1. Acceptance and eligibility
By accessing the GM Markets interface (the "Service") you agree to these Terms of Service (the "Terms"). If you do not agree, do not access or use the Service. These Terms apply to all visitors, including those who connect a wallet, browse markets, or transact in tokenized instruments or vaults.
You represent that you are at least 18 years old, that you are legally able to enter into a binding contract, and that you are not a Restricted Person (defined in Section 9).
2. Definitions
- "Service" means the GM Markets website at gm.markets and any associated user interface for interacting with tokenized instruments, vaults, and related on-chain functionality.
- "Interface Operator", "we", "us", and "our" mean the entity operating the Service.
- "Issuer" means the third-party tokenization infrastructure provider (Flo) and the bankruptcy-remote special-purpose vehicle issuing the Tokens.
- "Tokens" means the on-chain instruments referenced through the Service, including tokenized stocks, ETFs, commodities, FX, and vault tokens.
- "Vaults" means on-chain pools whose tokens (each prefixed with "g", except where the token uses a different convention) entitle holders to a pro-rata claim on the underlying strategy or assets.
- "Manager" means a third party that runs a vault strategy on existing assets.
- "gLP" means the protocol's liquidity-provider token.
- "Restricted Person" has the meaning set out in Section 9.
3. Nature of the Service
The Service is a software interface that reads from, and submits user-signed transactions to, public blockchain networks. The Interface Operator does not custody user assets, does not execute trades as principal, does not custody private keys, and does not act as a broker, dealer, exchange, investment adviser, or money transmitter. The Service runs on third-party tokenization infrastructure provided by the Issuer.
All transactions are initiated and authorized by the user and signed by the user's wallet. The Interface Operator has no ability to move, freeze, or seize on-chain assets held in user wallets.
4. Wallets and connection
To transact through the Service you must connect a self-custodial wallet you control. You are solely responsible for safeguarding your private keys, seed phrases, and devices. Loss of access to your wallet results in permanent and irreversible loss of the assets it holds. The Interface Operator cannot recover lost keys.
5. Tokenized instruments and SPV claim
Tokenized stocks, ETFs, commodities, and FX referenced through the Service are issued from a bankruptcy-remote SPV operated by the Issuer. Underlying assets are held in 1:1 segregated accounts at regulated prime brokers (Interactive Brokers and Alpaca). Holders of these Tokens have a direct contractual entitlement to the underlying through the Issuer's structure; they do not have a claim on the Interface Operator.
Crypto-native instruments are on-chain and do not involve a broker leg.
6. Vault products and manager risk
Vaults referenced through the Service are operated by Issuer or Manager principals. Vault risk, performance, and operational behavior are the responsibility of the Issuer or Manager, not the Interface Operator. The Interface Operator does not select assets for, manage, or guarantee any vault. Read the vault-specific disclosures and the Investor Disclosures and Risk Statement before transacting.
7. Fees, slippage, and pricing
The Service displays applicable fees, spreads, and estimated slippage at the point of transaction. The Interface Operator charges a single trading fee per transaction, applied symmetrically on buy and sell; VIP tiers may reduce the fee. Prices and fees are subject to change. Estimated slippage is an estimate, not a guarantee; actual execution may differ.
8. No advice, no fiduciary, no solicitation
Nothing on the Service constitutes investment, legal, tax, or financial advice or a recommendation to buy, sell, or hold any asset. The Interface Operator is not your fiduciary, broker, adviser, or agent. The Service does not solicit any transaction. You are solely responsible for evaluating the merits and risks of any transaction. Consult qualified professionals.
9. Jurisdictional notice and restricted use
The Service is offered on a permissionless basis at the interface layer (wallet connect, no account). Jurisdictional and per-asset restrictions are enforced at the Issuer layer.
A "Restricted Person" includes any person or entity that is: (a) located in, ordinarily resident in, or organized under the laws of a jurisdiction in which use of the Service or the relevant Tokens is prohibited or restricted by applicable law; (b) listed on, owned or controlled by a person listed on, or acting on behalf of a person listed on any sanctions list maintained by the United Nations, the United States Office of Foreign Assets Control, the European Union, the United Kingdom, or any other competent authority; or (c) otherwise prohibited by law from accessing the Service or holding the relevant Tokens.
You are solely responsible for determining whether your access to and use of the Service is lawful in your jurisdiction. If your jurisdiction changes such that you become a Restricted Person, you must cease using the Service.
Use of VPNs, proxies, or any other technical measure to circumvent jurisdictional gating, sanctions screening, or geofencing is prohibited and is a material breach of these Terms.
10. Sanctions and screening
Sanctions screening and per-asset gating are performed at the Issuer layer. The Interface Operator may additionally restrict interface access for any wallet or IP associated with sanctions concerns or prohibited conduct, without prior notice. The Interface Operator cannot freeze on-chain assets; restrictions apply only to the hosted Service.
11. Prohibited use
You agree not to use the Service in violation of these Terms or the Acceptable Use Policy at Schedule 1. Material violations may result in immediate restriction of your interface access.
12. Intellectual property
The Interface Operator and its licensors own all right, title, and interest in and to the Service, including trademarks, logos, copy, designs, and code, except for components made available under separate open-source licenses. Subject to your compliance with these Terms, you are granted a limited, non-exclusive, non-transferable, revocable license to access and use the Service for your personal, non-commercial purposes. Smart-contract code published in public source repositories is governed by the licenses stated in those repositories.
13. Third-party services
The Service integrates with third parties, including the Issuer, regulated brokers, MPC custody providers, attestation providers, RPC providers, wallet providers, and oracle services. Your use of those third-party services is governed by their own terms. The Interface Operator is not responsible for the acts, omissions, or failures of any third party.
14. Disclaimers of warranties
THE SERVICE IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT. THE INTERFACE OPERATOR DOES NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED, ERROR-FREE, SECURE, OR FREE OF HARMFUL COMPONENTS, OR THAT ANY DATA DISPLAYED THROUGH THE SERVICE WILL BE ACCURATE, CURRENT, OR COMPLETE.
15. Limitation of liability
TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE INTERFACE OPERATOR AND ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF PROFITS, REVENUE, DATA, GOODWILL, OR OTHER INTANGIBLE LOSSES, ARISING OUT OF OR RELATING TO YOUR USE OF OR INABILITY TO USE THE SERVICE, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
IN ALL CASES, THE INTERFACE OPERATOR'S AGGREGATE LIABILITY ARISING OUT OF OR RELATING TO ANY DISPUTED TRADE OR TRADES SHALL NOT EXCEED THE AGGREGATE TRADING FEES ACTUALLY RETAINED BY THE INTERFACE OPERATOR FROM THE SPECIFIC DISPUTED TRADE OR TRADES GIVING RISE TO THE CLAIM. THIS CAP REFLECTS THE ALLOCATION OF RISK BETWEEN THE PARTIES AND APPLIES TO ALL THEORIES OF LIABILITY, INCLUDING CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, AND STATUTE.
Some jurisdictions do not allow the exclusion or limitation of certain damages; in those jurisdictions, the foregoing limitations apply to the maximum extent permitted by law.
16. Indemnification
You agree to indemnify, defend, and hold harmless the Interface Operator and its affiliates, officers, directors, employees, and agents from and against any claims, liabilities, damages, losses, and expenses (including reasonable legal fees) arising out of or relating to: (a) your use of the Service; (b) your breach of these Terms or the Acceptable Use Policy; (c) your violation of any applicable law; or (d) your violation of any third-party right.
17. Modification, suspension, and termination
We may modify, suspend, or discontinue the Service or any feature at any time, with or without notice. We may also restrict or terminate your access to the Service at any time for breach of these Terms or for legal, security, or operational reasons. Your obligations under Sections 11, 14 through 16, and 18 through 20 survive termination.
18. Dispute resolution
The parties will first attempt to resolve any dispute informally by contacting legal@gm.markets. If a dispute is not resolved within 30 days, it shall be finally resolved by binding arbitration administered by a recognized arbitral institution under its then-current rules, by a single arbitrator, in the English language, with the seat of arbitration as designated by the Interface Operator. Each party bears its own legal fees and shares the arbitral costs equally, subject to the arbitrator's authority to allocate costs.
Class action waiver. The parties waive any right to participate in a class, collective, or representative action. Disputes shall be brought only on an individual basis.
Carve-outs. Either party may seek injunctive or other equitable relief in a court of competent jurisdiction to protect its intellectual property or confidential information. Nothing in this section limits any non-waivable consumer rights you may have under applicable law.
19. Governing law and forum
These Terms are governed by the laws of the Interface Operator's home jurisdiction, without regard to conflict-of-laws principles. Subject to Section 18, the courts of that jurisdiction have exclusive jurisdiction over any dispute not subject to arbitration.
20. General
Force majeure. Neither party is liable for any failure or delay caused by events beyond its reasonable control, including network outages, chain reorgs, oracle failures, exchange or broker disruptions, governmental action, natural disasters, and pandemics.
Severability. If any provision of these Terms is held unenforceable, the remaining provisions remain in full force and effect.
Assignment. You may not assign these Terms without our prior written consent. We may assign these Terms in connection with a merger, acquisition, reorganization, or sale of assets.
Notices. We may provide notices through the Service or to any email you have provided.
Entire agreement. These Terms (including Schedule 1) and the documents referenced herein are the entire agreement between you and the Interface Operator with respect to the Service and supersede all prior agreements on the subject.
Updates. We may update these Terms from time to time. Material changes take effect 30 days after publication on the Service. Your continued use after that date constitutes acceptance.
Schedule 1 — Acceptable use policy
You may not use the Service to:
- Launder proceeds of unlawful activity or finance terrorism.
- Evade or attempt to evade sanctions administered by the UN, OFAC, the EU, the UK, or any other competent authority, or transact with any sanctioned person or entity.
- Manipulate markets, including wash trading, spoofing, layering, front-running, or insider trading.
- Disrupt, degrade, or attempt to gain unauthorized access to the Service or the underlying infrastructure, including denial-of-service attacks, exploitation of vulnerabilities, or unauthorized scraping.
- Reverse engineer, decompile, or copy the Service except as permitted by applicable law.
- Impersonate the Interface Operator, its employees, or its partners.
- Access the Service from a restricted jurisdiction, misrepresent your eligibility, or use technical measures (VPN, proxy, residential rotation) to bypass jurisdictional gating or sanctions screening.
- Submit false, misleading, or fraudulent information.
- Infringe any third party's intellectual property, privacy, or other rights.
- Use the Service for any unlawful purpose or in any unlawful manner.
Enforcement. We may rate-limit, restrict, or block interface access for any wallet, IP, or session associated with prohibited conduct, without prior notice. The Interface Operator cannot freeze on-chain assets; restrictions apply only to the hosted Service.
Reporting abuse. Report suspected abuse to abuse@gm.markets, including the wallet address, transaction hashes, and a description of the conduct.
Contact
Questions about these Terms: legal@gm.markets.