Section A: General Provisions

1. Introduction

1.1 This agreement is made between GRANDE Club LTD (hereinafter referred to as the “Company”) and the Client, who may represent either an individual or a legal entity, having completed the Account Opening Application (hereinafter referred to as the “Client”).

1.2 This Client Agreement, along with the following documents available on the Company’s official website (including but not limited to: “General Terms of Commercial Activity”, “Partnership Agreement”, “Risk and Warning Notice”, “Client Complaint Procedure”), with possible amendments (hereinafter referred to as the “Agreement”), describe the terms of services provided by the Company to the Client and regulate all CFD operations of the Client under this Agreement.

1.3 This Agreement takes precedence over any other contracts, conditions, agreements, or statements made by the Company or its Representatives, whether express or implied.

2. Definitions

2.1 The following definitions are used within this document (Client Agreement):

• “Access Data” — refers to the login and password owned by the Client, required to place Orders on CFDs through the Company’s Trading Platform. Access Data also includes other confidential passwords, such as investor passwords, telephone passwords, and any other means of authorization in the Client’s Cabinet for non-trading operations.
• “Account Opening Application Form” — is an online or paper form completed by the Client on the Company’s website, through a mobile application(s), or on paper. This form is used to apply for the Company’s services under the Agreement and to open a Client Account. During the process, the Company obtains the necessary information to identify and verify the Client, classify them, and ensure compliance with applicable regulatory requirements.
• “Affiliate” — any individual or legal entity that directly or indirectly controls, is under the control of the Company, or is under common control with the Company. “Control” implies the right to manage the Company’s activities or another entity or to have grounds for such management.
• “Agreement” — this document (Client Agreement) and additional documents posted on the Company’s website, such as “General Commercial Terms”, “Partnership Agreement”, “Risk and Warning Notice”, “Client Complaint Procedure”, with possible amendments and additions, as well as any subsequent appendices.
• “Applicable Regulations” — refer to (a) the rules of regulatory authorities that have jurisdiction over the Company; (b) the rules of relevant markets; and (c) all other applicable laws, regulations, and rules of the Seychelles.
• “Ask” — the highest price in a Quote at which the Client can buy.
• “Balance” — the total financial result on the Client’s account after the last completed transaction and any deposit or withdrawal operations over a specified period.
• “Base Currency” — the first currency in a currency pair that the Client buys or sells against the quote currency.
• “Bid” — the lowest price in a Quote at which the Client can sell an asset.
• “Business Day” — any day except Saturday, Sunday, December 25, January 1, or other international holidays, as published on the Company’s website.
• “Client Account” — a unique personalized account showing all the Client’s trades, open positions, orders on the Trading Platform, balance, and deposit or withdrawal transactions.
• “Client Terminal” — the My Trading software, as well as any other trading platforms (including web and mobile versions) used by the Client to obtain real-time data on underlying markets, perform technical analysis, execute trades, place or cancel orders, and receive notifications.
• “Closed Position” — an opposite position to an open one, meaning a completed transaction that has liquidated the original open position.
• “Completed Transaction” — two opposing operations of the same volume, representing an opening and closing of a position: buying and then selling or vice versa within CFD trading.
• “Contract for Difference” (CFD) — a financial instrument that represents a contract based on the change in value of an underlying asset.
• “Contract Specifications” — key conditions for CFD trading, such as spread, trading commission, swaps, lot size, initial margin, required margin, hedged margin, minimum levels for stop-loss, take-profit, and limit orders, financing fees, and other charges. These parameters may be adjusted by the Company from time to time.
• “Client Account Currency” — the currency in which the Client’s account is maintained and which is available for use depending on the Company’s policy.
• “Currency Pair” — an object or underlying asset for CFD transactions, based on the exchange rate changes of one currency relative to another. A currency pair consists of two currencies — the quote currency and the base currency — and shows how much of the quote currency is needed to buy one unit of the base currency.
• “Equity” — the sum of the account balance increased or decreased by the current floating profit or loss arising from open positions. The calculation is made by the formula: Equity = Balance + Floating Profit — Floating Loss.
• “Erroneous Quote (Spike)” — an incorrect quote characterized by the following features:

A. A significant price gap;

B. A quick price return after a sharp movement;

C. The impression that there were no abrupt price fluctuations;

D. Occurs before or immediately after it becomes clear that no major macroeconomic data or corporate reports were released.

• “Event of Default” has the meaning as set out in clause 11.1. Section A of this Client Agreement.
• “Advisor” — an automated trading system designed to perform trading operations on the electronic platform. It can be programmed to alert the Client of trading opportunities and to fully automate trading, including placing orders on the platform, setting stop-loss, trailing stop, and take-profit levels.
• “Financial Instrument” — refers to Contracts for Difference (CFD).
• “Floating Profit/Loss” — the current result of open positions, calculated based on current quotes, considering all applicable trading commissions and fees.
• “Force Majeure Event” has the meaning as set out in clause 12.1. Section A of this Client Agreement.
• “Free Margin” — the amount of funds in the Client’s account available for opening new positions or maintaining already open ones. It is calculated as the difference between equity and the required margin: Free Margin = Equity — Required Margin.
• “Hedged Margin” — the margin required by the Company to open and maintain hedged positions in CFD trading.
• “Hedged Positions” — simultaneously opened long and short positions of the same volume for the same financial instrument on the Client’s trading account.
• “Indicative Quote” — a quote for which the Company may refuse to accept instructions or execute orders in CFD trading.
• “Initial Margin” — the margin required by the Company to open a position in CFD trading.
• “Investment Account” — a unique personalized account for investors, designed for participation in Social Trading.
• “Investor” — a Client using the Company’s Social Trading services by copying strategies developed by Strategy Providers.
• “Leverage” — the ratio between the transaction size and the initial margin in CFD trading. For example, with a 1:100 ratio, the initial margin is one hundred times smaller than the transaction size.
• “Long Position” — a buy position that profits from an increase in the underlying market price in CFD trading. In the case of currency pairs, this means buying the base currency against the quote currency.
• “Lot” — a unit of measure for the transaction volume, determined for each underlying asset in CFD trading.
• “Lot Size” — the number of underlying assets contained in one lot in CFD trading.
• “Margin” — the funds required to open or maintain open positions in CFD trading.
• “Margin Call” — a situation where the Company notifies the Client that their margin is insufficient to open new orders or to maintain already open positions.
• “Margin Level” — the percentage ratio between equity and the required margin in CFD trading, calculated by the formula: Margin Level = (Equity / Required Margin) x 100%.
• “Margin Trading” — trading with leverage, where the Client can execute transactions with a smaller amount of their own funds compared to the total transaction amount in CFD trading.
• “Required Margin” — the minimum margin required by the Company to maintain open positions in CFD trading.
• “Normal Market Size” — the maximum number of units of the underlying asset that the Company passes for execution in CFD trading.
• “Open Position” — a position that has not yet been closed; it can be either long or short. In the context of CFD trading, it is a position that is not a completed transaction.
• “Order” — the Client’s instruction to buy or sell financial instruments.
• “Order Level” — the price specified in the order during CFD trading.
• “Parties” — the participants in this Agreement: the Company and the Client.
• “Client’s Cabinet” — a personalized Client page on the Company’s website.
• “Politically Exposed Persons” — are:

A. Individuals who hold or have held within the last 12 months prominent public functions in any country, such as: heads of states or governments, ministers and their deputies, members of parliaments, judges of supreme or constitutional courts, members of audit chambers or boards of central banks, ambassadors, senior officers of the armed forces, and heads of state-owned enterprises. Middle or junior level positions are not included in this category.

B. Immediate family members of such persons, including: spouses, partners (equivalent to spouses according to national law), children and their spouses or partners, as well as parents.

C. Persons known to be close business partners of such individuals, including: those who have joint beneficial ownership of legal entities or structures, or who have other close business relations with the mentioned persons; or persons who are the sole beneficial owners of legal entities established for the benefit of the mentioned individuals.

• “Price Gap” — a situation where the difference between the current and previous price exceeds the minimum price movement of the asset.
• “Quote” — information on the current price of the underlying asset, expressed as bid and ask prices.
• “Quote Currency” — the second currency in a currency pair, which can be bought or sold by the Client for the base currency.
• “Quote Base” — information about the quote stream stored on the server during CFD trading.
• “Quote Stream” — a continuous flow of price quotes displayed on the Trading Platform for each CFD.
• “Relevant Amount(s)” — any free amount on the Client’s account that is not used for margin purposes.
• “Server” — the server-side software of the trading platform used to process Client orders, instructions, and requests, and to provide real-time trading information (to the extent determined by the Company). The server manages the execution of trades and the interaction between the Client and the Company, including web and mobile traders.
• “Services” — the services provided by the Company to the Client in accordance with clause 4 PART A of this Agreement.
• “Short Position” — a sell position that profits from a decrease in the price of the underlying market in CFD trading. For example, in currency pairs, this means selling the base currency against the quote currency. A short position is the opposite of a long position.
• “Slippage”:

A. This is the difference between the expected price at the time of concluding a CFD transaction and the actual price at which the trade was executed. Slippage often occurs in conditions of high volatility (e.g., during news releases) when executing an order at a specified price becomes impossible using market orders, as well as in large trades where there is insufficient interest at the chosen price level to maintain the expected price.

B. This is a parameter of the trading advisor that determines the allowable deviation between the requested price and the quote that the Company can provide upon request from the trading advisor.

• “Social Trading” — a service offered by the Company through its website and/or mobile application, allowing Clients to either become Investors who copy the strategies of Strategy Providers or become Strategy Providers who create their own investment strategies and attract Investors to follow them.

• “Social Trading Period” — a period that begins when the Strategy is created and ends on the last Friday of the current calendar month at 23:59:59 UTC+0.
• “Spread” — the difference between the bid (buy) and ask (sell) prices.
• “Strategy” — an account opened by a Strategy Provider to execute a series of trades within Social Trading, available for Investors to copy and invest in.
• “Strategy Executor” — a Client who uses the Social Trading service by creating a strategy in accordance with the Company’s rules and following the strategy opening procedures.
• “Swap or Rollover” — the interest credited or debited for holding an open position overnight in CFD trading.
• “Trading Commission” — the fee charged by the Company for providing the service.
• “Trading Platform” — the Company’s internet trading system, which includes a set of hardware, software, databases, and telecommunications tools that provide access to real-time quotes. The platform allows the Client to access real-time market information, conduct technical analysis, execute trades, place and remove orders, receive notifications from the Company, as well as manage trade records and calculate mutual obligations between the Client and the Company. The Trading Platform includes the Server and the Client Terminal.
• “Trailing Stop” — a type of stop-loss order set at a certain percentage below the current market price for a long position in CFD trading. The trailing stop price is automatically adjusted depending on market price movement. A sell trailing stop order sets the stop price at a level that is a certain value below the market price, adding the “trailing” amount. As the market price rises, the stop price increases by the same amount, but if the price starts to fall, the stop price remains unchanged, and the sell order is executed once the stop price is reached.
• “Trade” — any operation with CFDs performed on behalf of the Client in accordance with the terms of this Agreement.
• “Trade Size” — the lot size multiplied by the number of lots used in CFD trading.
• “Underlying Asset” — the asset underlying the CFD. It may include currency pairs, metals, futures, commodities, or other assets that the Company may choose according to its policy.
• “Underlying Market” — the market where the Underlying Asset of a CFD is traded.
• https://grandeclub.com or any other website the Company may use and maintain at its discretion from time to time.
• “Written Notification” — any message or notice sent via the internal mail of the Trading Platform, email, fax, postal service, courier service, airmail, or via the Company’s website.
• 2.2. In this Agreement, words in the singular include the plural and vice versa; words in the masculine gender include the feminine and vice versa, and terms referring to individuals extend to corporations, partnerships, other unincorporated entities, and legal entities, and vice versa.
• 2.3. The headings in this Agreement are provided solely for reading convenience and do not affect the meaning or interpretation of the text.
• 2.4. Any reference in this Agreement to laws, regulations, or acts includes such laws, regulations, or acts with their amendments, modifications, additions, consolidations, or re-enactments, as well as any related guidelines, directives, rules, or orders adopted pursuant to such laws.

3. Client Acceptance and Commencement of Work

3.1 The Company cannot register the Client and open an account until the Client provides a fully completed Account Opening Application Form along with the necessary documents confirming their identity. It is also required that all internal checks of the Company, including anti-money laundering procedures, compliance checks, and identification procedures, have been successfully completed. The Company reserves the right to request additional documentation and/or information from the Client during further business relations if this is required for ongoing monitoring of their activity. Moreover, the Company may impose additional verification requirements for Clients from certain countries.

The Client is entitled to deposit up to 2000 euros and start trading subject to the terms published on the Company’s website regarding the provision of Services. Within 45 calendar days from the date of the first deposit, the Client is required to provide all necessary documents for identity verification. If the Client fails to meet the identification document submission requirements within the specified timeframe, the Company may return the deposited funds to their country of origin, impose restrictions on the Client’s account such as banning further deposits, or terminate the business relationship with the Client entirely and close their account.

4. Services

4.1 Subject to the Client fulfilling all obligations under this Agreement, the Company may, at its discretion, provide the following Services to the Client:

A. Receive and transmit the Client’s orders for CFD trading.

B. Execute the Client’s orders on CFDs.

C. Provide custody and management of financial instruments on behalf of the Client (if applicable), including custodial services and related operations such as cash or collateral management.

D. Provide currency services if they are related to the receipt and transmission of funds as stipulated in sections 4.1 (A) and (B) of this Client Agreement.

5. Advice and Information Provision

5.1 The Company does not provide the Client with investment advice regarding the merits of any specific transaction or other investment recommendations. The Client understands and acknowledges that the provided services do not include investment advice on CFDs or the underlying markets. The Client makes decisions about transactions independently, based on their own judgment. By approaching the Company to execute a trade, the Client confirms that they are fully responsible for conducting their independent assessment and analysis of the risks associated with each trade. The Client declares that they have the necessary knowledge, experience, and professional qualifications to independently evaluate all benefits and risks of transactions. The Company does not guarantee the suitability of the products traded under this Agreement and does not assume fiduciary responsibility to the Client.

5.2 The Company is not obliged to provide legal, tax, or other advice related to any transaction. The Client is advised to consult independent experts if they have questions regarding tax obligations. The Client is informed that tax laws may change over time.

5.3 From time to time, the Company may, at its discretion, provide the Client with information, recommendations, news, market commentary, or other information (e.g., via newsletters on the website, through the trading platform, or other means), but this is not part of the services provided. In this case:

A. The Company is not responsible for the information provided;

B. The Company does not guarantee the accuracy, completeness, or timeliness of such information, nor does it assume liability for tax or legal consequences of transactions related to it;

C. The information is provided solely to enable the Client to make their own investment decisions and is not investment advice or a recommendation;

D. If the information is restricted to certain categories of individuals, the Client agrees not to distribute it to individuals subject to such restrictions;

E. The Client acknowledges that the Company may have used the information before providing it to the Client, and that the timing of receipt of such information may vary for different clients.

5.4 The Company reserves the right to amend or withdraw any market commentary, news, or other information provided at any time without prior notice.

6. Costs, Fees, and Taxes

6.3 The Company has the right to periodically change its costs. The Client will be informed of these changes in writing before they take effect. The changes will come into force on the date specified in the notice. The Company will attempt to notify the Client at least seven (7) business days before the changes take effect, and the Client will have the right to terminate the agreement immediately. If the changes are due to adjustments in interest rates, changes in the tax regime, or other valid reasons, the Company may implement changes without prior notice, provided that the Client is informed as soon as possible and also given the right to terminate the agreement immediately.

6.4 The Company may pay or receive fees, commissions, or other non-monetary benefits from third parties in connection with the provision of services to the Client, provided that this complies with Applicable Regulations. The Company undertakes to provide the Client with information about such benefits in accordance with the current legislation.

6.5 The Company does not act as a tax agent for the Client. The Client is solely responsible for preparing all necessary documents, tax reports, and declarations related to any transaction, as well as for paying all taxes (including, but not limited to, transfer taxes or value-added tax) arising from these transactions.

6.6 The Client agrees to cover all costs associated with the execution of this Agreement and any other documentation required for transactions under this Agreement.

6.7 The Company charges fees for deposits/withdrawals and for executing transactions. A fee may be charged upon opening or closing trades.

6.8 The Company has the right to increase the amount of commissions by notifying the Client seven (7) business days before the changes take effect.

6.9 The fee for deposits and withdrawals depends on several factors, including the amount, transaction type, currency, and payment system, and is displayed in the Client’s personal account.

6.10 Trading commission rates for Market Maker account operations are listed on the official Company website in the “Contract Specifications” section.

6.11 For interbank accounts, the Company is entitled to:

• A. Adjust the best available market prices to include its own commission;
• B. Display the amount of commission in a separate field in the Client terminal when placing an order.

7. Messages and Written Notices

GRANDE CLUB LTD

Postal Address: 

Phone: +44 (208) 00-28-722

Email: [email protected]

7.2 The Company may use any of the following methods to communicate with the Client:

• Internal mail of the Trading Platform;
• Email;
• Facsimile transmission;
• Telephone;
• Mail;
• Commercial courier service;
• Airmail;
• Company website;
• Client’s Cabinet.

7.3 Any messages sent to the Client (including documents, notices, confirmations, reports, etc.) are considered received in the following cases:

• When sent via the internal mail of the Trading Platform — immediately after being sent;
• When sent via email — one hour after sending;
• When sent via fax — upon the sender receiving a confirmation of delivery, provided the message was sent during business hours at the destination;
• When sent via telephone — upon completion of the telephone conversation;
• When sent by mail — seven calendar days after sending;
• When sent via commercial courier service — on the day of receipt and signature of the relevant notification;
• When sent via airmail — five business days after the date of dispatch;
• When posted on the company’s website — one hour after publication;
• When posted in the Client’s Cabinet — immediately after posting.

7.4 The Company will use the Client’s contact details provided during account opening or updated later for communication. The Client undertakes to promptly notify the Company of any changes to their contact information.

7.5 Facsimile documents received by the Company may be digitized, and reproduction of such scanned versions will be considered irrefutable evidence of the data in the facsimile instructions.

7.6 Telephone conversations between the Client and the Company may be recorded, and such recordings will be the exclusive property of the Company. The Client agrees that such recordings may be used as irrefutable evidence of any Orders, Instructions, or Requests made during the conversation.

7.7 The Client agrees that the Company may, in order to fulfill the terms of this Agreement, contact them from time to time by any of the methods listed in section 7.2 PART A of this Client Agreement.

8. Confidentiality, Personal Data, Records

8.1 The Company may collect information about the Client both directly (e.g., through the Account Opening Application) and from third-party sources, such as credit agencies, fraud prevention services, third-party authentication providers, other financial institutions, and registries.

8.2 Information about the Client held by the Company will be considered confidential and used exclusively for purposes related to the provision, administration, and improvement of the Services, as well as for research, statistical analysis, and marketing activities, as outlined in section 8.3 PART A of this Client Agreement. Information that is already public or in the possession of the Company without an obligation of confidentiality will not be considered confidential.

8.3 The Client agrees that the Company has the right to disclose their information (including confidential records, card data, and personal information) in the following cases, when necessary and to the extent required:

• If required by law or court order;
• At the request of a regulatory authority supervising the Company, the Client, or their business partners, or in the jurisdiction where the Company operates;
• To relevant government authorities for the investigation or prevention of fraud, money laundering, or other illegal activities;
• To execution venues or third parties when necessary to carry out the Client’s Instructions and provide Services;
• To credit agencies, fraud prevention services, authentication providers, and other financial institutions for creditworthiness checks, fraud and money laundering prevention, as well as for Client identification and verification. These agencies may check the Client’s data against available databases and use them for verification of other companies. A record of the data search is retained by the Company;
• To the Company’s professional advisers, provided they comply with confidentiality obligations;
• To other service providers who process databases, manage email services, or provide similar services to assist the Company in collecting, storing, and using Client data and improving the provision of Services;
• To service providers for statistical analysis for the Company’s marketing purposes, with data being transmitted in aggregated form;
• To marketing call centers for conducting surveys by phone or email to improve service quality;
• For the protection or enforcement of the Company’s legal rights;
• At the Client’s request or with their consent;
• To the Company’s Affiliates;
• To successors or buyers of the Company, with five business days’ notice to the Client, as provided in section 19.2 PART A of this Client Agreement.

9. Amendments

9.1 The Company may update the Client’s account, Platform, or improve the services provided to the Client if it believes that such changes will benefit the Client, provided that the cost of services for the Client does not increase.

9.2 Unless otherwise stated in this Agreement (“Client Agreement”), the Company has the right to amend its terms at any time by providing the Client with written notice at least five business days before the changes take effect. Such changes will be effective from the date specified in the notice. The Client acknowledges that changes required by legislation or regulations may take effect immediately, if necessary.

9.3 Unless otherwise provided, the Company may amend any documents that form part of the Agreement, except for this document (“Client Agreement”), without prior notice to the Client.

10. Termination

10.1 Either party may terminate this Agreement by providing written notice to the other party five (5) business days before the proposed termination date.

10.2 The Company may terminate this Agreement with immediate effect and without prior notice if there is a valid reason, such as the Client’s failure to fulfill their obligations as outlined in clause 11.1 of Part A of this Client Agreement.

10.3 Termination of the Agreement by either party does not cancel obligations related to already open positions, nor does it affect any legal rights or obligations that may have arisen under the Agreement or related transactions and operations of deposits/withdrawals.

10.4 Upon termination of the Agreement, all amounts owed by the Client to the Company become immediately payable, including (but not limited to):

• All outstanding costs and other amounts payable to the Company;
• Any expenses incurred by the Company in connection with the termination of the Agreement and the transfer of the Client’s assets to another investment company;
• Any losses and expenses related to the conclusion of transactions or settlement of unfulfilled obligations on behalf of the Client;
• All fees and additional costs incurred by the Company as a result of the termination of the Agreement;
• Any losses incurred in settling the Client’s unfulfilled obligations.

10.5 After sending a notice of termination or at the time of termination, the following provisions will apply:

• The Client is required to close all their open positions; otherwise, the Company will close them at the current market prices;
• The Company has the right to limit or terminate the Client’s access to the Trading Platform;
• The Company may refuse to allow the Client to open new positions;
• The Company may prohibit the Client from withdrawing funds from their account, withholding the amount necessary to close positions and fulfill the obligations under the Agreement.

10.6 After the termination of the Agreement, the following measures may be applied:

• The Company may consolidate all of the Client’s accounts, consolidate balances, and offset them against the Client’s obligations to the Company;
• The Company has the right to close the Client’s accounts;
• The Company may convert any currency in the Client’s accounts;
• The Company has the right to close the Client’s open positions at current market prices;
• If there are no suspicions of illegal activity or prohibitive instructions from authorities, and if there is a positive Balance on the Client’s accounts, the Company will pay out this Balance within a reasonable time after withholding necessary amounts to cover the Client’s future obligations. The payout will be made to the account specified by the Client, with the Company reserving the right to refuse payments to third parties.

11. Default Events

11.1 Any of the following events shall be considered a “Default Event”:

• The Client’s failure to provide initial margin, hedged margin, or other amounts due under the Agreement;
• The Client’s failure to fulfill any obligation to the Company, including but not limited to the provision of identification documents or other information requested by the Company;
• A bankruptcy petition is filed against the Client under the laws of Seychelles or similar laws in another jurisdiction (if the Client is an individual), or if a manager, trustee, administrator, or similar person is appointed for the Client’s company or partnership, or if the Client enters into an agreement with creditors, or a similar procedure begins;
• The Client’s inability to pay their debts when due;
• In the case of the Client’s death, declaration of disappearance, or recognition of incapacity (if the Client is an individual);
• If any statement or warranty made by the Client under clause 14 of PART A of this Agreement is found to be false;
• Any other circumstances where the Company reasonably believes it necessary or appropriate to take actions outlined in clause 11.2 of PART A of this Agreement;
• A competent regulatory authority, other authorities, or a court requires the action specified in clause 11.2 of PART A of this Agreement;
• The Client involves the Company in fraud or illegal activities or creates a risk of the Company being involved in such activities, as determined by the Company in good faith;
• A material breach of Seychelles or other countries’ laws by the Client, as reasonably determined by the Company in good faith;
• The Company suspects that the Client is involved in money laundering, terrorism financing, or other illegal activities, or that the Client’s actions may result in the Company’s involvement in illegal activities or actions considered suspicious by the Company.

11.2 In the event of a Default Event, the Company may, at its discretion and without prior written notice, take one or more of the following actions:

• Temporarily block the Client’s account and/or the accounts of other Clients who, in the Company’s opinion, may be involved in suspicious activity until the investigation is completed. The Company may request documents from the Client, and the Client is required to provide them;
• Consolidate any of the Client’s accounts, consolidate balances, and offset them against the Client’s obligations to the Company;
• Close the Client’s accounts;
• Convert the currency in the Client’s accounts;
• Close the Client’s open positions at current market prices;
• Terminate this Agreement without prior notice to the Client.

12. Force Majeure

12.1 A Force Majeure event includes, but is not limited to, the following:

A. Government actions, commencement or threat of war, acts of terrorism, states of emergency, riots, civil unrest, sabotage, requisition, or other international disasters, economic or political crises that, in the Company’s opinion, hinder maintaining a stable market for one or more Financial Instruments traded on the Platform;

B. Natural disasters such as earthquakes, tsunamis, hurricanes, typhoons, accidents, storms, floods, fires, epidemics, or other natural catastrophes that make it impossible for the Company to provide its Services;

C. Labor disputes and lockouts affecting the Company’s operations;

D. Suspension of trading on the market, establishment of minimum or maximum prices, regulatory prohibitions, decisions by governmental or self-regulatory organizations;

E. A moratorium on the provision of financial services imposed by regulatory authorities or any other acts of governmental or supranational bodies;

F. Failures, malfunctions, or breakdowns of electronic systems, network and communication lines (if not caused by the Company’s intentional actions or negligence), as well as DDoS attacks;

G. Any events or circumstances beyond the reasonable control of the Company, the consequences of which prevent the Company from taking measures to rectify;

H. Suspension, liquidation, or closure of the market, refusal or cancellation of a quote-related event, or imposition of trading restrictions;

I. Excessive price movements on any trades and/or underlying assets or the anticipation of such movements;

J. Failure by third parties, such as liquidity providers, brokers, banks, custodians, exchanges, or clearing houses, to fulfill their obligations.

12.2 If the Company recognizes the existence of Force Majeure circumstances, it may, without prior notice and at any time, take one or more of the following actions:

A. Increase margin requirements;

B. Close any open positions at prices the Company deems fair;

C. Refuse to accept new orders;

D. Suspend or modify the execution of any terms of the Agreement to the extent necessary due to Force Majeure circumstances;

E. Take or refrain from taking any actions the Company deems reasonable under the circumstances;

F. Increase spreads and/or trading commissions;

G. Reduce leverage;

H. Disable the Platform for maintenance or to prevent damage;

I. Deactivate the Client’s account.

12.3 Except as expressly provided in this Agreement, the Company shall not be liable for any losses or damages resulting from delays, interruptions, or failures in fulfilling its obligations caused by Force Majeure events.

13. Liability Limitations and Indemnification

13.1 If the Company provides the Client with information, recommendations, news, trade data, market commentary, or research (including newsletters posted on the website or sent to subscribers), the Company shall not be liable for any losses, costs, expenses, or damages that the Client may incur due to errors or inaccuracies in such information. Despite the Company’s right to cancel or close a trade under certain conditions outlined in the Agreement, any trade concluded after such an error remains valid and binding for both parties.

13.2 The Company shall not be liable for any losses, damages, costs, or losses incurred by the Client as a result of or directly or indirectly caused by the following circumstances, including but not limited to:

A. Any error or malfunction in the Trading Platform;

B. Errors in the settings of the Client terminal, delays in updates, malfunctions, or failure to follow the Client’s instructions;

C. Hardware or software failures or connection issues on the Client’s side;

D. Any orders placed using the Client’s access data;

E. Failure by the Company to fulfill obligations due to Force Majeure circumstances;

F. Actions, omissions, or negligence of third parties;

G. Insolvency or inaction of third parties, as mentioned in clause 1.6 of PART B of this Agreement;

H. Situations described in clause 1.7 of PART B of this Agreement;

I. Use of the Client’s access data by third parties before the Client has notified the Company of unauthorized use;

J. Unauthorized access to information, including electronic messages, personal data, and access data transmitted via the Internet or other communication means;

K. Actions or statements made by a Representative;

L. Currency risk;

M. Slippage;

N. The realization of risks described in the “Risk and Warning Notice” on the Company’s website;

O. Changes in tax rates;

P. The Client’s use of trailing stops or advisors;

Q. The Client’s reliance on stop-loss orders;

R. Any actions or transactions carried out by the Client under the Agreement.

13.3 If the Company incurs any claims, losses, costs, or expenses related to the execution of the Agreement and/or the provision of Services and/or any order, the Company shall not be liable, and the Client agrees to indemnify the Company for such losses.

13.4 Under no circumstances shall the Company be liable to the Client for indirect, special, or consequential damages, lost profits, or opportunities (including market fluctuations), costs, or expenses arising from this Agreement.

14. Representations and Warranties

14.1 The Client represents and warrants to the Company the following:

A. All information provided by the Client in the Account Opening Application and any information submitted later is true, accurate, and complete. All documents submitted by the Client are valid and authentic, and the Client agrees to notify the Company of any changes;

B. The Client has reviewed the terms of this Client Agreement as well as the documents posted on the Company’s website, such as the “General Terms of Business,” “Partnership Agreement,” “Risk and Warning Notice,” “Client Complaint Procedure,” and, if applicable, the “Partnership Agreement,” and agrees to comply with them;

C. The Client has the authority to enter into this Agreement, issue Orders, Instructions, and Requests, and fulfill their obligations under this Agreement;

D. The Client is acting as a principal and not as an agent, representative, or trustee for another person. The Client may act on behalf of another person only with the Company’s written consent and upon providing all required documents;

• D. The Client is an individual who has completed the Account Opening Application, or, if the Client is a company, the person completing the Application is duly authorized to do so;
• E. Any actions taken under the Agreement will not violate any laws or regulations applicable to the Client, nor will they conflict with any agreements the Client is bound by or that concern their assets;
• F. The Client has indicated in the Account Opening Application whether they are a politically exposed person and agrees to notify the Company if they become such a person during the term of the Agreement;
• G. The Client’s funds are not related to any illegal activities and are not intended for financing terrorism;
• H. The Client’s funds are not subject to any liens, obligations, or other restrictions;
• I. The Client has chosen the specific type of Service and Financial Instrument considering their financial circumstances, which they deem reasonable;
• J. There are no restrictions on the markets or financial instruments the Client can trade in due to their nationality or religion;
• K. The Client will consider any information from the Company’s promotional materials only in conjunction with the full description of the advertised services or promotions available on the Company’s website;
• L. The Client is at least 18 years old.

15. Client’s Acknowledgment and Acceptance of Risks

15.1 The Client unconditionally acknowledges and accepts the following provisions:

A. Trading in CFDs is not suitable for everyone, and the Client is aware of the high risk of incurring losses as a result of CFD trading. The Client accepts this risk and declares their readiness to bear responsibility for possible losses, including the loss of all funds and any additional fees and expenses to maintain open positions.

B. CFDs are associated with a high level of risk. The use of leverage means that a small deposit can lead to significant profits as well as substantial losses. Small price changes can lead to disproportionately large changes in the value of the Client’s investments, which may work both in their favor and against them.

C. CFD transactions involve contingent liability, and the Client must understand the implications, particularly with regard to margin requirements.

D. Trading on an electronic trading platform carries certain risks.

E. The Client is familiar with the risks and warnings contained in the “Risk and Warning Notice” document available on the Company’s website.

15.2 The Client acknowledges and understands that:

A. They are not entitled to delivery or ownership of the Underlying Asset of the CFD, nor do they have any ownership rights or other interests in it.

B. No interest is accrued on the funds held in the Client’s account with the Company.

C. Trading in CFDs is conducted on the over-the-counter (OTC) market and not on a regulated exchange, and the Client trades based on the price movement of the Underlying Asset.

15.3 The Client agrees that information under the Agreement will be provided through the Company’s website.

15.4 The Client confirms that they have constant access to the Internet and agree to receive information from the Company (including changes to terms, rates, fees, this Agreement, and Policies, as well as risk information) by posting such information on the website.

16. Applicable and Governing Law and Regulations

16.1 All disputes and disagreements arising from or in connection with this Agreement shall be resolved by the courts of Seychelles.

16.2 This Agreement is governed by the laws of Seychelles.

16.3 In providing services to the Client, the Company has the right to take any measures it deems necessary to ensure compliance with market rules and relevant laws.

16.4 All operations on behalf of the Client are subject to applicable regulations. The Company may take any measures necessary to ensure compliance with such regulations, and the Client agrees to comply with them.

16.5 The Client may submit claims in accordance with the “Client Complaint Procedure” available on the Company’s website.

17. Non-Waiver of Rights

17.1 The Company’s failure to seek compensation for a breach or its unwillingness to strictly enforce any provision of the Agreement, or its failure to exercise any right or remedy to which it is entitled under the Agreement, does not imply a waiver of those rights or remedies.

18. Assignment of Rights

18.1 The Company has the right to sell, transfer, or assign any of its rights, benefits, or obligations under this Agreement to a third party at any time, by providing written notice to the Client at least five (5) business days in advance. This may occur in the event of a merger, acquisition, reorganization, liquidation, sale, or transfer of all or part of the Company’s business or assets.

18.2 In the case of a transfer or assignment as mentioned in clause 18.1, the Company has the right to transfer all Client information (including personal data, records, correspondence, documents, and files related to Client verification), as well as the Client’s account and funds, to the third party, by providing written notice to the Client five (5) business days in advance.

18.3 The Client has no right to assign their rights or obligations under the Agreement without the prior written consent of the Company.

19. Language

19.1 The official language of the Company is English. The Client should always refer to the main website for the most up-to-date information about the Company. Translations into other languages are provided for informational purposes only and have no legal force. The Company is not responsible for any errors in translations.

20. Representative

20.1 If the Client interacts with the Company through a third party (Representative), the Client acknowledges that the Company is not responsible for the actions or statements of the Representative and is not bound by any separate agreements between the Client and the Representative.

20.2 The Client acknowledges that their agreement with the Representative may incur additional costs, as the Company may be obligated to pay commissions or fees to the Representative.

21. Identification

21.1 To prevent unauthorized access to the Client’s account, identity verification is conducted during non-trading operations such as:

A. Withdrawal requests;

B. Changes in leverage;

C. Changes in access data, etc.

21.2 The identification methods used by the Company (e.g., via email or SMS) are governed by the “General Terms of Business” available on the Company’s website.

21.3 The Company has the right to suspend the execution of non-trading operations if the Client’s identification data is incorrect until the Client provides the correct data.

22. Currency Conversion

22.1 The Company has the right to perform any currency conversions it deems necessary or appropriate without prior notice to the Client in order to credit funds to the Client’s account in the account’s currency (if the Client deposits funds in a different currency) or to fulfill its obligations and exercise its rights under this Agreement, as well as to complete any transaction or order. The conversion will be made at reasonable exchange rates selected by the Company based on current market conditions. The Company has the right to deduct from the Client or the Client’s account any expenses related to currency conversion, including bank fees, transfer charges, and intermediary commissions.

22.2 The Client bears all risks associated with currency exchange that may arise from any transaction or the Company’s execution of its rights under the Agreement or the law.

23. Miscellaneous Provisions

23.1 All rights and remedies provided to the Company under this Agreement are cumulative and do not exclude other rights and remedies provided by law.

23.2 If the Client is represented by two or more individuals, their liability under the Agreement is joint and several. Any notice sent to one of these individuals shall be deemed to have been sent to all individuals constituting the Client. Any instruction given by one of these individuals shall be considered valid on behalf of all participants.

23.3 In the event of the death or incapacity of one of the individuals constituting the Client, all assets held by the Company or its Nominee Representative shall be managed by the surviving individuals, who will be responsible to the Company for all obligations under the Agreement.

Part B: Client Funds and Account

1. Client Funds

1.1 The Company is not required to account to the Client for interest or profit earned on the Client’s funds (except for profit earned as a result of trading operations on the Client’s account under this Agreement), and the Client waives any rights to such interest.

1.2 The Company may place the Client’s funds in overnight deposits and retain any interest earned from such placements.

1.3 The Company may hold Client funds together with the funds of other clients in a single omnibus account.

1.4 The Company has the right to transfer the Client’s funds to third parties (e.g., intermediate brokers, banks, markets, settlement agents, clearing houses, or counterparties to OTC transactions) who may have a lien, right of retention, or right of set-off regarding these funds.

1.6 The third party to whom the Company transfers the Client’s funds may hold them in a pooled account, where segregation of funds may not be possible. In the event of the insolvency of such a third party or similar circumstances, the Company will have only an unsecured claim against this third party on behalf of the Client. The Client assumes the risk that the funds received from the third party may be insufficient to fully satisfy their claims. The Company is not responsible for any losses that may result from such situations.

1.7 Profits or losses from trading are credited to or debited from the Client’s account after the transaction is completed.

2. Lien

2.1 The Company has a general lien over all funds under its control, the control of its partners, or its Nominee Representatives on behalf of the Client until the Client’s obligations are fully satisfied. This right may extend to any legally enforceable claims, both current and future, arising from applicable laws, payment system rules, acquiring banks, payment service providers, or at the request of competent authorities.

3. Set-off and Netting

3.1 In the event that the total amount owed by the Client matches the total amount owed by the Company (taking into account any legally enforceable claims related to the Client arising from laws, payment system rules, acquiring banks, payment service providers, and regulatory bodies), mutual payment obligations shall be automatically set off and canceled.

3.2 If one party owes a larger amount than the other, taking into account all legally enforceable claims related to the Client (e.g., claims from payment systems or regulatory authorities), the party with the larger debt shall pay the difference to the other party, thereby fully satisfying and discharging all payment obligations.

3.3 The Company has the right to consolidate all or any of the Client’s accounts opened in their name and combine their balances for netting purposes in the event of the Agreement’s termination.

4. Client Account

4.2 The Company may offer different types of Client accounts with specific features, execution methods, and requirements. Detailed information about the account types is available on the Company’s website.

5. Temporary Blocking of Client Account

5.1 The Company may temporarily block the Client’s account without prior notice for any valid reason, including the following cases:

A. Upon the occurrence of a Client default event under clause 11.2(a) of PART A of this Client Agreement, for the period necessary for the Company to confirm the default;

B. Upon the Client’s request for temporary account blocking, in accordance with clause 5.5 of PART B of this Client Agreement;

C. If the Company receives credible information that the Client’s access data may have been compromised by unauthorized third parties;

D. If the Company receives reliable information about possible illegal activities or suspicious transactions by the Client, as indicated in clause 1.4 of the “General Terms of Business”;

E. In the event of Force Majeure circumstances and for the duration of such circumstances.

5.2 The Client’s account will be unblocked in the following cases, without prejudice to other rights of the Company:

A. If the Company determines that a default event has not occurred (if the account was blocked in accordance with clause 5.1(a) of PART B);

B. Upon the Client’s request to unblock the account (if the block was applied under clause 5.1(b));

C. If the security of the Access Data is restored or new Access Data is issued to the Client (if the account was blocked under clause 5.1(c));

D. When Force Majeure circumstances no longer exist (if the account was blocked under clause 5.1(e)).

5.3 During the account blocking period, the Company will investigate the circumstances, after which the account may either be unblocked or closed.

5.4 In the event of account closure, the Company has the right to retain funds based on the general lien right provided in clause 2 of PART B of this Client Agreement for as long as it deems necessary to cover any possible legally binding claims arising from laws, compliance rules, card schemes, acquiring bank requirements, payment service providers, or at the request of the relevant authorities.

5.5 The Client has the right to request temporary blocking of their account by sending an email to [email protected] or calling the Company and providing the account’s phone password. The Company will block the account within 24 hours of receiving the request.

5.6 To unblock an account that was blocked at the Client’s request, the Client must send an email to [email protected] or call the Company and provide the account’s phone password. The account will be unblocked within 24 hours of receiving the request.

6. Inactive and Dormant Client Accounts

6.1 If no trading or non-trading operations, including agency operations, have been carried out on a Client’s account with a balance of less than $5 (or the equivalent amount depending on the account’s currency) for 90 (ninety) calendar days, the account will be archived.

6.2 When a Client account is archived, all related transactions are also archived and cannot be restored. However, upon the Client’s request, the Company may provide a transaction history for the archived account.

6.3 If the Client’s account has transactions that are older than 35 (thirty-five) calendar days, they will be consolidated and deleted, and the total amount for such transactions will be credited to the Client’s account.

6.4 If a Client’s account remains inactive for four or more years, and after notifying the Client at their last known address, the Company reserves the right to close the account and mark it as dormant.

6.5 At the Client’s request, a previously archived account can be restored. The funds in the archived account remain available to the Client, and the Company is obligated to keep records of such funds and return them to the Client upon request at any time.

7. Deposits and Withdrawals to/from the Client’s Account

7.1 The Client has the right to deposit funds into their Account at any time during the term of this Agreement. Deposits can be made via bank transfer, debit/credit cards, or other methods the Company deems acceptable at that time. The Company does not accept payments from third parties or anonymous transfers to the Client’s Account.

7.3 The Company has the right to request documents from the Client at any time to verify the legality of the deposited funds. The Company reserves the right to reject a deposit if it is not confident in the legality of the funds’ origin.

7.6 In the case of a deposit by the Client, the Company credits the Client’s Account with the amount actually received into the Company’s bank account within one Business Day after the transaction is cleared.

7.8 The Company processes withdrawals after receiving the corresponding request from the Client, submitted through the Personal Account.

A. The withdrawal instruction must include all required details in the Personal Account;

B. The transfer is made to the sender’s account (whether it is a bank account, payment system account, etc.) from which the funds were originally deposited, or to the Client’s bank account in the case of a dispute;

C. The account for the transfer must belong to the Client;

D. At the time of the request, the Client’s free margin must exceed the withdrawal amount, including all payment fees;

E. No Force Majeure circumstances are preventing the transfer from being completed.

7.11 The Company reserves the right to reject a withdrawal request if the transfer method does not meet the requirements and may offer an alternative method.

7.12 The Client is responsible for all fees and charges related to fund transfers, which will be deducted from their account.

7.13 In the event of account closure, the remaining balance will be distributed proportionally to the accounts from which the deposit was made. Exceptions include cases of fraud involving bank cards or accounts, in which all funds will be returned to the legal owner of the card or account, regardless of the balance in the Company’s account. In such cases, information will be provided to the bank and law enforcement authorities.

7.14 If the account’s security type has been changed, withdrawals are only possible three business days after the change.

7.16 If more than 90 days have passed since the account was funded via a bank card and there have been no withdrawals during this period, funds can only be withdrawn to the Client’s bank account.

7.17 The Client may request a withdrawal through other payment systems, and the Company is obliged to send the funds to the specified bank account. The Company is not responsible for the time taken to complete the bank transfer.

7.18 The Client may request an internal transfer of funds to another trading account if the account supports the specified deposit/withdrawal method. Transfers are possible between accounts of the same or different types if the amount exceeds the minimum initial deposit.

7.19 All transfers between trading accounts are carried out in the account’s currency.

7.20 If an error in the transfer was made by a Company specialist, the amount will be returned to the Client at the Company’s expense.

7.21 In the event of an error in the transfer request made by the Client, the transfer amount will not be returned.

7.22 The Company reserves the right to reject an internal transfer without explanation.

Part C: Trading Platform

1. Technical Issues

1.1 The Client is fully responsible for providing and maintaining compatible equipment necessary to operate the Trading Platform, including a personal computer, Internet access, and a phone line or other means of communication. Internet access is a mandatory function, and the Client is fully responsible for all costs related to connectivity.

1.2 The Client confirms and guarantees that they have implemented appropriate security measures to protect their computer and data. They also agree to take all necessary measures to prevent threats such as viruses or malware that may damage the Company’s Website, Trading Platform, or other systems. The Client agrees to protect the Company from any unauthorized transmission of viruses or other harmful materials from their computer to the Company’s Trading Platform.

1.3 The Company is not responsible for any damage, loss, or malfunction of the Client’s computer system that may result in the destruction or corruption of data. If the Client encounters delays or data integrity issues due to the configuration of their equipment or its improper use, the Company is also not responsible.

1.4 The Company is not liable for any interruptions, delays, or communication problems that the Client may experience while using the Trading Platform.

2.1 The Client must not attempt to gain unauthorized access to the Trading Platform or attempt to reverse engineer or bypass any security measures implemented by the Company.

2.2 The Client agrees to use the Trading Platform solely for the benefit of their Client Account and not act on behalf of other persons.

2.3 The following actions are strictly prohibited:

A. Using software that applies artificial intelligence analysis to the Company’s systems or Trading Platform.

B. Intercepting, monitoring, altering, or damaging any communications not intended for the Client.

C. Using any types of malware, including viruses, worms, trojans, time bombs, or any other code designed to distort, delete, damage, or disassemble the Company’s system or Trading Platform.

G. Sending unsolicited commercial messages prohibited by applicable law or rules.

D. Performing actions that may compromise the integrity of the Company’s computer systems or the Trading Platform, leading to malfunctions.

E. Engaging in any actions that may result in unauthorized or abnormal access to the Trading Platform.

F. Using software, programs, applications, or other devices to automate access to or retrieve information through the Trading Platform.

G. Using the Trading Platform in violation of the terms of this Agreement.

2.4 Internet delays and pricing errors may sometimes cause the prices displayed on the Trading Platform to differ from actual market rates due to connection delays, market events, or abnormal trading conditions. Trading strategies aimed at exploiting such price errors or non-market quotes are not permitted. If the Company reasonably believes that the Client has intentionally or systematically exploited such errors or non-market prices, the Company may take the following actions:

A. Restrict or block the Client’s access to the Trading Platform;

B. Immediately terminate this Agreement;

C. Close the Client’s account;

D. Seek legal action to recover any damages incurred by the Company.

3. Access Data Security

3.1 The Client receives access to their account credentials for placing orders and performing non-trading operations. The Client agrees to keep their Access Data confidential and not to disclose it to third parties.

3.2 The Client has the ability to change their Access Data through the Personal Account, except for the username, email address, phone number, and phone password.

3.3 The Client must not record their Access Data. If received in written form, the Client must promptly destroy the notification containing such information.

3.4 The Client must immediately notify the Company if they become aware or suspect that their Access Data has been disclosed or may have been disclosed to unauthorized persons. In this case, the Company will take measures to prevent further use of such data and issue new Access Data to the Client. The Client will not be able to carry out trading or non-trading operations until the new data is received.

3.5 The Client agrees to cooperate with the Company in any investigations regarding the misuse or suspected misuse of their Access Data.

3.7 The Client agrees that any operations carried out through the Trading Platform or Personal Account using their Access Data are considered valid and binding on the Client.

4. Intellectual Property

4.1 This Agreement does not transfer ownership of the Trading Platform to the Client but grants only the right to use it under the conditions set forth in this Agreement.

4.2 Nothing in this Agreement implies a waiver of the Company’s or third-party rights to intellectual property.

4.3 The Client has the right to save, view, analyze, modify, reformat, and print information provided through the Website or Trading Platform. However, the Client is prohibited from publishing, transmitting, or reproducing this information in whole or in part in any format for third parties without the Company’s written permission. The Client must also not alter, delete, or obscure any copyright notices, trademarks, or other marks related to the provided information.

4.4 The Client is not permitted to reproduce, copy, duplicate, modify, repair, reverse-engineer, or resell any components of the Trading Platform.

Part D: Trading Terms

1. Execution

1.1 The Company’s trading procedures, including the types of orders and execution methods, are detailed in the “General Business Terms” document available on the Company’s website.

1.2 Depending on the type of Client Account, the Company may either act as a counterparty to the transaction and serve as the execution venue for the order or pass the order to a third party for execution (known as Straight Through Processing, STP), in which case the third party, not the Company, will be the execution venue.

1.3 Orders are placed through the Trading Platform using the Client’s Access Data from a personal computer connected to the Internet. The Company has the right to rely on any instructions submitted using this data without requiring further confirmation, and such instructions will be binding on the Client.

1.4 The Company is not obligated to monitor or notify the Client of the status of their trades or to close open positions unless otherwise provided in the Agreement. If the Company decides to take such actions, it will be done on a discretionary basis, and the Company is not obliged to continue such actions in the future. The Client is solely responsible for monitoring their positions.

2. Rejection of Client Orders, Requests, and Instructions

2.1 The Company has the right to reject or refuse to transmit or execute any Client order for CFDs for valid reasons, including but not limited to the following cases:

A. The order was placed before the first quote in the Trading Platform at the market opening;

B. Abnormal market conditions exist;

C. The Client submits an excessive number of requests compared to the number of completed trades;

D. The Client’s free margin is less than the amount required to execute the order, or the Client’s account lacks sufficient funds to cover all order costs;

E. The Company suspects the Client of involvement in money laundering, terrorist financing, or other illegal activities;

F. A request from regulatory or supervisory authorities or a court order;

G. Doubts about the legality or authenticity of the order;

H. The order lacks necessary details or is ambiguously formulated;

I. The trade size is below the minimum volume for the specified type of CFD, as outlined in the Contract Specification;

J. The quote was not received from the Company, is indicative, erroneous, or clearly incorrect (Spike);

K. Internet connection or communication issues;

L. Force majeure circumstances;

M. There is a presumed or actual default by the Client;

N. The Company has notified the Client of the termination of the Agreement;

O. The Client has not met the margin requirements;

P. The Client’s account is blocked, inactive, or closed.

3. Margin Requirements

3.1 The Client must deposit and maintain the initial or hedged margin in the amount specified by the Company at the time of opening the position.

3.2 The Client is responsible for understanding the calculations of margin requirements.

3.3 The Company has the right to change margin requirements, notifying the Client in advance, and may apply the new requirements to both new and already open positions.

3.4 Lower margin requirements for a specific financial instrument apply to all positions opened on that instrument.

3.5 The Company has the right to increase margin requirements before weekends or holidays. The Client will be notified of the period of increased requirements through the Personal Account.

3.6 Increased hedging reduces margin requirements for new locking orders.

3.7 Decreasing hedging is treated as opening a new position and leads to a proportional change in margin requirements for existing positions.

3.8 Information on margin requirements for different currency pairs is posted in the “Contract Specifications” section on the Company’s website. If the Client’s equity falls below the specified percentage of the required margin, the Company has the right to close any or all of the Client’s open positions without their consent or prior notice. Any amounts not expressed in the Client’s account currency will be converted at the market rate at the time of the transaction.

3.9 In the event of a Margin Call notification, the Client will not be able to open new positions except for hedging to reduce margin. If the Client fails to meet the Margin Call requirements, their positions will be closed, starting with the most unprofitable ones.

3.10 The Client must notify the Company if they are unable to meet the Margin Call payment by the due date.

3.11 All margin payments must be made in the Client’s account currency.

3.12 The Client agrees not to create or transfer any lien on the margin transferred to the Company and not to enter into any agreements on its assignment or transfer.

4. Trailing Stop, Advisor, and Stop-Loss Orders

4.1 The Client acknowledges that the use of such additional trading terminal functions as a trailing stop and/or advisor is done solely at their own risk. These functions directly depend on the performance of the Client’s trading terminal, and the Company is not responsible for their proper functioning.

4.2 The Client acknowledges that a stop-loss order does not always guarantee the limitation of losses at the planned level, as market conditions may prevent its execution at the specified price. The Company is not responsible for losses arising from such circumstances.

5. Trade Confirmation and Reporting

5.1 The Company provides the Client with access to their Client Account through the Trading Platform, where they can receive information on the status of orders, account status, balance, and confirmations of trades for each executed order.

5.2 Trade confirmations will be available on the Trading Platform until the back office closes on the next business day after the order execution.

5.3 If the Client believes that the received Confirmation is incorrect or has not received Confirmation for a trade that was executed, they must immediately contact the Company. Trade confirmations are considered final in the absence of an obvious error unless the Client notifies the Company in writing within two (2) business days of receiving the confirmation.

Part D: CFD Trading Conditions

1. CFD Order Execution

1.1 Orders can be placed, executed, and (if necessary) modified or deleted during the Trading Hours for each CFD specified on the Company’s Website, with possible changes made by the Company. If the order is not executed, it may remain active for the next trading session. All open spot positions are rolled over to the next business day after the base market closes, with the right of the Company to close an open position. Open forward positions will be extended upon expiration to the next period, also with the option for the Company to close them.

1.2 The Company is not obligated to execute Client orders during non-working hours specified on the Company’s website.

1.3 Orders are considered valid according to the time and type specified by the Client. If the order duration is not specified, it remains indefinite. However, the Company may delete all pending orders if the capital on the Client’s account reaches zero.

1.4 Orders cannot be changed or deleted if a trade confirmation has already been sent, they are in the process of being executed, or the market is closed. The Client also cannot modify or delete limit sell or take-profit orders if the price has reached the execution level.

1.5 The Client may change the validity period of pending orders.

2. Quotes

2.1 The Company’s quotes are based on the underlying asset price, but they are not required to exactly match the prices of that asset. When the underlying market is closed, the quotes provided by the Company will reflect the estimated current bid and ask price determined by the Company at its discretion.

2.2 Quotes on the client terminal are considered indicative, and slippage is possible.

2.3 If the Company is unable to execute the order at the specified price or size, it may offer the Client a re-quote with a new price for the potential conclusion of the deal.

2.4 The Company reserves the right to remove erroneous quotes (spikes) from its database.

3. Leverage

3.1 The Company may change the leverage on the Client’s account without prior notice, as described on the Company’s website.

3.2 A change in leverage, whether automatic according to the Company’s rules or initiated by the Client through the Personal Account, will result in the recalculation of margin requirements for all open positions.

3.3 The Company has the right to:

A. Set leverage no higher than 1:200 for 3 hours before market closure on weekends or holidays if the current leverage exceeds this value. This change will affect all trades opened during the specified period.

3.4 Information about changes in leverage is displayed in the Personal Account. In case of discrepancies between the information on the Website and in the Personal Account, the information in the Personal Account takes precedence.

4. Financing Fee

4.1 Some CFDs offered by the Company may include a daily financing fee. The financing fee for different types of CFDs is specified in the “Contract Specifications” section.

5. Swaps and Swap-Free Accounts

5.1 Swaps are calculated according to the Contract Specifications posted on the Company’s website. The Client can use the “Trader Calculator” on the website to calculate the swap cost for a specific trade.

5.2 Swap operations are carried out daily at 10:00 server time, except on Saturdays and Sundays. On Wednesday or Friday at 22:00 (depending on the underlying asset), a triple swap is added to or deducted from the Client’s account. Swap-Free accounts do not have such operations.

5.3 The Company offers Swap-Free accounts for CFD trading. The Company reserves the right to modify the underlying assets available for trading on swap-free accounts.

5.4 Not all account types may be converted to Swap-Free status. Only those Client accounts indicated on the website as Swap-Free are eligible for this status. The Company reserves the right to change the list of account types eligible for Swap-Free status.

5.5 Upon account opening, clients from Islamic countries may receive Swap-Free status. This is determined based on passport data or the phone number provided in the account opening application.

5.6 For Swap-Free accounts, there are no charges or swaps applied to trading positions held overnight. Information on any other fees for such accounts is listed in the “Contract Specifications” or on the Company’s website.

5.7 All terms of this Agreement apply to Swap-Free accounts, except for mentions of swaps.

5.8 Clients holding Swap-Free accounts cannot keep their positions open for an indefinite period to generate profit. In such cases, the Client must close their positions, and swaps may be applied retroactively. The Company reserves the right to cancel Swap-Free status on the Client’s account at its discretion.

6. Lots

6.1 The size of a standard lot is the unit designated for each CFD. The Company may offer different types of lots, including standard, micro, and mini-lots, at its discretion, as specified in the Contract Specifications or on the Company’s website.

PART E: Social Trading

1. Introduction

PART E applies exclusively to Clients using the “Social Trading” service.

2. Investor

2.1 By following a strategy provider, the Investor agrees to the following conditions:

3.1 To open a strategy, the Strategy Provider is required to:

A. Have an active trading account with the Company, which meets the requirements set by the Social Trading service;

B. Adhere to the procedures and conditions for opening and managing a strategy, as specified on the Company’s website or in the Social Trading service;

C. Accept the commission structure and leverage levels available to Investors who follow the strategy;

D. Ensure that the strategy complies with the applicable laws and Company policies;

E. Be aware that the strategy performance is available to the public through the Social Trading service on the website or mobile application.

3.2 The Strategy Provider must maintain a positive balance in the trading account associated with the strategy and meet the margin requirements established by the Company.

3.3 The Company reserves the right to terminate or suspend the strategy at any time, without prior notice to the Strategy Provider, in case of any violations or irregularities, as determined by the Company at its discretion.

3.4 The Strategy Provider agrees to accept the Company’s terms for calculating and distributing performance fees, including any changes made by the Company with prior notice.

3.5 The Strategy Provider is not allowed to perform the following actions:

• Engage in high-frequency trading with the sole intention of exploiting system flaws;
• Use price arbitrage techniques or delay orders to take advantage of time discrepancies;
• Misuse the system to manipulate the markets;
• Trade under abnormal market conditions.

3.6 The Strategy Provider may withdraw performance fees only after the end of the Social Trading Period and after confirmation from the Company that the performance meets the required standards.

3.7 The Company has the right to adjust the performance metrics of the Strategy Provider, including the removal of any profits that were obtained through illegal or unethical methods.

3.8 If the Strategy Provider fails to meet the obligations stated in the agreement, the Company may suspend or terminate the strategy and restrict access to the Social Trading service.

3.9 The Strategy Provider may modify the strategy settings, including risk levels and leverage, at any time, provided the changes are compliant with the Company’s terms and conditions. Investors will be notified of such changes through the Social Trading service.

4. Risk Disclosures

4.1 Social Trading involves significant risk, and Investors should be aware that past performance is not indicative of future results. Both Investors and Strategy Providers acknowledge and accept the risks associated with market fluctuations and other trading risks.

4.2 The Company does not provide any guarantees regarding the success or profitability of any strategy and is not responsible for losses incurred by Investors following any strategy.

4.3 The Company reserves the right to modify the terms of the Social Trading service, including the fee structure, risk management rules, and access rights, at any time with prior notice to Investors and Strategy Providers.

А. Create a name for the strategy;

Б. Describe the essence of the strategy;

В. Set the commission rate for Investors;

Г. Select the leverage for the strategy from the options provided by the Company;

Д. Choose the currency for the Strategy Provider account;

Е. Create a password for accessing the Strategy Provider account;

Ё. Fund the Strategy Provider account with the minimum amount required by the Company at the time of opening the strategy and maintain that balance;

Ж. Provide additional information upon the Company’s request.

3.2 The Company reserves the right to reject or modify the description or elements of the strategy if:

А. The strategy description does not comply with the Agreement, the Company’s regulations, contains illegal or unethical material, or provides false information;

Б. The strategy name is misleading, offensive, contains racist or religious references, violates ethical norms, or is otherwise unacceptable;

В. The image used for the strategy is inappropriate, misleading, offensive towards religion or race, or violates moral standards;

Г. There are insufficient funds in the Strategy Provider account to meet the minimum requirements;

Д. There are other reasons the Company considers the strategy or its elements to be unacceptable.

3.3 The Company has the discretion to close any open position of the Strategy Provider at any time.

3.4 The Strategy Provider acknowledges and agrees that they cannot deposit or withdraw funds from the Strategy Provider account if any positions remain open under the strategy.

3.5 In addition to the conditions outlined in section 11 of Part A of this Agreement, the following are considered “Events of Default” for the Strategy Provider:

А. The strategy consistently takes excessive risks for an extended period;

Б. The strategy description does not match the actual trading conditions;

В. The Strategy Provider engages in trading:

• Without a legitimate intention to profit but for speculative purposes based on market movements;
• By exploiting arbitrage opportunities or price delays;
• In activities considered market abuse;
• During abnormal market conditions.

3.6 In the event of a default, the Company may take one or more of the following actions:

А. Freeze, block, or terminate the Strategy Provider’s strategy and deny access to Social Trading;

Б. Request modifications to the strategy description.

3.7 The Strategy Provider’s commission is calculated and paid at the end of each Social Trading Period associated with each strategy.

3.8 The commission set by the Strategy Provider cannot exceed 50% of the Investor’s profit. Once the strategy is created, the commission cannot be changed.

3.9 The Strategy Provider’s commission is calculated and paid in U.S. dollars (USD) based on the profit generated for Investors. The calculation formula is: Strategy Provider’s Commission (USD) = Investment Profit × Commission, where:

• Investment Profit = Strategy Provider’s Profit × Copy Ratio;
• Commission — the percentage set by the Strategy Provider;
• Strategy Provider’s Profit — the profit generated from all orders during the social trading period;
• Copy Ratio = Investor’s Capital / Strategy Provider’s Capital.

3.10 If the Investor stops following the strategy before the end of the Social Trading Period, the Strategy Provider’s commission is calculated at the time of closure based on the market price.

4. Social Trading Risk Awareness and Consent

4.1 The Company provides no guarantees regarding the performance of any Strategy available under Social Trading.

4.2 Any descriptions or information concerning the Strategies are not considered confidential or personal data.

4.3 The Company reserves the right to close, suspend, or terminate the copying of any accounts, strategies, or orders belonging to an Investor or a Strategy Provider at any time, with or without notice.

4.4 The statistical data provided regarding Strategy Providers or Strategies is based on historical data, and the Company does not guarantee that the Investor will make a profit. Historical performance is not a reliable indicator of future returns. Investors are strongly encouraged to make decisions based on a thorough review of the actual history and performance of the chosen Strategy.

4.5 The Strategy Provider agrees that the Company may use, transfer, and process information about the strategy both within the Company’s group of companies and with external organizations and consultants.