The Real Money

Advisory Activity

Financial Advice · Gold Advice · Digital Asset Advice · V1.0

Providing entityReal Money Advisory Limited (The Real Money)

Registered officeBlock 4 Harcourt Centre, Harcourt Road, Dublin 2, Ireland, D02 HW77

Supervisory authorityCentral Bank of Ireland (CBI) — www.centralbank.ie

Regulatory frameworkDirective 2014/65/EU (MiFID II) · EU Reg. 2023/1114 (MiCAR) · GDPR

Type of adviceAncillary and preparatory to the Platform's services

Nature of the recommendationPersonalized; not binding on the client

Delivery channelwww.therealmoney.com Platform — Reserved Area

What THE REAL MONEY's Advisory Service is

THE REAL MONEY provides personalized advisory services upon the User's request.

The Advisory Service is ancillary to, and intended to facilitate access to, the Services available through the Platform: THE REAL MONEY assists the User in identifying the products and services that are most suitable for their personal circumstances and objectives, guiding the User in their choice before proceeding with the activation of the specific service.

What THE REAL MONEY's advice is NOTThe Advisory Service does not constitute: discretionary portfolio management; reception and transmission of orders; execution of transactions in the name of or on behalf of the client; any guarantee of return or result; tax or legal advice. It does not constitute a solicitation to invest in or purchase financial instruments.

Who it is for

The Advisory Service is available to all Users registered with THE REAL MONEY Platform who have completed the Onboarding process and MiFID Profiling. It is available to both retail clients and professional clients.

For retail clients, THE REAL MONEY applies the investor protection measures required under MiFID II, including a mandatory suitability assessment based on the client's profile before personalized advisory services are provided.

MiFID Profiling: how it works

At THE REAL MONEY, advisory services are provided only at the User's request, with the aim of helping the User understand the products and services available through the Platform.

Before receiving any direct information, each User is required to complete the MiFID Profiling questionnaire. This is a mandatory step provided for under the MiFID II Directive, which enables THE REAL MONEY to understand the User's profile and to ensure that the advisory services provided are appropriate to the User's circumstances.

3.1 Information collected

The questionnaire collects information on:

Financial situation: income, assets, current financial commitments, liquidity available for investment.
Investment objectives: time horizon, purpose (capital protection, growth, income), short-term liquidity needs.
Knowledge and experience: familiarity with financial instruments, crypto-assets and precious metals; transactions carried out in the past; level of financial literacy.
Risk appetite: tolerance to temporary or permanent losses; reaction to adverse market scenarios.
Sustainability preferences (ESG): any interest in considering environmental, social and governance factors in investment choices.

3.2 Updating the profile

The User is required to update their information whenever significant changes occur in their financial situation, their objectives or their risk appetite. THE REAL MONEY may periodically request a review of the questionnaire.

Where the information provided is incomplete or insufficient, THE REAL MONEY may be unable to carry out the required suitability assessment and will not provide personalized advisory services in relation to the relevant transaction.

Financial Advisory Services

4.1 What it consists of

THE REAL MONEY provides personalized advisory services relating to the financial instruments and products made available through the Authorized Intermediaries operating on the Platform, taking into account the User's profile resulting from the MiFID Suitability Questionnaire.

The recommendations may concern:

Portfolio composition according to the User's objectives and risk profile.
Whether to activate, modify or discontinue one or more Services available through the Platform.
Allocation across the various available asset classes (fiat currency, physical gold, digital assets, wealth-management instruments).
Accumulation plans and strategies for gradual market entry.

4.2 What each piece of information includes

Each piece of information includes:

a) A description of the product or service and its main features.
b) The rationale for the recommendation in relation to the User's profile.
c) The main risks associated with the product or service.
d) The applicable costs and fees, available in the «Fees» document on the Platform.
e) The reference to the Authorized Intermediary that provides the Service to which the information received relates.

Each recommendation is based on the information available at the time it is provided. Market conditions may change rapidly. Accordingly, THE REAL MONEY cannot guarantee that any recommendation will remain suitable unless the User's profile is reviewed and, where necessary, updated.

Gold Advisory Services

5.1 Scope of the advisory services

THE REAL MONEY provides advisory services relating to the purchase of LBMA-certified (London Bullion Market Association) physical investment gold and digital gold deposit certificates. These advisory services are intended to help Users understand the characteristics of the products, the applicable custody arrangements and the operation of gold accumulation plans before activating the relevant service.

5.2 Topics covered

Features of LBMA physical investment gold: purity, certification, international market standards.
Differences between physical gold, accumulation plans, digital gold deposit certificates and e-GOLD: structure, advantages and risks of each product.
Custody arrangements for the purchased gold: LBMA refineries, insurance, accessibility.
How gold accumulation plans operate: how they work, the advantages of dollar-cost averaging, flexibility of suspension and redemption.
Costs and fees applicable to the purchase, sale, transfer and custody of the gold.
Taxation of investment gold: VAT exemption, treatment of capital gains (for information purposes only — for specific tax assessments the client is invited to consult an accountant).

The advisory services described above do not constitute legal or tax advice. The User is responsible for their own tax assessments and is invited to consult a qualified professional on any tax matter.

Digital Asset Advisory Services

6.1 Scope of the advisory services

THE REAL MONEY provides educational and informational advisory services on crypto-assets and digital assets available on the Platform or currently undergoing the applicable authorization process, in accordance with Regulation (EU) 2023/1114 (MiCAR) and applicable law. The aim is to provide Users with the information necessary to understand the products and the risks before proceeding.

6.2 Topics covered

Features of the crypto-assets available through the Platform: utility tokens, asset-referenced tokens (ART), electronic money tokens (EMT).
e-GOLD: token structure, mechanism linking its value to LBMA-certified physical gold, ongoing MiCAR authorization process.
Blockchain and tokenization: how they work, smart contracts, custody of private keys.
Specific risks of digital assets: volatility, liquidity risk, technological risk, regulatory risk.
Blockchain projects present on the Platform: POAP, digital certification, systems for the tokenization of real-world assets.
Custody arrangements for digital assets: custodial vs. non-custodial wallets, THE REAL MONEY's custody policy.

Digital asset risk warningCrypto-assets are high-risk products and may experience significant price volatility, including the possible total loss of the capital invested. THE REAL MONEY does not guarantee the liquidity, value stability or operational continuity of any crypto-asset or digital asset. The advisory services described above are provided for informational purposes only and do not constitute investment advice, a recommendation to acquire crypto-assets or an offer to the public within the meaning of applicable law.

6.3 Authorization status of crypto-asset services

The crypto-asset trading, custody and exchange services are currently subject to an authorization application for the provision of crypto-asset services (CASP) under Regulation (EU) 2023/1114 (MiCAR). These services will become available only after the required authorization has been granted by the competent authority. THE REAL MONEY will promptly notify Users once such authorization has been obtained and the relevant services become available.

Access to the Advisory Service

7.1 Access procedure

To access the Advisory Service, the User must:

Have completed the Onboarding process (KYC/KYB) and opened an Account on the Platform.
Have completed and submitted the MiFID Suitability Questionnaire in the «My profile» section of the Reserved Area.
Request advisory services through the «Advisory Activity» section of the Platform or through an assigned Gold Advisor (where available in their plan).

7.2 Delivery channels

Channel	Method	Availability
Reserved Area	Dedicated Advisory Services section with interactive profiling and recommendation tools.	Available under all active plans
E-mail	consulenza@therealmoney.com	Response within two business days.

Limits of the advice and warnings

8.1 Non-binding nature

The information and advisory services provided by THE REAL MONEY are for informational purposes only and are not binding on the User. The User is free not to act on it. The final decision on any transaction rests exclusively with the User.

8.2 Scope of the advice

The advisory services provided by THE REAL MONEY relate exclusively to the products and services made available through the Platform. THE REAL MONEY does not provide recommendations on financial instruments, crypto-assets or gold products outside the Platform.

8.3 Past performance

The past performance of any financial instrument, crypto-asset or real asset is not indicative of future results. Any simulations, projections or examples provided as part of the advisory services are for illustrative purposes only and do not constitute any representation, warranty or guarantee of future performance or results.

8.4 Conflicts of interest

THE REAL MONEY adopts organizational and procedural measures to identify and manage potential conflicts of interest arising from the provision of advice in relation to the Services of the Authorized Intermediaries present on the Platform, in accordance with MiFID II. At the User's request, THE REAL MONEY provides further information on the measures adopted.

8.5 Retention of advisory records

THE REAL MONEY maintains records of the advisory services provided to each User. This documentation is available in the User's Reserved Area and is retained for a minimum period of 5 years pursuant to MiFID II.

Gold Advisor: who they are and what they do

Gold Advisors are professionals trained by THE REAL MONEY who specialize in physical investment gold and the products and services available through the THE REAL MONEY ecosystem. They operate exclusively within the Advisory Services and are subject to the same MiFID II conduct rules applicable to THE REAL MONEY.

The Gold Advisor:

Supports the User in understanding the gold products available on the Platform.
Assists the User in completing and updating the MiFID Suitability Questionnaire.
Provides personalized recommendations within gold advice and, where trained, also in the financial and digital asset areas.
Does not execute transactions on behalf of the User and has no authority to access or operate the User's Account.

Processing of personal data in connection with the advisory services

The personal data collected through the MiFID client profiling process and in connection with the provision of the Advisory Services are processed by the operator of THE REAL MONEY platform as Data Controller, pursuant to Regulation (EU) 2016/679 (GDPR) and the Data Protection Act 2018 (Ireland), for the following purposes:

Assessment of the suitability of investment recommendations (MiFID II — mandatory).
Provision of the personalized Advisory Service.
Retention of documentation for the purposes of MiFID II regulatory compliance (minimum retention of 5 years).
Improvement of profiling models and of the services offered (in anonymized form).

The MiFID questionnaire data are not shared with the Authorized Intermediaries without the User's prior explicit consent, except where disclosure is required by applicable law. For further information, please refer to the «Privacy» section of the Platform.