Terms of Service

Effective Date: October 16, 2025

By accessing or using this website, products, or services, you agree to these Terms of Service and consent to our use of essential cookies necessary to operate and secure the Services. If you do not agree, do not use the Services.

1) Definitions

In these Terms of Service, the following terms have the meanings set forth below:

"GlassVault," "we," "us," "our," or "the Company" means Round Asset LLC, a limited liability company organized under the laws of the State of New Hampshire, together with its affiliates, subsidiaries, officers, directors, employees, agents, contractors, and successors and assigns.

"You," "your," "User," or "Client" means the individual person or legal entity that accesses or uses the Services, creates an account, or otherwise enters into these Terms.

"Services" means the GlassVault website, platform, software, applications, APIs, digital asset custody services, exchange services, and all related products, features, content, and services offered by GlassVault or Round Asset LLC, whether accessed via web, mobile, or other interface.

"Terms" means these Terms of Service, including all sections, subsections, and provisions herein, as may be amended from time to time.

2) Eligibility and Accounts

You represent that you are of legal age, not subject to applicable sanctions or prohibitions, and eligible under your jurisdiction's laws.

You agree to provide accurate information and to complete any required identity verification (KYC/AML) requests. We may decline, suspend, or terminate accounts at our discretion for risk, compliance, or operational reasons.

3) Description of Services

Custodial Services: We provide digital asset custody. Title to your supported assets remains with you; we do not pay interest.

Exchange Services: We provide an order-matching venue with supported order types. We do not provide investment, legal, tax, or accounting advice. We do not guarantee best execution, continuous availability, or error-free operation.

Availability by Jurisdiction: Service availability varies by jurisdiction and asset class. Please refer to the section of the website where we communicate the geographies in which we are currently operational.

4) Security and Your Responsibilities

You must maintain the security of your account, credentials, devices, and 2FA, and promptly notify us of any compromise. We may take protective actions we deem appropriate.

We act in clients’ best interests on security matters; however, we are not a fiduciary and these Terms control our obligations.

5) Risks

General Market Risk: Digital assets are highly volatile and speculative. The value of your holdings may fluctuate significantly and rapidly, and you may lose some or all of your investment. Past performance is not indicative of future results.

Network and Protocol Risks: Blockchain networks can fork, stall, experience defects, or undergo protocol changes. Transactions can be delayed, reversed by consensus rules, become unconfirmed indefinitely, or become permanently irrecoverable. Consensus failures, 51% attacks, or protocol bugs may result in loss of assets.

Stablecoin Risks: Stablecoins (including USDC, USDT, and other pegged tokens) may lose their peg to the fiat currency or commodity they are intended to track. Stablecoin issuers may become insolvent, freeze assets, refuse redemptions, or fail to maintain adequate reserves. We do not control, audit, or guarantee any stablecoin issuer. The failure of a stablecoin issuer could result in total loss of value.

Smart Contract and Token Risks: ERC20, ERC721, ERC1155, and other token standards rely on smart contracts that may contain bugs, security vulnerabilities, or design flaws. Smart contracts may be exploited by malicious actors, leading to loss or theft of assets. We do not audit, verify, or warrant the security or functionality of any token smart contract. Tokens may be delisted, deprecated, or lose all value.

Regulatory and Legal Risks: Digital asset regulations are rapidly evolving and vary significantly by jurisdiction. Changes in law, regulation, or enforcement policy may require us to suspend services, delist assets, restrict access to users in certain jurisdictions, freeze accounts, or cease operations entirely. You may be subject to regulatory or legal actions related to your use of digital assets, and we are not responsible for any such consequences.

Third-Party Dependencies: The Services rely on third-party infrastructure and services, including blockchain networks, node operators, oracles, cloud hosting providers, identity verification services, payment processors, and communications providers. Any of these third parties may fail, become unavailable, experience outages, suffer security breaches, or act maliciously. We are not responsible for third-party failures.

Cybersecurity Risks: Despite our security measures, the Services and your account may be subject to hacking, phishing, malware, denial-of-service attacks, social engineering, or other cybersecurity threats. You may lose access to your account or lose assets as a result of such attacks. You are responsible for maintaining the security of your credentials, devices, and 2FA methods.

Operational Risks: We may experience system errors, downtime, maintenance windows, data loss, or operational failures. Orders may fail to execute, transactions may be delayed or lost, and account balances may be displayed incorrectly. We do not guarantee continuous, uninterrupted, or error-free operation.

Liquidity Risk: Trading pairs may have limited liquidity, resulting in difficulty executing orders, wide bid-ask spreads, and significant price slippage. You may be unable to buy or sell assets at desired prices or at all.

Counterparty Risk: When trading on the exchange, you rely on other users to fulfill their obligations. Counterparties may default, fail to deliver assets, or engage in fraud. While we implement settlement mechanisms, we do not guarantee counterparty performance.

Irreversibility: Blockchain transactions are generally irreversible. If you send assets to an incorrect address, experience a contract exploit, or fall victim to fraud, you may have no recourse to recover your assets.

Tax Consequences: Digital asset transactions may have complex and uncertain tax consequences. You are solely responsible for determining, reporting, and paying all applicable taxes. Tax laws vary by jurisdiction and are subject to change.

No Insurance: Your digital assets are not insured by any government agency or private insurance fund. In the event of loss, theft, or other adverse events, you may have no recourse for recovery.

Market Integrity: Self-trading (wash trading) is prohibited and technically blocked. Attempts to engage in wash trading, spoofing, market manipulation, or other abusive practices may result in account review, trading restrictions, or termination.

6) Fees and Execution

You agree to posted and in‑app fees (including network fees). Fees and pricing may change with notice. Orders may experience slippage or partial fills.

Network fees are not in our control and fluctuate naturally. Transaction costs may increase in periods of high demand on a given blockchain.

7) Custody; Unsupported Assets; Forks/Airdrops

Only supported assets are accepted; sending unsupported assets may result in permanent loss. Forks, airdrops, and protocol changes are handled at our sole discretion. Maintenance/downtime may occur. Withdrawals may be delayed or held for compliance or risk review.

8) Compliance

We perform KYC/AML/sanctions screening and risk-based monitoring. We may freeze assets, cancel orders, or restrict services to comply with law, respond to risk, or cooperate with lawful requests (including the Travel Rule, where applicable).

9) Prohibited Activities

Illegal activity; sanctions evasion; market abuse (including wash trading or spoofing); malware; IP infringement; or attempts to circumvent controls are prohibited.

10) Taxes

You are responsible for determining, reporting, and paying all taxes associated with your activity.

11) No Warranties

The Services are provided "as is" and "as available" without warranties of any kind, express or implied, including merchantability, fitness for a particular purpose, non‑infringement, and uninterrupted or error-free operation.

12) Limitation of Liability

To the maximum extent permitted by law, we disclaim all liability for any loss of funds, security breaches, hacks, fraud, unauthorized access, errors, interruptions, or third‑party failures. We are not liable for indirect, incidental, special, exemplary, punitive, or consequential damages.

Where liability cannot be excluded, it is limited to the lesser of (i) the amount you paid us in fees in the 12 months preceding the claim or (ii) USD $100.

13) Indemnification

You agree to defend, indemnify, and hold us harmless from claims, damages, liabilities, costs, and expenses (including reasonable attorneys’ fees) arising out of or related to your use of the Services, violations of these Terms, or prohibited activities.

14) Suspension and Termination

We may suspend or terminate your access at any time for compliance, risk, or breach. Sections that by their nature should survive (e.g., limitations of liability, indemnity, dispute resolution) will survive termination.

15) Changes to These Terms

We may update these Terms. Material changes will be communicated via the site or email. Your continued use after changes take effect constitutes acceptance.

16) Governing Law and Dispute Resolution

PLEASE READ THIS SECTION CAREFULLY. IT AFFECTS YOUR LEGAL RIGHTS, INCLUDING YOUR RIGHT TO FILE A LAWSUIT IN COURT.

(a) Governing Law and Venue: These Terms are governed by the laws of the State of New Hampshire, without regard to conflict-of-law rules. Any permitted court action shall be brought exclusively in the state or federal courts located in New Hampshire, and you consent to personal jurisdiction and venue in those courts.

(b) Binding Arbitration: Any dispute, claim, or controversy arising out of or relating to these Terms or your use of the Services (including the validity, scope, or enforceability of this arbitration provision) shall be resolved by binding arbitration. GlassVault shall have sole discretion to select the arbitration provider, arbitration rules, location of arbitration, and the number of arbitrators. The arbitrator's decision shall be final and binding, and judgment on the award may be entered in any court of competent jurisdiction.

(c) CLASS ACTION WAIVER: YOU AGREE THAT YOU MAY BRING CLAIMS AGAINST GLASSVAULT ONLY IN YOUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, CONSOLIDATED, OR REPRESENTATIVE ACTION. The arbitrator may not consolidate more than one person's claims and may not preside over any form of representative or class proceeding. You cannot join your claim with other users' claims, participate in a class action lawsuit against GlassVault, sue on behalf of other users, or have claims consolidated with those of other users.

(d) Jury Trial Waiver: YOU WAIVE ANY RIGHT TO A JURY TRIAL.

(e) Injunctive Relief: Nothing in this section prevents GlassVault from seeking injunctive or equitable relief in court for any reason, including but not limited to matters related to intellectual property, confidential information, unauthorized access to the Services, breach of these Terms, or any other actual or threatened violation of GlassVault's rights.

(f) Arbitration Costs: You shall bear your own attorneys' fees and costs under all circumstances. GlassVault shall bear its own attorneys' fees and costs, except that the arbitrator may award GlassVault recovery of its attorneys' fees, costs, filing fees, arbitrator compensation, and all other expenses incurred in the arbitration if the arbitrator determines that your claim was frivolous, brought in bad faith, or brought for an improper purpose. Under no circumstances shall GlassVault be required to pay or reimburse any of your attorneys' fees, costs, or expenses.

(g) Severability of Arbitration Provisions: If the class action waiver in subsection (c) is found to be unenforceable for any reason, this entire Section 16 arbitration provision (subsections b through g, but not subsection a or the rest of these Terms) shall be null and void, and any dispute shall be resolved in court pursuant to subsection (a).

17) Important Regulatory Disclosures

Not a Bank: GlassVault and Round Asset LLC are not banks. Your digital assets held with us are not deposits and are not insured by the Federal Deposit Insurance Corporation (FDIC), the Securities Investor Protection Corporation (SIPC), or any other government agency or private insurance fund.

No Interest: We do not pay interest on digital asset balances.

Money Services Business Registration: Round Asset LLC is registered with the Financial Crimes Enforcement Network (FinCEN) as a Money Services Business. State-level money transmission compliance is maintained as required by jurisdiction.

Custody Model: We provide custodial wallet services where we maintain control of private keys on your behalf. You authorize transactions through your account authentication, including password, mandatory two-factor authentication (2FA), and email confirmation for withdrawals. Each wallet has a unique blockchain address. Title to your supported digital assets remains with you at all times.

Private Key Policy: The private keys, mnemonic seed phrases, and cryptographic key material associated with your wallets are proprietary operational data of GlassVault and are not your property or personal information. For security reasons, private keys and seed phrases will never be disclosed, displayed, or transmitted to you or any third party under any circumstances, including upon your request, during account closure, or pursuant to legal process. You acknowledge that you have no right, entitlement, or expectation to access, receive, export, or control the private keys or seed phrases for any wallet provided through the Services. Your exclusive means of authorizing transactions is through the account authentication methods described in these Terms.

Bankruptcy and Insolvency Risk: In the event of GlassVault's or Round Asset LLC's bankruptcy, insolvency, or similar proceeding, customer digital assets held in custody are intended to be treated as customer property that is segregated from GlassVault's corporate assets and excluded from the bankruptcy estate. However, there is no guarantee that a bankruptcy court or other legal authority would recognize this treatment. In such an event, you may face significant delays in recovering your assets, may incur legal costs to assert your claims, or may lose some or all of your assets.

No Investment Advice: We do not provide investment, legal, tax, or financial planning advice. The Services are provided for self-directed management of digital assets. You are solely responsible for evaluating the merits and risks of any transaction or holding. You should consult your own professional advisors before making financial decisions.

No Fiduciary Relationship: Except as expressly stated in these Terms, we are not your fiduciary, trustee, agent, or advisor. We do not owe fiduciary duties to you under common law or otherwise.

18) Beneficiary Designations

(a) Beneficiary Features: You may designate beneficiaries for each of your wallets through the Services by specifying a percentage allocation (1-100%) of wallet assets to each beneficiary. Beneficiary designation features are offered as a convenience to facilitate transfer of digital assets upon your death or incapacity. These designations do not create a trust, payable-on-death account, joint tenancy, or any other legal arrangement beyond a contractual instruction to GlassVault.

(b) Percentage Allocations: Each beneficiary designation specifies a percentage of wallet assets to be distributed to that beneficiary. The sum of all percentage allocations for a given wallet may not exceed 100%. Any unallocated percentage (the difference between 100% and the sum of your designated percentages) is treated as "Unspecified" and may be distributed according to applicable law, your estate plan, or as determined by legal process. You may designate the same beneficiary multiple times with different percentage allocations if desired.

(c) Asset-Specific Rules for Ethereum Wallets: For Ethereum wallets, the percentage allocations you specify apply to fungible assets (native ETH and ERC-20 tokens). Non-fungible tokens (NFTs) are subject to different rules: ERC-721 tokens (non-fungible) may be assigned to a single beneficiary for the entire wallet (you may specify one beneficiary to receive all ERC-721 tokens in that wallet); ERC-1155 tokens (semi-fungible) may be assigned to a single beneficiary for the entire wallet (you may specify one beneficiary, which may be the same as or different from the ERC-721 beneficiary). If you do not designate a beneficiary for ERC-721 or ERC-1155 tokens, those assets are treated as Unspecified. Bitcoin wallets do not hold NFTs and are distributed solely according to your percentage allocations.

(d) Your Responsibilities: You are responsible for ensuring that your beneficiary designations are current, accurate, and legally valid under applicable law. You should consult legal and estate planning professionals to ensure beneficiary designations align with your overall estate plan, will, trust, or other estate planning documents.

(e) Beneficiary Claims Process: Upon your death, a designated beneficiary may claim assets by contacting us and providing documentation we deem satisfactory in our sole discretion, which typically includes: government-issued death certificate; valid government-issued identification of the claimant; proof of beneficiary designation (if not in our records); completed claim forms and identity verification (KYC/AML) as required by law; and any additional documentation we reasonably request.

(f) Conflicting Claims and Disputes: If we receive conflicting claims from multiple beneficiaries, or claims from both beneficiaries and representatives of your estate (executor, administrator, trustee, or heirs), or if the validity of a beneficiary designation is disputed, we reserve the right in our sole discretion to: withhold distribution pending resolution of the dispute; require a court order or legal settlement determining rightful ownership; interplead the disputed assets into a court of competent jurisdiction and recover our costs from the assets or the parties; or take any other action we deem necessary to protect ourselves and resolve the dispute fairly.

(g) Legal Priority: Beneficiary designations may be superseded, invalidated, or modified by operation of law, including but not limited to court orders, divorce decrees, probate proceedings, valid wills or trusts, creditor claims, tax liens, or other legal processes. We are not responsible for determining the legal effect of such instruments. If we become aware of a potential conflict between a beneficiary designation and other legal authority, we may require a court order before releasing assets.

(h) Changes and Revocation: You may change or revoke beneficiary designations at any time through the Services, subject to verification requirements. Changes take effect when processed by our systems. We are not responsible for honoring beneficiary changes made through any method other than the designated process in the Services.

(i) No Guarantee: We make reasonable efforts to honor beneficiary designations, but we do not guarantee that beneficiary designations will be legally enforceable in all circumstances or jurisdictions. You acknowledge that laws governing beneficiary designations, digital assets, probate, and estate administration vary by jurisdiction and are subject to change. We disclaim all liability for the legal effect or tax treatment of beneficiary designations.

(j) Limitation of Liability: Our liability in connection with beneficiary claims is subject to all limitations in Section 12 of these Terms. We are not liable for delays, disputes, legal challenges, tax consequences, fractional distribution challenges, or distributions made in good faith reliance on documentation provided to us.

19) Miscellaneous

(a) Severability: If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court or other tribunal of competent jurisdiction, that provision shall be limited or eliminated to the minimum extent necessary so that these Terms otherwise remain in full force and effect and enforceable.

(b) Entire Agreement: These Terms, together with any Privacy Policy we may adopt, constitute the entire agreement between you and GlassVault regarding the Services and supersede all prior or contemporaneous agreements, understandings, representations, and communications, whether written or oral.

(c) No Waiver: Our failure to enforce any provision of these Terms, or to exercise any right or remedy available to us, does not constitute a waiver of that provision, right, or remedy, or any other provision, right, or remedy. No waiver by us shall be effective unless made in writing and signed by an authorized representative of GlassVault.

(d) Assignment: You may not assign, transfer, or delegate these Terms or your rights and obligations hereunder, in whole or in part, without our prior written consent. Any attempted assignment, transfer, or delegation without such consent is void. We may freely assign, transfer, or delegate these Terms and our rights and obligations hereunder, in whole or in part, without restriction and without notice to you, including in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all of our assets.

(e) Force Majeure: We are not liable for any delay, failure to perform, or interruption of the Services resulting from causes beyond our reasonable control, including but not limited to acts of God, natural disasters, war, terrorism, riots, embargoes, acts of civil or military authorities, fire, floods, accidents, pandemics, epidemics, network infrastructure failures, power outages, strikes or labor disputes, shortages of transportation facilities, fuel, energy, labor or materials, or failures of third-party service providers (including blockchain networks, cloud hosting providers, payment processors, and communications providers).

(f) Electronic Communications: You consent to receive all communications, agreements, documents, receipts, notices, and disclosures electronically (collectively, "Communications") from us, including via email to the address associated with your account, posting on the Services, or in-app messages. You agree that all Communications we provide to you electronically satisfy any legal requirement that such communications be in writing. It is your responsibility to maintain a current email address and to check your email and the Services regularly.

(g) Headings: Section and subsection headings in these Terms are for convenience and reference only and do not affect the interpretation or meaning of these Terms.

(h) Third-Party Beneficiaries: These Terms do not create any third-party beneficiary rights in any person or entity except as expressly stated herein.

(i) Survival: All provisions of these Terms that by their nature should survive termination shall survive termination of your account or these Terms, including but not limited to Sections 5 (Risks), 10 (Taxes), 11 (No Warranties), 12 (Limitation of Liability), 13 (Indemnification), 16 (Dispute Resolution), 17 (Regulatory Disclosures), 18 (Beneficiary Designations), 19 (Miscellaneous), and 21 (Intellectual Property).

(j) Government Rights: If you are a U.S. government entity or using the Services on behalf of a U.S. government entity, the Services constitute "commercial computer software" and "commercial computer software documentation" as those terms are used in 48 C.F.R. §12.212, and are provided with only those rights as granted to all other users pursuant to these Terms.

(k) Export Controls: You represent and warrant that you are not located in, under the control of, or a national or resident of any country to which the United States has embargoed goods or services, and that you are not on any U.S. government list of prohibited or restricted parties. You will not use the Services in violation of any U.S. export law or regulation.

20) Privacy and Data Protection

Your privacy and the security of your personal information are important to us. By using the Services, you acknowledge and consent to our collection, use, storage, and disclosure of your personal information as necessary to provide the Services and comply with legal obligations.

(a) Information We Collect: We collect personal information you provide during account registration, identity verification (KYC/AML), and use of the Services, including but not limited to name, address, date of birth, government-issued identification, email address, phone number, transaction history, wallet addresses, beneficiary information, and device/usage data.

(b) How We Use Information: We use your information to operate the Services, verify your identity, comply with legal and regulatory obligations (including KYC, AML, sanctions screening, tax reporting, and the Travel Rule), prevent fraud and unauthorized access, communicate with you, improve the Services, and enforce these Terms.

(c) Information Sharing: We may share your information with service providers and vendors who assist us in operating the Services (cloud hosting, identity verification, compliance screening, email delivery, etc.); regulatory authorities, law enforcement, and government agencies as required by law or legal process; professional advisors (legal, accounting, auditing) under confidentiality obligations; successors in interest in the event of a merger, acquisition, or sale of assets; and other parties with your consent or as permitted by law.

(d) Data Security: We implement reasonable administrative, technical, and physical safeguards to protect your information. However, no system is completely secure, and we cannot guarantee the absolute security of your information. You are responsible for maintaining the security of your account credentials and devices.

(e) Data Retention: We retain your information for as long as necessary to provide the Services, comply with legal obligations (including tax and regulatory recordkeeping requirements), resolve disputes, and enforce these Terms. Some information may be retained indefinitely as required by law.

(f) Your Rights: Depending on your jurisdiction, you may have rights to access, correct, delete, or restrict the processing of your personal information. However, we may be unable to delete certain information due to legal, regulatory, or operational requirements.

(g) Cookies and Tracking: We use essential cookies necessary to operate and secure the Services. By using the Services, you consent to our use of these cookies.

(h) International Users: If you access the Services from outside the United States, your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate. By using the Services, you consent to such transfers.

(i) Changes to Privacy Practices: We may update our privacy practices from time to time. Material changes will be communicated via the Services or email. Your continued use of the Services after changes take effect constitutes acceptance of the updated practices.

(j) Children: The Services are not intended for individuals under the age of 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children.

For more detailed information about our privacy practices, we may provide a separate Privacy Policy, which will be incorporated by reference into these Terms.

21) Intellectual Property

(a) Ownership: All right, title, and interest in and to the Services, including all software, code, algorithms, databases, text, graphics, logos, trademarks, service marks, trade names, interfaces, and other content and materials (collectively, "GlassVault IP"), are and shall remain the exclusive property of GlassVault, Round Asset LLC, and our licensors. The Services and GlassVault IP are protected by copyright, trademark, patent, trade secret, and other intellectual property laws of the United States and other jurisdictions.

(b) Limited License: Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Services for your personal or internal business purposes in accordance with these Terms. This license does not include any right to resell, redistribute, or commercially exploit the Services or GlassVault IP; copy, reproduce, modify, adapt, translate, or create derivative works from the Services or GlassVault IP; reverse engineer, decompile, disassemble, or attempt to discover the source code or underlying algorithms of the Services; use any automated means (bots, scrapers, crawlers) to access the Services without our express written permission; remove, alter, or obscure any copyright, trademark, or other proprietary notices; or use the Services or GlassVault IP in any manner that infringes, misappropriates, or violates any intellectual property or other rights.

(c) Trademarks: "GlassVault," the GlassVault logo, and other marks used in connection with the Services are trademarks or registered trademarks of Round Asset LLC. You may not use these marks without our prior written permission. All other trademarks, service marks, and logos referenced in the Services are the property of their respective owners.

(d) Feedback and Suggestions: If you provide us with any feedback, suggestions, ideas, or other input regarding the Services ("Feedback"), you grant us a perpetual, irrevocable, worldwide, royalty-free, fully paid-up, transferable, sublicensable license to use, reproduce, modify, distribute, display, perform, and otherwise exploit the Feedback in any manner and for any purpose without restriction or compensation to you. You waive any moral rights or attribution rights you may have in the Feedback.

22) Trading Rules and Market Integrity

(a) Order Matching and Execution: We operate a central limit order book for supported trading pairs. Orders are matched based on price-time priority. Market orders are matched against the best available prices in the order book. Limit orders are executed when a matching opposite-side order is available at the specified price or better.

(b) Order Types and Time-in-Force: We support various order types (market, limit) and time-in-force instructions (GTC, IOC, FOK, GTD) as described in the Services. Order execution is subject to availability, liquidity, and system capacity. We reserve the right to modify, limit, or discontinue order types at any time.

(c) No Guarantee of Execution: We do not guarantee that any order will be executed, executed in full, or executed at any particular price. Orders may experience partial fills (only part of the order is executed); slippage (execution at worse prices than displayed due to market movement); rejection (due to insufficient funds, self-trading prevention, system errors, or other reasons); or delays or failures (due to system congestion, maintenance, or technical issues).

(d) Prohibited Trading Practices: The following practices are strictly prohibited and may result in immediate suspension, order cancellation, trading restrictions, or account termination: Wash Trading (Self-Trading), which means placing orders that trade against your own opposite-side orders, whether in a single account or across multiple accounts under your control (our systems automatically block self-trades, and attempts to circumvent these controls will result in enforcement action); Spoofing and Layering, which means placing orders with the intent to cancel them before execution in order to create a false impression of market depth, manipulate prices, or gain an unfair trading advantage; Market Manipulation, which means any conduct intended to artificially inflate, depress, or manipulate the price of a digital asset or create a false or misleading appearance of trading activity; Front-Running, which means using non-public information about pending orders to trade ahead of them for personal gain; Insider Trading, which means trading based on material non-public information related to digital assets, issuers, or the Services; Coordinated Trading, which means coordinating with other users to manipulate prices, create artificial volume, or engage in other abusive practices; and Automated Trading Without Permission, which means using bots, algorithms, or automated trading systems without our express written consent (high-frequency trading and algorithmic trading are permitted only with prior approval).

(e) Order Cancellation and Trade Finality: We reserve the right to cancel or reject any order before it is matched and executed. However, once an order is matched and a trade is executed (settlement transfers initiated), the trade is final and irreversible. You acknowledge that trades involve wallet-to-wallet transfers of digital assets on blockchain networks and cannot be reversed, modified, or undone after execution. We have no obligation or ability to reverse trades, restore pre-trade positions, or provide compensation for executed trades, including trades resulting from system errors, price feed errors, market volatility, user error, or any other cause. The only exception is if we are compelled by a court order, regulatory mandate, or applicable law to take remedial action, in which case we will make commercially reasonable efforts to comply but make no guarantee of success given the technical limitations of blockchain transactions. We are not liable for any losses, opportunity costs, or other damages related to trade execution or our inability to reverse trades.

(f) Trading Halts and Circuit Breakers: We may halt trading in any or all pairs at any time, with or without notice, due to extreme price volatility; system maintenance or technical issues; regulatory requirements or requests; security concerns or suspected market manipulation; or low liquidity or operational concerns. During a trading halt, you may be unable to place, modify, or cancel orders. Open orders may be cancelled at our discretion.

(g) Price Limits and Position Limits: We may impose price limits (maximum deviation from reference prices) or position limits (maximum order size or total position size) on any trading pair at any time for risk management or operational reasons.

(h) No Best Execution Obligation: We do not guarantee "best execution" as defined in traditional securities regulations. You acknowledge that you may be able to obtain better prices on other trading venues, and you are solely responsible for evaluating whether to trade on our platform.

(i) Conflicts of Interest: To the extent permitted by law, GlassVault, Round Asset LLC, and our affiliates, officers, directors, and employees may hold digital assets, trade on the Services, or have other financial interests that may conflict with your interests. We implement policies to manage such conflicts, but we do not guarantee the absence of all conflicts.

(j) Market Data and Pricing: Pricing data and market data provided through the Services are for informational purposes only and may be delayed, inaccurate, or incomplete. We are not liable for errors in market data or for trading decisions made in reliance on such data.

23) Contact

GlassVault Digital Asset Custodian and Exchange is a product of Round Asset LLC, a registered Money Services Business (FinCEN).

Email: safe@glassvault.xyz

For specific inquiries, please use an appropriate subject line, e.g. "Support" for general support and account questions.

We do not provide telephone support. All support is provided via email. Beware of phishing attempts; we will never call you unsolicited or ask for your password or 2FA codes.