Terms of Service

These Terms govern the relationship between Silver Bullion (Hong Kong) Limited, referred to as the "Company", "we", "us" or "our", and each Customer using the Services, referred to as "you" or "your".

We provide services relating to the purchase, sale, storage, custody and administration of physical precious metals and related services that we make available from time to time.

Subject to these Terms, Holdings remain the property of the relevant Customer and are not treated as our own assets merely because they are held, stored or administered by or on behalf of us, except to the extent necessary to exercise rights expressly granted under these Terms, an Approved Security Arrangement or applicable law.

Subject to these Terms, applicable law and the operating model of the relevant Service, our objective is that Customer Holdings will:

These Terms apply to Account opening and maintenance, Platform access, purchases, Sellbacks, S.T.A.R. Storage, S.T.A.R. Grams, storage and custody, payments and payouts, redemptions withdrawals and releases, Fees, Approved Security Arrangements and related Services.

Unless we expressly agree otherwise, we do not provide investment or financial advice, wealth management, testing or assaying, lending by the Company, or physical retail collection in Hong Kong. We may administer Holdings used as security for financing provided by a separate Secured Party under an Approved Security Arrangement without ourselves providing the financing.

By opening an Account, accessing the Platform, accepting these Terms electronically or using the Services, you agree to these Terms and the Schedule of Charges, which is incorporated into and forms part of these Terms.

References to a person include an individual, company, partnership, trustee acting in that capacity and any other person or legal arrangement accepted by us. References to the singular include the plural and vice versa. Headings are for convenience only and do not affect interpretation.

References to a law or regulation include amendments, re-enactments, replacements, subsidiary legislation and applicable official guidance.

To use the Services, you must open an Account in the form and manner we require. We may offer individual, joint, company, partnership, trustee or other approved Account structures, subject to our approval, operational capability and applicable law.

By applying for or maintaining an Account, you represent and confirm on an ongoing basis that:

Where the Customer is a company, partnership, trustee or other non-natural person or legal arrangement, you additionally confirm that it is validly established or constituted where applicable, has power to own its assets and use the Services, all necessary approvals have been obtained, and each person acting in relation to the Account is duly authorised.

A change in directors, trustees, partners, beneficial owners, Authorised Persons, signatories or Account authority takes effect for the purposes of the Account only after we have received, verified and accepted the change. Until then, we may continue to rely on the authority recorded in our systems unless we know that doing so would be unlawful.

We may request further information or documents, impose reasonable conditions, limit the Services available to you, or decline to open or continue an Account. We may not always be able to provide reasons for our decision.

Unless we agree otherwise, the same Customer or substantially the same beneficial ownership group may not maintain multiple Accounts of the same type for the same purpose where we reasonably consider this to create legal, compliance, operational or security risk.

Your Account, the Platform and the Services are intended for the Customer's own lawful use and Holdings, unless we expressly approve another arrangement. You must not, without our prior written approval:

This does not prevent a Joint Account, an Authorised Person, an Approved Security Arrangement or another arrangement expressly accepted by us.

You must comply with applicable law and with the reasonable anti-money laundering, counter-terrorist financing, sanctions, counter-proliferation financing, fraud prevention, anti-corruption, tax reporting and risk-management requirements, procedures and controls that we apply from time to time in connection with the Services.

We may at any time require you to provide, update, explain or verify information or documents reasonably required for compliance, legal, operational or risk purposes, including identity and address information, bank account ownership, corporate or trust documents, beneficial ownership and control, source of funds and source of wealth, transaction purpose and supporting records, and tax residency or classification information.

You must provide requested information promptly and in the form reasonably required by us. We may rely on information and documents provided by you, but are not obliged to accept them as sufficient and may require independent verification, further evidence, updated documents, certified copies, translations, video or in-person verification, or other reasonable procedures even where information has previously been provided.

We may establish, amend, replace or withdraw from time to time our compliance and risk-management requirements, procedures, verification methods, documentary requirements, transaction controls, limits and other conditions applicable to the Services. We may do so in response to changes in law, regulation or regulatory guidance, sanctions, money laundering, terrorist financing or proliferation financing risks, fraud or scam risks, our risk assessments, operational or security considerations, or other relevant risk-management factors. Unless expressly stated otherwise, these requirements and procedures do not form part of these Terms and may be changed without amending these Terms, subject to applicable law.

We may maintain and update lists of prohibited, restricted or higher-risk countries, jurisdictions, persons, institutions, payment methods, products or activities. We may refuse to onboard or continue a Customer, restrict the Services, require additional due diligence or impose transaction conditions where a Customer, beneficial owner, controller, Authorised Person, payment source, transaction or other relevant connection involves a country, jurisdiction or other risk category that we prohibit or restrict from time to time.

You must comply with the compliance, verification and documentary requirements applicable when we process an application, review, instruction or transaction, including any different or additional information, documents or verification that were not required previously.

We may refuse, delay, hold, reverse where possible, restrict, suspend or terminate an Account, transaction, payment, payout, access or Service where:

We are not obliged to disclose the full reasons for action taken under this Section except where required by law.

A review, monitoring measure, hold or restriction may continue for as long as reasonably necessary to resolve the relevant matter.

Access to an Account is provided only to the Customer and, where applicable, through Authorised Persons and access arrangements approved by us. We do not provide third-party wealth manager, delegate, adviser or view-only access as a standard feature.

For a company, partnership, trustee or other non-individual Account, no person has an independent right of access merely because that person is a director, shareholder, beneficiary, settlor, trustee, employee, adviser or other related person. Access is only through the credentials and authority accepted by us.

You must keep your login credentials, passwords, devices and authentication methods secure. You must not share your login credentials or allow another person to use them unless we have expressly approved that person's access arrangement. You must notify us immediately if you suspect unauthorised access, compromise, fraud, error or misuse.

We may rely on an instruction, communication or action received through an approved channel where it reasonably appears to have been made or authorised by you, until we receive notice of unauthorised use and have had a reasonable opportunity to act.

Instructions and acceptances may be given electronically. Our electronic records may be used as evidence of instructions, acceptance, communications and transactions.

We may require additional identity or security verification before acting on any instruction, especially where it is unusual, high value, time sensitive, inconsistent with prior activity or raises compliance, fraud, scam, coercion, security, authority or ownership concerns.

A change to Account or profile details, including a Linked Bank Account, payout instruction, registered name, contact details or mandate, must be submitted through the authenticated Platform process or a Change Request accepted by us and may be subject to further verification.

If the Account holds or may receive a Cash Balance, Sellback proceeds, refunds or payouts, you must maintain at least one Linked Bank Account. Unless we expressly approve otherwise, it must be held in the legal name of the Customer and, for a Joint Account between adults, in the names of both joint Account holders. For a Joint Account with a Minor, we may accept a bank account held by the adult joint Account holder, a joint bank account including the adult joint Account holder, or another account structure approved by us.

We may refuse to add, retain or use a Linked Bank Account that is connected with a sanctioned, prohibited, unlicensed, opaque or high-risk institution, jurisdiction or payment arrangement, or where the payer or account ownership cannot be satisfactorily identified.

Each Account is a separate legal and operational relationship. There is no right to re-title, re-designate, novate, transfer or move Cash Balances, Holdings or entitlements between Accounts unless we expressly approve the transfer under our procedures or agree otherwise in writing.

Internal allocation, reallocation, bar assignment, consolidation, de-allocation or other operational adjustment within the applicable service model is not a Customer transfer and remains permitted under these Terms.

Where we offer an Account-to-Account transfer process, we may require evidence of the underlying legal transaction, transfer forms, ownership declarations, consents, deeds of gift, tax or legal documents, identity verification or other information. We may refuse a transfer where ownership, authority, compliance, security, tax, legal or operational concerns are not satisfactorily resolved.

If we open a Joint Account, including a Joint Account with a Minor that we expressly approve, the joint Account holders are treated as co-owners and the Account is held in joint tenancy with the right of survivorship regardless of individual contributions, subject to applicable law and, for a Joint Account with a Minor, Sections 6.9 to 6.15.

Unless dual approval is required under this Section, we may treat an instruction or transaction entered into by either joint Account holder as authorised by the other.

We may require both joint Account holders to approve an instruction where we receive contradictory instructions, the action affects ownership, payout control, survivorship or core Account details, or we otherwise consider dual approval reasonably necessary for security, legal, compliance or operational reasons.

Except where one joint Account holder is a Minor and Section 6.11 applies, both joint Account holders must approve removal of a holder, closure or conversion of the Joint Account, a change to its Linked Bank Account or payout mandate, a transfer or re-titling of Holdings out of the Joint Account, and the creation, amendment, substitution, release or termination of an Approved Security Arrangement affecting Joint Account Holdings.

We may verify each holder's consent through documentary, telephone, video or other verification. If conflicting instructions arise, we may freeze affected activity until the conflict is resolved to our reasonable satisfaction.

If one joint Account holder dies, the survivor retains ownership by right of survivorship, subject to satisfactory evidence of death, any lien or Approved Security Arrangement and applicable law. If the survivor is an adult, the survivor also assumes control of the Account and, after accepting the evidence, we may treat the Account as a personal Account of the survivor. If the survivor is a Minor, Section 6.13 applies.

To the extent permitted by law, we are released from claims by heirs, executors, administrators or personal representatives of the deceased holder where we act in good faith in accordance with the survivorship mandate and continuing rights affecting the Holdings.

Holdings transferred into a Joint Account with our approval become subject to the Joint Account ownership and survivorship arrangements when the transfer is completed, subject to any continuing lien, Approved Security Arrangement or other right affecting those Holdings.

We may permit a Joint Account to be opened between one adult and one Minor, subject to our approval, applicable law and our onboarding, verification and Account requirements. We may require evidence of the relationship between the holders, parental or guardianship status, authority, consent or other information or documents that we consider appropriate.

While the Minor remains under 18, the adult joint Account holder is the operating holder of the Account and may access the Account and submit ordinary instructions and transactions on behalf of the Joint Account. The Minor has no independent right to access or operate the Account until the requirements in Section 6.14 have been completed.

For an action described in Section 6.4, the adult joint Account holder may submit the request while the other holder remains a Minor, but we may require additional evidence, verification, consent, approval or other safeguards before acting and may refuse or defer the request where the ownership, authority, legal, compliance or operational requirements are not satisfactorily resolved.

The Minor remains a co-owner of the Joint Account and its Holdings notwithstanding that the Minor has no independent operating authority while under 18. The adult holder's operating authority does not by itself give the adult sole ownership of the Minor's interest.

If the adult joint Account holder dies, loses legal capacity or ceases to have the authority required by us while the Minor remains under 18, we may restrict or freeze the Account until we receive and accept satisfactory evidence of a lawful guardian, representative or other arrangement that we consider appropriate. We may require the Account to be converted to another Account structure that we make available.

When the Minor reaches 18, we may require that holder to complete identity verification, onboarding, acceptance or ratification of the applicable Terms and Account mandate, and any other requirements we reasonably impose before granting independent access or normal Joint Account authority. Until those requirements are completed, we may continue to restrict that holder's access or authority.

A Joint Account with a Minor is not eligible for an Approved Security Arrangement while either joint Account holder remains a Minor.

You may submit an Order through the channels we make available. We do not accept physical cash for the Services and may limit available payment methods, products, order sizes, settlement windows or other conditions.

A displayed price, quotation, spot indication or estimate before final confirmation is indicative only and may change without notice.

An Order becomes binding when you submit it and the applicable price is locked by the Platform or otherwise confirmed by us in the manner we specify.

A binding Order is final and non-cancellable by you unless we expressly agree otherwise or these Terms provide otherwise. A market movement, change of mind or change in your circumstances does not create a right to cancel or fail to settle.

You must pay and complete the Order in full, in cleared funds, within the deadline and settlement requirements we specify. Failure to do so is a Late Payment and breach of these Terms, and Section 11 applies.

We may refuse, delay or cancel an Order where reasonably necessary for legal, compliance, security, product availability or system-related reasons, including where Sections 4, 14 or 18 apply. Where an Order cannot be completed in full, we may, with your agreement, complete part of the Order and cancel the uncompleted balance. If the reason is not caused by your default or breach, you will not be charged under Section 11 for the cancelled or uncompleted portion, and any amount received for that portion will be returned or credited to you.

On completion, the purchased Metals or Holdings will be recorded or allocated to your Account under the applicable service model, including S.T.A.R. Storage or S.T.A.R. Grams.

Unless expressly agreed otherwise for a transaction, title to purchased Metals or Holdings passes to you when they are recorded or allocated to your Account as completed. Until then, risk of physical loss remains with us; thereafter physical Loss is governed by Section 9.

Metals purchased through us may be held in one or more service formats that we make available, including S.T.A.R. Storage and S.T.A.R. Grams.

Under S.T.A.R. Storage, specifically identified physical Metals are recorded and held for the Customer as a Parcel. A Parcel may be a bar, coin, other bullion product, standard quantity or packaging accepted by us for storage and is not intended to form part of a pooled holding model.

Subject to these Terms, applicable law, our lien and any Approved Security Arrangement, ownership of a Parcel remains with the Customer. S.T.A.R. Storage is structured as a bailment: we act as custodian and storage provider and will not use Customer Holdings as collateral for our own obligations or lend them to third parties, except under an Approved Security Arrangement authorised by the Customer or as required by law.

We may move, reposition, repackage, reseal, photograph, record, audit or otherwise administratively handle a Parcel where reasonably necessary for storage, security, logistics, compliance or operations, provided the Customer's ownership and the recorded product type and quantity are not altered except as permitted by these Terms. Ownership may be evidenced by invoices, transaction records, Account records and our parcel or storage records.

S.T.A.R. Grams records the Customer's legal ownership of an identifiable portion of physical Metals of the relevant type, measured by weight. The recorded Holdings are fully backed by physical Metals held within our storage arrangements, and the Customer's ownership is proportionate to the recorded quantity, subject to these Terms, our lien and any Approved Security Arrangement.

For operational purposes, the physical bars backing S.T.A.R. Grams may be allocated, pooled with bars of the same metal type and standard, de-allocated, reallocated, consolidated, substituted or reassigned for vaulting, audit, tracking, settlement, security, compliance or liquidity purposes.

You authorise us, to the limited extent necessary, to make the operational adjustments described in Section 8.6 at our discretion and without prior notice. They do not create a wider agency or fiduciary relationship and must not change the quantity, metal type, quality or assay represented by your recorded S.T.A.R. Grams Holdings. Those operational adjustments do not of themselves convert the Customer's Holdings into an unsecured claim against us.

We determine how S.T.A.R. Grams and the underlying physical Metals are assigned, recorded, reconciled, rounded and administered and may make appropriate ownership or reconciliation records available through the Platform or other reporting channels.

In our insolvency, liquidation, winding up or analogous proceeding, the Customer's ownership rights in the identifiable physical Metals represented by S.T.A.R. Grams are intended to remain Customer property and not part of our beneficial estate, subject to applicable law and mandatory insolvency rules.

You may use eligible S.T.A.R. Grams Holdings to redeem physical precious metal products that we make available for redemption from time to time, subject to applicable minimum redemption quantities, product availability, premiums, Fees and our procedures. Redemption does not entitle you to withdraw or receive the particular physical bar or bars then backing your S.T.A.R. Grams Holdings.

You may request that specified eligible Holdings secure obligations to Silver Bullion Finance Limited or another Secured Party approved by us.

We need not recognise or administer a security interest unless we have expressly approved it, the Security Documents and compliance requirements are completed to our satisfaction, and the affected Holdings are specifically recorded as Secured Holdings. For S.T.A.R. Storage, security is Parcel-specific; for S.T.A.R. Grams, it applies only to the recorded quantity and metal type. It does not automatically extend to other Holdings.

We may mark, restrict, block or otherwise control Secured Holdings. You may not sell, redeem, withdraw, transfer, re-designate, further pledge or otherwise deal with them except in accordance with the Security Documents and instructions accepted by us.

You remain the owner of Secured Holdings, subject to the security rights and our rights under these Terms.

We may act on release, substitution, partial release, enforcement or other instructions relating to Secured Holdings to the extent permitted by the Security Documents and arrangements accepted by us.

Where enforcement is permitted, we may restrict, transfer, sell or otherwise deal with the relevant Secured Holdings and apply or remit proceeds in accordance with the Security Documents and applicable law. Any surplus remaining after the secured obligations and properly applicable costs are satisfied remains for the Customer.

Our custody, control or administration of Secured Holdings does not make us the lender, borrower, guarantor or beneficial owner and does not make us a party to the Customer's financing obligations except as expressly stated in the Security Documents.

Applicable security administration Fees are set out in the Schedule of Charges. Unless the Security Documents expressly provide otherwise, an Approved Security Arrangement remains subject to our lien and other rights for Fees and amounts properly due in connection with the relevant Secured Holdings.

By using S.T.A.R. Storage or S.T.A.R. Grams, you authorise us to arrange the storage, transportation, handling, administration and safekeeping of your Holdings as reasonably necessary.

Our safekeeping of Holdings under S.T.A.R. Storage and S.T.A.R. Grams is structured and intended to operate as a bailment for customer asset protection. For S.T.A.R. Grams, the bailment applies in accordance with the fractional ownership model described in Section 8, notwithstanding the allocation, pooling, substitution, reallocation or other operational adjustments permitted under that Section. Except for authority expressly given by these Terms, no wider agency, partnership, joint venture, trust, fiduciary or similar relationship is created. Subject to our rights under these Terms, title and ownership remain with the Customer under the applicable holding model.

Customer Holdings held on a bailment basis are intended to remain Customer property and not part of our beneficial estate in our insolvency, liquidation, winding up or analogous proceeding, subject to applicable law and mandatory insolvency rules.

We may store or arrange storage with our affiliates or approved third-party vault operators, custodians, warehouse, logistics, insurance or other service providers. Holdings may be stored outside Hong Kong, including in Singapore, or another location we designate, subject to applicable law and the relevant service model.

We will maintain books, ownership records and recovery arrangements reasonably designed to identify and reconstruct Customer Holdings, including following material system failure, operational disruption or insolvency. We may change the format, frequency and detail of statements, confirmations, photographs, audit records and other reporting materials.

Subject to this Section, we assume contractual liability for physical Loss of Eligible Holdings during our Period of Responsibility, including direct physical Loss or damage caused by theft, fire, employee infidelity or mysterious disappearance.

The Period of Responsibility begins when Eligible Holdings are accepted by or on behalf of us into the relevant storage arrangement and properly recorded as under our control, or at any earlier point where we expressly assume physical-loss risk under Section 7. It ends when the Holdings are sold to us, released, withdrawn, delivered, transferred out or otherwise cease to be under our control as provided in this Section.

We are not liable under this Section for:

Where reasonably practicable, we may satisfy liability for physical Loss by replacing the affected Eligible Holdings with Metals or products of like kind and quality. Otherwise, our liability for the Loss shall not exceed the Replacement Value of the affected Eligible Holdings.

If you become aware of actual or suspected Loss, you must notify us as soon as reasonably practicable and provide reasonable information and assistance for investigation, mitigation and recovery. Delay does not extinguish a claim except to the extent it materially prejudices those efforts.

If we replace Holdings or make payment for a Loss, we may, to the extent of the value provided, exercise the Customer's recovery rights against a responsible person. You must provide reasonable assistance and documents, provided you are not required to incur unreimbursed out-of-pocket costs.

A Loss may arise from one event or a series of related, continuous or repeated acts, errors, omissions or events during the Period of Responsibility. The liability assumed under this Section forms part of the storage service and, unless expressly stated otherwise, no separate fee is charged for it.

We are not an insurer, insurance intermediary or insurance broker. Insurance maintained or arranged by or for us is for our own liability or risk-management purposes. You do not purchase a standalone policy from us and have no direct right to claim under, enforce, inspect or rely upon it, except to the extent required by law. Insurance does not limit the liability expressly assumed by us under this Section.

Unless we expressly agree otherwise, the Services do not include testing, assaying or authentication of Customer-supplied Metals or acceptance of third-party transfer-ins for storage.

You must pay applicable storage, administration and related Fees while Holdings remain under our administration or storage arrangements. S.T.A.R. Storage Holdings may be withdrawn or released through the channels, locations and procedures we make available. S.T.A.R. Grams may be redeemed for eligible physical precious metal products in accordance with Section 8 and our applicable redemption procedures. No right of physical retail collection in Hong Kong is created by these Terms.

We may refuse or delay a withdrawal, release or redemption while Holdings are subject to a lien, Approved Security Arrangement, unpaid Fees, compliance restriction, authority or ownership dispute, or where we reasonably identify a genuine fraud, security, sanctions, authority or ownership concern. We may require advance notice, identification, documents, appointments, transport instructions, customs information or other reasonable verification.

You must pay applicable withdrawal, release, logistics, transport, customs, duties, taxes and third-party costs. If you or your authorised recipient collect the Holdings, our Period of Responsibility ends on physical handover. If you nominate your own carrier, it ends on handover to that carrier. If we agree to arrange delivery, it continues until delivery to you or your accepted recipient at the agreed delivery point, unless the applicable arrangement expressly states otherwise. A receipt or delivery acknowledgement signed by you or your accepted recipient is prima facie evidence that the Holdings were received in apparent good order and condition, except for latent damage not reasonably discoverable on receipt.

You may submit a Sellback through the channels we make available. A displayed buyback indication or price before final confirmation is indicative only and may change without notice.

A Sellback becomes binding when you submit it and the applicable price is locked by the Platform or otherwise confirmed by us in the manner we specify.

A binding Sellback is final and non-cancellable by you unless we expressly agree otherwise or these Terms provide otherwise. A market movement, change of mind or change in circumstances does not create a cancellation right.

You must complete all required steps and satisfy applicable product eligibility, quantity, settlement, de-allocation, payout, lien and Approved Security Arrangement conditions within the time and manner we specify.

If you fail to complete a binding Sellback or otherwise breach these Terms in connection with it, we may cancel, unwind, close out, replace, cover or reverse it, restrict or suspend Services and exercise our rights under Section 11.

We may refuse, delay or cancel a Sellback where Sections 4, 14 or 18 permit. Where a Sellback cannot be completed in full, we may, with your agreement, complete part of the Sellback and cancel the uncompleted balance. If the reason is not caused by your default or breach, you will not be charged under Section 11 for the cancelled or uncompleted portion, and any Holdings relating to that portion will remain or be restored to your Account under the applicable service model.

The Schedule of Charges forms part of these Terms. You must pay all Fees applicable to the Account, Holdings and Services. The Schedule is the source of the applicable standard Fee amounts, rates, calculation methods and billing rules, unless we expressly agree a different Fee with you in writing for a particular transaction or service.

Fees may include storage and custody, withdrawal and release, transfer, security administration, Late Payment, Cancellation, exceptional or manually intensive administration, banking and remittance, foreign exchange, taxes and duties, estate administration, reasonable legal and recovery costs where permitted by law, and applicable third-party charges.

Where we perform exceptional, bespoke, investigative, recovery, estate, remedial or manually intensive work outside the standard trading and storage service, we may charge on a time-and-materials basis at the rates or calculation basis stated in the Schedule of Charges. Storage and custody Fees accrue and are billed on the basis stated in that Schedule.

If a binding Order or Sellback is not settled or completed as required, or if we agree to cancel, unwind, close out, replace, cover or reverse it at your request or because of your Late Payment, default, failure to complete or breach, we may take those actions, refuse further transactions, restrict or suspend Services and exercise the other rights in this Section.

In those circumstances, you must pay the applicable Cancellation Fee and any Market Loss Charge. The Market Loss Charge is the adverse difference between the confirmed price and the prevailing market price at the time we reasonably execute or determine the cancellation, unwind, close-out, replacement, cover or reversal, multiplied by the applicable contracted quantity or weight, together with reasonable direct costs. We determine the prevailing market price using the market price or pricing source we ordinarily use for the relevant product. If the market movement results in no loss or a gain to us, the Market Loss Charge is zero and you are not entitled to that market gain.

You remain responsible for reasonable direct costs, charges, expenses, losses or damages caused by your Late Payment, default, failure to complete or breach to the extent not already included in the Cancellation Fee or Market Loss Charge. We will not recover the same loss, cost or expense more than once under different remedies.

If an amount due to us is not paid by the due date, we may charge the applicable Late Payment Fee in addition to other rights and remedies.

We do not accept physical cash. Unless expressly approved otherwise, incoming payments must originate from the Customer's Linked Bank Account. We may reject, hold, review or return a payment from a third party, unregistered source or source that does not match the Customer, require payer information, declarations or supporting documents, and refuse to apply it to an Order or obligation.

You are responsible for reasonable bank, intermediary, return, chargeback, reversal and related costs attributable to your payment or instruction. Outgoing Sellback proceeds, refunds and Cash Balance withdrawals will be paid only to a Linked Bank Account accepted by us.

We may deduct or set off against any payment, payout, Cash Balance or proceeds in the relevant Account any Fees, taxes, costs or other amounts properly due to us in connection with that Account. Unless expressly agreed otherwise, our deduction, set-off, lien and sale rights do not automatically extend to another Account, and a personal liability of one Joint Account holder is not recoverable from the Joint Account merely because that person is a joint holder.

We are not responsible for intermediary bank deductions, foreign exchange losses, correspondent bank delays, beneficiary bank requirements or similar third-party processing issues outside our reasonable control.

If funds are credited in error, or a payment is reversed, recalled, disputed, charged back, frozen or found to be improper, we may reverse the credit where possible, place a hold, recover the amount and reasonable direct costs, and take other reasonable corrective action.

We have a contractual lien over Holdings in an Account as security for Fees and other amounts properly due and payable to us in connection with that Account. While an amount secured by the lien remains unpaid, we may refuse to release, withdraw, transfer or otherwise deal with affected Holdings to the extent reasonably necessary to protect our rights.

If a payment default continues for 30 calendar days, you authorise us, after at least 7 days' prior notice by email where reasonably practicable, to sell only such quantity of Holdings as is reasonably required to recover the unpaid amount, accrued Fees and reasonable direct recovery or sale costs.

Sale proceeds under our lien are applied first to reasonable direct sale costs and then to amounts properly due to us. Any surplus remains yours and will be credited or paid to you under our procedures. If an amount remains unpaid for 60 calendar days and cannot reasonably be recovered from the Cash Balance or Holdings in the relevant Account, we may restrict or wind down the Account without extinguishing the debt or our other rights.

A Cash Balance is maintained only as an ancillary feature for transaction settlement, refunds, Sellback proceeds, Fees and other permitted purposes. It is not a bank deposit, savings account, remittance facility, stored value facility or general-purpose payment account and does not earn interest unless we expressly state otherwise.

We may return an unused or excess Cash Balance to the Linked Bank Account, including where it has remained unused for 90 days and is not reasonably required for an active or anticipated transaction, an amount due or another permitted purpose.

If we receive notice of an individual Customer's death, bankruptcy, loss of legal capacity or another event affecting authority, or reasonably suspect that an instruction may not validly reflect the Customer's authority or intention because of possible incapacity, coercion, fraud or similar circumstances, we may review the affected activity and delay voluntary instructions while making reasonable enquiries.

We may require evidence of authority, including a death certificate, probate, letters of administration, grant of representation, court order, enduring power of attorney, guardianship or other document acceptable to us. We are not obliged to accept instructions merely because a person is a spouse, relative, business partner, co-director, beneficiary or other person claiming an interest.

For a company, partnership, trustee or other non-individual Customer, we may similarly review affected instructions where an event or concern affects a director, trustee, partner, signatory, protector, Authorised Person or representative until satisfactory continuing or replacement authority is verified.

We may conduct identification, residency, sanctions and compliance checks on an executor, administrator, attorney, trustee, liquidator, receiver, personal representative or other person seeking to act in relation to the Account.

We may charge the applicable estate or administration Fee and reasonable third-party and time-and-materials costs. Pending satisfactory authority, we may delay voluntary action while continuing storage, safeguarding, recurring administration, applicable Fees and mandatory legal or regulatory actions.

A lien, Approved Security Arrangement, unpaid Fee or other continuing obligation remains effective despite death, incapacity or loss of authority and must be dealt with before Holdings or proceeds are released or distributed.

Where we expressly offer and accept a standing instruction concerning the treatment of specified Holdings following your death, that instruction is effective only on the conditions and in the form we prescribe. We may suspend action until satisfactory evidence of death and any required verification has been completed. Any sale, payment or transfer remains subject to applicable law, any lien or Approved Security Arrangement, the continuing validity of the nominated destination and any competing claim or legal restriction notified to us.

This optional feature applies only if you expressly enable it in the manner we prescribe and have not revoked it before the relevant Nationalization Event occurs.

If enabled and a Nationalization Event affects eligible S.T.A.R. Storage Holdings lawfully stored in Singapore, we will use commercially reasonable efforts, only to the extent lawful under Hong Kong and Singapore law, to prevent, mitigate or deny implementation of the foreign nationalization or seizure against those Holdings.

You give us a standing instruction, upon such an event, to suspend remote dealing in the affected Holdings and to require that a subsequent sale, purchase, withdrawal, release or movement may be effected only when you are physically present in Singapore and we are reasonably satisfied that your instruction is given freely.

The feature applies only where you had enabled it before the event, you own or control the affected asset, and the event occurs in a sovereign territory other than Singapore. Where you are an individual, the relevant territory must correspond to your passport or permanent residence record with us; where you are a legal entity, to your place of incorporation, establishment or registration.

After the Nationalization Event occurs, revocation or variation of this standing instruction is suspended while the event remains effective unless you are physically present in Singapore and we accept the revocation or amendment.

This feature is not insurance or a guarantee that governmental action can be prevented. It applies only to eligible S.T.A.R. Storage Holdings lawfully stored in Singapore unless we expressly state otherwise and remains subject to applicable law and events outside our reasonable control.

We may place a hold, restriction, suspension or refusal on an Account, Holdings, Order, Sellback, payment, payout, access, instruction or Service where reasonably necessary for legal, compliance, security, operational, risk-management, dispute-resolution or asset-protection purposes.

A restricted Account may use only Services we permit. A suspended Account may be prevented from carrying out substantially all voluntary activity while an issue is reviewed. A wind-down Account may not enter new voluntary transactions, but necessary storage, Sellbacks, withdrawals, payouts, compliance and closure actions may continue.

Without limiting Section 14.1, we may take action under this Section where:

A hold, restriction, suspension or wind-down status may continue until the relevant issue is resolved to our reasonable satisfaction or the Account is brought to an orderly close.

Subject to Sections 9 and 18.1, we are not liable for delay, missed opportunity or price movement arising from protective action taken in good faith under this Section, except to the extent liability cannot lawfully be excluded or limited.

We may correct a manifest error, or an objectively verifiable clerical, accounting, allocation, recording, pricing, system, configuration, eligibility or restriction error and reverse an erroneous credit, debit, allocation, price or record to restore the position that should properly have existed. We may not retrospectively alter a properly confirmed transaction merely because market prices later changed.

Where there has been no transaction or activity for a period determined by us, we may treat the Account as dormant and disable selected higher-risk functions pending appropriate re-verification. Dormancy does not affect ownership of Holdings; storage, safeguarding, recurring administration and applicable Fees may continue.

You may request closure of your Account, but we may defer closure until obligations are satisfied, compliance reviews are completed and Holdings, balances, security arrangements and instructions are properly dealt with.

We may terminate an Account or Service where:

A shorter notice period or immediate termination may apply where reasonably necessary under paragraphs (a) to (d).

Termination or closure may place the Account into wind-down until Holdings, Cash Balances, Approved Security Arrangements, Fees and continuing obligations are resolved. No new voluntary business need be accepted, but necessary storage, safeguarding, Sellbacks, withdrawals, payouts, compliance and administration may continue. Your ownership of Holdings is not affected merely by wind-down.

On termination or closure, access may cease, unpaid amounts become due, amounts properly owed may be deducted from balances or proceeds in the relevant Account, outstanding Orders or Sellbacks may be completed, cancelled or otherwise dealt with having regard to the circumstances, and remaining Holdings or balances must be dealt with under our procedures, applicable law and any lien or Approved Security Arrangement.

If you fail to give acceptable instructions for remaining Holdings or balances within a reasonable time, we may continue charging applicable Fees, maintain the Holdings in custody, sell some or all Holdings and, after deducting amounts properly due and reasonable direct sale costs, hold or remit the net proceeds for you, or take another reasonable step to bring the relationship to an orderly close.

Termination does not affect accrued rights, liabilities, obligations, indemnities, set-off, lien, evidentiary rights, Security Documents or provisions intended by their nature to survive termination.

We collect, use, process, store and disclose personal data in connection with the Services in accordance with applicable law and our Privacy Policy, including the Personal Information Collection Statement contained in that Privacy Policy.

If you provide personal data about another person, you must be lawfully permitted to provide it to us for the relevant purpose.

Our Privacy Policy explains, among other matters, the purposes of processing, disclosures to third parties, processing and storage outside Hong Kong, retention and security measures, and rights of access and correction.

The current Privacy Policy is available on our website and may be updated in accordance with applicable law.

Precious metals prices can fluctuate materially. The value and liquidity of Holdings may rise or fall and market spreads may widen, particularly during volatile or disrupted conditions.

Execution, settlement, storage, release, movement and payout may be affected by market conditions, legal restrictions, banking arrangements, operational constraints, Nationalization Events and compliance reviews.

S.T.A.R. Storage and S.T.A.R. Grams have different ownership and operational features. You are responsible for understanding the service model, Fees, liquidity mechanics and procedures applicable to the Service you use.

We do not provide investment, financial, tax, accounting or legal advice, fiduciary services or wealth management under these Terms. You are responsible for obtaining independent advice where you consider it necessary and for your own legal and tax consequences.

Holding precious metals does not provide interest or dividends and may involve storage, liquidity, market, legal, operational and other risks.

If you use Holdings as security, those Holdings may become unavailable for sale, redemption, withdrawal, transfer or other dealing and may be transferred, sold or otherwise enforced following default in accordance with the Security Documents. You are responsible for understanding the relevant financing and security terms.

Nothing in these Terms excludes or limits liability that cannot lawfully be excluded or limited.

Subject to Section 18.1, we are not liable for indirect, consequential, incidental, punitive, exemplary or special loss, loss of profit, opportunity, goodwill or revenue, business interruption, market movement or loss arising from delay, even if foreseeable.

Subject to Section 18.1 and liability expressly assumed under Section 9, we are not liable for loss arising from:

Subject to Section 18.1, and whether the claim arises in contract, tort including negligence, breach of statutory duty or otherwise, our aggregate liability for claims arising from the Services, other than physical Loss of specific Eligible Holdings during the Period of Responsibility, shall not exceed the total Fees actually paid by you to us in the twelve months immediately preceding the event giving rise to the claim. All claims arising from the same act, omission, event or series of related acts, omissions or events shall be treated as one claim arising from one event for the purposes of this limitation.

A claim for physical Loss of specific Eligible Holdings during the Period of Responsibility is governed exclusively by Section 9, including its exclusions and the limitation to the Replacement Value of the affected Eligible Holdings.

You indemnify us against liabilities, claims, losses, damages, costs and reasonable legal expenses arising from:

We take reasonable steps to maintain accurate systems, pricing information and transaction records. If a market is closed or disrupted, reliable pricing is unavailable, a pricing or data feed is stale or unreliable, or a material system, communications or execution failure affects the Platform or a transaction, we may suspend or limit pricing or trading, delay or reject execution, withdraw an unreliable quote, or cancel or correct a transaction affected by a manifest pricing or system error under Section 14. Such disruption does not of itself affect ownership of Holdings already recorded to the Account.

We are not responsible for failure or delay caused by events beyond our reasonable control, including acts of God, war, terrorism, riot, civil unrest, epidemic or pandemic, labour or utility disruption, cyberattack, banking or transport disruption, Nationalization Event, market closure, communications failure or a law or order restricting performance.

During such an event, we may suspend affected Services, extend time for performance, revise procedures or take other reasonable steps. The event does not of itself transfer title to Holdings to us, extinguish the Customer's ownership, or alter liability for physical Loss expressly assumed under Section 9, subject to the exclusions in that Section.

The current versions of these Terms and the Schedule of Charges are available on our website.

We may amend them prospectively to govern new features, products or services, reflect changes in law or regulation, or update the operation of the Services, subject to this Section.

If an amendment materially affects ownership rights in Cash Balances, Metals, Holdings or other property held through the Account, we will give at least 60 days' detailed notice, unless a shorter period is reasonably necessary to comply with law, regulation, court order or an urgent security requirement.

If an amendment increases a storage, custody, withdrawal, release or other Fee that materially affects existing Holdings, we will give at least 30 days' detailed notice, unless a shorter period is reasonably necessary to comply with law or regulation.

A new or amended Fee applying only to a future optional Order, Sellback, transfer, Approved Security Arrangement, withdrawal or other transaction may apply from its published effective date if the Fee is disclosed or made available before you confirm that transaction or Service. No amendment will retrospectively increase a Fee that became payable before its effective date.

We may make a change effective sooner where reasonably necessary for law, regulation, court order, regulatory direction, sanctions, fraud prevention, cybersecurity or another urgent safety or legality requirement and will notify you where reasonably practicable.

A new Account opened during a notice period under this Section is subject to the Terms and Schedule of Charges in effect when the Account is opened, together with any notified future effective date applicable to the relevant provision or Fee.

Continued use of the affected Services after the effective date constitutes acceptance of the amendment to the extent permitted by law. If you do not agree to a material amendment, you must stop using the affected Services and may request closure subject to Section 15 and continuing obligations. Where an existing-Holdings Fee increase is subject to notice, an available sale, withdrawal or closure validly completed before the effective date remains subject to the previous Fee.

We may maintain and rely on electronic records identifying the version of these Terms and Schedule of Charges applicable to the Account or a transaction, together with the effective date and acceptance record.

These Terms and the Schedule of Charges constitute the agreement between you and us for the Services and supersede prior discussions, correspondence, understandings and agreements on the same subject, except for a separate written agreement expressly stated to prevail, including applicable Security Documents.

If documents are inconsistent: Security Documents prevail for the relevant Approved Security Arrangement; a transaction confirmation prevails for the specific price, quantity, settlement details or expressly confirmed transaction term; these Terms govern substantive contractual rights and obligations; and the Schedule of Charges governs standard Fee amounts, rates and calculation methods unless a different Fee is expressly agreed in writing. Website content, FAQs, marketing materials, customer service communications and automated messages do not amend or override these Terms unless expressly incorporated into a transaction confirmation, Security Document or amendment made in accordance with Section 19.

If a provision is illegal, invalid or unenforceable, it is severed to the minimum extent necessary and the remaining provisions continue in force.

A failure or delay in exercising a right is not a waiver, and a single or partial exercise does not prevent further exercise of that or another right.

You may not assign, transfer, charge, pledge, declare a trust over or otherwise dispose of or create security over Holdings or rights under these Terms without our prior written consent, except under an Approved Security Arrangement.

We may assign, transfer, subcontract, delegate or novate rights or obligations to an affiliate or third party provided this does not materially reduce the substance of your rights except as required by law or regulation.

A person who is not a party to these Terms has no right to enforce them except where these Terms, Security Documents or applicable law expressly provide otherwise. A Secured Party has only the rights expressly granted under the applicable Security Documents.

These Terms may be accepted and stored electronically. Our electronic records, communications, statements, confirmations, screenshots and logs, including the applicable Terms and Schedule version and acceptance record, are prima facie evidence of the matters recorded unless manifest error is shown.

We may communicate with you by email to your registered email address, Platform notification, website notice, message, post to your registered address or another reasonable method appropriate to the communication. You must keep your contact details current and check your registered email and Platform notifications regularly.

Unless applicable law requires otherwise, an electronic communication is treated as received when sent or made available to you, a website notice when published, and a postal communication three Business Days after dispatch.

A notice required under Sections 19.3 or 19.4 will be sent to you by email or Platform notification and may also be published on our website.

In the event of any inconsistency between an English version and a translated version of these Terms, the English version shall prevail unless we expressly state otherwise.

These Terms and any non-contractual obligations arising out of or in connection with them are governed by the laws of Hong Kong.

You and we submit to the exclusive jurisdiction of the courts of Hong Kong for disputes arising out of or in connection with these Terms, the Account, the Services or related non-contractual obligations.

An Approved Security Arrangement and its Security Documents may specify another governing law and jurisdiction, including where appropriate having regard to the location of the Secured Holdings or the Secured Party.