App Terms & Conditions

Gold Program — Terms and Conditions

Version 2.2 FINAL • 25 May 2026

IMPORTANT – PLEASE READ CAREFULLY
By downloading, installing, or using the Gold Program application, you acknowledge that you have read, understood, and agree to be bound by these Terms and Conditions. If you do not agree to these terms, you must not use the application.

1. Introduction and Definitions

1.1 The Gold Program application (“the App”) is owned and operated by Brookville Capital Limited (“we”, “us”, “our”, or “the Company”), a company registered in England and Wales under company number 6578589, with its registered office at Harwood House, 43 Harwood Road, Fulham, London SW6 4QP.

1.2 In these Terms and Conditions:

(a) “App” means the Gold Program mobile application available on Apple App Store and Google Play Store;
(b) “Content” means all information, data, text, graphics, and other materials displayed within or generated by the App;
(c) “User”, “you”, or “your” refers to any individual who downloads, installs, or uses the App;
(d) “Gold Program System” means the educational investment programme published by Brookville Capital Limited;
(e) “Portfolio Data” means any investment information, holdings, transactions, or valuations you enter into or view through the App;
(f) “AI-Assisted Features” means the automated data processing features of the App, including but not limited to ticker symbol lookup, portfolio data extraction, and photo/document scanning using optical character recognition (OCR) and artificial intelligence technologies;
(g) “Imported Data” means any Portfolio Data extracted by AI-Assisted Features from photographs, images, screenshots, or documents you submit to the App for processing.

2. Acceptance of Terms

2.1 By ticking the acceptance checkbox and/or by downloading, installing, accessing, or using the App, you confirm that:

(a) You have read and understood these Terms and Conditions in their entirety;
(b) You agree to be legally bound by these Terms and Conditions;
(c) You are at least 18 years of age;
(d) You have the legal capacity to enter into a binding agreement.

2.2 The App is intended for users aged 18 and over only. If you are under 18 years of age, you must not use the App.

2.3 If you do not agree to these Terms and Conditions, you must immediately cease using the App and delete it from your device.

3. Nature of the Service

3.1 The App is a portfolio tracking and educational tool only. It is designed to help you organise and monitor your investment holdings. The App does not execute trades, hold your assets, or have any access to your brokerage accounts.

3.2 THE APP DOES NOT PROVIDE FINANCIAL ADVICE. Nothing contained in the App, the Gold Program System, or any associated materials constitutes or should be construed as:

(a) Investment advice, financial advice, or tax advice;
(b) A recommendation or solicitation to buy, sell, or hold any investment;
(c) An offer of any regulated financial service;
(d) A substitute for professional financial advice from a suitably qualified independent financial adviser.

3.3 Brookville Capital Limited is not authorised or regulated by the Financial Conduct Authority (FCA) to provide investment advice. You must always consult with a suitably qualified professional independent financial adviser before making any investment decisions.

4. AI-Assisted Features and Photo Scanning

4.1 The App includes AI-Assisted Features that allow you to:

(a) Photograph or upload images of paper documents, brokerage statements, computer screens, or other materials containing investment information;
(b) Have the App automatically extract investment data from such images using optical character recognition (OCR) and artificial intelligence;
(c) Have the App automatically look up ticker symbols, stock exchanges, and current prices based on minimal data you provide.

4.2 You acknowledge and agree that:

(a) AI-Assisted Features use automated processing technologies including third-party artificial intelligence services to extract and interpret data;
(b) Imported Data may be inaccurate, incomplete, or incorrectly interpreted by the automated systems;
(c) You are solely responsible for reviewing, verifying, and confirming all Imported Data before it is saved to your portfolio;
(d) We accept no responsibility or liability for any errors in Imported Data, whether arising from OCR misreading, AI misinterpretation, or any other cause;
(e) Imported Data is presented for your review and confirmation only, and should not be treated as verified or accurate until you have checked it against your original documents.

4.3 Images and documents you submit for processing via AI-Assisted Features:

(a) Are transmitted securely to our third-party AI processing providers for the sole purpose of data extraction;
(b) Are not permanently stored by us or our third-party providers beyond the time reasonably necessary to complete the extraction;
(c) May contain personal or financial information which will be processed in accordance with Section 8 (Data Protection and Privacy) of these Terms and Conditions.

4.4 We do not warrant that AI-Assisted Features will correctly identify all holdings, ticker symbols, stock exchanges, prices, or other data from the materials you submit. Complex, handwritten, damaged, or low-quality documents may produce unreliable results.

5. Disclaimer of Liability

IMPORTANT DISCLAIMER
TO THE FULLEST EXTENT PERMITTED BY LAW, BROOKVILLE CAPITAL LIMITED, ITS DIRECTORS, EMPLOYEES, AGENTS, AND AFFILIATES ACCEPT NO RESPONSIBILITY OR LIABILITY WHATSOEVER FOR ANY LOSS, DAMAGE, COST, OR EXPENSE (WHETHER DIRECT, INDIRECT, CONSEQUENTIAL, OR OTHERWISE) ARISING FROM OR IN CONNECTION WITH YOUR USE OF THE APP OR ANY INVESTMENT DECISIONS YOU MAY MAKE.

5.1 No liability is accepted for any investment you may choose to make. All investment decisions are made entirely at your own risk. The value of investments can go down as well as up, and you may receive back less than you originally invested.

5.2 We do not warrant, represent, or guarantee that:

(a) The App will be uninterrupted, timely, secure, or error-free;
(b) Any information, data, or valuations displayed in the App are accurate, complete, reliable, or current;
(c) The App will meet your requirements or expectations;
(d) Any defects or errors in the App will be corrected;
(e) The App or any server that makes it available is free of viruses or other harmful components;
(f) Any data extracted by AI-Assisted Features, including photo scanning and ticker lookup, is accurate or complete.

5.3 Without limiting the generality of the foregoing, we specifically disclaim all liability for:

(a) Any loss of profits, income, revenue, anticipated savings, or business opportunities;
(b) Any loss or corruption of data;
(c) Any indirect, special, incidental, or consequential damages;
(d) Any losses arising from reliance on information displayed in the App;
(e) Any losses arising from third-party data providers, API services, or market data feeds;
(f) Any losses arising from inaccurate, incomplete, or incorrectly interpreted Imported Data produced by AI-Assisted Features.

6. Accuracy of Information and Valuations

6.1 All price data, valuations, and market information displayed in the App are provided for informational purposes only and are estimates based on publicly available data. Such information:

(a) May be delayed, incomplete, or inaccurate;
(b) May not reflect actual market prices at any given time;
(c) Should not be relied upon for making investment decisions;
(d) May differ from valuations shown by your broker, custodian, or other financial institutions.

6.2 Physical gold valuations displayed in the App are estimates based on spot prices and exclude dealer premiums, discounts, storage costs, insurance costs, and any other fees or charges. Actual purchase and sale prices may differ significantly from displayed estimates.

6.3 Past performance information shown in the App is not a reliable indicator of future results.

6.4 Data extracted from photographs or documents via AI-Assisted Features is derived using automated optical character recognition and artificial intelligence. Such extracted data is presented as a suggested interpretation only and may contain errors. You must verify all Imported Data against your original documents before confirming it for inclusion in your portfolio.

7. User Responsibilities

7.1 You are solely responsible for:

(a) The accuracy and completeness of any Portfolio Data you enter into the App;
(b) Verifying any information displayed in the App against your official statements and records;
(c) Seeking independent professional advice before making any investment decisions;
(d) Maintaining the confidentiality of your account credentials;
(e) Ensuring your use of the App complies with all applicable laws and regulations;
(f) Reviewing and verifying all Imported Data extracted by AI-Assisted Features before confirming it for inclusion in your portfolio;
(g) Ensuring that any documents or images you submit for processing via AI-Assisted Features do not contain information belonging to third parties without their consent.

7.2 You acknowledge that you must always speak with a suitably qualified professional independent financial adviser before buying or selling any investments, including gold, gold funds, and mining shares.

8. Intellectual Property

8.1 All intellectual property rights in the App, including but not limited to copyright, trademarks, trade names, designs, methodologies (including the football formation portfolio visualisation), and all associated content, remain the exclusive property of Brookville Capital Limited.

8.2 You may not copy, reproduce, distribute, modify, create derivative works from, reverse engineer, decompile, or disassemble any part of the App without our prior written consent.

9. Data Protection and Privacy

9.1 We process your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Your use of the App is also subject to our Privacy Policy, which forms part of these Terms and Conditions.

9.2 We collect and process only such personal data as is necessary to provide the App services. Your Portfolio Data is stored securely using industry-standard encryption and security measures.

9.3 Your personal data and Portfolio Data may be processed by the following categories of third-party service providers, solely for the purpose of delivering the App services:

(a) Cloud infrastructure and database services (for secure data storage and synchronisation);
(b) Market data providers (for retrieving gold prices, stock prices, and fund valuations);
(c) Artificial intelligence and machine learning services (for AI-Assisted Features including ticker lookup, data extraction, and photo/document scanning).

9.4 We do not sell your personal data. We share your data with third-party service providers only as described in clause 9.3 and as necessary to provide the App services, or as required by law.

9A. AI Processing and Automated Decision-Making

9A.1 The App uses automated processing technologies, including artificial intelligence provided by third-party services, to:

(a) Extract text and data from photographs and documents you submit;
(b) Identify and look up investment ticker symbols and stock exchanges;
(c) Calculate portfolio valuations and performance metrics.

9A.2 This automated processing does not produce legal effects or similarly significant effects on you. All data extracted by AI-Assisted Features is presented for your review and confirmation before being added to your portfolio. No investment decisions are made or recommended by the automated systems.

9A.3 Images and documents you submit for AI processing are transmitted securely to our third-party AI service providers. These providers process the data solely for the purpose of extracting the requested information and do not retain your data beyond the processing period.

9A.4 You have the right to request information about the automated processing of your data, and to request human review of any AI-generated output, by contacting us at the address set out in Section 16.

10. Access and Termination

10.1 The App is available to any individual who has purchased The Gold Program System and has not cancelled or received a refund. Accounts are created by Brookville Capital Limited via the admin dashboard.

10.2 If a refund is requested and granted under the 30-day money-back guarantee, your access to the App will be revoked.

10.3 We reserve the right to terminate or suspend your access to the App at any time if:

(a) You breach these Terms and Conditions;
(b) A refund is requested and granted under the 30-day money-back guarantee;
(c) We reasonably believe such action is necessary to protect our interests or the integrity of the App.

10.4 Brookville Capital Limited may terminate a user’s access to the App immediately and without notice if the user is found to be in breach of these Terms and Conditions. Upon termination, you must cease all use of the App and delete it from your device.

11. Limitation of Liability

11.1 The App is a portfolio tracking tool only and does not constitute financial advice. Brookville Capital Limited is not liable for any direct, indirect, incidental, special, consequential, or exemplary losses or damages arising from or in connection with your use of the App, including but not limited to losses arising from investment decisions, data inaccuracies, service interruptions, or reliance on any information provided through the App.

11.2 Nothing in these Terms and Conditions excludes or limits our liability for:

(a) Death or personal injury caused by our negligence;
(b) Fraud or fraudulent misrepresentation;
(c) Any other liability that cannot be excluded or limited under applicable law.

11.3 Subject to clause 11.2, our total aggregate liability to you under or in connection with these Terms and Conditions, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, shall not exceed the amount you have paid to Brookville Capital Limited for the Gold Program System in the 12 months preceding the claim.

12. Indemnification

12.1 You agree to indemnify, defend, and hold harmless Brookville Capital Limited, its directors, officers, employees, agents, and affiliates from and against any and all claims, damages, losses, costs, and expenses (including reasonable legal fees) arising from or in connection with:

(a) Your use of the App;
(b) Your breach of these Terms and Conditions;
(c) Any investment decisions you make;
(d) Your violation of any applicable law or regulation.

13. Changes to Terms and Conditions

13.1 We reserve the right to modify these Terms and Conditions at any time. We will endeavour to provide you with reasonable advance notice of material changes via the App or by email. Your continued use of the App after such changes take effect constitutes acceptance of the modified terms.

13.2 If you do not agree to any modified terms, you must stop using the App and may request cancellation of your account.

14. Governing Law and Jurisdiction

14.1 These Terms and Conditions shall be governed by and construed in accordance with the laws of England and Wales.

14.2 Any disputes arising out of or in connection with these Terms and Conditions shall be subject to the exclusive jurisdiction of the courts of England and Wales.

15. General Provisions

15.1 Severability: If any provision of these Terms and Conditions is held to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect.

15.2 Entire Agreement: These Terms and Conditions, together with our Privacy Policy, constitute the entire agreement between you and Brookville Capital Limited regarding the use of the App.

15.3 No Waiver: Our failure to enforce any right or provision of these Terms and Conditions shall not constitute a waiver of such right or provision.

15.4 Assignment: You may not assign or transfer your rights or obligations under these Terms and Conditions without our prior written consent. We may assign our rights and obligations without restriction.

16. Contact Information

16.1 If you have any questions about these Terms and Conditions, please contact us at:

Brookville Capital Limited
Mill House, Mill Road
Lewes
East Sussex BN7 2RT

Company Registration Number: 6578589

Email: simonpopple@brookvillecapital.com

USER ACCEPTANCE
By ticking the checkbox in the App, I confirm that:
☐ I have read and understood these Terms and Conditions in their entirety
☐ I understand that the App does not provide financial advice
☐ I accept that Brookville Capital Limited accepts no liability for any investment decisions I may make
☐ I understand that AI-Assisted Features including photo scanning use automated processing and may produce inaccurate results
☐ I agree to be bound by these Terms and Conditions

The value of investments can go down as well as up. Past performance is not a reliable indicator of future results. Brookville Capital Limited does not provide financial advice.

Document Version 2.2 FINAL • 25 May 2026