Trade Responsibly: Contracts for Difference (‘CFDs’) are derivative financial products that are traded on margin. Trading on margin carries a significant level of risk since leverage can magnify your profits as well as your losses. Thus, Leveraged Products may not be suitable for you as you may lose all your invested capital. You should not risk more than you are prepared to lose.

1. INTRODUCTION

1.1. A reference in this document to “we”, “us”, “our”, “ours”, “Company” and “ourselves” (as appropriate) is a reference to Pipsix LTD, Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands MH96960

1.2. A reference to “you”, “your”, “Customer” is a reference to you, the Client.

1.3. These terms (including any Schedules), once we have accepted your application and opened a Trading Account for you, will form an agreement (Agreement) between us and you and will govern all Transactions entered into between us and you and all dealings between us.

For your benefit and protection, please ensure you take sufficient time to read the Agreement as well as any other additional documentation and information available to you via our Website prior to opening an account and/or carrying out any activity with us. You should contact us for any further clarification or seek independent professional advice (if necessary).

1.4. All of the Financial Products or financial services are subject to the general terms in this Agreement (including the Schedules) which apply to particular financial services you may receive or particular Financial Products we issue to you.

1.5. You should read this Agreement carefully, including any other disclosure documents that we supply to you in connection with your Account.

1.6. By accepting these terms, you enter into a legally binding agreement with us. You acknowledge that you have read and understood the terms of the Agreement.

1.7. We do not provide investment, financial, legal, tax or regulatory advice nor do we provide any other form of recommendation. You understand that you shall make your own assessment of any transaction prior to entering into a trade, and shall not rely on any opinion, material or analysis provided by us or any of our affiliates, employees, or other related parties as being advice or recommendation. If you are unsure whether you should proceed with this Agreement, you may wish to seek independent advice.

1.8. We do not offer investment research, and any material containing market analysis is considered marketing communication and should not be construed as advice, recommendation or research.

1.9. You understand that CFDs are derivative products, and therefore you will not be entitled to own any underlying instrument. You also understand that no physical delivery of any underlying asset shall occur.

1.10. We do NOT accept Clients who are under 18 years old.

2.COMMENCEMENT, DURATION OF THE AGREEMENT AND RIGHT TO CANCEL

2.1. This Agreement will come into effect when we accept your application and open your Trading Account, and You transfer funds to the Company’s account(s) to ensure minimum trading deposit.

2.2. You have the right to cancel the Agreement by giving us notice in writing within the first fourteen (14) days of your account being activated. We will return to you any amount you have transferred to us, subject to you not having entered into any trades via our platform(s).

2.3. Where the Agreement has not been cancelled, it will continue to be in effect until its termination, in accordance with the provisions contained in the ‘Termination’ section of this document.

2.4. We will offer you, on an execution-only basis, access to trading a number of instruments in the form of CFDs (also referred to as ‘Leveraged Products’).

2.5. We will act as principal in Transactions with you and not as agent on your behalf.

2.6. You will enter into each Transaction with us as principal and not as agent for any undisclosed person. This means that unless we have otherwise agreed in writing, we will treat you as our Client for all purposes and you will be directly and personally responsible for performing your obligations under each Transaction entered into by you, whether you are dealing with us directly or through an agent. If you act in connection with or on behalf of someone else, whether or not you identify that person to us, we will not accept that person as an indirect Client of ours and we will accept no obligation to them unless otherwise specifically agreed by us in writing.

2.7. Dealings with you will be carried out by us on an execution-only basis unless otherwise agreed by us

3. FUNDINGS AND WITHDRAWALS

3.1. You must fund your trading account within 90 calendar days from the date of its opening in an amount not less than define terms for the type of account (minimum initial deposit).

3.2. We have the right to close/cancel an account with the balance less than 1 cent (one-hundredth of a US dollar) if the above account balance existed for more than 90 calendar days.

3.3. You may request withdrawal of funds from your trading account in the amount not used to cover the margin, but not more than current balance, in case that all your positions on the Trading account are closed and all charges and commissions have been paid to us.

3.4. You may place a funds withdrawal order by using our website’s interface. We are not responsible for any third-party access to your personal information and withdrawal orders. Once an order has been received, the withdrawal amount may be deducted from your trading account.

3.5. In some cases, fund transfer may take up to 5 business days after receiving a Client’s order due to third parties involvement, i.e., payment service providers, payment institutions, banks, card processing schemes etc. The security service of the company has the right to hold the order up to 10 business days. You will be previously notified in this case.

3.6. You shall have the Company’s banking details to transfer your funds into your trading account via the Company’s website or may place an account funding order in electronic (placed using the Company website’s interface) or written form.

3.7. You shall use the Company’s current banking or electronic wallet details from our website only and effective on the payment date. Current banking details mean details received within 24 (twenty four) hours prior to payment. We are not responsible for the funds which were transferred by using banking details different from the website. Additionally, we are not obliged to investigate and refund your payment and cannot credit these funds to your trading balance. Trading deposit funding orders may be issued, and current banking details may be received in the appropriate section of trader’s web entry on the payment day.

3.8. You agree to pay any banking or money transfer fees associated with any transfer, settlement or movement of funds or assets on your behalf (Deposit/withdrawal fees).

3.9. When the trading account balance is funded using online payment systems, you may order a withdrawal to the same payment system only which was previously used to fund your Trading account in the corresponding currency or it's equivalent. Trading profit may be withdrawn the different payment systems at any kind according to your wish.

3.10. When the trading account balance is funded using direct bank transfer, funds will be credited within 1 business day (after the transfer are actually credited to our account). The minimum funding amount is 5000 (EUR or USD). In case if you fund your account using direct bank transfer you may order withdrawal only to the account from which the payment was transferred. An upfront bank transfer fee 50 USD will be applied (for international bank transfer).

3.11. We reserve the right to reject a request for withdrawal in case of an explicit intention to exchange customer funds from one payment system to another.

3.12. Account balance funding using a third person credit card is prohibited.

3.13. If case of funding by using Visa/Mastercard, withdrawals can be done via bank transfer, or by using a specially issued Master card, sent to client by ordered mail.

3.14. We may require you to provide sufficient evidence (to our satisfaction) of the source of any funds you use to make any payments to us and we reserve our rights to prohibit you from entering into any Contracts or Transactions until we are satisfied with the information (or evidence) you have supplied and that information (or evidence) does not give us any reason to suspect any illegality in respect of those payments.

3.15. All payments by you to us are:

• (a) to be made without any set-off by you, counter claim or condition made by you and without you making any deduction or withholding for any Tax or any other reason unless the deduction or withholding is required by applicable law or the set-off arises by express application of this Agreement;
• (b) payable in any currency that we may reasonably require or determine;
• (c) to be made on the date and time due for payment otherwise we will be entitled to charge interest on the overdue amount (at a minimum rate of 4%), accruing daily until the date of payment;
• (d) satisfied when we receive the payment in cleared funds; and
• (e) to be made in the currency of your Trading Account.

3.16. Without prejudice to our right to require payment from you in accordance with this Agreement, we have the right (at any time) to set- off any losses incurred or any amounts you owe in respect of your Transactions or any debit balances in any Trading Account. If any loss or debit balance exceeds all amounts held, you must immediately pay us any excess whether demanded or not.

3.17. All payments to be made by you under this Agreement, which are due and payable are due immediately on our verbal or written demand. Once demanded, such payments must be paid by you, and must be received in full by us (in cleared funds) for your payment obligations to be satisfied.

3.18. In particular, we will not accept payments from a bank account if it is not evident to us that the bank account is in the Client’s name.

3.19. You acknowledge that in some instances there might be delays in your deposited funds being reflected in your trading account. You acknowledge and agree that the Company shall not be held responsible for any such delays.

4. MUTUAL UNDERSTANDING

4.1. We will only provide you with our services in accordance with our policies and procedures as long as we are not in breach of any legal requirements. There can be instances where we will not be able to provide you with a reason for refusing the provision of our services, where for instance doing so would be in contrast with the law. Examples of when we will not provide services (or cease providing services) to you include instances (i) where we reasonably believe that you are abusing any of our offerings (e.g. where you are involved in latency abuse, insider trading or abusing NBP), (ii) where there is a regulatory justification for doing so, or (iii) where you have been using inappropriate/ defamatory language.

4.2. We shall enter into transactions with you and conclude them in good faith.

4.3. We shall take all reasonable and necessary steps to ensure compliance with the applicable rules and regulations. Therefore, you agree to be bound by any decision we may make in order to comply with any rule, regulation or obligation of the Company.

4.4. Where we provide you via our Website with any links to other websites and/or resources from third parties, these links are provided for information only. We have no control over the content, quality or security of the information contained on those websites and/or resources, and therefore we cannot be made responsible for any losses that may arise from your use of these.

4.5. We take reasonable care in trying to ensure that any information and/or content, including third-party features on our Website and e-mail communications from us is accurate and complete. However, some information may be provided ‘as is’ and on an ‘if available’ basis, and therefore we cannot give any warranties or representations (either expressed or implied), relating to the said features and any third-party information.

4.6. We reserve the right to amend the product specifications and conditions, as available from our Website from time to time, when we deem necessary. You shall ensure to remain updated with regards to our product specifications and conditions, as well as any other information which may be of your interest, and you shall take all necessary actions to safeguard your interest where you believe you may be affected in any way by any such amendments. You understand that you will continue to be bound by the Agreement in the event of any of these amendments taking place. However, nothing in this clause shall affect your right to terminate the Agreement, without any penalty whatsoever, subject to any existing obligations.

4.7. Further to the clause above, you understand that we may remove any of our products and/or cease providing you with the ability to place an order at any time. Where we have ceased to provide any product and you have a previously open position in that product, it is your responsibility to cancel and/or close such position during the time that we should allow you to do so, otherwise we will close the position at the last available price for the relevant instrument. You also understand that any open positions on CFDs with expiration date will be automatically closed at the end of the last trading day.

4.8. You understand that in order to provide you with our services, we may enter into agreements with external service providers for any activity and/or operation we may conduct. As stated above, we will do our best to maintain the operation of our systems. Further, you understand and accept that we cannot and do not accept any responsibility for any means you use to access the services we provide and cannot guarantee the continued availability of any other person’s site or address.

4.9. By becoming our Client, you do not obtain any rights in any intellectual property belonging to us. Our Website, any data, information, documentation and/or creation shall be protected in accordance with the applicable laws and you shall have no right, neither at the time of entering into the Agreement, nor at any point of time in the future. All rights whether expressed or implied, and whether existing now or in the future are reserved.

4.10. You shall not cause or permit any actions to be caused which might endanger or damage any intellectual property belonging to us.

4.11. You, the Client, acknowledge and confirm to us for our benefit in relying on the following:

• (a) you (or, if a corporate entity, your directors) have read and understood all documentation provided to you by us including this Agreement and any other disclosure documents in relation to any Financial Products which you request THE Company to make available to you in relation to your Trading Account;
• (b) you agree to be bound by this Agreement;
• (c) all dealings in Financial Products and the performance by us of our obligations under this Agreement are subject to the Governing Legislation;
• (d) The Company relies on your representation that at all times you will be able to make payments and fulfil all commitments on your part arising under this Agreement and under the conditions applicable to dealings between you and us;
• (e) that trading in Transactions incurs a risk of loss as well as a potential for profit;
• (f) that dealing in the Contracts for Difference is highly speculative and you may lose more than your Initial Margin, Variation Margin and other payments you make to us;
• (g) it is your obligation to continuously monitor your Account and ensure that it constantly has sufficient Margin Cover;
• (h) you will indemnify and keep indemnified us and each of its related bodies corporate and their respective directors, officers, employees and agents from and against all sums of money, actions, proceedings, suits, Claims, complaints, Loss, demands, damages, costs, expenses and any other amounts whatever claimed against any of them;
• (i) We are not required to act in accordance with your instructions if in our opinion to do so would or could constitute a breach by us or our agent or hedge counterparty or any other Governing Legislation;
• (j) if errors have occurred in the pricing of Transactions quoted by us to you, we may choose not to be bound by such Transactions (without further liability to the Client) if we believe that there was a Manifest Error at the time of the Transaction;
• (k) an Open Position must remain open for the minimum period of time as determined by us and cannot be Closed Out by you during this period;
• (l) the English version of this Agreement prevails over any other translated version of this Agreement;

5. CONFLICT OF INTEREST

5.1. A conflict of interest may arise when our interests compete or interfere or appear to compete or interfere with your interests under the Agreement. You understand and agree that such circumstances may arise, and where they do, we will make our best endeavours to mitigate them.

5.2. We are required by law to take all reasonable steps to identify conflicts of interests between ourselves, our associates and our Clients, or between one Client and another, that arise in the course of providing our financial services.

5.3. Subject to the Governing Legislation, we may pay to and accept from third parties (and not be liable to account to you) benefits, commissions or remunerations which are paid or received as a result of Transactions entered into by you.

5.4. We are not under any obligation to account to you for any profit, commission or remuneration made or received from or by reason of Transactions or circumstances in which we have a material interest or where in particular circumstances a conflict of interest may exist.

5.5. You acknowledge that you are aware of the possibility that the conflicts disclosed in this clause will arise and consent to us acting notwithstanding such conflict.

6. TRANSACTIONS

6.1 The terms of each Transaction are agreed between you and us before entering into a Transaction can be found in a window of your personal Trading terminal.

6.2 Before you enter into a Transaction, you are required to have sufficient Trading Deposit on your Account. The Minimum Trading Deposit shall be able to cover the amounts for Realised/Unrealised Losses or any fees and charges which you may owe.

6.3 We have the right to decline your request to open a new position, if the balance on your trading account is not sufficient to place a minimal trade.

6.4 We have the right to suspend our operations or revise Client’s trades for the following reasons:

• failures on part of Internet access providers,
• failures in information flows,
• hacker attacks
• and other illegal actions against the our servers and equipment,
• force majeure circumstances,
• and suspension of trading on financial markets which concerns financial instruments used by the Company.

6.5. We may revise (change) an executed trade upon discovery of software malfunction within 5 trading sessions after malfunction was discovered. In this case, we will provide you a market prices history from at least 2 independent quotes sources.

6.6. We have the right to cancel your trading orders and reject service provision, if fraud attempts were done in order to make profit using particularities of trading conditions and trading equipment, including registrations in our affiliate programs with a purpose of getting an extra profit from trading activity, where trading account holder and affiliate account holder is the same person, or trading account and affiliate account is operated by the same person.

6.7. Under certain trading conditions, you should note that it may be impossible to execute an Order at their requested price. In such cases we reserve the right to execute the Order at the first available price. Such instances may occur during times of high market volatility and price fluctuations e.g. when the price of an asset rises or falls in one trading session to such an extent that, under the rules of the relevant exchange, trading is suspended or restricted. In the event if we unable to proceed with an Order in relation to price or size or any reason, the Order will be executed at the first available price or not executed at all. In addition, please note, that we are entitled, at any time and at its discretion, without giving any notice or explanation to the you, to decline or refuse to transmit or arrange for the execution of any Order or request of the Client in circumstances explained in the Terms & Conditions.The Company does not accept any orders outside of the market hours of the relevant underlying financial instrument.

6.8. Subject to any other provision in this Agreement, each Transaction opened by you will be binding on you notwithstanding that by opening the Transaction you may have exceeded any credit or other limit applicable to you or in respect of your dealings with us.

6.9. Non-Availability of Quotations: Should there arise a situation where a quotation for any financial instrument is not available due to any circumstance, the Company reserves the unilateral right, at its sole discretion, either to cancel the client's order or to execute it at the price of the first quotation available subsequent to the event causing the unavailability.

6.10. Discretionary Quotation Provision and Selection of Liquidity Providers: The Company acts as a broker and engages various liquidity providers to furnish the necessary market data for operations. It is within the Company's exclusive discretion to determine the appropriate quotation data to be provided to clients. The Company retains the authority to select and deliver such data selectively based on its strategic and operational considerations.

7. MANIFEST ERROR

7.1. We may, without your consent, either determine a Transaction or Open Position from the outset or at any time amend the terms of any Transaction containing or based on any error that we reasonably believe to be a Manifest Error.

7.2. If, in our discretion, we choose to amend the terms of any such Transaction or Open Position due to a Manifest Error, the amended terms will be such level as we reasonably believe would have been fair at the time the Transaction was entered into had the Manifest Error not occurred.

7.3. In deciding whether an error is a Manifest Error we will act reasonably, and we may (but not obliged to) take into account any relevant factors including, without limitation, the state of the Underlying Market at the time of the Manifest Error or any error in, or lack of clarity of, any information source or pronouncement upon which we base our quoted prices. Any financial commitment that you have entered into or refrained from entering into in reliance on a Transaction with us will not be taken into account in deciding whether or not there has been a Manifest Error.

7.4. In the absence of our fraud, wilful default or negligence, we will not be liable to you for any Loss, cost, claim, demand or expense following a determination of a Manifest Error (including where the Manifest Error is made by any information source, commentator or official on whom we reasonably rely) or any action (or omission) taken (or omitted) by as a result.

7.5. If a Manifest Error has occurred and we choose to exercise any of our rights under this clause or any other provision in this Agreement, and if you have received any monies from us in connection with the Manifest Error, you agree that those monies are due and payable to us on our written demand and you agree to return an equal sum of those monies to us within the period stated in our written demand.

7.6. If a Transaction or Open Position is based on a Manifest Error, we may (in addition to our other rights) without your consent do any or all of the following:

• (a) amend the terms of a Transaction to reflect what we consider to have been the fair terms at the time the Transaction had been entered into had there been no Manifest Error;
• (b) Close Out the Transaction and any Open Positions resulting from it;
• (c) adjust or suspend your Account;
• (d) treat the Transaction as void from its inception;
• (e) refrain from taking action to amend or void the Transaction;
• (f) or any other action that we believe is appropriate in the circumstances.

7.7. We will exercise our rights under this clause reasonably, in good faith and as soon as reasonably practical after we become aware of the Manifest Error.

7.8. To the extent reasonably practicable, we will give you prior notice of any action we take under this clause; but if it is not reasonably practicable, we will give you notice as soon as reasonably practicable afterwards.

7.9. In the absence of fraud or gross negligence on our part, to the extent permitted by law we are not liable to you for any Loss, cost, claim, demand or expense that your incur or suffer (including loss of profits or indirect or consequential losses), arising from or connected with the Manifest Error including if the Manifest Error arises from an information service on which we rely.

8. KYC and AML

8.1. You acknowledge and agree:

• (a) that we are required to properly identify and verify you prior to agreeing to open an Account because we are subject to the AML Laws;
• (b) to provide all information and documentation we require to verify you;
• (c) if we cannot properly verify you, we reserve our rights to reject your application for an Account and will not be liable whatsoever for that rejection;
• (d) that we may delay, block or refuse to make any payment or to provide any service if we believe on reasonable grounds that to do so may breach AML Laws or any law in Seychelles or any other country, and we will incur no liability to you if we do so;
• (e) that during the term of this Agreement, we also reserve our rights to take whatever action we believe is necessary against you if we suspect that you are breaching any AML Laws; and

8.2. You warrant that any documents sent to us during your Account opening process, as well as throughout the duration of the Agreement, are valid and authentic. In the event that we believe, in our sole discretion, that any document is incorrect or invalid, we will request for alternative documentation. Failure from you to provide such documentation may lead to take action as we deem necessary.

8.3. You agree to provide all information (and complete any documents) that we are required to obtain in accordance with the Foreign Account Tax Compliance Act.

9. COMMUNICATIONS

9.1. Any communication between us and you may be made:

• (a) verbally by telephone, provided by you during the registration;
• (b) by email or post, provided by you during the registration;
• (c) in such other manner as we may specify from time to time, as per the details provided in our website

9.2. We will be using the details specified by you upon the registration. You must immediately notify us of any changes in your contact information.

9.3. Any correspondence (documents, announcements, notifications, confirmations, reports, etc.) will be considered as received by you:

• After one hour after sending to your e-mail address
• Immediately after sending the internal mail in the trading platform
• Immediately after the telephone conversation with you
• After one day after placing announcement on our Web site.

9.4. If at any time you are unable, for whatever reason, to communicate with us, we do not receive any communication sent by you, or you do not receive any communication sent by us under this Agreement, we will not:

• (a) be responsible for any Loss, damage or cost caused to you by any act, error delay or omission resulting therefrom where such loss, damage or cost is a result of your inability to open or close a Transaction;
• (b) and (except where your inability to communicate with us results from our fraud, wilful default or negligence) be responsible for any Loss, damage or cost caused to you by any act, error, omission or delay resulting therefrom including without limitation, where such Loss

10.EXCLUSION OF LIABILITYy

10.1. In the absence of any negligence or fraud from the Company (including its employees), the use of our services by a Client or the use of any systems owned or used by the Company is entirely at the own risk of the Client.

10.2. In general, neither party shall be liable for any losses which may arise as a result of unforeseeable events at the time when the Agreement was made effective, nor shall any party be liable for any losses that were not caused by any breach of the terms contained herein.

10.3. Where we outsource any activity to third parties, in order to be able to provide you with our Services under the Agreement, we will exercise all reasonable endeavours prior to contracting with them. However, you understand that it is not possible to control the activities of such third parties. Our responsibility, therefore, shall be to exercise all efforts to minimise any losses that you may suffer as a result of an act and/or omission of the outsourced party(ies). Nonetheless, we shall not be liable for any loss that you may suffer as a result of such acts and/or omissions from third-party service providers, unless we have acted negligently.

10.4. You acknowledge and accept that you are entering into all and any transactions with us at your own risk, and we assume no liability for any loss whatsoever as a result of your trading activity with us, unless in the event of any wrongdoing from our behalf. Nothing in this clause shall be taken to exclude any liability for death or personal injury.

10.5. We shall not be liable for any direct, indirect, consequential, incidental and/or special losses (including, but not limited to loss of profits, trading losses, or damages) which result from a breach of contract by you.

10.6. Further, and notwithstanding any other provision in the Agreement, we will not be liable to you as a result of:

• a) Negligence, fraud, breach of the Agreement, breach of any law and/or any other act and/or omission by you;
• b) Unavailability of the Website and/or our systems, other than in instances of wrongdoing by us;
• c) You being unable to access our Website and/or System or any other system, or any delay you may suffer when attempting to contact any of our customer support staff, unless this is due to wrongdoing by us.
• d) Us taking measures to ensure compliance with any applicable law or regulation, including where we are precluded from processing any instruction from you which may result in us breaching the applicable law.
• e) Such loss or damage, which is not reasonably foreseeable result of any such breach.
• f) Any other event and/or circumstance which is outside our control.

10.7. We are not responsible for any delays, delivery failures, or any loss or damage which results from the transmission of information over any network, including but not limited to the internet.

10.8. The limitations and/or exclusions included in the Agreement shall apply irrespective of whether we, including any of our employees and/or affiliates are aware of any losses you may incur, or any claims you may make against us.

11. IDEMNITY

11.1. You shall indemnify us on demand against all liabilities, costs, expenses, damages (including reputational) and losses (including, but not limited to any direct, indirect or consequential losses), and all interest, penalties and professional costs and expenses (calculated on a full indemnity basis) incurred by us as a result of:

• a) your breach of the Agreement;
• b) the provision by you of any false or misleading information to us;
• c) and/or the enforcement of the Agreement.

11.2. In general, indemnity means a sum of money paid as compensation for losses suffered.

12.FORCE MAJEURE EVENTS

12.1. We may, in our reasonable opinion, determine that a Force Majeure Event exists, in which case we will, in due course, take reasonable steps to inform you.

12.2. If we determine that a Force Majeure Event has occurred, we may, in our absolute discretion, conclude that it is an Event of Default and take any action we consider necessary as outlined in clause 10, 11.

13. PRIVACY

13.1. You confirm that you understand and agree that we will collect your personal information for the purposes of assessing your application and maintaining and operating your Trading Account including the enforcement of the provisions of this Agreement in accordance with the General Data Protection Regulation along with any other regulation that may apply for the protection of the personal information.

13.2. You authorise us to collect your personal information from you when we provide services to you under this Agreement. You authorise us to use (and disclose) any information we collect from you or from others, or such other relevant documents:

• (a) to assess your request for us to provide our services to you;
• (b) to provide our services to you in accordance with this Agreement;
• (c) for the purposes of complying with our obligations regarding your beneficial interests;
• (d) to allow us to communicate with third parties in connection with the matters contemplated by this Agreement, such as in connection with the Account; and
• (e) to ensure that legal and regulatory requirements under Governing Legislation are met.

13.3. You must immediately notify us if any of your information that you have previously provided to us changes. This is a continuing obligation of yours.

13.4. You have the right to request and view any documentation we have collected from you (free of charge).

14. TERMINATION OF THE AGREEMENT

14.1. You may terminate the Agreement at any time and for whatever reason by providing us with a 7-day notice via e-mail using your registered e-mail address, provided that there are no open positions on your Account, nor are there any outstanding obligations to us.

14.2. We may terminate the Agreement at any time and for whatever reason by providing you with a minimum of 7 days’ notice. Where we decide to terminate the Agreement, we will specify the termination date and we will proceed with closing any open positions on your Account, as we see fit.

14.3. We shall terminate the Agreement, with immediate effect, in the event of:

• a) a breach of any part of the Agreement by you;
• b) where we have reasonable grounds to believe that you have not acted in good faith,
• c) an issuance of an application, order, resolution or other announcement in relation to bankruptcy or winding-up procedures involving you;
• d) your death or incapacity (please note that in the event of death, any funds available in your Account(s) shall form part of your estate);
• e) a breach of any applicable law by you, including, but not limited to the Anti-Terrorism Act 2004 and the Securities Industry (Anti-Money Laundering and Countering the Financing of Terrorism) Rules 2015;
• f) you have acted contrary to our ‘Order Execution Policy’ or any other of our policies or procedures.
• g) all accounts being inactive for a period of 12 months.

14.4. Termination of the Agreement shall not imply that any of your responsibilities cease to exist. You will still be liable to pay us, and/or we will have the right to immediately deduct from your Account:

• a) any amount due to us;
• b) any expenses incurred by us as a result of the termination of the Agreement;
• c) any damage arisen after an arrangement or settlement.

14.5. Upon termination of the Agreement, we will transfer any amount available in your Account(s) to you, net of any outstanding amount that is due to us, except where we are prohibited to do so by law.

15.MISCELLANEOUS

15.1. We reserve the right to suspend your Account at any time (without notice) if we believe it is appropriate in the circumstances.

15.2. We may amend this Agreement from time to time and we will give you the notice required by Governing Legislation prior to the amendment taking effect. We may give you notice of the amendment by posting the amended Agreement (or details of the amendments) on our Website or by sending you a copy.

15.3. This Agreement and any relevant Application Form completed by you contain the entire understanding between you and us concerning the provision of the Financial Products or financial services and any other services referred to in or provided under this Agreement, as later amended only in accordance with this Agreement.

15.4. Our rights and remedies under this Agreement will be cumulative, and our exercise or waiver of any right or remedy will not preclude or inhibit the exercise of any additional right or remedy. Our failure to enforce or exercise any right under this Agreement will not amount to a waiver or bar to enforcement of that right.

15.5. Each of us and you must do everything reasonably possible to give full effect to this Agreement.

15.6. We may assign, novate or otherwise transfer any of the rights and obligations of this Agreement to a third party, in whole or in part, without your prior consent. You agree that you may not assign, novate or otherwise transfer any of the rights and obligations of this Agreement to a third party, without our prior written consent.

15.7. You acknowledge and agree that the copyrights, trademarks, database and other property or rights in any information distributed to or received by you from us (including, but not limited to, our Quotes), together with the contents of our Website, brochures and other material connected with our dealing service and in any database, that contains or constitutes such information, will remain the sole and exclusive property of ours or any third party identified as being the owner of such rights.

15.8. If any clause (or any part of any clause) is held by a court of competent jurisdiction to be unenforceable for any reason then such clause will, to that extent, be deemed severable and not form part of this Agreement, but the enforceability of the remainder of this Agreement will not be affected.

15.9. You will be responsible at all times for the payment of all Taxes due and for providing any relevant tax authority with any information relating to your dealings with us. You agree that if we provide you with any information or express any opinion in relation to the tax treatment of your dealings with us it will not be reasonable for you to rely upon any such statement and it will not constitute tax advice.

15.10. This Agreement and each Transaction entered into with you is in all respects governed by the laws in force in __________ and the parties submit to the non-exclusive jurisdiction of the courts of __________.

15.11. If you are situated outside of ____________, an originating process by which any proceedings in Seychelles are begun may be served on you in accordance with our local rules for service out of the Seychelles jurisdiction. Nothing in this clause affects our right to serve process in another manner permitted by law.

16.REFERRAL PROGRAM

16.1. To use the Referral program, you must use a special referral link from the Referrals section on the website.

16.2. The commission of the Referral program is fixed on 20% of each deposit amount of the referred client after all payment system fees. Example: The referral Client has funded his trading account with $ 1000 (after the fees of the payment system), so you will receive a commission of $ 200.

16.3. The following limitations to the Referral program shall apply:

• You can attract only real customers;
• you have no right to open a trading account in your own name by using referral link and receive commissions for this;
• for attracting referral customers, you may use any promotional methods, except for SPAM mailings and other prohibited ways;
• you may claim a commission for the referral customer if this customer has trading activity and a trading turnover of at least 100% of his deposit;
• in case If the client withdraws more than 50% of his deposit, we have the right to cancel the commission.

16.4. We may at our own discretion cancel the commission and block your account in case of violation of the terms of this Clause.

17. FEES AND CHARGES

17.1. Any profit or loss net of any fees and charges (that is, the realised gain or loss) arising on Closing Out a Transaction will be credited or debited (as the case may be) in your Trading Account or your credit card on file.

17.2. Your access to the history of transactions in your Trading account is free of charge.

17.3. The opening or maintaining your Trading account is free of charge as well. However, if you fail to transact at least one trade per one calendar month an account service fee of $10 per month will be levied. Additionally, we may remit the balance of your account in case that no transactions were made for at least twelve months.

17.4. If you have questions considering maintenance of your account ( claiming funds from a dormant account, close, block or exclude account, etc.) please contact our Payments team on the following email - __________________.

18.BONUSES

18.1. We may provide bonuses to our new and existing Clients. The bonus will offer additional funds which you may can trade on your account. Bonus and Promotions as a part of our promotional program are for a bounded time. Bonuses on deposits appear to your Trading account for the first deposit made (or following deposits if mentioned and at the our sole discretion).

18.2. You are never forced to accept the bonuses. Once trading is initiated on an account after a trading bonus has been applied to the available account balance, we believe that you are willingly accepted the bonus and it cannot be reversed. if you wish to accept no bonus during initial depositing, please send a request to [email protected], however the rest of the terms in this Agreement shall apply. If you have accepted bonus by mistake you shall contact the support as well withing 3 days. During that time, you shall make no trading activity on your Trading account.

18.3. We reserve the right to refuse, cancel or change the bonus at any time without any prior notice. Any indication of fraud, manipulation, cash-back arbitrage or other forms of deceitful or fraudulent activity based on the provision of the bonus will render the account inactive along with any and all profits or losses garnered.

18.4. We do not recommend that you accept bonuses unless you are committed to trading over an extended period of time and know that all bonuses are bound by the following conditions:

• No withdrawals are permissible until a trading volume of 1 Lot of the bonus is achieved (hereinafter: “the Trading Requirement”).
• An added fund is not transferable; a bonus provided to one account cannot be transferred to another.

18.5. First 3 risk free trades” bonus.

In case your first three transactions is negative in total we may compensate the loss in the form of a bonus, and terms and conditions of the 18 Clause will apply. Compensation of risk-free trades shall not exceed the amount of the initial deposit. In order to be able to use this bonus you need to request it prior. Please contact [email protected] or your account manager, if available, for more information.

Risk free trades bonus must be requested by email only on the above address and can not be requested through online chat.

19. DEMO ACCOUNT

A demo account is offered to you for educational purposes and upgrading your trading skills.

On a demo account you may trade with virtual money, which is not considered as real money. You can not withdraw, exchange, or transfer virtual money to any other account.

rading functionality on a demo account matches with the functionality on a real account. Quotes on a demo account matches with market quotes, however, they may differ from quotes on a real account due to an infrequent update of the price feed to optimize the functioning of the trading platform.

Glossary

• 1. Account: means the trading account(s), which has a unique number, maintained by a the Client for the purposes of trading financial instruments through our trading platform(s).
• 2. Balance Currency: means the currency in which Account(s) are denominated. All charges including spread(s), commission(s), and swap(s), will be calculated in that currency.
• 3. Balance: means the funds available in an Account that may be used for trading on financial instruments.
• 4. Business Day means any day other than a Saturday, Sunday and a gazetted public holiday
• 5. Client refers to the person who is not under 18 years old (or entity) who has an Account.
• 6. Contracts for Differences: CFDs, which are traded off-exchange (or Over-the-Counter (‘OTC’)), are agreements to exchange the difference in value of a particular instrument or currency between the time at which the agreement is entered into and the time at which it is closed. This allows the Clients to replicate the economic effect of trading in particular currencies or other instruments without requiring actual ownership of those assets. A full list of the CFDs on offer by us is available on our Website.
• 7. Financial Product includes the Contracts and any other financial products issued by the Company from time to time.
• 8. General Data Protection Regulation refers to the Regulation (EU) 2016/679 of the European Parliament and of the Council as of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data and other applicable data protections laws, as amended from time to time.
• 9. Instructions: means any request made by you in relation to your account, other than an order to buy or sell any of the financial instruments available on our platform(s).
• 10. Leveraged Products means financial products that are traded on margin
• 11. Website: means ___________

20.NTERPRETATION

A reference to:

• (a) a clause is a reference to a term of this Agreement;
• (b) an Act of Parliament is a reference to such Act as from time to time amended, consolidated or re-enacted (with or without modification) and includes all instruments or orders made under such enactment;
• (c) any time or date will be to the place of Company registration, unless expressly noted to the contrary; and
• (d) the singular will import the plural and the masculine will import the feminine as the context requires. The following rules also apply in interpreting this document, except if the context makes it clear that a rule is not intended to apply.
• (a) Headings used in this Agreement are used for convenience only, and do not affect interpretation.
• (b) A reference to legislation (including subordinate legislation) is to that legislation as amended, re-enacted or replaced, and includes any subordinate legislation issued under it.
• (c) A singular word includes the plural and vice versa.
• (d) A word which suggests one gender includes the other gender.
• (e) If a word or phrase is defined, any other grammatical form of that word or phrase has a corresponding meaning.
• (f) A reference to time is to local time in place of Company registration, unless otherwise specified.
• (g) Anything permitted to be done by us in accordance with this Agreement may be done in its absolute discretion, and any opinion or view required to be formed by us may be formed in its absolute discretion.
• (h) For the avoidance of doubt, time will continue to run on days which are not Business Days.
• (i) The English version of this Agreement prevails over any other translated version of this Agreement.

21. Terms for trading CFDs

How the Price is formed

The price for a given contract is calculated by reference to the price of the relevant underlying financial instrument. For any given CFD, the Company will quote two prices: the higher price (ASK) at which the Client can buy (go long) that CFD, and the lower price (BID) at which the Client can sell (go short) that CFD. Collectively, the ASK and BID prices are referred to as the Company’s prices and can be found on the Company’s trading platform.

The difference between the lower and the higher price of a given CFD is the spread.

Prices will be obtained from reputable third-party price feeders and provided by the Company. Prices are updated frequently as the limitations of technology and communication links allow.

The Company ensures that the Client will receive the best price by guaranteeing that the calculation of the quoted prices is made with reference and compared to a range of underlying price providers and data sources. The Company additionally ensures to monitor its Execution Venue(s) on an ongoing basis and review their performance at least annually to confirm that relevant and competitive pricing is offered.

Please note that despite taking reasonable steps to obtaining best possible results for Clients, the Company is unable to guarantee, when executing orders, that the prices offered will be more favourable that prices that might be available elsewhere.

Under certain trading conditions, the Client should note that it may be impossible to execute an Order at their requested price. In such cases the Company reserves the right to execute the Order at the first available price. Such instances may occur during times of high market volatility and price fluctuations e.g. when the price of an asset rises or falls in one trading session to such an extent that, under the rules of the relevant exchange, trading is suspended or restricted.

What are the Costs

In most circumstances, a spread is applied. The spread is dynamic for certain Financial Instruments, and may take into account such factors as liquidity in external markets for the underlying financial instrument and competitive pricing. The Company reserves the right to charge the Client a swap fee (of 0.07% of the face value of the position) for keeping a position open overnight. This swap fee can be subject to changes in the future. The swap fee is calculated as the rounded result of the following formula: ((23%)/360) + Libor rate.

The Company reserves the right to charge a commission for opening an unleveraged Cryptocurrency CFD trading position which shall vary from 1% to 2.5% of the transaction. For leveraged CFD cryptocurrency positions, the Company will charge a commission fee of up to 5% of the transaction.

In certain circumstances (such as increased volatility or illiquidity in relation to the underlying market concerned) the Company reserves the right to alter the spreads offered.

In other circumstances, clients may be charged overnight funding premiums.

The Company reserves the right to, at any time, apply such charges in the future with prior notice to the Client. Such notice may be sent personally to the Client and/or posted on the Company’s website in the section General Fees. Should the Company at any period of time decide not to charge any costs, it shall not be construed as a waiver of its rights to apply them in the future.

What is the Speed of Execution

The Company strives to offer a high speed of execution however, in certain circumstances, for example low internet speed or market volatility, the quoted price may no longer be representative of the underlying market price and may result in the Client placing his/her Order at a delay, this may result in orders being executed at a better or worse prevailing price offered by the Company.

What is a Likelihood of Execution

The Company arranges for the execution of Client orders with the Execution Venue, as such, execution may at times be difficult. The likelihood of execution depends on the availability of the prices of the Execution Venue(s). In some instances, it may not be possible to arrange an Order for execution during abnormal market conditions. This can occur, but is not limited to, the following examples: overnight, during news times, the opening of trading sessions, volatile markets (where prices may move significantly up or down and away from declared prices), where there is rapid price movement, where there is insufficient liquidity for the execution of the specific volume at the declared price or a force majeure event has occurred.

In the event that the Company is unable to proceed with an Order in relation to price or size or any reason, the Order will be executed at the first available price or not executed at all. In addition, please note, that the Company is entitled, at any time and at its discretion, without giving any notice or explanation to the Client, to decline or refuse to transmit or arrange for the execution of any Order or request of the Client in circumstances explained in the Terms & Conditions.

The Company does not accept any orders outside of the market hours of the relevant underlying financial instrument.

What is a Likelihood of Settlement

The Company shall proceed to the settlement of all transactions upon execution of such transactions. The CFDs offered by the Company do not involve the delivery of the underlying asset, so they are not settled physically as there would be for example if the Client had bought Shares. All CFDs are cash settled.

The Company shall proceed with the settlement of all transactions upon the execution and/or time of expiration of the specific transaction.

What shall be the Size of Order

All orders are placed in monetary values. The Client is able to place an order as long as they have enough balance in their trading account. The minimum size of an Order may be different for each type of CFD, please refer to the Company’s trading platform for the value of the minimum size of an Order in each CFD, as well as the value of the maximum size of a single Order.

If the Client wishes to execute a large Order, in some cases the price may become less favourable. The Company reserves the right to decline an Order in case the size of the Order is large and cannot be filled by the Company.

What about Market Impact

Some factors may rapidly affect the price of the underlying instrument/product from which the Company’s quoted price is derived and may also affect other factors listed herein. The Company will take all reasonable steps to obtain the best possible result for its Clients.

The Company does not consider the above list exhaustive and the order in which the above factors are presented shall not be taken as priority factor.

Different Types of CFDs

The Company offers the following types of CFDs on its platform:

• Forex: CFDs in currency pairs (FX)
• CFD stocks
• "Crypto": CFDs in Cryptocurrencies

What Types of Orders can be executed

The Client may give instruction to execute or initiate a trade with the Company by way of:

• Market Order: whereby the Client gives instructions to immediately buy or sell at the best available price.

Execution Practices in CFDs

Slippage: You are warned that Slippage may occur when trading in CFDs. Slippage is the difference between the expected price of an Order, and the price the Order is actually executed at. In some situations, at the time an Order is presented for execution, the specific price shown to the Client may not be available; therefore, the Order will be executed close to or a number of pips away from the Client’s requested price.

Slippage can occur at times of low liquidity or high volatility (e.g. after economic events or news announcements) and is a normal element of trading in CFDs.

Leverage (Multiplier): The use of the multiplier tool in CFD trading enables the client to trade in the markets and increase proportionally the returns of his/her invested amount, in relation to the returns in the market. However, the maximum loss a client can incur from a trade is limited to his/her original investment amount meaning the remaining amount of his/her equity is secured. The Company applies a maximum multiplier of 1:100 for all clients by default, in line with relevant legislation.

E.g. (for long positions with 1:50 multiplier): A trader decides to invest €1,000 (Investment Amount) on the upwards movement of EUR/USD. He/she also chooses to use a multiplier of 50 for this trade. After one day, the trader decides to close the position. At that moment, the price of EUR/USD moved from 1.153250 (opening price) to 1.158000 (closing price) or otherwise 0.41188%. The realised profit for the client will be €205.94 or otherwise 20.594%. To better understand the calculations, the invested capital increased by the percentage move in the market multiplied by the multiplier (0.41188% x 50 = 20.594%).

(Closing Price / Opening Price -1) x Multiplier x Investment Amount = Profit/Loss

i.e. (1.158000 / 1.153250 -1) x 50 x 1000 = 205.93973553 or €205.94

For short positions: i.e (1-closing price / opening price) Multiplier Investment Amount = Profit/Loss.

Without the use of the multiplier tool the trader’s profit would have been 4.1187947106 or €4.12.

In the opposite scenario, if the market had moved against his/her position, the realised losses would have been larger with the use of the multiplier compared to a position opened without the use of it. To demonstrate with the same example, if the market had moved 1% down from the opening price of 1.153250, because of the use of the multiplier tool, the invested capital will decrease by 50% (1% x 50).

i.e. 1% x 50 x 1000 = €500

Without the use of the multiplier tool, the trader’s losses would have been €10.

If the trader had used a lower multiplier both the profit and loss amount in the examples above, would have been smaller as well.

E.g. Using a multiplier of 20, the realised profit in the first example would be (1.158000 / 1.153250 -1) x 20 x 1000 = 82.374 or €82.40 and 1% x 20 x €1,000 = €200 for the second example.

As it will be explained more in Maintenance Margin section the trader will never lose more that the investment amount of a position.

It should be noted that the Company may offer higher multipliers to clients it considers to possess the necessary knowledge, experience and understanding of the high risks involved with trading with leverage. Leverage restrictions may apply to certain instruments and/or jurisdictions.

Warning: Trading CFDs carries a high level of risk since the multiplier tool (leverage) can work both in your advantage and disadvantage. As a result, it may not be suitable for all investors because you may lose all your invested capital.

Maintenance Margin: The Maintenance Margin is the minimum amount of equity in a position required to maintain the open position. Should this amount fall below 5% of the initial investment, the Company will automatically close the position.

E.g. Using the data from the previous example with €1,000 investment in EURUSD and using a multiplier of 50, the maintenance margin is calculated as 5% x €1,000 = €50. Therefore, the maximum loss the trader can occur, before their position is closed by the Company is 95% or €950 (If the trader has not already closed the position themselves).

The price when the position will be closed by the Company, and only if the trader hasn’t decided to already close the position, is 1.131338. At this price, the remaining amount of the investment will have reached the maintenance margin.

To better understand the calculations the return in the market when 95% of the investment amount will be lost is 1.9% on the downside since the position is long the EURUSD.

Maximum Loss / multiplier = return in market.

i.e. 95% / 50 = 1.9%*

For an opening price of 1.153250, a 1.9% decline will cause the price to move to 1.131338.

Opening Price x (1 – return in market) = price when position will be closed.

i.e. 1.153250 x (1-1.9%) = 1.131338

In majority of situations, position will be automatically closed as soon as it declines by 95%. It can happen that the position will be closed in a range between 95% and 100%, such situations can occur at times of low liquidity or high volatility (e.g. after economic events or news announcements) and is a normal element of trading in CFDs.

In case of 100% loss, calculations will be like this:

Maximum Loss / multiplier = return in market

i.e. 100%/50 = 2%

For an opening price of 1.153250, a 1.9% decline will cause the price to move to 1.130185

Opening Price x (1 – return in market) = price when position will be closed

i.e. 1.153250 x (1-2%) = 1.130185

The Company assigns the following importance level to the Best Execution Factors:

Best Execution Factor	Level of Importance
Price	High
Costs	High
Speed of Execution	High
Likelihood of Execution	High
Likelihood of Settlement	Medium
Size of Order	Medium
Market Impact	Medium