantity of Gold allocated to you and held for you separately from the proprietary assets of Aspora, Goldwise and Vault Operator.

9.2 Subject to the applicable Goldwise and Vault Operator’s storage arrangements, legal title to the Gold recorded for you is held by you and not by Aspora or Goldwise. Goldwise must maintain records sufficient to evidence your entitlement to the allocated Gold.

(a) allocated precious metal;

(b) fractional ownership of larger bars;

(c) pool-allocated precious metal;

(d) pooled precious metal;

(e) gold units;

(f) ledger balances backed by precious metal; or

(g) another structure disclosed by Goldwise.

9.3 You should read the applicable product disclosure carefully before placing a transaction.

9.4 Aspora does not hold legal title to your Gold Holding and does not treat your Gold Holding as Aspora property.

9.5 Goldwise is responsible for maintaining records of your Gold Holding.

9.6 Your Gold Holding is not a cash balance, bank deposit, e-money balance, payment account or guaranteed investment.

9.7 Unless expressly confirmed in a product disclosure, your Gold Holding is not protected by the Financial Services Compensation Scheme, the Financial Ombudsman Service, any deposit guarantee scheme or any investor compensation scheme.

9.8 Your precise ownership rights and the process on an insolvency, provider cessation or vault event are governed by the applicable Goldwise and Brink’s storage arrangements.

10. Storage, vaulting and insurance

10.1 Gold purchased through Aspora Gold UK is stored by Goldwise with Brink’s in secure vaulting facilities in London.

10.2 Aspora does not operate, control, supervise or audit any vault.

10.3 Goldwise is responsible for maintaining the storage, custody, vaulting, insurance, audit and reconciliation arrangements with Vault Operator. Goldwise must provide Aspora with sufficient evidence to support the storage, allocation and insurance disclosures made to customers.

10.4 Gold held in Vault Operator’s custody is insured against physical loss, theft or damage while in Vault Operator’s custody, subject only to the insurance policy terms disclosed in the product disclosure.

10.5 Insurance may not cover all losses. Exclusions may include market loss, price movements, customer error, fraud, identity theft, cyber incidents, unauthorised account access, government action, force majeure events, delivery issues after acceptance and other exclusions specified by the insurer or Goldwise.

10.6 Goldwise may change the Vault Operator, storage location, logistics provider, insurance arrangements or audit process, subject to applicable law and Goldwise’s terms.

10.7 You may not directly instruct any Vault Operator unless Goldwise expressly permits this.

10.8 The insurance and liability arrangements maintained by the Vault Operator provide aggregate cover of up to US$25,000,000 for loss, damage or destruction of precious metals held in the vault, subject to the applicable insurance policy, its terms, exclusions, limits and conditions. This is an aggregate limit across all customers affected by the same event and is not a separate US$25,000,000 limit for each customer. Accordingly, if total claims arising from the same event exceed that amount, the recoverable amount may not fully compensate all affected customers.

11. Sale of precious metals

11.1 You may submit a request to sell all or part of your Gold Holding, subject to market availability, the limits displayed in the Aspora App, Goldwise acceptance, compliance checks, system availability and applicable law.

11.2 The sale price displayed in the Aspora App is indicative until the sale order is accepted and executed.

11.3 The sale price may differ from the purchase price due to market movements, spreads, mark-ups, fees, taxes, FX rates, liquidity and payment costs.

11.4 Sale proceeds will be paid to a previously verified bank account in your name. They are usually sent within minutes but may take up to four business days, depending on payment-system, bank, compliance and operational checks.

11.5 Aspora is not liable for market price changes between the time you view a price, submit an order, receive confirmation or receive sale proceeds.

12. Withdrawal and physical delivery

12.1 Physical delivery or withdrawal of Gold is not available at launch.

12.2 If Goldwise makes physical delivery or withdrawal available in the future, it will be subject to separate terms presented to you before you make a request. Those terms may include minimum quantity requirements, applicable fees, taxes, identity and address-verification requirements, delivery locations, restrictions and delivery timeframes.

13. Fees, spreads, mark-ups and taxes

At launch, there are no transaction fees, account fees, storage fees or separate insurance fees. The buy and sell prices shown in the Aspora App include:

(a) the applicable spread.

(b) purchase spread or mark-up;

(c) sale spread or mark-down;

(d) storage or vaulting fees;

(e) insurance fees;

(f) payment processing fees;

(g) card, bank, payment gateway, acquirer or network charges;

(h) delivery, minting, fabrication, packaging or courier fees;

(i) FX conversion charges;

(j) inactivity, account, administrative or recovery fees; and

(k) any other fees disclosed in the Aspora App or by Goldwise.

During normal market hours, the expected spread is approximately 1% when you buy and 1% when you sell. The spread may be higher outside market hours, but the applicable spread and total price will always be displayed before you confirm a Transaction.

13.1 No fee or charge may be deducted from your payment, sale proceeds or Gold Holding unless it was clearly disclosed to you before you confirmed the relevant Transaction or is required by law.

13.2 You are responsible for all taxes, reporting, duties and charges arising from your use of Aspora Gold UK.

13.3 Aspora does not provide tax advice.

13.4 Aspora or Goldwise may change future fees or spreads only by giving at least 30 days’ notice of a material change, except where an immediate change is required by law, a payment provider, market disruption, fraud prevention or security. A change will never alter a price already locked or a completed Transaction.

13.5 Gold meeting the legal definition of “investment gold” under UK VAT law is generally exempt from VAT on purchase. Whether any particular product, coin or bar qualifies, and how it will be treated for Capital Gains Tax or other tax purposes, depends on its specification and your personal circumstances. This is general information only, is not tax advice, and you should seek advice from a qualified tax adviser if you are unsure.

14. Payments, wallets and settlement

14.1 At launch, purchases are made by open-banking payment directly from your UK bank account to Goldwise’s merchant account. You approve each payment in your own banking app. Cards and Apple Pay are not available at launch.

14.2 Goldwise is the merchant of record for gold transactions. You may see Goldwise’s name when approving a payment or reviewing your bank statement.

14.3 A Transaction may not be completed until payment has been authorised, received, cleared and reconciled.

14.4 Any fiat money, wallet balance, e-money balance or payment account used to purchase gold is separate from your Gold Holding.

14.5 Any protection, safeguarding or regulatory treatment that applies to fiat money, e-money or payment services does not automatically apply to your Gold Holding.

14.6 If a payment is reversed, charged back, refunded, rejected, delayed, cancelled or found to be fraudulent, the corresponding Transaction may be cancelled, reversed or adjusted.

14.7 If payment failure occurs after precious metals have been allocated, Goldwise may reverse the allocation, sell the relevant precious metal, freeze your account, recover the relevant amount from you or take any other action permitted by law.

15. Refunds, reversals and chargebacks

15.1 Once a purchase or sale is accepted and completed, it may not be refundable or cancellable unless required by law or expressly permitted by Goldwise.

15.2 Refunds, reversals and chargebacks may be delayed or refused if:

(a) the Transaction has already been executed;

(b) gold has already been allocated, sold, delivered, withdrawn or transferred;

(c) the issue arises from incorrect information provided by you;

(d) you fail KYC, AML/CTF, sanctions or fraud checks;

(e) the payment provider, card network, bank or regulator rejects or delays the refund;

(f) market movement has occurred;

(g) Goldwise disputes liability; or

(h) applicable law does not require a refund.

15.3 If a chargeback, reversal, refund request or payment dispute is raised, Aspora and Goldwise may suspend your account, freeze your Gold Holding, reverse the relevant Transaction, withhold settlement, deduct amounts from future proceeds or request further information.

15.4 You agree to cooperate with Aspora and Goldwise in relation to any refund, reversal, chargeback or payment investigation.

16. No lending, leasing or yield unless expressly offered

16.1 Gold leasing, lending, yield, rewards, cashback, referral gold and promotional-gold features are not available. If any such feature is introduced, it will be subject to separate supplemental terms and will not apply unless you expressly accept those terms.

17. Risk warning

17.1 Gold are not cash, e-money, bank deposits or guaranteed investments.

17.2 The value of Gold may go up or down. You may receive less than you paid.

17.3 You should use Aspora Gold UK only if you understand the risks.

17.4 Key risks include:

(a) Market risk: Gold prices fluctuate and may be volatile.

(b) Spread risk: the buy price and sell price may differ.

(c) FX risk: currency movements may affect your return.

(d) Liquidity risk: you may not always be able to sell immediately or at your preferred price.

(e) Provider risk: Goldwise or a third-party provider may fail, delay, suspend services or become insolvent.

(f) Custody and vault risk: storage, vaulting and insurance arrangements are provided by Goldwise or third parties, not Aspora.

(g) Delivery risk: physical delivery may be delayed, unavailable, refused, restricted or subject to additional fees and checks.

(h) Regulatory risk: laws, regulations or regulatory expectations may change.

(i) Technology risk: the Aspora App, Goldwise systems, price feeds or payment systems may be unavailable or inaccurate.

(j) Cyber and fraud risk: unauthorised access, cyber incidents, identity theft or fraud may affect your account.

(k) Tax risk: buying, selling, holding or delivering Gold may have tax consequences.

(l) No-advice risk: Aspora does not assess whether Gold are suitable for you.

17.5 Past performance of precious metals is not a reliable indicator of future performance.

17.6 Any educational or marketing content displayed in the Aspora App is general information only and is not investment, financial, legal, tax or other professional advice.

18. UK regulatory and protection disclosure

18.1. Gold are not the same as cash, e-money or bank deposits.

18.2. Gold is not cash, e-money, a bank deposit or an FSCS-protected investment. Aspora does not provide investment advice or personal recommendations and does not assess whether Gold is suitable for you. This disclosure does not affect protections that may apply separately to Aspora’s regulated payment services.

18.3. Complaints about Gold Services are handled under Clause 23. The availability of any Financial Ombudsman Service right depends on the nature of the complaint and the relevant service; nothing in these Terms excludes a mandatory right you may have.

18.4. Any fiat wallet, payment account, e-money balance or payment service used to purchase precious metals is separate from your Gold Holding.

18.5. Any safeguarding, regulatory protection or complaint rights that apply to a fiat wallet, e-money balance or payment service do not automatically apply to your Gold Holding.

18.6. Aspora does not provide investment advice or personal recommendations. Aspora does not assess whether buying, selling, holding or withdrawing Gold is suitable for you.

18.7. Nothing in these Terms limits any mandatory consumer rights you may have under UK law.

19. System availability and errors

19.1. Aspora Gold UK may be unavailable, delayed or interrupted due to maintenance, outages, market conditions, third-party failures, payment issues, price feed issues, cyber incidents, regulatory issues, force majeure or other events.

19.2. Prices, balances, charts, confirmations, order statuses and other information displayed in the Aspora App may be delayed, incorrect or incomplete.

19.3. Aspora and Goldwise may correct any error, including:

(a) pricing error;

(b) balance error;

(c) allocation error;

(d) payment error;

(e) settlement error;

(f) fee error;

(g) delivery error; or

(h) duplicate or mistaken Transaction.

19.4. If an error occurs, Aspora or Goldwise may reverse, cancel, amend, reprice, freeze, suspend or otherwise correct the affected Transaction where permitted by law.

19.5. You must notify Aspora promptly if you notice any error, discrepancy or unauthorised activity.

20. Force majeure (Events Outside Our Control)

20.1. Neither Aspora nor Goldwise will be liable for any failure or delay in performing any obligation under these Terms caused by an event outside its reasonable control (an “Event Outside Our Control”), including strikes or industrial action, civil unrest, war or terrorism, fire, flood or other natural disaster, epidemic or pandemic, failure of public or private telecommunications or transport networks, suspension or disruption of bullion market trading (including any suspension of LBMA benchmark pricing), and any act or restriction of a government, regulator, vault operator or payment network.

20.2. If an Event Outside Our Control occurs, Aspora will notify you as soon as reasonably possible, and the affected obligations will be suspended for as long as the event continues, without either party being in breach of these Terms.

21. Provider insolvency or cessation of operations

21.1. If Goldwise ceases operations, becomes insolvent or cannot provide Gold Services, your allocated Gold must remain separate from the proprietary assets of Aspora and Goldwise to the extent provided in the applicable Goldwise and Vault Operator’s arrangements. Aspora will give you the information and support reasonably necessary to sell, transfer or otherwise deal with your Gold Holding, subject to applicable law.

21.2. Aspora will use reasonable efforts to keep the Aspora App available and to provide information about your Gold Holding during any provider cessation or insolvency event, but cannot guarantee immediate access while legal, insolvency, verification or operational processes are ongoing.

21.3. There may be delays, costs, legal processes, identity checks, ownership verification steps or operational requirements before your Gold Holding can be dealt with.

21.4. Aspora is not liable for Goldwise insolvency, Vault Operator insolvency, payment provider insolvency or any related delay or loss, except to the extent caused directly by Aspora’s own fraud, wilful misconduct or breach of applicable law.

22. Account suspension and closure

22.1. Aspora or Goldwise may suspend, restrict or close your access to Aspora Gold UK if:

(a) you breach these Terms;

(b) you breach Goldwise’s terms;

(c) you fail to provide requested information;

(d) you fail KYC, AML/CTF, sanctions or fraud checks;

(e) your account is suspected of fraud, misuse, illegal activity or suspicious activity;

(f) required by law, court order, regulator, payment provider or law enforcement authority;

(g) there is a dispute, chargeback, reversal or unpaid amount;

(h) continuing to provide Aspora Gold UK creates legal, regulatory, operational, commercial or reputational risk; or

(i) Goldwise stops providing the Precious Metals Services.

22.2. Suspension may affect your ability to buy, sell, withdraw, deliver or otherwise deal with your Gold Holding.

22.3. If your Aspora account is closed, your Gold Holding may need to be sold, transferred, delivered or otherwise dealt with in accordance with Goldwise’s terms and applicable law.

23. Complaints and support

23.1. Aspora will provide first-level support for Aspora Gold UK.

23.2. You should contact Aspora first through in-app support or the gold-specific support contact published in the Aspora App if you have a complaint or query relating to:

(a) access to Aspora Gold UK;

(b) onboarding or KYC;

(c) app display issues;

(d) failed or pending Transactions;

(e) incorrect balances;

(f) refunds, reversals or chargebacks;

(g) withdrawal or delivery;

(h) fees or pricing;

(i) account suspension; or

(j) any other customer issue.

23.3. Aspora may refer or escalate your complaint to Goldwise where the issue relates to precious metals procurement, pricing, allocation, storage, insurance, sale, withdrawal, delivery, fulfilment, compliance review or Goldwise systems.

23.4. Goldwise may contact you directly where required for legal, regulatory, KYC, delivery, complaint, fraud prevention or operational purposes.

23.5. Aspora and Goldwise may require documents, screenshots, transaction references, proof of payment, identity verification or other information before investigating a complaint.

23.6. Complaint resolution timelines may depend on the nature of the issue, Goldwise, third-party providers, payment networks, delivery partners, banks, regulators and applicable law.

23.7. Nothing in these Terms limits any mandatory complaint rights you may have under UK law.

23.8. Because the Precious Metals Services are not a regulated activity, the standard regulatory complaint-handling timelines that apply to Aspora’s regulated payment services (including the right to escalate to the Financial Ombudsman Service after 8 weeks) do not apply to complaints about the Precious Metals Services. Aspora will nonetheless aim to acknowledge and resolve complaints about Aspora Gold UK promptly and fairly.

24. Communications

24.1. Aspora may communicate with you through the Aspora App, push notification, email, SMS, WhatsApp, phone or any other contact method you have provided.

24.2. Communications may include confirmations, receipts, KYC requests, delivery updates, complaints updates, legal notices, risk warnings, operational notices, pricing notices, fee notices and regulatory notices.

24.3. You must keep your contact information accurate and up to date.

24.4. Notices sent to your registered contact details will be treated as received unless Aspora receives a delivery failure notification.

25. Customer responsibilities

25.1 You must:

(a) provide accurate, complete and up-to-date information;

(b) keep your account credentials secure;

(c) use Aspora Gold UK only for lawful purposes;

(d) not use Aspora Gold UK for money laundering, terrorist financing, sanctions evasion, fraud, tax evasion or illegal activity;

(e) ensure your payment method belongs to you and is lawfully funded;

(f) review prices, fees, confirmations and disclosures before placing any order;

(g) monitor your account and report errors promptly;

(h) comply with applicable tax, customs, import and reporting obligations;

(i) cooperate with KYC, AML/CTF, sanctions, fraud and complaint investigations; and

(j) comply with these Terms and Goldwise’s terms.

25.2 You are responsible for all activity on your account unless caused by Aspora’s fraud, wilful misconduct or breach of applicable law.

26. Limitation of liability

26.1 Nothing in these Terms limits or excludes liability that cannot be limited or excluded by law, including liability for death or personal injury caused by negligence, fraud or fraudulent misrepresentation.

26.2 Aspora is not liable for:

(a) gold price movements;

(b) market loss;

(c) loss of profit, opportunity, goodwill, business or anticipated savings;

(d) indirect, special or consequential loss;

(e) Goldwise’s acts or omissions;

(f) Vault Operator acts or omissions;

(g) payment provider, bank, card network, courier, logistics provider or third-party failures;

(h) delays in delivery, sale, settlement, withdrawal or redemption;

(i) rejected, suspended or delayed Transactions due to KYC, AML/CTF, sanctions, fraud or legal checks;

(j) taxes, duties, customs charges or import restrictions;

(k) system outages, price feed errors or data display errors caused by third parties;

(l) force majeure events; or

(m) any loss caused by your breach of these Terms.

26.3 Subject to clause 26.1 and to the extent permitted by applicable law, Aspora’s aggregate liability for direct loss arising from its breach of these Terms, negligence or failure to perform the Aspora Role shall not exceed the greater of:

(a) £1,000; and

(b) the value of the Transaction giving rise to the claim.

Nothing in these Terms limits or excludes any right or remedy that cannot lawfully be excluded or limited.

26.4 Goldwise’s liability to you is governed by Goldwise’s applicable terms.

27. Changes to these Terms

27.1 Aspora may update these Terms from time to time.

27.2 Changes may be made to reflect changes to the Precious Metals Services, Goldwise’s terms, applicable law, regulation, regulator expectations, operational requirements, payment arrangements, tax treatment, compliance controls, fees, product structure or risk controls.

27.3 Aspora will give at least 30 days’ notice of a material adverse change through the Aspora App, email or another communication channel, unless an immediate change is required by law, a regulator, fraud prevention, security or urgent operational risk.

27.4 Continued use of Aspora Gold UK after a change takes effect means you accept the updated Terms, except where you exercise any right to close your Gold position or terminate the relevant service before the change takes effect.

28. Termination or withdrawal of Aspora Gold UK

28.1 Aspora may suspend, withdraw, discontinue or terminate Aspora Gold UK at any time.

28.2 Aspora may do so where:

(a) the Goldwise relationship ends;

(b) Goldwise can no longer provide the Precious Metals Services;

(c) required by law or regulator expectation;

(d) payment, banking, vaulting, delivery or compliance arrangements become unavailable;

(e) Aspora changes or discontinues the product; or

(f) continuing the product creates unacceptable legal, regulatory, commercial or operational risk.

28.3 If Aspora Gold UK is terminated, Aspora will give reasonable notice unless immediate action is required by law or to manage an urgent risk, and will provide information about how existing Gold Holdings may be sold, transferred or otherwise dealt with under the applicable Goldwise and Vault Operator’s arrangements.

29. Governing law and disputes

29.1 These Terms are governed by the laws of England and Wales.

29.2 The courts of England and Wales shall have jurisdiction over disputes arising from or in connection with these Terms, unless mandatory consumer law requires otherwise.

30. Customer acknowledgement

By using Aspora Gold UK, you confirm that:

(a) you have read and accepted these Terms;

(b) you understand that Goldwise is the seller and merchant of record and that Aspora is not the seller, buyer, custodian, vault operator, insurer or deliverer of Gold;

(c) you understand that Goldwise provides the Gold Services and Goldwise’s custody arrangement with Brink’s applies to your Gold Holding;

(d) you understand that precious metals prices may go down as well as up;

(e) you understand that your Gold Holding is not cash, e-money or a bank deposit;

(f) you understand that your Gold Holding may not be protected by the Financial Services Compensation Scheme;

(g) you acknowledge that Aspora may share your personal data and transaction data with Goldwise and relevant service providers as described in the Aspora Privacy Policy; Aspora will not share copies of your identity-verification documents or KYC records with Goldwise unless required by law or specifically disclosed to you; and

(h) you understand that Transactions may be delayed, rejected, suspended or reversed for KYC, AML/CTF, sanctions, fraud, payment, legal, regulatory, technical or operational reasons.