Glossary · Platform Definitions and Terms

The User's personal reserved area within THE REAL MONEY Platform, accessible via login credentials. From the Account, the User can view their data, activate and manage available Services, check their transactions, and contact customer service.

Alternative dispute resolution procedures, out-of-court and generally free of charge for consumers, can be activated as an alternative to recourse to ordinary judicial authorities. For THE REAL MONEY services, the reference ADR body is the Irish Financial Services and Pensions Ombudsman (FSPO).

A set of regulations, procedures, and controls aimed at preventing money laundering and terrorist financing. THE REAL MONEY and its Authorized Intermediaries are subject to the AML regulations applicable in their respective countries of establishment.

The European Union's Sixth Anti-Money Laundering Directive (EU Directive 2018/1673) harmonizes the rules for the prevention of money laundering and terrorist financing at the European level. It extends criminal liability for predicate offenses for money laundering and strengthens customer due diligence requirements.

Physical gold in the form of bars or coins, with a purity equal to or greater than 995 parts per thousand (for bars) or 900 parts per thousand (for coins), which falls within the definition of "investment gold" under European tax law (VAT Directive). The purchase of investment gold is VAT exempt in the European Union.

A company holding a license or authorization issued by the competent Supervisory Authority, which provides one or more specific Services through THE REAL MONEY Platform. Each Authorized Intermediary is solely responsible for providing the respective Service to the User. The Authorized Intermediaries of the Platform are: ORENDA FS Holding Ltd, Easy Payment and Finance E.P. S.A., Transact Payments Malta Limited, Transact Payments Limited, UPTOVALUE SA, and MyGOLD SpA.

Distributed Ledger Technology (DLT) that allows the recording, sharing, and synchronization of data or transactions across a decentralized network of nodes, without the need for a central authority. Each block of data is cryptographically linked to the previous one, making the ledger immutable and verifiable by anyone.

Crypto-asset service provider pursuant to Regulation (EU) 2023/1114 (MiCAR). An entity that, on a professional basis, provides one or more crypto-asset services (custody, exchange, trading, consultancy, etc.) and is required to obtain specific authorization from the competent supervisory authority in its Member State.

License issued by the Central Bank of Ireland (CBI) authorizing an entity to provide regulated financial services in Ireland and, through the European passporting regime, in other European Union member states. TOGO INFINITY LIMITED operates through the "Agency" process under the "plug and play" procedure with ORENDA and its relevant operators authorized by the CBI under the MiFID II Directive for the provision of investment advisory services.

The Irish Financial Supervisory Authority, responsible for the regulation and supervision of financial institutions authorised in Ireland, including payment institutions, asset management companies and entities authorised under MiFID II. Website: www.centralbank.ie.

Code of Conduct issued by the Central Bank of Ireland (updated) establishing specific consumer protection obligations for all entities regulated by the CBI, including investment firms authorized under MiFID II. It complements European regulations with specific operational requirements for the Irish market regarding client communications, complaint handling, conflicts of interest, and fair dealing in the sale of financial products and services. The Advisory Services offered through THE REAL MONEY Platform are provided in compliance with the CPC.

A written report by which the customer notifies THE REAL MONEY or an Authorized Intermediary of a specific problem relating to the Services received, requesting specific intervention. This is distinct from simple requests for information or technical assistance. The complaint handling procedure is governed by the "Complaints Handling Procedure" document available on the Platform.

The set of activities, procedures, and internal controls designed to ensure that an organization operates in compliance with applicable laws, regulations, industry standards, and codes of ethics. The Compliance Officer is responsible for overseeing these activities within THE REAL MONEY.

This document — or any specific agreement entered into between the User and THE REAL MONEY or an Authorized Intermediary — governs the terms and conditions of use of the Platform and provision of the Services.

A digital representation of a value or right that can be transferred and stored electronically using distributed ledger technology or similar technology, as defined in Regulation (EU) 2023/1114 (MiCAR). It includes virtual currencies, utility tokens, asset-linked tokens (ART), and tokenized electronic money (EMT). It is not considered legal tender.

A service consisting of the storage and administration of crypto-assets on behalf of third parties, including the management of private cryptographic keys. This service is regulated under the MiCAR Regulation.

A service consisting of the storage and administration of physical gold in maximum-security vaults. The custody service allows the customer to hold gold they own and manage the financial value of the gold through their account. Furthermore, unlike ordinary banks where money forms part of the bank's assets, in the case of the Bullion Bank (Banco Metalli) the custody of the gold is kept separate from the assets of the Bullion Bank and does not contribute to any loss for the deposit holder in the event of the Bullion Bank's insolvency.

A set of mandatory procedures required by anti-money laundering regulations (AMLD6 and the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010) that allow THE REAL MONEY and Authorized Intermediaries to identify customers, verify their identity, understand the nature of their business, and monitor their transactions. This includes the collection and verification of identity documents, information on the source of funds, and, where applicable, income documentation.

An electronic payment instrument linked directly to the User's current account or e-money account. Amounts are debited immediately or in real time upon use. Physical and virtual cards in the Elite, Evolution, and Unique versions are available on THE REAL MONEY Platform.

A digital representation of a value or right, transferable and stored electronically via distributed ledger technology (DLT/blockchain). Includes cryptoassets governed by the MiCAR Regulation (EU 2023/1114), utility tokens, asset-linked tokens (ART), and tokenized electronic money (EMT). Does not include central bank digital currencies (CBDCs).

A financial instrument representing ownership of a specific quantity of LBMA-certified physical gold, stored at smelters or authorized warehouses. It allows investors to hold and transfer gold without physically moving the metal. Available on THE REAL MONEY Platform.

A distributed ledger technology that allows data to be shared and updated across multiple nodes of a network in a decentralized manner. Blockchain is the most widespread form of DLT.

Regulation (EU) 2022/2554 on digital operational resilience for the financial sector, applicable from 17 January 2025. It applies to all financial entities regulated in the EU, including investment firms authorised under MiFID II. DORA imposes obligations regarding: ICT Risk Management Framework, classification and reporting of serious ICT incidents to competent authorities, periodic digital operational resilience testing, and contractual management of risk arising from third-party ICT providers. It provides for a principle of proportionality that allows smaller entities to apply a simplified framework for certain obligations, in compliance with the instructions of their national supervisory authorities.

An ART (Asset-Referenced Token) cryptoasset whose value is pegged to LBMA-certified physical gold. Currently being developed and authorized under the MiCAR Regulation by the competent Supervisory Authorities. Available on THE REAL MONEY Platform once the authorization process is complete.

Second European Electronic Money Directive (Directive 2009/110/EC), which regulates the issuance and management of electronic money by authorized institutions (EMIs). Transposed into national law by EU Member States.

Electronically stored monetary value representing a claim on the issuer, issued against the receipt of funds for the purpose of executing payment transactions. It is not a bank deposit and does not earn interest. Regulated by the EMD2 Directive.

Environmental, social, and governance criteria used to assess the sustainability and ethical impact of an organization or investment. These criteria are increasingly relevant in regulated financial advisory services (MiFID II integrates the assessment of sustainability preferences into client profiling since 2022).

An international intergovernmental body that sets global standards in combating money laundering, terrorist financing, and the proliferation of weapons of mass destruction. Its recommendations are incorporated into European legislation (AMLD) and national regulations.

Legal tender issued by a state or central monetary authority (e.g., the euro, US dollar, or British pound), whose value is not tied to a physical asset but is guaranteed by trust in the issuing entity. Distinct from cryptoassets and physical gold.

Regulated investment service consisting of the provision of personalized recommendations to a client, either at the client's request or at the provider's initiative, regarding one or more transactions involving financial instruments. Pursuant to Directive 2014/65/EU (MiFID II), the provider is required to assess the appropriateness of the recommendation based on the client's profile (MiFID profiling).

An independent Irish body responsible for the out-of-court resolution of disputes between clients and financial institutions authorized in Ireland, including those authorized by the CBI under MiFID II. Free for clients. Website: www.fspo.ie.

Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. Directly applicable in all EU Member States from 25 May 2018. THE REAL MONEY processes Users' personal data in accordance with the GDPR and the Data Protection Act 2018 (Ireland).

Contract whereby the User undertakes to periodically purchase (e.g., monthly) a specific quantity or value of physical LBMA gold, distributing the average purchase cost (dollar-cost averaging) over time. Available on THE REAL MONEY Platform.

Professionals trained by THE REAL MONEY to provide advice and support to clients regarding investments in LBMA physical gold and related products. Gold Advisors operate within the Advisory Services of REAL MONEY ADVISORY and REAL MONEY EUROPE LIMITED, depending on their licenses.

An internationally standardized alphanumeric code that uniquely identifies a bank or payment account. Required for SEPA and SWIFT transfers.

Identification and verification procedure applied to legal entities (companies, entities, associations) requesting to open an Account or activate Services on THE REAL MONEY Platform. It includes verification of corporate information, ownership structure, and beneficial owners (Ultimate Beneficial Owners — UBO).

Identification and verification procedure applied to natural persons who request to open an Account or activate Services on THE REAL MONEY Platform. It includes verification of identity documents, residency, and, where required by AML regulations, the source of funds.

London-based international association that sets standards for the physical gold and silver market. The "LBMA Good Delivery" mark certifies that bars and coins meet globally recognized minimum purity and weight requirements.

Regulation (EU) 2023/1114 of the European Parliament and of the Council on markets in crypto-assets. It constitutes the first harmonized European regulatory framework for crypto-assets, regulating the issuance of tokens (ART, EMT, utility tokens) and the provision of crypto-asset services (CASP). Applicable from December 30, 2024.

Directive 2014/65/EU of the European Parliament and of the Council on markets in financial instruments. It regulates the provision of investment services (including financial advice) in the European Union, imposing requirements regarding authorization, transparency, suitability, and investor protection.

Mandatory process under the MiFID II Directive whereby THE REAL MONEY collects information about the User (financial situation, investment objectives, time horizon, knowledge and experience of financial instruments, risk appetite, ESG sustainability preferences) in order to assess the appropriateness of the investment recommendations provided as part of the Advisory Services.

European platform for online dispute resolution between consumers and traders, made available by the European Commission at https://ec.europa.eu/consumers/odr. It allows consumers residing in the EU to initiate an ADR procedure with accredited bodies.

Registration and identity verification process that the User must complete to open an Account on THE REAL MONEY Platform and request the activation of one or more Services. It includes KYC or KYB procedures, acceptance of contractual documents, and, for Advisory Services, completion of the MiFID profiling questionnaire.

The THE REAL MONEY website and mobile application, accessible at www.therealmoney.com, including all the features and reserved areas made available to the User. The Platform is operated by TOGO INFINITY LIMITED.

A non-fungible token (NFT) used to digitally certify participation in a physical or virtual event. Within the context of THE REAL MONEY Platform, it can be used in initiatives related to blockchain projects and tokenization.

Payment instrument not linked to a bank account, usable within the limits of the previously loaded available balance. Governed by the electronic money legislation (EMD2 Directive).

The European Payment Services Directive (EU Directive 2015/2366), which regulates the provision of payment services in the European Union, introduces Strong Customer Authentication (SCA) and opens the payments market to third parties (open banking). Implemented in Ireland by the European Union (Payment Services) Regulations 2018 (SI No. 6/2018).

Strong customer authentication, mandatory under the PSD2 Directive, requires the use of at least two independent elements: something the user knows (e.g., password), something the user has (e.g., smartphone), or something that identifies the user (e.g., fingerprint). Applied for account access and payment authorization.

Transfer of funds in euros between bank or payment accounts within the Single Euro Payments Area (SEPA), which includes the European Union countries, plus Iceland, Norway, Liechtenstein, Switzerland, Andorra, Monaco, San Marino, Vatican City, and the United Kingdom. Governed by PSD2 and SEPA regulations.

The set of financial, payment, precious metals investment, digital asset, and advisory services available on THE REAL MONEY Platform. Each Service is provided by the relevant Authorized Intermediary.

An international financial messaging network used by banks and financial institutions for the secure exchange of information relating to international financial transactions. See also SWIFT Transfer.

International funds transfer via the SWIFT (Society for Worldwide Interbank Financial Telecommunication) network, used for transactions to countries outside the SEPA area or in currencies other than the euro. Subject to higher fees and longer processing times than SEPA credit transfers.

Trade name of TOGO INFINITY LIMITED. This refers to both the brand and the multi-service platform accessible at www.therealmoney.com. In the contractual documents, "THE REAL MONEY" refers to TOGO INFINITY LIMITED as the owner of the trademark and operator of the therealmoney.com platform.

A company incorporated under Irish law with registered office at Block 4 Harcourt Centre, Harcourt Road, Dublin 2, Ireland, D02 HW77. Owner of the use of THE REAL MONEY trademark and the Platform.

A digital unit issued on a blockchain or distributed ledger. Depending on its characteristics, it can be classified as a utility token, an asset-referenced token (ART), a tokenized electronic money (EMT), or a non-fungible token (NFT). The classification under the MiCAR Regulation determines the applicable regulatory regime.

The process of digitally representing a real-world asset (e.g., physical gold, real estate, artwork, credit) on a blockchain in the form of a token. It allows for the asset's divisible, transferable, and programmable nature via smart contracts.

The natural person who ultimately owns or controls a legal entity, or on whose behalf a transaction or activity is conducted. UBO identification is mandatory as part of KYB procedures under AML regulations.

Any natural person of legal age (18 years or older) or legal entity who accesses THE REAL MONEY Platform and/or requests the activation of one or more Services. Depending on their status (natural person or legal entity), the User is subject to KYC or KYB procedures.

Date from which amounts credited or debited to an account take effect for the purposes of calculating interest or the availability of funds.

A software or hardware tool that allows you to store, send, and receive cryptoassets by managing the associated cryptographic keys.

Internal reporting procedure for possible regulatory violations committed by employees or contractors of an organization, governed in Ireland by the Protected Disclosures (Amendment) Act 2022 and EU Directive 2019/1937. This is separate from complaints relating to the Services received by the User. THE REAL MONEY guarantees the confidentiality of the identity of the reporter.