Platform Terms and Legal Policies

1. Terms and Conditions

1.1 About SIMODI GOLD

SIMODI GOLD FZCO is a digital precious-metals ownership and storage platform that allows eligible users to buy, sell, store, track, and redeem physical gold and silver through the SIMODI GOLD application, website, and related channels. SIMODI GOLD provides access to physical precious-metals ownership records, custody arrangements, transaction processing, redemption coordination, customer support, compliance operations, and related platform services. SIMODI GOLD is not a bank, deposit-taking institution, investment fund, securities exchange, broker, regulated investment adviser, payment institution, collective investment scheme, or virtual asset exchange unless expressly stated in writing and supported by the relevant licence or approval.

1.2 Agreement between the user and SIMODI GOLD

These Terms, together with any product terms, fee schedule, privacy policy, AML/KYC policy, risk disclosure, redemption policy, audit policy, complaints policy, cookie policy, platform notices, and any other policy published by SIMODI GOLD from time to time, form the agreement between the user and SIMODI GOLD. If there is any inconsistency between these Terms and a product-specific or transaction-specific notice, the more specific notice will apply to the relevant product or transaction, unless prohibited by applicable law. The agreement applies from the earlier of the date the user accepts these Terms, creates an account, accesses the app or website, submits information, places an order, makes a payment, receives a metal credit, requests redemption, or otherwise uses SIMODI GOLD services.

1.3 Availability and eligibility

SIMODI GOLD services are available only to users who satisfy SIMODI GOLD eligibility requirements and applicable legal, regulatory, compliance, operational, and risk requirements. Users must be at least 18 years old or the legal age of majority in their jurisdiction, whichever is higher. SIMODI GOLD may restrict or refuse access from any country, region, user, entity, payment method, transaction type, delivery location, product type, or risk category at its discretion and in accordance with applicable law, including where:

• The user is located in a prohibited or restricted jurisdiction;
• The user is subject to sanctions or acts for a sanctioned person;
• The user uses illegal, suspicious, third-party, or unverifiable funds;
• The user fails onboarding, screening, risk assessment, or verification;
• SIMODI GOLD determines that providing services would create legal, regulatory, banking, payment, logistics, reputational, or operational risk.

1.3A U.S. Persons Restriction

SIMODI GOLD FZCO does not currently provide services to U.S. persons. For the purposes of these Terms, a U.S. person may include, without limitation, any person who is a citizen, national, resident, green-card holder, tax resident, or person located in the United States, and any entity organised, incorporated, established, registered, operating from, or beneficially owned or controlled by U.S. persons, where applicable under U.S. or other relevant laws.

Users must not access, register, onboard, purchase, sell, store, redeem, transfer, or otherwise use SIMODI GOLD services if they are a U.S. person or are acting on behalf of a U.S. person, unless SIMODI GOLD expressly confirms eligibility in writing after completing legal, regulatory, banking, payment-provider, sanctions, tax, and compliance review.

SIMODI GOLD may require users to provide declarations regarding citizenship, nationality, residence, tax residence, location, beneficial ownership, source of funds, and any U.S. connection. SIMODI GOLD may reject onboarding, block registration, restrict access, suspend or close an account, cancel or reverse transactions, refuse redemption or withdrawal, and return funds where permitted if SIMODI GOLD determines or reasonably suspects that the user is a U.S. person, is located in the United States, is acting for a U.S. person, or presents U.S. legal, regulatory, tax, banking, sanctions, payment, or operational risk.

Users are responsible for ensuring that their use of SIMODI GOLD is lawful in their country of citizenship, nationality, residence, tax residence, physical location, and delivery destination. SIMODI GOLD may update this restriction at any time to reflect changes in law, regulatory expectations, licensing, banking requirements, payment-provider requirements, risk appetite, or business operations.

1.4 Gold and silver products

The products available through SIMODI GOLD may include physical gold and physical silver ownership rights, storage, sale, purchase, tracking, redemption, gifting, promotional features, and related operational services. Unless otherwise stated in the app, one gram of gold shown in the platform equals one gram of .999 pure physical gold, and one gram of silver shown in the platform equals one gram of .999 pure physical silver. SIMODI GOLD intends to maintain physical gold and silver reserves corresponding to customer metal holdings on a one-to-one basis, subject to operational reconciliation, audit timing, settlement timing, transaction processing, and other reasonable operational adjustments. Customer metals are not intended to be lent, pledged, leased, borrowed against, or rehypothecated by SIMODI GOLD, except where expressly disclosed, legally permitted, and separately agreed with the user.

1.5 Allocated, pooled, and segregated holdings

Customer holdings may be held in allocated, pooled, or segregated custody arrangements, depending on product type, vault arrangements, operational requirements, redemption requirements, availability, legal requirements, Shariah review, and applicable law. Unless SIMODI GOLD expressly confirms that a holding is individually allocated or segregated, customer holdings may represent beneficial ownership rights in a pooled quantity of physical gold or silver of equivalent type, purity, and quantity recorded in the user account. Pooled holdings do not necessarily entitle the user to specific serial-numbered bars, coins, or products unless SIMODI GOLD expressly confirms such allocation in writing or through the app. SIMODI GOLD may substitute bars, lots, serial numbers, refiners, vault locations, or product forms of equivalent metal type, quantity, and purity where needed for operational, security, redemption, audit, or vault-management purposes.

1.6 No deposit, no e-money, no investment product

Balances and metal quantities shown in the SIMODI GOLD app are platform records of metal holdings, transaction entitlements, or account balances. They are not bank deposits, e-money, stored-value balances, securities, fund units, debt instruments, profit-sharing interests, guaranteed repayment obligations, or insured deposits unless expressly required by applicable law. SIMODI GOLD does not guarantee profit, capital protection, liquidity, redemption timelines, price stability, future performance, or continuous availability of any service.

1.7 Shariah principles

SIMODI GOLD aims to structure its gold and silver services in a manner consistent with Shariah principles relating to physical ownership and exchange of precious metals, including principles commonly associated with Bay al-Sarf. The platform is designed to support physical backing, clear ownership records, no interest, no yield, no dividend, no guaranteed return, no speculative leverage, no metal lending, and transfer of ownership after confirmed payment and transaction acceptance. SIMODI GOLD may appoint Shariah advisers, obtain Shariah review, or publish Shariah-related disclosures from time to time. Users acknowledge that Shariah interpretations may differ between scholars, institutions, jurisdictions, and regulators.

1.8 No advice

SIMODI GOLD provides execution, storage, tracking, redemption, and operational services on a non-advisory basis. SIMODI GOLD does not provide financial, investment, legal, tax, accounting, regulatory, estate-planning, or Shariah advice. Information provided through the app, website, marketing material, pricing pages, customer support, market commentary, educational content, or notifications is general information only and must not be treated as a recommendation, advice, guarantee, or personal suitability assessment. Users are responsible for making their own independent decisions and obtaining independent professional advice where appropriate.

1.9 Regulatory status and applicable law

SIMODI GOLD operates under applicable UAE laws, Dubai laws, commercial permissions, licences, registrations, regulatory requirements, AML/CFT/CPF obligations, sanctions requirements, tax obligations, and business requirements relevant to its activities. Unless expressly stated in writing, SIMODI GOLD is not licensed as a bank, securities exchange, investment fund, virtual asset exchange, deposit-taking institution, regulated investment adviser, broker-dealer, payment institution, or collective investment scheme. SIMODI GOLD may update its regulatory structure, licences, registrations, operating model, service availability, jurisdictional coverage, onboarding requirements, or product availability to comply with law, regulator expectations, banking requirements, payment-provider requirements, or business requirements. Users are responsible for ensuring that use of SIMODI GOLD is lawful in their country of residence, citizenship, tax residence, nationality, location, and delivery destination.

1.10 Account registration and verification

To use SIMODI GOLD, users must create an account and provide accurate, current, complete, and non-misleading information. SIMODI GOLD may request information before onboarding, during onboarding, before a transaction, during ongoing monitoring, before withdrawal or redemption, during complaint handling, or at any other time required for compliance, operational, legal, risk, security, or audit purposes, including:

• Full legal name, date of birth, nationality, residential address, phone number, and email address;
• Identity documents, proof of address, selfie or biometric verification where required;
• Bank-account, payment-method, wallet, or card details;
• Source of funds and source of wealth information;
• Company documents, ownership information, authorised-person information, and corporate approvals where applicable;
• Tax information, declarations, sanctions information, beneficial-owner information, and any additional compliance documents requested by SIMODI GOLD.

1.11 User information and ongoing duties

Users must promptly update SIMODI GOLD if any information provided becomes inaccurate, incomplete, outdated, or misleading, including changes to name, nationality, residence, tax residence, beneficial ownership, authorised representatives, bank details, payment method, phone number, email address, or source of funds. If the user fails to provide requested information or provides information that SIMODI GOLD considers incomplete, inaccurate, suspicious, unverifiable, or inconsistent with risk requirements, SIMODI GOLD may refuse onboarding, reject transactions, freeze, restrict, suspend, block, close, or terminate the account, delay settlement, reject redemption, or report activity to competent authorities where required or permitted by law.

1.12 AML, KYC, sanctions, fraud, and CPF controls

SIMODI GOLD maintains anti-money laundering, counter-terrorist financing, counter-proliferation financing, sanctions screening, fraud prevention, customer due diligence, enhanced due diligence, transaction monitoring, suspicious-activity reporting, and record-keeping controls in accordance with applicable UAE laws and regulations, including UAE AML/CFT/CPF requirements as amended or replaced from time to time. Where SIMODI GOLD is classified as a dealer in precious metals and stones, designated non-financial business or profession, or other regulated business, it will comply with applicable registration, reporting, customer due diligence, enhanced due diligence, goAML, suspicious transaction reporting, record-keeping, and supervisory obligations. SIMODI GOLD may screen users, beneficial owners, authorised persons, payment senders, recipients, counterparties, delivery addresses, and transactions against UAE, United Nations, OFAC, European Union, United Kingdom, FATF-related, sanctions, watchlist, politically exposed person, adverse media, and other risk databases.

1.12A Compliance governance and AML controls

SIMODI GOLD maintains compliance governance arrangements responsible for day-to-day compliance operations, customer due diligence, enhanced due diligence, sanctions screening, transaction monitoring, escalation of suspicious activity, record keeping, regulatory coordination, and implementation of internal AML/CFT/CPF controls. This may include or support a nominated compliance officer, MLRO or equivalent responsible person where required by applicable law, regulator expectations, banking requirements, payment-provider requirements, or internal governance.

1.12B UAE DPMS and DNFBP compliance

Where SIMODI GOLD is classified as a Dealer in Precious Metals and Stones, Designated Non-Financial Business or Profession, or other supervised business under applicable UAE AML/CFT/CPF laws and regulations, SIMODI GOLD will comply with applicable Ministry of Economy, UAE Financial Intelligence Unit, goAML, targeted financial sanctions, customer due diligence, enhanced due diligence, suspicious transaction reporting, record-keeping, audit, registration, and supervisory requirements as amended or replaced from time to time.

1.12C Targeted financial sanctions and goAML reporting

SIMODI GOLD may immediately freeze, suspend, reject, block, cancel, restrict, or report any account, transaction, payment, redemption, delivery, transfer, or asset where there is a confirmed, potential, partial, or suspected sanctions match, without prior notice to the user where permitted or required by law. SIMODI GOLD may submit required reports, suspicious transaction reports, suspicious activity reports, funds-freeze reports, partial-name-match reports, or other regulatory filings through goAML or any other official UAE reporting channel.

1.12D Transaction monitoring, thresholds, and linked transactions

SIMODI GOLD may monitor single transactions, linked transactions, split transactions, cumulative transactions, repeated small purchases, rapid buy-and-sell activity, unusual redemption activity, third-party funding patterns, geographic risk, product risk, payment risk, device and IP indicators, and activity inconsistent with the user's profile. SIMODI GOLD may apply UAE-relevant thresholds, including any threshold applicable to dealers in precious metals and stones, and may request additional information, source of funds, source of wealth, invoices, bank statements, proof of business activity, tax information, or other documents before accepting or completing a transaction.

1.12E No anonymous, nominee, or undisclosed third-party accounts

SIMODI GOLD does not permit anonymous accounts, false-name accounts, nominee accounts, undisclosed beneficial-owner accounts, accounts operated on behalf of an undisclosed third party, third-party funded accounts, third-party withdrawals, or accounts used to disguise the true customer, payer, beneficiary, source of funds, source of wealth, or purpose of a transaction. Payments, withdrawals, refunds, sale proceeds, transfers, and redemptions may be limited to accounts and persons verified and approved by SIMODI GOLD.

1.12F Responsible sourcing and supplier due diligence

SIMODI GOLD may conduct due diligence on suppliers, refineries, mints, vault providers, logistics providers, counterparties, and precious-metal supply chains. SIMODI GOLD may require invoices, assay certificates, refinery documentation, customs documents, shipping documents, responsible-sourcing confirmations, sanctions confirmations, ownership confirmations, or other supporting evidence. SIMODI GOLD may reject, suspend, or report any metal, supplier, counterparty, transaction, or delivery linked or suspected to be linked to sanctions, conflict, illegal mining, smuggling, fraud, bribery, corruption, human-rights abuse, tax evasion, money laundering, terrorist financing, proliferation financing, or other unlawful activity.

1.12G Internal AML framework and records

The user-facing Terms form part of SIMODI GOLD's external legal framework and are supported by internal compliance procedures, which may include an enterprise-wide risk assessment, customer risk-rating methodology, onboarding and ongoing monitoring procedure, sanctions and targeted financial sanctions procedure, transaction monitoring rules, suspicious-activity escalation procedure, record-retention procedure, staff training, compliance testing, audit review, and management oversight. SIMODI GOLD may retain customer, transaction, screening, compliance, audit, and communication records for the period required or permitted by applicable law and may use those records for compliance, audit, regulatory reporting, dispute resolution, security, and enforcement purposes.

1.12H Enhanced due diligence and refusal of service

SIMODI GOLD may apply enhanced due diligence to higher-risk customers, politically exposed persons, high-risk jurisdictions, complex ownership structures, unusual payment patterns, unusually large or linked transactions, redemption requests, adverse media matches, sanctions exposure, or any activity that SIMODI GOLD considers higher risk. SIMODI GOLD may refuse onboarding, delay or reject transactions, restrict services, terminate accounts, return funds to source, or report activity where information is incomplete, unverifiable, suspicious, inconsistent with the user profile, or not aligned with SIMODI GOLD's risk appetite.

1.12I User declarations and continuing compliance duties

Users must provide accurate and complete declarations relating to identity, nationality, residence, tax residence, beneficial ownership, U.S. person status, source of funds, source of wealth, payment ownership, delivery details, sanctions exposure, and purpose of transactions. Users must promptly update SIMODI GOLD if any information changes. SIMODI GOLD may rely on user declarations and may independently verify information through internal checks, third-party vendors, public sources, official registers, banks, payment providers, regulators, law enforcement, or other lawful sources.

1.13 Orders, quotes, and transaction acceptance

A price, quote, rate, chart, indicative value, estimate, or displayed amount in the SIMODI GOLD app or website is indicative only and is not an offer, guarantee, or commitment to execute a transaction at that price unless SIMODI GOLD expressly accepts the order. An order is received only when SIMODI GOLD systems receive it, and an order is binding only when SIMODI GOLD accepts it. SIMODI GOLD is not liable for delayed receipt, non-receipt, duplication, corruption, incompleteness, ambiguity, system delay, transmission failure, or payment delay relating to any order. SIMODI GOLD is not obliged to accept any order, payment, sale request, purchase request, transfer, gift, redemption request, withdrawal, or instruction. SIMODI GOLD may reject, delay, cancel, reverse, amend, or refuse to process any request for legal, compliance, security, operational, market, liquidity, payment, pricing, fraud, sanctions, tax, banking, logistics, vault, technology, or risk reasons.

1.14 Buying gold and silver

Users may purchase gold or silver through approved SIMODI GOLD channels using approved payment methods. A purchase is confirmed only when payment is successfully received in cleared funds, compliance checks are completed, SIMODI GOLD accepts the transaction, and the relevant metal quantity is credited to the user account. Displayed prices may include market price, spread, service fees, storage fees, taxes, payment fees, currency conversion, bank charges, or other applicable charges. Prices may change before confirmation due to market movement, liquidity, payment settlement, operational delay, system processing, or risk controls.

1.15 Selling gold and silver

Users may sell eligible holdings through the SIMODI GOLD app, subject to platform availability, market conditions, liquidity, fees, minimums, maximums, compliance checks, account status, and operational requirements. A user may not sell more metal than the eligible quantity recorded in the user account. Sale proceeds may be paid only to an approved bank account, payment method, wallet, or account registered under the verified user name unless SIMODI GOLD approves otherwise. SIMODI GOLD may delay, reject, cancel, adjust, or reverse a sale request where required or appropriate for compliance, legal, fraud, sanctions, payment, operational, market, liquidity, pricing, or security reasons.

1.16 Manifest error, system error, and pricing error

If SIMODI GOLD reasonably believes that an order, quote, price, fee, metal quantity, exchange rate, account balance, chart, transaction, redemption value, promotional value, or calculation contains or is based on a manifest error, system error, feed error, typographical error, pricing error, liquidity error, latency issue, data-source error, operational error, or obvious mistake, SIMODI GOLD may cancel, void, reverse, amend, reprice, correct, or adjust the affected order, transaction, balance, record, or instruction. SIMODI GOLD may take into account market conditions, reference prices, liquidity, data sources, system logs, payment status, transaction history, third-party provider information, customer conduct, and any other relevant information when determining whether an error occurred. Where the user exploits or attempts to exploit latency, system faults, misquotations, promotional errors, app defects, arbitrage opportunities created by system error, or any other abnormal pricing or platform condition, SIMODI GOLD may cancel or reverse affected transactions, restrict the account, recover amounts, set off balances, and terminate access.

1.17 Payments, deposits, withdrawals, and return to source

SIMODI GOLD may accept payment through bank transfer, debit card, credit card, payment gateway, digital wallet, or other approved method. Payments must come from accounts, cards, wallets, or payment methods held in the verified user name unless SIMODI GOLD approves otherwise. SIMODI GOLD does not normally accept third-party payments. SIMODI GOLD may reject, return, freeze, hold, investigate, or report third-party, suspicious, mismatched, duplicate, chargeback-related, unverifiable, or irregular payments. Withdrawals and sale proceeds may be subject to a return-to-source policy. SIMODI GOLD may return funds to the same payment method, bank account, card, or source from which funds were received, unless prohibited by law or otherwise approved by SIMODI GOLD. Deposits, withdrawals, refunds, and sale proceeds may be delayed due to bank processing, payment-provider review, compliance checks, sanctions screening, fraud checks, technical issues, weekends, public holidays, currency conversion, or third-party provider delays. SIMODI GOLD is not liable for delays outside its reasonable control.

1.18 Chargebacks and disputed payments

If a user initiates a chargeback, card dispute, payment reversal, cancellation request, bank recall, or similar process after using SIMODI GOLD, SIMODI GOLD may suspend the account, freeze metal holdings, withhold withdrawals, reverse or cancel transactions, set off amounts owed, recover fees, reject further orders, or terminate the account. If SIMODI GOLD reasonably suspects that a chargeback, cancellation, or payment dispute is dishonest, abusive, fraudulent, mistaken, or inconsistent with the user's completed transaction, SIMODI GOLD may investigate, provide records to banks and payment providers, recover losses, and report the matter where required or permitted by law. The user is responsible for chargeback fees, failed-payment fees, bank charges, payment-provider charges, legal costs, administrative costs, and losses arising from failed, reversed, disputed, fraudulent, or unauthorised payments except to the extent prohibited by applicable law.

1.19 Currency conversion and calculations

SIMODI GOLD may make currency conversions where necessary or desirable for payments, purchases, sales, withdrawals, refunds, fees, taxes, redemption, account records, or compliance requirements. Currency conversions may be made at rates determined by SIMODI GOLD, payment providers, banks, liquidity providers, or other third parties. Users bear foreign-exchange risk, spread, conversion charges, and timing differences unless prohibited by applicable law. SIMODI GOLD may determine calculation methods for balances, prices, fees, spreads, taxes, refunds, adjustments, and conversions acting in good faith.

1.20 Physical redemption and delivery

Users may request physical redemption of gold or silver where available. For now, SIMODI GOLD offers physical delivery only within the United Arab Emirates. International delivery is not currently available unless SIMODI GOLD expressly confirms otherwise in writing or through the app. Redemption may be provided in bars, coins, minted products, or other approved formats selected by SIMODI GOLD or made available in the app. Redemption is subject to minimum and maximum quantities, product availability, vault availability, fabrication, minting, UAE delivery coverage, insurance, tax, logistics, compliance, and security requirements. SIMODI GOLD may use third-party couriers, insurers, vault providers, logistics companies, mints, refiners, or service providers for UAE delivery. Users are responsible for accurate UAE delivery information, identity verification at delivery, local laws, taxes, duties, and receiving arrangements. If delivery fails because the user provides inaccurate information, is unavailable, fails identity checks, refuses delivery, or does not cooperate, SIMODI GOLD may cancel the delivery request, charge re-delivery or storage fees, return the item to custody, sell or re-credit the metal, or process the matter as reasonably appropriate.

1.21 Gifts, transfers, and promotions

SIMODI GOLD may allow gifting, transfers, referrals, rewards, promotional wallets, bonus credits, discounts, or other promotional features from time to time. Promotional features are discretionary and may be subject to separate terms, eligibility criteria, expiry dates, minimum purchases, redemption restrictions, country restrictions, and fraud controls. Promotional credits, where offered, are not cash, deposits, e-money, stored value, or withdrawable balances unless expressly stated. SIMODI GOLD may modify, suspend, cancel, reverse, expire, or withdraw promotions at any time where permitted by law, including where abuse, fraud, error, duplicate accounts, or misuse is suspected.

1.22 Storage, custody, and insurance

SIMODI GOLD arranges secure storage of physical gold and silver through internal vault facilities, approved vault operators, or other secure custody arrangements. Metals may be stored in the UAE or other approved jurisdictions. Physical delivery is currently available only within the United Arab Emirates unless SIMODI GOLD expressly confirms otherwise. SIMODI GOLD may maintain insurance coverage for metals held in custody, subject to policy terms, exclusions, deductibles, limits, insurer approval, claim procedures, and applicable law. Insurance may not cover all losses, events, countries, products, or circumstances. Users acknowledge that custody may involve vault risk, logistics risk, insurance exclusions, third-party provider risk, audit timing risk, operational risk, force majeure, and regulatory restrictions.

1.23 Audits, reconciliations, and proof of reserves

SIMODI GOLD may conduct daily or periodic internal reconciliations and independent third-party audits, confirmations, attestations, or proof-of-reserve reports of gold and silver reserves. Audits may include vault balance verification, user balance reconciliation, physical metal inspection, reserve-to-customer-liability reconciliation, confirmation from vault providers, and exception reporting. SIMODI GOLD may publish audit summaries, reserve attestations, or proof-of-reserve reports from time to time while protecting sensitive vault, security, customer, commercial, regulatory, and operational information. Audit frequency, auditor identity, methodology, scope, and publication format may vary.

1.24 Fees, charges, spreads, and taxes

SIMODI GOLD may charge buy spreads, sell spreads, storage fees, redemption fees, delivery fees, insurance fees, minting fees, fabrication fees, currency conversion fees, payment processing fees, bank transfer fees, failed-payment fees, chargeback fees, compliance review fees, account closure fees, inactive-account fees, and other fees displayed in the app, website, or fee schedule where reasonably practicable. Fees may be deducted from account balances, payments, sale proceeds, refunds, withdrawals, metal balances, promotional balances, or redemption amounts where permitted by law. Users are responsible for determining and paying all taxes, duties, levies, zakat, reporting obligations, customs duties, import taxes, VAT, income tax, capital gains tax, wealth tax, or other obligations arising from use of SIMODI GOLD. SIMODI GOLD does not provide tax advice.

1.25 User responsibilities and prohibited activities

Users agree to provide accurate information, keep credentials secure, use only lawful funds, comply with applicable law, cooperate with SIMODI GOLD checks, avoid misuse of the platform, monitor account activity, and notify SIMODI GOLD immediately of unauthorized access or suspicious activity. Users must not use SIMODI GOLD for fraud, money laundering, terrorist financing, proliferation financing, sanctions evasion, tax evasion, illegal trade, market abuse, false documentation, unauthorized access, stolen funds, abusive promotions, duplicate accounts, bot activity, reverse engineering, interference with platform operations, or any unlawful purpose.

1.26 Authority to act on instructions

SIMODI GOLD may act on any order, instruction, communication, account action, redemption request, payment instruction, withdrawal request, transfer, gift, or support request that appears to come from the user, an authorised person, or a person using the user's access credentials, without further inquiry, unless SIMODI GOLD determines that additional verification is required. Users are responsible for all account activity resulting from their credentials, devices, authorised persons, negligence, failure to secure access, or failure to notify SIMODI GOLD promptly of suspected unauthorized access, except to the extent prohibited by applicable law.

1.27 Account suspension, restrictions, termination, and set-off

SIMODI GOLD may immediately suspend, freeze, restrict, block, close, or terminate an account, reject orders, refuse withdrawals, delay redemption, withhold settlement, or take other protective action if SIMODI GOLD considers it necessary or appropriate for legal, compliance, sanctions, fraud, security, tax, payment, operational, market, vault, logistics, regulatory, reputational, or risk reasons. SIMODI GOLD may set off, deduct, retain, recover, or apply any money, metal balance, promotional credit, refund, sale proceeds, redemption amount, or other amount held for the user against any amount owed by the user to SIMODI GOLD, its affiliates, payment providers, logistics providers, or other service providers, to the extent permitted by applicable law. Where legally permitted, SIMODI GOLD may allow the user to sell, withdraw, or redeem remaining eligible metals after compliance review and settlement of outstanding obligations.

1.28 Events of default

Each of the following may constitute an event of default or risk event: breach of these Terms; failure to pay amounts due; failed or disputed payments; fraud or suspected fraud; false or misleading information; failure to complete KYC or ongoing due diligence; sanctions match or suspected sanctions risk; suspicious activity; unlawful use; abusive trading or promotional conduct; insolvency, bankruptcy, liquidation, death, incapacity, or corporate restructuring; unauthorized access; chargeback abuse; misuse of the app; default under another agreement with SIMODI GOLD; or any event that SIMODI GOLD reasonably considers may create legal, regulatory, operational, financial, reputational, or market risk. Upon an event of default or suspected event of default, SIMODI GOLD may refuse further orders, cancel pending transactions, close the account, set off amounts, sell or liquidate holdings where permitted, withhold withdrawals, restrict redemption, recover losses, report activity, or take any action reasonably required to protect SIMODI GOLD, users, service providers, or the integrity of the platform.

1.29 Death, incapacity, estate, and corporate changes

If SIMODI GOLD is notified of a user's death or incapacity, SIMODI GOLD may freeze or restrict the account until it receives documents, court orders, probate documents, succession certificates, inheritance documents, corporate approvals, authorised-person instructions, or other evidence satisfactory to SIMODI GOLD. SIMODI GOLD may act on instructions from a competent court, authority, executor, administrator, guardian, authorised representative, corporate officer, or other person recognised by SIMODI GOLD under applicable law. SIMODI GOLD is not liable for delay caused by incomplete, disputed, conflicting, foreign, unverifiable, or legally insufficient documents.

1.30 Technology, cybersecurity, and app availability

SIMODI GOLD uses reasonable security measures to protect the platform. However, SIMODI GOLD does not guarantee that the app, website, systems, servers, databases, APIs, payment links, notifications, or communication channels will be uninterrupted, error-free, secure, virus-free, or immune from cyberattack. SIMODI GOLD is not liable for losses caused by app downtime, internet failure, device failure, system error, data feed error, cyberattack, unauthorized access caused by user negligence, transmission error, payment gateway failure, third-party outage, maintenance, force majeure, or events outside its reasonable control, except to the extent liability cannot be excluded by law. Users must not use bots, scripts, scraping tools, automated trading systems, artificial intelligence tools, mass data entry, reverse engineering, vulnerability scanning, or other technical methods to access or use the platform without SIMODI GOLD's prior written approval.

1.31 Third-party providers

SIMODI GOLD may use banks, payment processors, card schemes, payment gateways, wallet providers, vault operators, insurers, logistics companies, KYC/AML vendors, sanctions-screening vendors, fraud-prevention vendors, technology vendors, cloud providers, auditors, legal advisers, tax advisers, compliance advisers, mints, refiners, and other service providers. SIMODI GOLD is not responsible for third-party delays, outages, rejections, fees, restrictions, errors, customs issues, courier failures, bank delays, payment-provider disputes, vault-provider limitations, or regulatory restrictions except to the extent required by applicable law.

1.32 Data protection, confidentiality, and records

SIMODI GOLD processes personal data in accordance with applicable UAE data protection laws, including the UAE Personal Data Protection Law where applicable, and the SIMODI GOLD Privacy Policy. SIMODI GOLD may collect, process, disclose, transfer, and retain personal data and transaction records for account creation, identity verification, AML/CFT/CPF controls, sanctions screening, fraud prevention, transaction processing, redemption, customer support, audit, reporting, legal compliance, dispute resolution, security monitoring, service improvement, and marketing where permitted. SIMODI GOLD may retain customer identification records, transaction records, communications, compliance reviews, screening results, audit logs, and supporting documents for the minimum period required by applicable law and longer where necessary for legal, regulatory, tax, audit, security, dispute, or enforcement purposes. SIMODI GOLD records, system logs, app records, communications, confirmations, statements, and transaction records are evidence of user activity and may be used in complaints, investigations, audits, regulatory reporting, and legal proceedings.

1.33 Communications, notices, and electronic acceptance

SIMODI GOLD may communicate with users through the app, website, email, SMS, phone, post, push notification, in-app message, electronic chat, customer support channel, or any other approved method. Users agree that electronic acceptance, including clicking a button, checking a box, entering a code, using the app, placing an order, submitting a payment, or continuing to use the services, is legally binding. SIMODI GOLD may record, monitor, retain, and use communications for training, security, compliance, complaint handling, regulatory reporting, fraud prevention, and dispute resolution where permitted by law.

1.34 Intellectual property

All intellectual property rights in the SIMODI GOLD app, website, logo, brand, trade names, trademarks, software, designs, text, content, databases, pricing screens, documentation, workflows, and platform materials belong to SIMODI GOLD or its licensors. Users may not copy, reproduce, distribute, modify, resell, scrape, reverse engineer, decompile, exploit, or commercially use SIMODI GOLD intellectual property without prior written consent.

1.35 Limitation of liability

To the maximum extent permitted by law, SIMODI GOLD, its directors, officers, employees, shareholders, affiliates, agents, representatives, and service providers are not liable for loss of profit, loss of opportunity, market losses, price movement, currency losses, tax losses, indirect losses, consequential losses, special damages, punitive damages, loss of goodwill, loss of data, payment delays, third-party failures, technology failures, force majeure, regulatory actions, user error, unauthorized access caused by user negligence, or any loss not directly and solely caused by SIMODI GOLD's proven fraud or gross negligence. Where liability cannot be excluded, SIMODI GOLD's total liability shall be limited to the lower of the value of the user's eligible metal balance affected by the relevant event, the amount of fees paid by the user to SIMODI GOLD for the affected service in the preceding six months, or the maximum amount permitted under applicable law. Nothing in these Terms excludes liability that cannot be excluded under applicable law.

1.36 Indemnity

Users agree to indemnify and hold harmless SIMODI GOLD, its directors, officers, employees, shareholders, affiliates, agents, representatives, and service providers from claims, losses, damages, liabilities, penalties, fines, taxes, costs, expenses, legal fees, administrative costs, and third-party claims arising from breach of these Terms, violation of law, misuse of the platform, false information, fraudulent activity, unauthorized account use caused by user negligence, chargebacks, tax obligations, third-party claims, or failure to comply with user responsibilities.

1.37 Force majeure and exceptional events

SIMODI GOLD is not liable for delay or failure to perform caused by events beyond its reasonable control, including war, civil unrest, terrorism, natural disaster, fire, flood, pandemic, cyberattack, power outage, internet failure, banking disruption, payment-network failure, sanctions, regulatory action, government restriction, customs delay, logistics disruption, vault closure, supplier failure, mint failure, refiner failure, market closure, excessive market movement, or gold or silver supply disruption. During a force majeure or exceptional event, SIMODI GOLD may suspend, delay, modify, cancel, reverse, restrict, reprice, or refuse services, orders, withdrawals, redemptions, deliveries, payments, or app access as reasonably necessary.

1.38 Amendments and policy updates

SIMODI GOLD may update these Terms and policies from time to time by publishing the updated version in the app, on the website, by email, or through another approved channel. Where SIMODI GOLD makes a material change, it may provide notice where reasonably practicable and legally required. Continued use of SIMODI GOLD after the effective date of an update means the user accepts the revised Terms. If a user does not accept revised Terms, the user must stop using the platform and may request account closure, subject to compliance checks, settlement of outstanding obligations, and applicable restrictions.

1.39 Language, severability, assignment, and survival

These Terms may be provided in English and other languages. If there is any inconsistency, the English version prevails unless applicable law requires otherwise. If any provision is invalid or unenforceable, the remaining provisions remain valid and enforceable to the maximum extent permitted by law. Users may not assign, transfer, charge, or create a trust over their rights or obligations without SIMODI GOLD's prior written consent. SIMODI GOLD may assign or transfer its rights, obligations, business, assets, contracts, or platform to an affiliate, successor, purchaser, or service provider where permitted by law. Clauses relating to fees, taxes, payments, records, data retention, confidentiality, intellectual property, liability, indemnity, set-off, dispute resolution, governing law, and any accrued rights survive termination.

1.40 Governing law and disputes

These Terms are governed by the laws of the United Arab Emirates and, where applicable, the laws of Dubai. Any dispute arising from these Terms or the SIMODI GOLD platform shall first be addressed through good-faith negotiation and the SIMODI GOLD complaints process. If no resolution is reached, disputes shall be submitted to the competent courts of Dubai, United Arab Emirates, unless SIMODI GOLD specifies arbitration or another dispute resolution process in a separate written agreement or product-specific terms.

2. Privacy Policy

SIMODI GOLD collects and processes personal data to operate the platform, comply with legal obligations, prevent fraud, process transactions, provide storage and redemption services, support customers, protect the platform, and improve services. Personal data may include name, date of birth, nationality, address, email, phone number, identity documents, selfie or biometric verification data where required, bank details, payment information, transaction history, device information, IP address, app usage data, source of funds information, source of wealth information, tax information, communications, support records, and compliance records. SIMODI GOLD may use personal data for KYC verification, AML/CFT/CPF screening, sanctions checks, fraud prevention, transaction processing, payment processing, custody operations, redemption, delivery, customer support, security monitoring, legal compliance, regulatory reporting, audit, service improvement, and marketing communications where permitted. SIMODI GOLD may share personal data with regulators, law enforcement, banks, payment providers, card schemes, KYC/AML vendors, sanctions-screening vendors, fraud vendors, vault providers, logistics providers, auditors, insurers, cloud providers, legal advisers, tax advisers, compliance advisers, affiliates, and other service providers where required or permitted by law. Personal data may be transferred outside the UAE where necessary for cloud hosting, payment processing, compliance screening, customer support, audit, logistics, legal, or operational purposes. SIMODI GOLD will take steps required by applicable law for cross-border transfers. SIMODI GOLD may retain data for as long as required or permitted for legal, regulatory, AML, tax, audit, security, dispute, enforcement, and business purposes. Users may request access, correction, deletion, or restriction of personal data where permitted by law. SIMODI GOLD may refuse deletion where retention is required or permitted for legal, compliance, AML, audit, dispute, regulatory, or security purposes.

3. AML, KYC, Sanctions and CPF Policy

SIMODI GOLD is committed to preventing money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud, illegal trade, tax evasion, and other unlawful activity. SIMODI GOLD may conduct identity verification, address verification, beneficial-owner checks, sanctions screening, politically exposed person screening, adverse media checks, source of funds checks, source of wealth checks, transaction monitoring, account review, enhanced due diligence, suspicious-activity review, and ongoing monitoring. SIMODI GOLD may reject, freeze, delay, restrict, report, or cancel transactions that appear suspicious, unlawful, unverifiable, inconsistent, high risk, linked to sanctioned persons, linked to prohibited jurisdictions, or inconsistent with the user profile. Users must provide truthful, complete, and timely information. False documents, misleading information, refusal to cooperate, third-party payments, unusual activity, or suspicious conduct may result in account closure, rejected transactions, frozen balances, reporting to competent authorities, and other lawful action.

4. Risk Disclosure Statement

Market risk

Gold and silver prices can rise or fall. Users may receive less than they paid when selling.

Silver volatility risk

Silver may be more volatile than gold and may have wider spreads, lower liquidity, higher storage cost relative to value, and greater price movement.

Liquidity risk

SIMODI GOLD may not always be able to instantly process buy, sell, withdrawal, delivery, or redemption requests.

Storage and custody risk

Metals are stored in vault or custody arrangements. Insurance may not cover all events, losses, products, jurisdictions, or circumstances.

Regulatory risk

Laws, regulations, sanctions, customs rules, tax rules, licensing requirements, or supervisory expectations may change and affect access, products, fees, redemption, delivery, or platform operations.

Technology risk

App outages, cyberattacks, data errors, payment failures, device issues, third-party outages, or system errors may affect access or transactions.

Redemption and logistics risk

Physical redemption may be delayed or unavailable due to vault availability, product availability, minting, logistics, customs, sanctions, country restrictions, identity checks, supply constraints, or force majeure.

Tax risk

Users are responsible for taxes, duties, zakat, customs, reporting, and other obligations in their relevant jurisdictions.

No guaranteed return

SIMODI GOLD does not guarantee profit, capital protection, liquidity, price stability, yield, dividend, or future performance.

5. Gold and Silver Redemption Policy

Users may request physical delivery of gold or silver where available through the app or approved SIMODI GOLD channels. For now, physical delivery is available only within the United Arab Emirates. International delivery is not currently available unless SIMODI GOLD expressly confirms otherwise in writing or through the app. Redemption may be available as gold bars, silver bars, coins, minted products, or other approved products. SIMODI GOLD may set minimum and maximum redemption amounts and available product formats. Users are responsible for redemption fees, minting fees, fabrication fees, UAE delivery fees, insurance fees, VAT, local duties where applicable, identity checks, and receiving arrangements. Redemption requests may be delayed or rejected due to compliance checks, insufficient balance, product unavailability, UAE delivery coverage limitations, logistics disruption, failed delivery, force majeure, sanctions restrictions, unpaid fees, or account restrictions. Ownership records in the app may be adjusted once redemption is approved, processed, dispatched, delivered, cancelled, reversed, or otherwise resolved.

6. Refund Policy

This Refund Policy applies to payments, deposits, purchase requests, sale proceeds, disputed payments, rejected payments, cancelled transactions, and physical redemption requests made through SIMODI GOLD services. A payment, refund, withdrawal, sale proceed, or redemption may be delayed, refused, adjusted, cancelled, reversed, or returned where required or appropriate for legal, compliance, sanctions, fraud, security, banking, payment, operational, market, pricing, liquidity, logistics, vault, tax, or risk reasons.

Payments and Deposits

SIMODI GOLD may accept payment through bank transfer, debit card, credit card, payment gateway, digital wallet, or other approved method. Payments must come from accounts, cards, wallets, or payment methods held in the verified user name unless SIMODI GOLD approves otherwise. SIMODI GOLD does not normally accept third-party payments. SIMODI GOLD may reject, return, freeze, hold, investigate, or report third-party, suspicious, mismatched, duplicate, chargeback-related, unverifiable, or irregular payments.

Transaction Acceptance and Cancellation

A purchase is confirmed only when payment is successfully received in cleared funds, compliance checks are completed, SIMODI GOLD accepts the transaction, and the relevant metal quantity is credited to the user account. An order, payment, sale request, purchase request, transfer, gift, redemption request, withdrawal, or instruction is not guaranteed to be accepted. SIMODI GOLD may reject, delay, cancel, reverse, amend, or refuse to process any request for legal, compliance, security, operational, market, liquidity, payment, pricing, fraud, sanctions, tax, banking, logistics, vault, technology, or risk reasons. If SIMODI GOLD reasonably believes that a price, fee, metal quantity, exchange rate, account balance, transaction, redemption value, promotional value, or calculation contains or is based on a manifest error, system error, feed error, typographical error, pricing error, liquidity error, latency issue, data-source error, operational error, or obvious mistake, SIMODI GOLD may cancel, void, reverse, amend, reprice, correct, or adjust the affected order, transaction, balance, record, or instruction.

Withdrawals, Refunds, and Return to Source

Withdrawals, refunds, and sale proceeds may be subject to a return-to-source policy. SIMODI GOLD may return funds to the same payment method, bank account, card, or source from which funds were received, unless prohibited by law or otherwise approved by SIMODI GOLD. Deposits, withdrawals, refunds, and sale proceeds may be delayed due to bank processing, payment-provider review, compliance checks, sanctions screening, fraud checks, technical issues, weekends, public holidays, currency conversion, or third-party provider delays. SIMODI GOLD is not liable for delays outside its reasonable control. Fees, charges, spreads, taxes, payment processing fees, bank charges, failed-payment fees, chargeback fees, currency conversion charges, storage fees, redemption fees, delivery fees, insurance fees, minting or fabrication fees, compliance review fees, account closure fees, inactive-account fees, and other applicable charges may be deducted from refunds, withdrawals, sale proceeds, metal balances, or account balances where permitted by law.

Chargebacks and Disputed Payments

If a user initiates a chargeback, card dispute, payment reversal, cancellation request, bank recall, or similar process after using SIMODI GOLD, SIMODI GOLD may suspend the account, freeze metal holdings, withhold withdrawals, reverse or cancel transactions, set off amounts owed, recover fees, reject further orders, or terminate the account. If SIMODI GOLD reasonably suspects that a chargeback, cancellation, or payment dispute is dishonest, abusive, fraudulent, mistaken, or inconsistent with the user's completed transaction, SIMODI GOLD may investigate, provide records to banks and payment providers, recover losses, and report the matter where required or permitted by law. The user is responsible for chargeback fees, failed-payment fees, bank charges, payment-provider charges, legal costs, administrative costs, and losses arising from failed, reversed, disputed, fraudulent, or unauthorized payments except to the extent prohibited by applicable law.

Redemption and Delivery

Users may request physical redemption of gold or silver where available through the app or approved SIMODI GOLD channels. Redemption may be available as gold bars, silver bars, coins, minted products, or other approved products. SIMODI GOLD may set minimum and maximum redemption amounts and available product formats. Users are responsible for redemption fees, minting fees, fabrication fees, delivery fees, insurance fees, customs duties, import taxes, VAT, local licensing requirements, identity checks, and receiving arrangements. Redemption requests may be delayed or rejected due to compliance checks, insufficient balance, product unavailability, country restrictions, customs issues, logistics disruption, failed delivery, force majeure, sanctions restrictions, unpaid fees, or account restrictions. If delivery fails because the user provides inaccurate information, is unavailable, fails identity checks, refuses delivery, or does not cooperate, SIMODI GOLD may cancel the delivery request, charge re-delivery or storage fees, return the item to custody, sell or re-credit the metal, or process the matter as reasonably appropriate.

Contact

All refund, payment, cancellation, chargeback, withdrawal, and redemption questions should be sent to SIMODI GOLD FZCO at the registered address above or to Compliance@simodigold.com.

7. Fees Schedule

• Buy spreads or fees
• Sell spreads or fees
• Storage fees
• Redemption fees
• Minting or fabrication fees
• Delivery fees
• Insurance fees
• Currency conversion fees
• Payment processing fees
• Bank transfer fees
• Failed-payment or chargeback fees
• Inactivity fees
• Account closure fees
• Compliance review fees where applicable
• Taxes, duties, customs, VAT, or other charges where applicable

SIMODI GOLD may update fees from time to time. Current fees should be displayed in the app, website, transaction screen, quote screen, redemption screen, or fee schedule where reasonably practicable. The user should review all fees before confirming a transaction.

8. Audit and Proof-of-Reserve Policy

SIMODI GOLD aims to maintain gold and silver reserves corresponding to customer metal holdings, subject to operational reconciliation and transaction timing. SIMODI GOLD may conduct daily or periodic internal reconciliations, vault balance checks, independent third-party audits, reserve attestations, proof-of-reserve reporting, and user balance reconciliation. Audit reports or summaries may include total customer gold liabilities, total customer silver liabilities, total gold reserves, total silver reserves, vault confirmations, reconciliation exceptions, and methodology summaries where appropriate. SIMODI GOLD may publish summary reports while protecting sensitive vault, security, customer, regulatory, commercial, and operational information.

9. Complaints Handling Policy

Users may submit complaints through SIMODI GOLD's official support or compliance channels. Complaints should include the user's name, registered email or phone number, account reference, transaction reference where applicable, description of the issue, supporting documents, and preferred contact method. SIMODI GOLD will review complaints fairly and may request additional information. SIMODI GOLD aims to resolve complaints within a reasonable period, subject to complexity, third-party response times, compliance checks, regulatory requirements, weekends, public holidays, and force majeure events. Users may contact relevant authorities where applicable if they are not satisfied with SIMODI GOLD's response.

10. Cookie Policy

SIMODI GOLD may use cookies and similar technologies on its website, app, and digital platforms for login sessions, security, fraud prevention, analytics, performance improvement, user preferences, and marketing where permitted. Users may disable cookies through browser settings, but some features may not work properly. SIMODI GOLD may use third-party analytics, advertising, security, fraud-prevention, and performance tools where permitted by law.

11. Contact and Legal Notices

All legal notices, compliance communications, support requests, complaints, and official correspondence should be sent to:

SIMODI GOLD FZCO
1902, The Dome Tower, Cluster N, JLT
Dubai, United Arab Emirates
Compliance Email: Compliance@simodigold.com
Website: Simodigold.com

Customer Acceptance. By creating an account, accessing the platform, placing an order, making a payment, selling metals, requesting redemption, or continuing to use SIMODI GOLD services, the user confirms that the user has read, understood, and accepted these Terms and all policies incorporated by reference.