Legal

Prohibited Countries/Regions

Due to compliance and regulatory requirements, CGOLD currently doesn't provide its services to customers from the following countries/regions/territories:

Asia

Democratic People's Republic of Korea, Iran, Syria, Myanmar

Americas

Cuba

Europe

Crimea, Sevastopol, Russia

CGOLD's products and services may not be available in certain jurisdictions other than the above.

CGOLD Privacy Policy

Last updated on July 2026

1. Introduction

Thank you for choosing the relevant service(s) (the "Services") and/or product(s) (the "Product") provided by RWA Issuer Trust ("CGOLD") and its affiliates (hereinafter also referred to as "I", "me", "my", "we", "us" and "our" or the "Company"). By accessing or using our Services/Products, you CONSENT to the policies and practices set out in this privacy policy (the "Privacy Policy") and represent and warrant that you have the valid consent and authority from the Relevant Person(s) (defined below) for us to collect, use, disclose and/or process your Personal Data as described herein. This Privacy Policy describes how we will collect, use and disclose your personal data when you access or use our Services/Products. You agree that CGOLD may update this Privacy Policy at any time by posting the amended version on our website and associated application program interface or mobile applications (the "Site") or sending the latest Privacy Policy to you via email. Your use or continued use of any Services/Products after such amendment shall be deemed as your acceptance and agreement to the same.

2. What Personal Data We Collect

We may from time to time collect, process, and store certain personally identifiable information that can be used to contact or identify you and your beneficial owners, directors, officers, authorized signatories, employees, representatives, guarantee/security providers and other natural persons related to you ("Relevant Persons") via your use of the Services/Products or where you have given your consent ("Personal Data"). Such Personal Data may include contact details, information and data generated in the ordinary course of your relationship with us, information and data collected when you or a Relevant Person participates in events organized by us and information from cookies or the use of any information technology applications. The Personal Data that you may provide to us during the onboarding process may also include, without limitation:

Individual customers:

• Full legal name (including former name, and names in English and Chinese, if applicable)
• Identification document type (e.g. Passport)
• Identification document number (e.g. Passport No.)
• Gender
• Date of birth
• Place of birth
• Nationality
• Residential address
• Country/state of residence
• Total net wealth (approximately in USD)
• Purpose of account opening
• Initial and ongoing sources of wealth or income
• Nature and details of the business/occupation/employment
• Level of activity anticipated
• Source of funds/crypto-assets to be used in the relationship
• Contact phone number
• Email address
• Bank account information
• Blockchain address
• Additional personal data or documentation at the discretion of our Compliance team

Corporate customers:

• Legal name (including the legal name in English and the legal name in Chinese, if applicable)
• Business name (if different from legal name)
• Incorporation/registration information
• Contact personal details
• Related party details
• Authorized representative details
• Asset information
• Additional information or documentation at the discretion of our Compliance team

3. How We Use Your Personal Data

We may use the collected Personal Data for the following purposes:

• To make decisions relating to the provision or continued provision of the Services/Products to you.
• To administer, operate, deliver, improve, and personalize the Services/Products.
• To monitor and record the usage of the Services/Products and communications with you and/or the Relevant Persons (including for investigation and fraud prevention purposes).
• To detect, prevent and address technical issues.
• For risk assessment and data analysis (including data processing, anti-money laundering and credit analyses), internal management and to carry out internal/external audits.
• To communicate with you, your affiliates and/or your representatives in relation to events, our Services/Products and other products or services offered by CGOLD or its affiliates, unless you have opted not to receive such information.
• To fulfil any applicable legal, regulatory and compliance requirements (including anti-money laundering and tax obligations applicable to us).
• To enforce or defend the rights or property of CGOLD, its affiliates and other Users.
• Carry out any other purpose(s) described to you at the time the data was collected.

4. Do We Share Your Personal Data

We may share your Personal Data with the following persons:

• Our third party service providers (including any "Know Your Client" or other blockchain analytics service providers and service providers that provide website hosting, data analysis, information technology, mailing, telecommunications, human resource, data processing, payments, credit references or other services).
• Any person or entity that is part of CGOLD and its affiliates who is under a duty of confidentiality to the disclosing entity.
• Any person to whom we are under an obligation or otherwise to make disclosure pursuant to legal process or pursuant to any foreign or domestic legal, tax, and/or regulatory obligation or request.
• Any actual or proposed assignee or business transferee of CGOLD and/or its affiliates.

We may also share aggregated or anonymized Personal Data with the above persons to help administer, operate, deliver and improve the Services/Products.

5. Do We Transfer Your Personal Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Please note that we may transfer the data, including Personal Data, outside your jurisdiction and process it there. Your consent to this Privacy Policy and your submission of such information represents your agreement to that transfer.

We will take reasonable measures to ensure that your Personal Data is treated securely and in accordance herewith and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your Personal Data and other personal information.

6. How We Store Your Personal Data

The Personal Data that we collect from you may be transferred to, and stored at, a destination outside of Singapore or your state, province, country or other jurisdictions. By submitting your Personal Data, you agree to this transfer, storing or processing. Information you provide to us may also be stored on our and/or third-party cloud servers.

7. How Long Do We Retain Your Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. By accessing/using our Services/Products you are giving a consent for us to retain your Personal Data.

8. Legal Basis For Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area ("EEA"), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. We may process your Personal Data because:

• We need to use your Personal Data to contract with you or to perform our obligations thereunder.
• You have given us consent to do so.
• The processing is in our legitimate interests or necessary to comply with our legal obligations.
• To comply with applicable laws and regulations.

If you are a resident of the EEA, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. Please see section 15 (Contacting Us About Privacy Questions or Concerns) below.

In certain circumstances, you have the following data protection rights:

• The right to access, update or to delete the information we have on you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request us to restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

9. Marketing Communications

We may communicate company news, promotions, and information relating to our products and services provided by us. We may share Personal Data with our affiliates to send marketing communications. By using our Services/Products, you accept this Privacy Policy and you agree to receive such marketing communications, unless you choose to opt out from these marketing communications during the onboarding process.

If you change your mind and wish not to receive these communications, please send an email to cgold@quodagis.ch with the subject "MARKETING OPT OUT".

To ensure the quality of our Services/Products, for Service/Product related communications, such as amendments to terms and conditions, updates and operational notifications, you understand you will not be able to opt out of receiving such information.

10. Cookie Usage

While you access the Site, we may use the industry practice of placing a small amount of data that will be saved by your browser ("Cookies"). This information can be placed on your computer or other devices used to visit the Site. This information helps us recognize you as a customer, collect information about your use of our Services/Products to better customize our services and better your experience. We may also use the information collected to ensure compliance with our compliance program, and to ensure your account security has not been compromised by detecting irregular or suspicious account activities.

Most browsers are setup to accept Cookies automatically. Some Cookies expire when you finalize the session and other Cookies remain on your computer or other devices until deleted or expired. You have the option to decline the use of our Cookies, but this may affect the functionality of the Services/Products or your user experience.

Some browsers have a do not track feature that lets you tell websites that you do not want to have your online activities tracked. At the moment, we do not respond to browser do not track signals.

11. Information Security

We endeavour to protect ourselves and you from unauthorized access, alteration, disclosure, or destruction of data we collect and store. We take various measures to ensure information security, including encryption of our communications with SSL, requiring two-factor authentication for all sessions, periodic review of our Personal Data collection, storage, and processing practices and restricted access to your Personal Data on a need-to-know bases.

The Security of your data is important to us, but you understand and acknowledge that no method of transmission over the Internet, or method of electronic storage is fully secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

12. Links To Other Site

Our Site may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit. You understand we have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

13. Minor Policy

We do not provide Services/Products to anyone under the age of 18. We do not knowingly and intentionally collect the personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us and we will take appropriate measures.

14. Your Contact With Other Customers

You understand you are solely responsible for your interactions with other Users. We reserve the right, but have no obligation, to monitor disputes between you and other Users.

15. Contacting Us About Privacy Questions Or Concerns

If you have any questions about this Privacy Policy or the use of your Personal Data, please contact us by sending an email to the following address cgold@quodagis.ch with the subject "PRIVACY QUESTION".

If you wish to know what Personal Data we retain and if you want it to be updated, corrected or deleted from our systems, please contact cgold@quodagis.ch with the subject "DATA INQUIRY". We will do our best to do so as soon as possible with exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes.

If you wish to withdraw your consent, please contact cgold@quodagis.ch with the subject "DATA INQUIRY". Where you or a Relevant Person withdraws your/its/their consent or fails to supply relevant information or data required for us to provide our Services/Products to you, we may be unable to provide or continue to provide Services/Products to you.

In response to data access, correction, deletion or data portability request, we will verify the requesting party's identity to ensure that he or she is legally entitled to make such request. While we aim to respond to these requests free of charge, we reserve the right to charge you a reasonable fee especially if the request is repetitive or onerous.

16. Language

If this Agreement is translated into any other language from English, the English language version shall prevail to the extent of any inconsistency.

Non-Solicitation Declaration

Last Updated: July, 2026

I/We hereby confirm that the decision to enter into any agreement and/or accept any services provided by CGOLD or any of its affiliates is/are based on my/our own independent research and consideration.

CGOLD or any of its affiliates did not make any offer or invitation, issue any advertisement containing any offer or invitation, or conduct any other solicitation activities to solicit me/us to become its client.

Anti-Money Laundering & Countering Financing of Terrorism Policy Statement

Last updated on July 2026

CGOLD is dedicated to actively engaging in global initiatives aimed at combating illicit activities of money laundering (ML) and the funding of terrorism (TF). Our commitment extends to ensuring strict adherence to the regulations concerning Anti-Money Laundering (AML), Countering Financing of Terrorism (CFT), and sanctions. Collectively these obligations and guidance form our AML Program.

The AML Program is put together to ensure that CGOLD complies with the applicable legislation and regulations in the countries that we operate in. This includes having adequate risk and control mechanisms to mitigate any AML/CFT risk.

The components of our AML Program encompass, among various elements:

1. AML/CFT Policy

The AML/CFT Policy sets out the minimum standards which must be complied with by CGOLD. This includes:

1. Written policies, procedures, and internal controls designed to ensure compliance with applicable AML laws and regulations
2. Designation of a Money Laundering Reporting Officer (MLRO), who is accountable for the AML Program
3. Designation of Compliance Officers who are responsible for the day to day monitoring of AML operations
4. Robust Governance Framework where the Senior Management have oversight over the AML Program
5. Adequate Know-Your-Customer (KYC) standards to identify and verify all customers including all related parties, authorised representatives, beneficial owners where applicable. Purpose of account, source of funds, source of wealth are also obtained upon onboarding
6. Risk assessments of clients are performed based on client types, industries, jurisdictions and products offered
7. Enhanced due diligence are conducted for customers who have been identified as presenting higher risk, including those who are assessed to have Politically Exposed Person (PEP) nexus, High Risk Industries, Adverse news or any other risk elevating factors as detected through our ongoing compliance effort such as Know Your Transactions (KYT) or Transaction Monitoring (TM)
8. Escalating and filing of suspicious activities internally and externally with the relevant regulatory authorities
9. Periodic Reviews (PR) are conducted based on the risk rating of customers
10. Annual mandatory AML/CFT training is required for all employees, all new joiners are required to complete the AML/CFT training
11. Independent audit to review and assess the compliance with the AML Program
12. Maintenance of client records according to the period prescribed by the relevant authorities

2. Prohibited Uses, Customers and Businesses

Prohibited Business Relationships

CGOLD shall not conduct business relationships with the following client types:

• Sanctioned individuals and entities by the BVI authorities or under International Sanctions lists (e.g. United Nations Security Council, United States Office of Foreign Asset Control (OFAC), EU Sanctions, Singapore Monetary Authority of Singapore lists etc)
• Business enterprises and persons which it knows or must presume to be involved in terrorist financing or to be a criminal organisation or belong to or support such an organisation
• Shell banks which have no physical presence at their place of incorporation
• Clients operating under fictitious names or pseudonyms
• Clients that are in Weapons, Armament Manufacturers, Armament Trading
• Clients involved in Tobacco trading
• Clients involved in Adult Entertainment
• Clients involved in Casinos, Gambling or similar industries

Prohibited Assets

CGOLD shall not allow funds, of which it knows via its Know Your Transaction (KYT) monitoring or KYC checks to be the proceeds of a crime or to be used for financing terrorism or belonging to a criminal organisation, to enter into a client business relationship, even if the crime or offence was committed abroad.

Restricted Jurisdictions

CGOLD shall not enter business relationships with clients from restricted jurisdictions. This includes but is not limited to jurisdictions with sanctions nexus, severe political instability and/or economic inequality.

3. KYT at CGOLD

CGOLD strictly prohibits users from using our platforms to engage in illegal activities such as money laundering, terrorist financing or illegal commerce.

Real time and continuous KYT screening is performed on all users' transactions. In case of any suspected illegal transactions or illegal acts found through KYT and transaction monitoring, CGOLD may take actions against the user, including but not limited to rejecting funds, issuing request for information, freezing accounts or reporting of suspicious activity to appropriate regulatory authorities. CGOLD reserves all rights under its contractual arrangements with you and under the laws applicable to it.

4. Prohibited Activity

CGOLD would like to remind users of prohibited actions at our platforms, including but not limited to:

• Transactions that may violate, or cause CGOLD to violate applicable economic sanctions imposed or enforced by various governmental agencies including, but not limited to, those administered by the Office of Foreign Asset Control of the U.S. Department of Treasury, U.S. Department of State, the United Nations Security Council, the European Union member state, Federal Council of Switzerland and etc. CGOLD is committed to combatting financial crime and complying with all applicable sanctions laws and regulations in the jurisdictions in which we operate.
• Transactions related to illicit activities, such as frauds, scam, stolen funds, ransomware, malware.
• Transactions related to risky activities, such as mixing, darknet markets.
• Transactions related to casinos, gambling or similar industries.
• Transactions with irregular, unusual or uncommon transaction patterns and no logical business explanation, such as deposit followed by almost immediate withdrawal without additional activity.

Fee Schedule