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BT SA · Swiss Company · XBTM Portal

Terms and Conditions

Effective date: 2 October 2026 · Version 1.0

These Terms and Conditions govern the contractual relationship between BT SA and the Client in relation to the XBTM portal (https://xbtm.net), the purchase and sale of physical gold and silver held in custody in Switzerland, and their digital representation through GLD NFT and SLV NFT identifiers.

Operator: BT SA, company incorporated under Swiss law with registered seat at Microcity, Rue de la Pierre-à-Mazel 39, 2000 Neuchâtel, Switzerland.
Official correspondence: CS@XBTM.NET — Registered postal address: Microcity, Rue de la Pierre-à-Mazel 39, 2000 Neuchâtel, Switzerland.
Governing law: Swiss law — Jurisdiction: Neuchâtel, Switzerland.

1. Object and Scope

The present Terms and Conditions (the "Terms") govern, on the one hand, the access to and use of the XBTM internet portal published at https://xbtm.net (the "Portal") and, on the other hand, the opening and maintenance of a client account, the acquisition, holding and disposal of rights relating to physical gold and silver (the "Metals") placed in custody in Switzerland, and the digital representation of such rights through the product identifiers designated as "GLD NFT" for gold and "SLV NFT" for silver.

These Terms, the order confirmations issued by BT SA in written durable form, the fee schedule published on the Portal and the product information sheets constitute the entire contractual framework between the Parties (the "Contract"). Any general terms of the Client that are incompatible with these Terms shall not apply unless BT SA has expressly accepted them in writing. Mandatory provisions of applicable law shall prevail over any contractual clause that is inconsistent therewith.

2. Definitions and Interpretation

"Metals" shall mean physical gold and silver, in the form of bars, ingots or other allocated units as specified in the relevant product information sheet, with the fineness, weight and identification details indicated therein. "GLD NFT" and "SLV NFT" shall mean the non-fungible digital identifiers issued and maintained under the XBTM technical framework for the sole purpose of referencing, respectively, the Client's rights relating to gold and silver under this Contract. "Available Balance" shall mean the fiat amounts credited to the Client's account and cleared in accordance with Article 7, which may be freely applied to orders or withdrawals pursuant to these Terms. "Custodian" shall mean the Swiss vault operator appointed by BT SA under the custody arrangements described in Article 4. "Allocation Register" shall mean the internal ledger maintained by BT SA that records, for each Client, the corresponding metal quantities, bar or lot references, digital identifiers and supporting documents.

The expressions GLD NFT and SLV NFT are commercial designations of BT SA and do not denote, by themselves, any affiliation with third-party funds, investment vehicles or product issuers using similar acronyms. References in these Terms to specific third-party operators, refiners or custodians by name reflect the operational arrangements in force as of the effective date of the present version.

3. Nature of the Product and Rights of the Client

The Client acquires, under the conditions set out herein, direct and verifiable rights over physical Metals held in custody on its behalf by the Custodian at the Swiss depository designated by BT SA. The precise nature of the right — whether full individual ownership of an allocated bar or a co-ownership share in a specifically identified lot — is determined by reference to the relevant product information sheet, which also specifies the quantity, fineness, method of allocation, timing of the transfer of rights and the supporting evidence available to the Client.

The transfer of rights relating to the Metals takes place, as the case may be, upon (i) full and final settlement of the corresponding price and any fees due and (ii) the actual and documented entry of the corresponding quantity in the Allocation Register in favour of the Client. The Portal clearly distinguishes between orders still pending execution and positions definitively allocated. Should the allocation of a specific quantity of Metal be rendered impossible through no fault of the Client, BT SA shall promptly inform the Client and refund any cleared amounts already received, without prejudice to any remedies available to the Client under mandatory law.

The GLD NFT and SLV NFT identifiers are evidentiary elements linked to the corresponding position in the Allocation Register and do not have, by themselves, any intrinsic value separate from the Metals to which they refer. The mere holding of a token does not, without corroboration against the Allocation Register and BT SA's internal records, constitute sufficient proof of title to the underlying Metal. Entries recorded on a public blockchain pursuant to Article 6 are made for transparency and traceability purposes and do not, by themselves, constitute an independent certification of reserves or a public guarantee within the meaning of any applicable financial regulation.

The Product offered under these Terms does not carry any undertaking of interest, guaranteed return or capital protection. The classification of the Product and of the GLD NFT / SLV NFT identifiers for regulatory, financial, tax or accounting purposes shall be determined by the law and by the competent authorities of each relevant jurisdiction on the basis of the actual characteristics of the Product, and not merely of the labels used. The offer made through the Portal is directed exclusively at persons and entities located in jurisdictions where such offer is lawfully permitted.

4. Custody of Metals in Switzerland

The Metals underlying the positions acquired by the Client are held in custody in Switzerland in a secured and regularly audited vault infrastructure, operated by the Custodian appointed by BT SA under the custody arrangements in force. The identity and contact details of the Custodian, together with the main characteristics of the vault (LBMA-compliant infrastructure, applicable insurance cover and audit frequency), are accessible, for each position, through the authenticated Client area of the Portal.

BT SA discloses, before any order is placed, the main elements of the custody regime: identity of the Custodian, place of custody, method of segregation of the Metals from the assets of BT SA and from the assets of other clients, nature of the insurance cover (insured perils, policy limits, deductible, insured party and claim reporting procedures). No representation is made that insurance cover is unlimited or that it extends to all possible categories of loss.

BT SA performs, on a regular operating schedule, a reconciliation between the quantities and bar references recorded in the Allocation Register and the Metals actually held in custody on behalf of the corresponding clients. Evidence of the specific position allocated to the Client is available through the authenticated dashboard of the Portal. Allocated Metals are not lent, pledged, assigned or otherwise used to satisfy the obligations of BT SA, unless and to the extent that BT SA has obtained a separate written agreement from the Client, executed in accordance with the applicable legal requirements.

Accounting segregation of Metals on behalf of the Client does not automatically entail legal segregation vis-à-vis the creditors of BT SA or of the Custodian in the event of insolvency. The respective rights of the Client, BT SA and the Custodian, including the modalities for the restitution of Metals and their enforceability against third parties, are governed by the applicable Swiss law and by the specific custody arrangements of which BT SA holds the original documentation.

5. Client Registration and Verification

Registration on the Portal is open exclusively to natural persons of full age and capacity, and to legal entities duly represented by persons with the necessary powers. At the time of registration and at any later time during the relationship, the Client shall provide accurate, complete and up-to-date information concerning its identity, domicile, beneficial ownership, source of wealth and source of funds, and shall transmit such supporting documentation as BT SA may reasonably require for the performance of its obligations.

BT SA carries out identity verification, screening for sanctions and politically exposed persons, and anti-money-laundering and counter-terrorist-financing controls, either directly or through service providers specifically appointed for that purpose, in accordance with the regulatory obligations applicable to BT SA and to the operations envisaged. Such controls are performed under the responsibility of BT SA and do not, in themselves, constitute an indication of any particular regulatory authorisation.

BT SA reserves the right to refuse the opening of an account or to limit, suspend or terminate the relationship in the cases and under the conditions provided for in these Terms and in applicable law. Where it is reasonably possible to do so without contravening a legal or regulatory prohibition, BT SA shall inform the Client of the grounds for any such decision.

6. Credentials, Token Framework and Authentication

The Client undertakes to keep its passwords, authentication codes, second-factor devices and any other credentials strictly confidential and to use reasonable efforts to protect them against unauthorised disclosure or use. The Client shall notify BT SA without undue delay at CS@XBTM.NET of any unauthorised access or any reasonably suspected compromise of its account or credentials. BT SA shall take proportionate and timely measures upon receipt of such a report.

The GLD NFT and SLV NFT identifiers operate under a technical framework managed and controlled by BT SA, the purpose of which is exclusively to ensure the traceable link between the Client, the entry in the Allocation Register and the corresponding physical Metal position. The main technical specifications of this framework — including the blockchain networks supported, the applicable smart-contract addresses, the token identification ranges, the permitted and prohibited transfer scenarios and the account recovery procedures — are published in the authenticated Client area and may be consulted at any time by the Client.

Should the technical framework involve any element of private control held by the Client, the loss of the corresponding key material may restrict the Client's ability to access or transfer the token; however, such loss shall not, by itself, extinguish the Client's underlying right to the Metals, as evidenced by the Allocation Register and by BT SA's internal records. BT SA shall apply, in such cases, the alternative proof-of-title procedure published in the technical specifications. Any on-chain transfer shall only produce the effects provided for in these Terms if it complies with all the conditions of form, identity and substance required under the Contract; no such transfer shall, by itself and mechanically, operate a valid transfer of rights in the Metals.

7. Funding of the Account — Payment Methods

The Client may credit amounts to its Available Balance by bank transfer, by enabled payment cards or by transfer of supported crypto-assets, in accordance with the methods, limits and disclosures specified on the Deposit page of the Portal. All payment accounts and crypto-asset receiving addresses made available to the Client shall be held in the name of, or controlled by, BT SA or by a service provider expressly appointed by BT SA for that purpose. The use by the Client of payment instruments or accounts not in its own name is permitted only where specifically approved in advance and in writing by BT SA.

Before each funding operation is confirmed, the Portal displays the currency, the gross amount, any foreign-exchange conversion applied, the fees, if any, the beneficiary details and the estimated time for the credit to become available. A funding amount shall only be credited to the Available Balance after the corresponding payment has been received by BT SA or its appointed payment service provider, reconciled and, where applicable, cleared under the applicable control procedures. In the case of crypto-asset transfers, the Portal explicitly indicates the supported asset, the network, the receiving address, the number of on-chain confirmations required and the applicable conversion rate. Transfers made on an incorrect network or involving an incorrect asset may be irretrievable; any recovery operation, where technically feasible, shall be subject to prior communication of the applicable costs.

The Available Balance represents a claim of the Client for the restitution of the corresponding funds and is not represented as a bank deposit, as electronic money or as an insured balance unless such qualification is expressly and specifically provided for in writing under a separate agreement. The modalities of restitution of the Available Balance and the applicable protective regime are set out in Article 10 and in the disclosures published on the Portal.

8. Purchase and Sale of Metals

The Client may submit purchase or sale orders through the authenticated Portal whenever the ordering interface is available. The submission of an order does not constitute a guarantee of execution and does not imply a commitment to continuous quotation, permanent availability of liquidity or uninterrupted operation of the ordering interface. The applicable execution hours, maintenance windows, public holiday arrangements and any applicable operational limits are published on the Portal.

Before an order is confirmed, the Portal displays at least the following information, as applicable: type and quantity of Metal, fineness, price, currency, foreign-exchange component, spread, fees, taxes, if any, total amount payable or net proceeds receivable, validity period of the quotation and expected settlement timeline. The Portal also indicates whether BT SA acts as direct counterparty to the transaction or as intermediary, and identifies the execution counterparty where applicable.

The Client confirms an order through the acceptance procedure accessible in the authenticated Client area. A contract for an individual purchase or sale is validly concluded only upon BT SA's issuance of a written order confirmation on a durable medium. An expired quotation may not be relied upon and requires a fresh re-confirmation. BT SA shall issue a durable-medium order confirmation to the Client for each validly concluded contract. Obvious and material clerical errors in a quotation or in an order confirmation may be corrected by BT SA, with written reasons; no correction shall retroactively alter the price or conditions of an order already validly confirmed, save where such correction is required by mandatory law or is manifestly the result of a typographical error.

Upon final settlement of a sale, the corresponding physical position, the Allocation Register and the records of the GLD NFT or SLV NFT framework are updated in accordance with the applicable technical procedure. BT SA ensures that the same Metal quantity is not the subject of double representation or of inconsistent rights. The net proceeds of a sale are credited to the Client's Available Balance within the operating timelines published on the Portal.

9. Fees and Taxes

The fee schedule applicable under these Terms is published in the Fees section of the Portal and may also be obtained, upon request, from CS@XBTM.NET. The schedule lists separately the applicable spread, trading fees, custody fees, insurance fees, payment processing fees, foreign-exchange margins, on-chain operation fees, withdrawal fees and, where applicable, physical delivery fees. The modalities and timing for the deduction of custody fees, and the treatment of any insufficient Available Balance scenario, are defined before the Client places its first order and are disclosed in the fee schedule. No involuntary forced sale of Metals shall be effected without an express and valid contractual basis providing for such measure.

Gold and silver may be subject to different tax regimes depending on the applicable jurisdiction and product structure. Not every gold product automatically qualifies for any value-added-tax or stamp-duty exemption; no exemption is presumed for silver products. All applicable taxes, duties, levies and reporting obligations shall be determined by reference to the product structure, the place of custody, the domicile or residence of the Client and the Client's own specific situation. BT SA fulfils its own tax and documentary obligations; the Client remains solely responsible for the fulfilment of any personal tax, reporting or filing obligation to which it may be subject in its relevant jurisdictions.

10. Withdrawals and Physical Delivery

The Client may request the withdrawal of all or part of its Available Balance through the fiat withdrawal channels offered in the authenticated Client area, in accordance with the minimum amounts, fees and operating timelines published thereon. Security reviews, third-party payment disputes or legally mandated holds may, where applicable, legitimately delay execution; BT SA shall, where permitted, inform the Client of the reasons and of the expected timing for release. No penalty, surcharge or charge that has not been previously published shall be applied to a withdrawal.

The redemption of physical bars by the Client is available at the minimum quantities, formats and delivery destinations specified in the physical delivery section of the Portal, which also sets out the rules for any required conversion, the applicable fees, the taxes and duties, the insurance cover in force, the delivery timelines and the passing of risk. Where physical bar redemption is not available for a specific product tier or category, BT SA clearly indicates this limitation before the corresponding purchase is made; in such cases the liquidation of the position shall proceed through the standard sale procedure.

11. Risks

Prices of Metals and foreign-exchange rates are subject to significant fluctuations. The Client may sustain losses, including the partial or total loss of the sums invested. Spreads, fees, commissions and other costs may reduce the net proceeds of a transaction even in the absence of any significant movement in spot prices. Temporary unavailability of counterparties or delays in execution may also occur.

The custody structure and the tokenisation framework entail risks inherent to the holding of physical Metals in a third-party vault and to the operation of distributed-ledger and software systems, including, without limitation, risks of theft, loss, damage, error in allocation, insolvency of the Custodian or of a service provider, service interruption, smart-contract vulnerability, compromise of cryptographic material and prolonged unavailability of a blockchain network. The risk disclosure contained in this Article is an integral part of the Contract and does not, and may not, operate as a waiver of any non-derogable statutory remedy available to the Client.

12. Right of Withdrawal and Cancellation

An order may be cancelled prior to the issuance of BT SA's durable-medium order confirmation, through the cancellation facility available in the authenticated Client area, provided that the state of the order still permits such cancellation. After the conclusion of the individual contract, cancellation shall only be possible in accordance with applicable mandatory law and with the specific rules applicable to the product in question. Where the Client qualifies as a consumer, BT SA clearly indicates, before the order is placed, whether any statutory right of withdrawal applies, the conditions and formalities for its exercise and the applicable statutory exceptions.

In respect of contracts that may be subject to EU or EEA consumer law, a possible statutory exception linked to the supply of goods whose prices are determined by financial-market fluctuations may apply to purchase and sale contracts for Metals. The applicability of such exception is verified by BT SA for each specific contract category and does not automatically extend to every ancillary service or to the client relationship as a whole. No clause in these Terms excludes or limits the right of withdrawal beyond the extent permitted by applicable mandatory law.

13. Suspension and Termination

BT SA may restrict or suspend, on a proportionate basis, the operation of the Client's account or of individual services where this is justified by serious security concerns, by a reasonably documented suspicion of fraud or abuse, by a material breach of these Terms by the Client, by scheduled maintenance work communicated in advance where reasonably practicable, or by a binding legal or regulatory obligation. Where permitted under the applicable rules, BT SA shall inform the Client of the measure adopted, of its grounds and of the expected duration. In the case of prolonged outage or restriction, the Client may contact BT SA at CS@XBTM.NET for information and urgent requests.

The Client may request the closure of its account through the authenticated Client area or by written notice to CS@XBTM.NET. BT SA may terminate the contractual relationship by prior written notice on a durable medium given within a reasonable period, or immediately in the event of a serious documented ground or a binding legal requirement. The termination of the relationship shall not affect the rights already acquired by the Client in respect of allocated Metals and of the Available Balance. Pending orders, the restitution of cleared funds and the treatment of physical positions shall be dealt with in accordance with these Terms and with applicable mandatory law.

14. Liability

BT SA shall be liable for the due and proper performance of its own obligations under the Contract, for the accuracy and completeness of the entries recorded in the Allocation Register and, generally, for all matters for which liability is imposed on it by applicable mandatory law. The recourse by BT SA to custodians, sub-custodians, information-technology service providers or other third parties shall not, by itself, relieve BT SA of its liability towards the Client as contractual counterparty. Liability for wilful misconduct and for gross negligence, and any liability that cannot be excluded or limited by law, are fully reserved.

BT SA does not guarantee any particular level of Metal prices, foreign-exchange rates, investment returns or financial results. External events beyond BT SA's reasonable control may temporarily prevent the execution of certain operations; BT SA shall take reasonable steps to mitigate the consequences of such events and shall keep the Client appropriately informed. The occurrence of an external event shall not release BT SA from its obligations of custody, reporting and restitution where such obligations are otherwise owed to the Client.

15. Complaints, Amendments and Dispute Resolution

Any complaint by the Client relating to the performance of this Contract shall be sent in writing to CS@XBTM.NET or by registered letter to BT SA at its registered office. BT SA shall acknowledge receipt of the complaint promptly and shall provide a reasoned written response within the applicable statutory time limits or, in the absence thereof, within a reasonable time consistent with good market practice. Where an alternative dispute resolution scheme is formally applicable to the complaint, BT SA shall indicate the relevant scheme in its response.

BT SA may amend these Terms by written notice to the Client on a durable medium within a reasonable prior notice period, save where urgent amendments are required for reasons of immediate compliance with a new legal, regulatory or security requirement. No amendment shall retroactively alter the conditions of orders already executed or of rights already definitively accrued at the date of the amendment. Material amendments that require the Client's express acceptance shall be presented in accordance with such requirement; where the Client does not accept such a material amendment, it shall be entitled to close its account under fair conditions that preserve its rights in respect of its Metal positions and Available Balance.

These Terms and the entire contractual relationship between the Client and BT SA shall be governed by the substantive laws of Switzerland. Save where a non-derogable rule of jurisdiction applicable to a consumer provides otherwise, the courts of Neuchâtel, Switzerland, shall have exclusive jurisdiction to settle any dispute arising out of or in connection with these Terms or their subject matter.

For and on behalf of BT SA

XBTM — Gold & Silver Platform

Microcity, Rue de la Pierre-à-Mazel 39

2000 Neuchâtel — Switzerland

CS@XBTM.NET

Governing clauses

— Swiss law applies exclusively

— Jurisdiction: Neuchâtel, Switzerland

— Effective: 2 October 2026 · Version 1.0

— Site: https://xbtm.net

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