Participation Agreement

Version 1.0 Effective: March 10, 2026
This Participation Agreement (the "Agreement") is entered into between ORYON TECH LIMITED, a company incorporated and existing under the laws of Hong Kong, operating the Bao Trader brand and platform (the "Company", "Bao Trader", "we", "us", or "our"), and the individual person who applies for, enrolls in, purchases, accesses, or participates in any Bao Trader Program (the "Participant", "Trader", "you", or "your").

Chapter 1 — Parties, Acceptance, and Contractual Scope

ORYON TECH LIMITED
Unit 1126, 11/F., Eton Tower
8 Hysan Avenue, Causeway Bay
Hong Kong

1.1 Purpose of this Agreement

This Agreement governs your participation in any Bao Trader evaluation program, simulated trading challenge, instant funded simulation program, tournament, performance-based reward program, or any other participation-based simulated trading service made available by the Company through its website, platform, or associated systems (collectively, the "Program").

1.2 Binding Acceptance

By clicking to accept, registering, purchasing, activating an account, accessing the Program, using any Program-related service, or otherwise participating in the Program, you acknowledge that:

  1. you have read and understood this Agreement;
  2. you agree to be legally bound by it;
  3. you enter into a binding contract with the Company; and
  4. you agree that electronic acceptance shall have the same legal force and effect as a handwritten signature.

If you do not agree to this Agreement, you must not purchase, access, activate, or participate in the Program.

1.3 Relationship with Other Documents

This Agreement shall be read together with the following documents, each of which forms part of the contractual framework between you and the Company:

  1. the Terms of Service;
  2. the Privacy Policy;
  3. any Program Rules, Account Rules, Payout Policy, Tournament Rules, or other product-specific rules published by the Company;
  4. any operational, compliance, or technical notices issued by the Company in connection with the Program.

To the extent of any conflict between the Terms of Service and this Agreement, this Agreement shall prevail with respect to the Program.

To the extent of any conflict between this Agreement and any product-specific rules expressly designated by the Company as supplementary Program Rules, the supplementary Program Rules shall prevail solely with respect to the specific product or account type to which they apply.

1.4 Nature of Contractual Relationship

Your participation in the Program creates a limited contractual relationship for access to:

  1. a simulated trading environment;
  2. trader evaluation services;
  3. educational tools, analytics, and performance monitoring features; and
  4. conditional eligibility for performance-based rewards, subject strictly to compliance with this Agreement and all applicable Program requirements.

For the avoidance of doubt, nothing in this Agreement shall be interpreted as creating any of the following relationships between you and the Company:

  1. employer and employee;
  2. principal and agent;
  3. partnership, joint venture, or fiduciary relationship;
  4. broker and client;
  5. investment manager and investor;
  6. trustee and beneficiary;
  7. financial adviser and client; or
  8. any regulated financial services relationship of any kind.

1.5 No Offer of Regulated Financial Services

The Program is offered strictly as a simulated trading evaluation, educational, and skill-assessment service.

The Company does not, under this Agreement or otherwise in connection with the Program:

  1. provide brokerage services;
  2. receive or execute orders in financial instruments on your behalf;
  3. provide investment advice, financial advice, or portfolio management;
  4. manage assets or funds for you;
  5. hold client money for trading purposes;
  6. offer deposit-taking, custody, or money transmission services; or
  7. operate an exchange, multilateral trading facility, or other regulated trading venue for your benefit.

1.6 No Promise of Funding, Employment, or Guaranteed Benefit

Your enrollment, purchase, participation, progression, or apparent success within the Program does not create or guarantee:

  1. any right to employment, engagement, or appointment by the Company;
  2. any right to manage real capital of the Company;
  3. any right to receive a payout, reward, or financial benefit unless and until such payout is expressly approved by the Company in accordance with this Agreement;
  4. any guaranteed access to future programs, accounts, or commercial opportunities.

1.7 Personal Participation Only

The Program is personal to the Participant and approved by the Company.

You may not:

  1. transfer your participation rights to another person;
  2. permit any third party to access or use your Program account;
  3. share login credentials, access devices, or verification credentials with another person;
  4. purchase or use an account on behalf of another person without the Company's prior written approval.

Any suspected delegation, outsourcing, pass-through use, nominee participation, account sharing, or third-party operation may result in immediate suspension or termination.

1.8 Company Discretion as to Admission and Continuation

The Company reserves the absolute right, at any time and in its sole discretion, to:

  1. accept or reject any applicant;
  2. limit access to any jurisdiction, region, product, account type, or Program feature;
  3. impose additional eligibility, KYC, compliance, technical, or behavioral conditions;
  4. suspend, restrict, review, or terminate participation where necessary for Program integrity, fraud prevention, compliance, operational security, or legal risk management.

No person has a right to be admitted to, remain in, or continue within the Program except as expressly permitted by the Company.

1.9 Business Purpose of Fees

Any fee paid by you in connection with the Program is paid solely for access to the simulated evaluation environment, related educational services, and Program administration.

No fee paid under this Agreement shall be construed as:

  1. an investment;
  2. a capital contribution;
  3. a managed account deposit;
  4. client money held for trading; or
  5. consideration paid in exchange for any guaranteed return.

1.10 Survival of Foundational Characterization

The provisions of this Chapter, including without limitation the clauses relating to the nature of the Program, absence of regulated financial services, absence of client funds, absence of fiduciary relationship, and absence of guaranteed benefit, shall survive suspension, termination, expiration, cancellation, dispute, or rescission of this Agreement to the fullest extent permitted by law.

Chapter 2 — Core Disclosures and Regulatory Positioning

2.1 Educational and Evaluation Nature of the Program

The Program is designed exclusively as a trader evaluation, simulation, and educational service.

The purpose of the Program is to provide Participants with access to a simulated trading environment through which their trading discipline, risk management, and strategy execution may be evaluated according to predetermined rules.

The Program does not constitute an investment service, trading service, or financial product.

Participation in the Program should be understood as participation in a skill-assessment and simulated market environment, not as participation in financial markets.

2.2 Simulated Trading Environment

All trading activity conducted within the Program takes place exclusively within a simulated trading environment.

Orders placed within the Platform:

Any trading balances, profits, losses, equity curves, or account values displayed within the Platform are purely hypothetical and simulated.

Such values exist solely for the purpose of evaluating Participant performance within the Program.

Simulated accounts do not represent:

2.3 No Live Market Access

Participants do not trade in live financial markets through the Platform.

The Company does not provide Participants with:

Participants acknowledge that no trade executed within the Program results in any real market transaction.

2.4 Hypothetical Performance Disclosure

Performance results displayed within the simulated environment are hypothetical.

Hypothetical performance has inherent limitations and should not be interpreted as indicative of real trading results.

Simulated trading results may differ significantly from real-world trading due to factors including but not limited to:

Accordingly, simulated trading performance should not be relied upon as a predictor of future performance in real financial markets.

2.5 No Investment Advice

Nothing within the Program, Platform, Content, or Services provided by the Company constitutes:

The Company does not recommend, endorse, or advise Participants regarding the purchase, sale, or holding of any financial instrument.

All trading decisions made by Participants within the simulated environment are made independently by the Participant.

2.6 No Client Funds or Deposits

The Company does not accept, hold, or manage funds from Participants for the purpose of trading.

Participants do not deposit funds for trading purposes.

Any payments made by Participants represent fees paid for access to the Program, including access to the simulated trading environment and related services.

Such fees are not:

Participants retain no financial claim over any simulated capital displayed within the Program.

2.7 Performance-Based Rewards

In certain circumstances, Participants who successfully complete program requirements may become eligible for performance-based rewards.

Performance rewards are:

Performance rewards do not represent:

Eligibility for any reward does not create a legal entitlement until such reward has been reviewed, approved, and authorized by the Company.

2.8 Internal Trade Mirroring

The Company may, at its sole discretion, internally replicate or mirror certain simulated trades using the Company's own capital.

Such activity, if undertaken, is performed solely for the Company's internal purposes.

Any mirroring conducted by the Company:

Participants have no right, claim, or entitlement to any results generated from such internal trading activity.

2.9 No Fiduciary Relationship

Nothing contained within the Program or this Agreement creates any fiduciary duty owed by the Company to the Participant.

The Company does not act as:

Participants acknowledge that the Company's role is limited to providing access to the Program and evaluating simulated trading performance according to established Program rules.

2.10 No Guarantee of Earnings

Participation in the Program does not guarantee:

Many Participants will not successfully complete the Program or qualify for performance rewards.

Participants should not rely on the Program as a source of income.

2.11 Participant Responsibility

Participants are solely responsible for:

The Company does not assume responsibility for any losses incurred by Participants in real-world trading conducted outside the Platform.

2.12 Acknowledgement of Disclosures

By participating in the Program, the Participant acknowledges and agrees that:

  1. All trading conducted within the Program occurs in a simulated environment.
  2. No real market transactions are executed through the Platform.
  3. The Company does not provide regulated financial services.
  4. The Program constitutes a simulated trading evaluation service.
  5. Any rewards are discretionary and subject to verification.

Participants further acknowledge that these disclosures constitute fundamental contractual representations forming the basis of this Agreement.

Chapter 3 — Definitions

For purposes of this Agreement, the following capitalized terms shall have the meanings set forth below. These definitions apply throughout this Agreement, the Program Rules, and any related documentation unless expressly stated otherwise.

3.1 Account

"Account" means the Participant's registered user account within the Company's Platform through which the Participant accesses the Program, simulated trading environment, trading dashboard, analytics tools, and any associated services. An Account may include one or more Program-specific trading environments, including but not limited to evaluation accounts, simulated funded accounts, or other program-related environments. Accounts are strictly personal to the Participant and may not be transferred, sold, shared, delegated, or otherwise made accessible to any third party.

3.2 Simulated Account

"Simulated Account" means any account within the Platform that operates using fictitious or simulated capital solely for the purpose of trading simulation and performance evaluation. Simulated Accounts do not represent real trading accounts; do not contain real funds; do not execute trades in real financial markets; and exist solely for simulation and evaluation purposes. All balances displayed within a Simulated Account are hypothetical.

3.3 Challenge Account

"Challenge Account" means a Simulated Account provided to a Participant for the purpose of evaluating the Participant's trading discipline, risk management, and adherence to Program rules. Challenge Accounts may require Participants to meet specific criteria, including but not limited to profit targets, drawdown limits, trading activity requirements, and time-based requirements. Completion of a Challenge Account does not guarantee advancement within the Program.

3.4 Instant Funded Account

"Instant Funded Account" means a Program structure in which Participants receive immediate access to a Simulated Account designated as eligible for potential Performance Rewards, subject to compliance with all Program rules. Instant Funded Accounts remain simulated accounts and do not represent real trading accounts or capital allocation.

3.5 Live Simulated Account

"Live Simulated Account" means a Simulated Account that has met Program requirements and has been designated by the Company as eligible for Performance Reward evaluation. The designation "Live" refers solely to eligibility for reward evaluation and does not indicate access to live financial markets.

3.6 Simulated Capital

"Simulated Capital" means the fictitious account balance displayed within any Simulated Account. Simulated Capital does not represent real money; does not belong to the Participant; cannot be withdrawn; and does not constitute a financial asset. Simulated Capital exists solely for the purpose of measuring trading performance within the Program.

3.7 Account Equity

"Account Equity" means the current simulated account value calculated as the total Simulated Capital balance including open and closed simulated profit and loss positions. Account Equity is used for the purpose of calculating drawdown limits, position risk, reward eligibility, and compliance with Program rules.

3.8 Trading Day

"Trading Day" means any calendar day during which the Participant executes at least one trade within the Simulated Account. Trading Days are used for the purpose of measuring minimum trading activity, consistency rules, and evaluation periods.

3.9 Drawdown

"Drawdown" means the decline in Account Equity from a previous peak equity level. The Program may include different types of drawdown rules, including but not limited to Maximum Relative Drawdown, Maximum Daily Drawdown, and Maximum Overall Drawdown. Violation of any drawdown limit constitutes a Program breach.

3.10 Maximum Relative Drawdown

"Maximum Relative Drawdown" means the maximum allowable reduction in Account Equity relative to the highest equity value previously achieved within the account. If the Account Equity falls below the permitted drawdown threshold, the account shall be considered breached.

3.11 Profit Target

"Profit Target" means the simulated profit threshold that must be achieved within a Challenge Account in order to qualify for advancement within the Program. Profit Targets are calculated based solely on simulated trading results within the Platform.

3.12 Eligible Profit

"Eligible Profit" means simulated profit generated within a Live Simulated Account that qualifies for consideration in determining Performance Rewards. Eligible Profit may be subject to Program rules, including but not limited to consistency rules, trading activity requirements, Risk Management Compliance, and anti-abuse controls. Not all simulated profit qualifies as Eligible Profit.

3.13 Performance Reward

"Performance Reward" means a discretionary payment made by the Company to a Participant based on simulated trading performance within a Live Simulated Account. Performance Rewards are not investment returns; are not profit-sharing from real trading accounts; and do not represent returns on invested capital. Performance Rewards are subject to verification, compliance review, and Company approval.

3.14 Performance Reward Cycle

"Performance Reward Cycle" means the time period between reward eligibility dates within a Live Simulated Account. The duration of each cycle may be determined by the Company and may be modified in accordance with Program rules.

3.15 Inactivity

"Inactivity" means a period during which the Participant does not execute any trades within the Simulated Account. Unless otherwise specified by the Program, Inactivity shall be defined as ten (10) consecutive calendar days without executed trades. Inactivity may result in suspension of reward eligibility, account review, or other enforcement action.

3.16 Breach

"Breach" means any violation of Program rules or this Agreement, including but not limited to exceeding drawdown limits, violating trading restrictions, engaging in prohibited trading practices, providing false information, and attempting to manipulate the Platform. A Breach may result in immediate account termination, loss of reward eligibility, and permanent suspension from the Program.

3.17 Prohibited Trading Practices

"Prohibited Trading Practices" means any trading activity that violates Program rules or attempts to exploit technical, operational, or market simulation characteristics of the Platform. Examples include but are not limited to latency arbitrage, price feed manipulation, coordinated group trading, account sharing, automated trading where prohibited, and trading designed to artificially inflate profit metrics.

3.18 Abuse Trading

"Abuse Trading" means any trading activity that, in the Company's sole judgment, attempts to manipulate the Program structure or undermine the integrity of the evaluation environment. Determination of Abuse Trading shall be made exclusively by the Company based on technical analysis, behavioral review, or internal risk assessment.

3.19 Program Rules

"Program Rules" means the operational rules governing participation in specific Program products, including risk limits, trading restrictions, reward conditions, and evaluation criteria. Program Rules may be published separately and incorporated into this Agreement by reference.

3.20 Platform

"Platform" means the software systems, trading simulation engine, dashboards, interfaces, servers, and associated technology used by the Company to provide the Program.

3.21 Company Discretion

"Company Discretion" means the Company's sole authority to interpret Program rules, evaluate Participant behavior, approve or reject rewards, and enforce compliance measures in order to maintain the integrity of the Program. Such determinations shall be final unless otherwise required by applicable law.

Chapter 4 — Program Structure and Account Types

4.1 Overview of the Program

The Program consists of simulated trading environments designed to evaluate Participant trading performance, discipline, and risk management in accordance with predefined Program Rules.

Participants may access one or more Program structures offered by the Company, which may include:

Each Program structure operates exclusively within the simulated trading environment described in this Agreement.

Participation in any Program structure does not constitute trading in real financial markets.

4.2 Program Enrollment

Participation in the Program requires:

  1. registration of a Participant Account within the Platform;
  2. acceptance of this Agreement and the Terms of Service;
  3. payment of the applicable Program fee;
  4. successful completion of any required verification procedures.

Upon successful enrollment, the Participant will be granted access to a Simulated Account corresponding to the selected Program structure.

The Company reserves the right to approve, reject, or delay any Program enrollment request.

4.3 Program Duration

Unless otherwise specified by the Company, participation in the Program is valid for a maximum duration of twelve (12) months from the date of account activation.

The Company may establish shorter or longer evaluation periods depending on the specific product in the Program.

The Company may terminate Program participation earlier in the event of:

4.4 Account Activation

A Simulated Account is considered activated when the Participant receives access credentials and the account becomes accessible within the Platform.

The activation date marks the beginning of the Participant's Program participation period.

Participants are responsible for accessing and managing their Simulated Accounts once activation occurs.

The Company is not responsible for delays caused by:

4.5 Types of Program Accounts

The Program may include multiple account structures, including but not limited to:

a) Challenge Accounts

Challenge Accounts are evaluation-based Simulated Accounts in which Participants must meet predefined trading objectives, including:

Successful completion of a Challenge Account may allow the Participant to advance within the Program according to the applicable Program Rules.

b) Instant Funded Accounts

Instant Funded Accounts provide Participants with immediate access to a Simulated Account designated as eligible for Performance Reward evaluation.

Participants operating Instant Funded Accounts must comply with all risk management and trading rules established by the Program.

Instant Funded Accounts remain simulated accounts and do not represent real capital allocation.

c) Live Simulated Accounts

Live Simulated Accounts are Simulated Accounts designated by the Company as eligible for Performance Reward consideration.

These accounts operate under strict risk management parameters and are subject to ongoing performance monitoring.

The term "Live" refers solely to reward eligibility and does not indicate participation in real financial markets.

4.6 Program Advancement

Advancement within the Program may occur when a Participant successfully meets the criteria established for a specific Program stage.

Advancement may include:

Advancement is subject to verification by the Company and may require:

The Company retains full discretion to approve or deny advancement where Program integrity concerns exist.

4.7 Account Scaling and Adjustments

The Company may offer Program features allowing for simulated account scaling, account balance adjustments, or additional Program opportunities based on Participant performance.

Such features may include:

All such features remain subject to Program Rules and the Company's discretion.

Participants have no contractual right to scaling benefits unless expressly granted by the Company.

4.8 Account Reset or Reattempt

Certain Program structures may allow Participants to reset or restart a Challenge Account upon payment of a new Program fee.

Reset availability, conditions, and limitations shall be determined by the Company and communicated through Program Rules.

A reset does not erase any prior breach history maintained by the Company for internal risk monitoring.

4.9 Account Ownership

Simulated Accounts remain the exclusive property of the Company at all times.

Participants are granted a limited right to access and operate the Simulated Account solely for the purposes of participating in the Program.

Participants acquire no ownership interest in:

4.10 Program Modifications

The Company reserves the right to modify Program structures, account types, or operational rules in order to maintain Program integrity, operational efficiency, or compliance with applicable laws.

Such modifications may include:

Any modifications shall be communicated through the Platform or official Company channels.

4.11 No Guarantee of Advancement

Participation in any Program stage does not guarantee advancement to subsequent stages.

The Company retains sole discretion to determine whether a Participant has successfully met Program requirements.

Advancement may be denied where the Company reasonably determines that:

Chapter 5 — Trading Rules and Risk Management

5.1 Compliance with Trading Rules

Participants must comply at all times with the trading rules and risk management parameters established by the Program.

These rules are designed to ensure that trading activity within the simulated environment reflects responsible trading behavior and does not undermine the integrity of the evaluation process.

Failure to comply with any trading rule may constitute a Program Breach and may result in enforcement actions including, but not limited to:

5.2 Maximum Relative Drawdown

Participants must not exceed the Maximum Relative Drawdown limit applicable to their Simulated Account.

Maximum Relative Drawdown represents the maximum allowable reduction in Account Equity relative to the highest equity value previously achieved.

If the Account Equity falls below the permitted drawdown threshold at any time, the account shall be considered breached, and the Program participation for that account may be terminated.

Drawdown calculations are performed automatically by the Platform and are final.

5.3 Maximum Risk per Trade

Participants must not expose more than two percent (2%) of Account Equity to risk on any individual trade.

Risk exposure is calculated based on the difference between the trade entry price and the stop-loss level at the time the trade is executed.

Participants are responsible for ensuring that appropriate risk management practices are implemented before executing any trade.

Failure to comply with the risk limitation may result in enforcement actions as determined by the Company.

5.4 Mandatory Stop-Loss Requirement

Each trade executed within the Simulated Account must include a defined stop-loss order at the time of trade execution.

The stop-loss must be placed immediately upon opening the position and must reflect a reasonable risk management approach consistent with the Program's rules.

Failure to use a stop-loss order may constitute a violation of the Program's risk management standards.

5.5 Minimum Trading Activity

Participants must maintain a minimum level of trading activity within their Simulated Accounts.

Unless otherwise specified by the Program Rules, Participants must execute at least five (5) trades during each Performance Reward Cycle.

This requirement ensures that reward eligibility is based on consistent trading activity rather than isolated trades.

The Company may modify minimum activity requirements for specific Program products.

5.6 Inactivity Rule

A Simulated Account shall be considered inactive if no trades are executed for a period of ten (10) consecutive calendar days.

Inactivity may result in:

The Company may, at its discretion, waive inactivity enforcement due to technical issues or other exceptional circumstances.

5.7 Position Netting

Participants may maintain only one open position per instrument at any given time unless otherwise permitted by the Platform.

Opening multiple positions in the same instrument in order to circumvent risk limits or drawdown calculations is prohibited.

Where the Platform supports position netting, opposing positions may be automatically consolidated.

Participants remain responsible for managing their risk exposure at all times.

5.8 Consistency Rule

To ensure that trading results reflect consistent trading performance rather than isolated events, the Program applies a Consistency Rule.

Under this rule, the profit generated during any single Trading Day may not exceed twenty percent (20%) of the total simulated profit achieved during the Performance Reward Cycle.

If this threshold is exceeded, the Company may determine that the trading performance does not meet the consistency standards required for reward eligibility.

In such cases, additional trading activity may be required before reward eligibility is granted.

5.9 Market Conditions and Execution

Participants acknowledge that simulated trading conditions may differ from real-world market conditions.

The Platform may simulate various market behaviors, including:

The Company does not guarantee that simulated market conditions replicate real-world market conditions.

Participants are responsible for adapting their strategies accordingly.

5.10 Trading Hours

Trading may only occur during the hours permitted by the Platform.

The Company may impose restrictions on trading during certain periods, including but not limited to:

Participants must comply with all trading-hour restrictions communicated through the Platform.

5.11 Monitoring of Trading Behavior

The Company continuously monitors trading activity within the Platform to ensure compliance with Program Rules.

Monitoring methods may include:

Participants acknowledge that such monitoring is necessary to maintain the integrity of the Program.

5.12 Final Authority on Rule Interpretation

The Company retains sole authority to interpret and apply the trading rules contained in this Agreement and any associated Program Rules.

In the event of any ambiguity regarding rule interpretation, the Company's determination shall prevail unless otherwise required by applicable law.

Chapter 6 — Prohibited Practices and Platform Abuse

6.1 General Prohibition of Platform Abuse

Participants must not engage in any trading activity, behavior, or technical action intended to exploit, manipulate, or otherwise abuse the simulated trading environment or the Program structure.

Any activity that undermines the fairness, integrity, or intended purpose of the Program may constitute Platform Abuse.

The Company reserves the right to investigate and take enforcement action against any activity it reasonably determines to be abusive, manipulative, or inconsistent with the Program's objectives.

6.2 Latency Arbitrage

Participants are strictly prohibited from engaging in latency arbitrage or any strategy designed to exploit delays between market data feeds and order execution.

This includes, but is not limited to:

Latency arbitrage is considered a serious breach of Program integrity.

6.3 Price Feed Exploitation

Participants must not attempt to exploit inaccuracies, delays, or irregularities in the simulated price feed.

Prohibited conduct includes:

Where the Company determines that a Participant has attempted to exploit such conditions, the account may be terminated.

6.4 Coordinated or Group Trading

Participants may not coordinate trading activity with other individuals or groups in order to manipulate Program outcomes.

Prohibited conduct includes:

The Company reserves the right to investigate suspicious correlations between accounts.

6.5 Multi-Accounting

Participants may not create or operate multiple accounts in order to circumvent Program rules.

Multi-accounting includes, but is not limited to:

The Company may consolidate accounts or terminate accounts where multi-accounting is suspected.

6.6 Account Sharing or Delegated Trading

Program participation must be conducted exclusively by the registered Participant.

Participants must not:

Any evidence that an account is being operated by a third party may result in immediate account termination.

6.7 Automated Trading Systems

Unless explicitly permitted by the Program Rules, Participants may not use:

The Company may monitor order patterns to detect automated behavior.

The use of prohibited automation tools may result in immediate enforcement action.

6.8 External Signal Services

Participants may not rely on external signal services for the purpose of passing Program evaluations.

Prohibited conduct includes:

The Program is intended to evaluate the Participant's own trading ability.

6.9 Challenge Passing Services

Participants are strictly prohibited from using third-party services designed to pass evaluation programs.

This includes services offering:

Accounts found to be associated with such services may be permanently banned from the Program.

6.10 Artificial Trading Behavior

Participants must not engage in trading behavior designed solely to manipulate Program metrics rather than reflect genuine trading activity.

Examples include:

The Company may review trading activity patterns and determine whether such behavior constitutes abuse.

6.11 Use of Anonymization Technologies

Participants may not use anonymization technologies for the purpose of circumventing Platform monitoring systems.

This includes:

The Company may monitor IP addresses, device fingerprints, and login patterns to detect suspicious behavior.

6.12 Platform Manipulation

Participants must not attempt to interfere with or manipulate the Platform.

Prohibited conduct includes:

Any attempt to compromise platform security may result in permanent suspension and potential legal action.

6.13 Investigation and Enforcement

The Company reserves the right to investigate any activity suspected of violating this Agreement.

Investigations may involve:

Participants agree to cooperate with any such investigation.

Failure to cooperate may result in account suspension.

6.14 Enforcement Actions

Where the Company determines that a violation has occurred, the Company may take any enforcement action it deems appropriate.

Such actions may include:

The Company's decision regarding enforcement shall be final.

Chapter 7 — Performance Rewards and Payout Conditions

7.1 Eligibility for Performance Rewards

Participants operating a Live Simulated Account may become eligible for Performance Rewards based on simulated trading performance achieved within the Platform.

Eligibility for Performance Rewards is strictly conditional upon:

Eligibility does not create an automatic right to receive payment.

7.2 Nature of Performance Rewards

Performance Rewards represent discretionary payments issued by the Company in recognition of simulated trading performance achieved within the Program.

Performance Rewards do not constitute:

Participants acknowledge that simulated profits displayed within the Platform are not financial assets and do not create ownership rights.

7.3 Reward Calculation

Performance Rewards may be calculated based on Eligible Profit generated within the Participant's Live Simulated Account.

The calculation of Eligible Profit may take into account:

The Company reserves the right to exclude certain trading activity from reward calculations if such activity is determined to be inconsistent with Program objectives.

7.4 Initial Reward Eligibility

Unless otherwise specified by the Program Rules, Participants may become eligible to request their first Performance Reward seventeen (17) days after activation of the Live Simulated Account.

This period includes a compliance buffer designed to allow the Company to verify trading behavior and Participant identity.

The Company may extend the verification period where additional review is required.

7.5 Reward Cycles

Following the first reward eligibility date, Performance Reward requests may generally be submitted on a recurring fourteen (14) day cycle, unless otherwise specified by the Company.

The Company may modify reward cycle durations for specific Program products.

Participants must comply with all Program requirements during each reward cycle in order to remain eligible.

7.6 Reward Caps

For certain Program structures, including Instant Funded Accounts, Performance Rewards may be subject to payout limits.

Unless otherwise specified by the Program Rules, the maximum monthly reward may not exceed six percent (6%) of the Simulated Account starting balance.

The Company may modify payout caps or introduce additional limitations for specific Program products.

7.7 Reward Request Procedure

Participants must submit a reward request through the Platform in accordance with the procedures established by the Company.

A reward request may require the Participant to provide:

Incomplete or inaccurate submissions may delay or invalidate reward requests.

7.8 Compliance Review

All reward requests are subject to a compliance review process.

The review may include:

The Company reserves the right to delay reward approval pending completion of any compliance review.

7.9 Withholding of Rewards

The Company may temporarily withhold reward payments where:

Withholding of rewards during investigation does not constitute a breach of this Agreement.

7.10 Denial of Reward Requests

The Company may deny a reward request if it determines that:

Where a reward request is denied, the Company may terminate the associated account.

7.11 Clawback of Rewards

The Company reserves the right to reclaim or offset previously issued rewards if it subsequently determines that:

Clawback rights shall survive termination of this Agreement.

7.12 Payment Methods

Approved Performance Rewards may be paid through payment methods determined by the Company, which may include:

Participants are responsible for providing accurate payment information.

7.13 Taxes and Financial Reporting

Participants are solely responsible for any tax obligations arising from Performance Rewards received.

The Company does not provide tax advice and does not assume responsibility for the Participant's tax reporting obligations.

Participants may be required to provide tax documentation where required by applicable law.

7.14 Payment Processing Time

Once approved, reward payments are typically processed within forty-eight (48) to ninety-six (96) hours.

Processing times may vary depending on:

The Company shall not be liable for delays caused by third-party payment providers.

7.15 Suspension of Reward Eligibility

Participants may lose reward eligibility if:

Loss of reward eligibility may occur even if simulated profits are displayed within the Platform.

7.16 Final Determination

The Company retains sole authority to determine:

Such determinations shall be final unless otherwise required by applicable law.

Chapter 8 — Verification, Compliance, and Monitoring

8.1 Identity Verification (KYC)

In order to maintain the integrity of the Program and comply with applicable legal and regulatory requirements, the Company may require Participants to complete identity verification procedures ("Know Your Customer" or KYC).

Such procedures may include the submission of:

The Company reserves the right to refuse access to the Program or suspend any Account if the Participant fails to complete the required verification procedures.

8.2 Ongoing Verification

The Company may require additional verification procedures at any time during the Participant's involvement in the Program.

Such verification may be requested:

Participants must cooperate fully with any such verification request.

Failure to do so may result in suspension or termination of the Account.

8.3 Biometric Verification

The Company may use biometric verification technologies for identity confirmation purposes.

Such verification may include:

Biometric data collected during verification processes shall be used solely for identity verification and fraud prevention purposes.

8.4 Device Identification and Monitoring

The Company may monitor the devices used to access the Platform in order to detect suspicious behavior.

Monitoring methods may include:

This information is used solely to protect the integrity of the Platform and prevent unauthorized access.

8.5 IP Address Monitoring

The Company may record and analyze IP addresses used to access the Platform.

IP monitoring may be used to detect:

Participants acknowledge that such monitoring is necessary for fraud prevention and platform security.

8.6 Behavioral Analysis

The Company may analyze Participant behavior in order to identify patterns indicative of platform abuse.

Such analysis may include:

Behavioral analysis may be conducted through automated systems or manual review by compliance personnel.

8.7 Investigation of Suspicious Activity

The Company reserves the right to investigate any activity that it reasonably suspects may constitute:

Investigations may include:

Participants agree to cooperate with any such investigation.

8.8 Temporary Account Suspension

Where suspicious activity is detected, the Company may temporarily suspend the Participant's Account pending completion of an investigation.

During such suspension:

Suspension during investigation does not constitute a breach of this Agreement.

8.9 Compliance with Sanctions and Legal Restrictions

Participants must not be located in or operate from jurisdictions subject to economic sanctions or legal restrictions that prohibit participation in the Program.

The Company reserves the right to deny or terminate participation where required by applicable sanctions laws or compliance policies.

Participants may be required to provide information necessary to verify compliance with such restrictions.

8.10 Data Processing for Compliance Purposes

Information collected during verification and monitoring processes may be processed for purposes including:

Such processing shall be conducted in accordance with the Company's Privacy Policy.

8.11 Cooperation Requirement

Participants agree to cooperate fully with any compliance or verification procedures conducted by the Company.

Failure to cooperate with reasonable requests for information may result in:

8.12 Final Determination

The Company retains sole authority to determine whether verification and compliance requirements have been satisfied.

Where the Company determines that verification requirements have not been met, participation in the Program may be denied or terminated.

Chapter 9 — Fees, Billing, Refunds and Chargebacks

9.1 Program Fees

Participation in the Program requires payment of the applicable Program fee.

Program fees represent payment solely for:

Program fees do not represent:

All Program fees must be paid in full prior to account activation unless otherwise specified by the Company.

9.2 Pricing and Fee Changes

The Company reserves the right to modify Program pricing at any time.

Price changes may apply to:

Price changes do not affect Program fees already paid for active accounts.

9.3 Non-Refundable Fees

Unless expressly stated otherwise by the Company, all Program fees are non-refundable.

Once a Participant has received access to the Platform or activated a Simulated Account, the Program fee shall be considered fully earned by the Company.

Participants acknowledge that the Program involves immediate access to proprietary systems and services and therefore refunds are not available after activation.

9.4 Refund Exceptions

In exceptional circumstances, the Company may grant refunds at its sole discretion.

Such circumstances may include:

Refund decisions made by the Company are final.

9.5 Payment Methods

Program fees may be paid using payment methods supported by the Platform.

Accepted payment methods may include:

The Company reserves the right to change accepted payment methods at any time.

9.6 Billing Responsibility

Participants are responsible for ensuring that payment information provided to the Company is accurate and valid.

The Company shall not be responsible for failed payments resulting from:

Participants may be required to verify payment information before account activation.

9.7 Chargeback Policy

Initiating a chargeback without legitimate cause after accessing and using the Program constitutes a violation of this Agreement.

Participants acknowledge that initiating a chargeback after receiving Program access may be considered fraudulent dispute activity.

Legitimate chargeback claims are limited to situations involving:

Chargebacks initiated after a Participant has accessed the Platform, executed trades, or otherwise used the Program will be contested by the Company.

9.8 Company Rights in the Event of Chargebacks

In the event of an unjustified chargeback, the Company reserves the right to:

The Company may also block the Participant from accessing future Programs.

9.9 Recovery of Chargeback Losses

Where a chargeback is determined to be fraudulent or unjustified, the Company may pursue recovery of all associated losses.

Such losses may include:

Participants agree to reimburse the Company for such costs where applicable.

9.10 Obligation to Contact Support

Participants agree to contact the Company's support team prior to initiating any chargeback or payment dispute.

The Company will make reasonable efforts to resolve any legitimate concerns raised by Participants.

Failure to attempt resolution through the Company's support process may be considered evidence of an unjustified dispute.

9.11 Payment Fraud Prevention

The Company reserves the right to implement fraud detection systems to identify suspicious payment activity.

Such systems may include:

Transactions flagged as potentially fraudulent may be delayed or cancelled.

9.12 Currency and Conversion

Program fees may be displayed in various currencies.

Where currency conversion occurs, the exchange rate applied may be determined by the payment processor.

The Company shall not be responsible for fluctuations in currency exchange rates.

9.13 Taxes on Program Fees

Participants are responsible for any taxes that may apply to Program fees in their jurisdiction.

The Company may collect applicable taxes where required by law.

Participants remain responsible for complying with their local tax obligations.

Chapter 10 — Confidentiality, Intellectual Property and Platform Integrity

10.1 Ownership of Platform and Systems

All rights, title, and interest in and to the Platform, including all software, systems, databases, algorithms, trading simulation engines, dashboards, interfaces, and related infrastructure, are the exclusive property of the Company or its licensors.

Nothing contained in this Agreement shall transfer any ownership rights to the Participant.

Participants are granted only a limited, revocable, non-transferable right to access and use the Platform solely for the purpose of participating in the Program.

10.2 Intellectual Property

All intellectual property associated with the Platform and the Program is owned by the Company or its licensors.

This includes, but is not limited to:

Participants may not reproduce, distribute, modify, publish, or create derivative works based on any part of the Platform without prior written consent from the Company.

10.3 Proprietary Program Methodology

The methodologies used by the Company to evaluate simulated trading performance constitute proprietary business processes.

These methodologies may include:

Participants acknowledge that these systems are confidential and proprietary.

Participants agree not to attempt to analyze, replicate, reverse engineer, or otherwise derive such methodologies.

10.4 Confidential Information

Participants may obtain access to confidential information during their participation in the Program.

Confidential Information may include:

Participants agree to maintain the confidentiality of such information and not disclose it to any third party without the Company's prior written consent.

10.5 Reverse Engineering Prohibition

Participants are strictly prohibited from attempting to reverse engineer, decompile, disassemble, or otherwise analyze the technical structure of the Platform.

This prohibition includes attempts to:

Any such attempt may result in immediate termination of Program participation.

10.6 Scraping and Data Extraction

Participants may not use automated tools or manual processes to collect or extract data from the Platform.

Prohibited activities include:

Unauthorized data extraction may result in legal action.

10.7 Protection of Platform Integrity

Participants must not engage in any activity that could interfere with the normal operation of the Platform.

This includes attempts to:

Any attempt to compromise platform integrity may result in permanent termination and potential legal action.

10.8 Participant Content

Participants may submit information to the Platform, including:

Participants grant the Company a non-exclusive license to use such information for purposes including:

Participants represent that any information provided is accurate and does not violate the rights of third parties.

10.9 Non-Disparagement

Participants agree not to make false or defamatory statements regarding the Company, the Platform, or its personnel.

Nothing in this clause prevents Participants from expressing legitimate opinions or raising lawful complaints.

However, knowingly false statements intended to harm the reputation of the Company may constitute a breach of this Agreement.

10.10 Survival of Confidentiality Obligations

The confidentiality and intellectual property obligations contained in this Chapter shall survive termination of this Agreement.

Participants remain bound by these obligations indefinitely following termination of Program participation.

Chapter 11 — Breach, Suspension and Termination

11.1 Breach of the Agreement

A Breach occurs when a Participant violates any provision of this Agreement, the Terms of Service, or any applicable Program Rules.

Examples of Breach include, but are not limited to:

A Breach may result in enforcement actions as described in this Chapter.

11.2 Immediate Suspension of Accounts

The Company reserves the right to immediately suspend any Participant Account where it reasonably believes that:

During suspension:

Suspension does not constitute termination of this Agreement.

11.3 Investigation Period

Where an Account has been suspended for investigation, the Company may conduct a review of the Participant's activity.

The investigation may include:

Participants agree to cooperate with any investigation conducted by the Company.

Failure to cooperate may result in termination of participation in the Program.

11.4 Termination by the Company

The Company may terminate a Participant's Account at any time, including but not limited to the following circumstances:

Termination may occur with or without prior notice.

11.5 Termination by the Participant

Participants may terminate their participation in the Program at any time by providing written notice to the Company.

Such termination does not entitle the Participant to any refund of Program fees already paid.

Termination by the Participant does not affect any obligations arising prior to termination.

11.6 Effect of Account Breach

Where a Simulated Account is determined to be breached due to violation of Program rules:

The Company may allow the Participant to restart the Program by purchasing a new account, subject to the Company's discretion.

11.7 Forfeiture of Reward Eligibility

If an Account is terminated due to Breach, any simulated profits generated within that account shall be considered invalid for purposes of reward eligibility.

Participants acknowledge that simulated profits do not constitute financial assets and may be cancelled upon termination of the account.

11.8 Permanent Suspension

In cases involving serious violations, including but not limited to fraud, platform manipulation, or multi-accounting, the Company may impose permanent suspension from future participation in the Program.

Permanent suspension may include:

11.9 Survival of Certain Obligations

Termination of participation in the Program does not affect obligations that, by their nature, survive termination.

Such obligations include, but are not limited to:

11.10 Company Discretion

The Company retains sole authority to determine whether a breach of this Agreement has occurred.

Where the Company reasonably determines that a breach has occurred, it may take any enforcement action necessary to protect the integrity of the Program.

Such determinations shall be final unless otherwise required by applicable law.

Chapter 12 — Disclaimer of Warranties and Limitation of Liability

12.1 Service Provided "As Is"

The Platform, Program, and all associated services are provided on an "as is" and "as available" basis.

The Company makes no warranties or representations, express or implied, regarding:

Participants acknowledge that use of the Platform involves inherent technological risks.

12.2 No Warranty of Performance

The Company does not guarantee:

Simulated trading performance does not guarantee future results in actual financial markets.

Participants assume full responsibility for any decisions made based on their experience within the Program.

12.3 No Liability for Simulated Trading Results

The Company shall not be liable for any losses, damages, or claims arising from:

Participants acknowledge that the simulated environment is designed solely for evaluation purposes.

12.4 Technical Interruptions

The Company shall not be liable for interruptions to the Platform caused by:

The Company may temporarily suspend Platform access to perform maintenance or address technical issues.

12.5 Limitation of Liability

To the maximum extent permitted by applicable law, the Company's total liability arising out of or relating to this Agreement shall not exceed the total Program fees paid by the Participant during the twelve (12) months preceding the claim.

This limitation applies regardless of the legal theory under which the claim is brought.

12.6 Exclusion of Indirect Damages

To the fullest extent permitted by law, the Company shall not be liable for any:

This limitation applies even if the Company has been advised of the possibility of such damages.

12.7 Responsibility for External Trading

The Company shall not be responsible for any financial losses incurred by Participants in real-world trading conducted outside the Platform.

Participation in the Program does not constitute financial advice or investment guidance.

Participants are solely responsible for any trading activities conducted in real financial markets.

12.8 Third-Party Services

The Platform may rely on third-party service providers, including:

The Company shall not be liable for failures or disruptions caused by such third-party services.

12.9 Force Majeure

The Company shall not be liable for failure or delay in performing its obligations under this Agreement due to events beyond its reasonable control.

Such events may include:

During such events, the Company may suspend the operation of the Program until normal operations can resume.

12.10 Participant Acknowledgment

By participating in the Program, Participants acknowledge and agree that:

Participants further acknowledge that these disclaimers and limitations form an essential part of this Agreement.

Chapter 13 — Governing Law and Dispute Resolution

13.1 Governing Law

This Agreement and any dispute arising out of or related to it shall be governed by and construed in accordance with the laws of Hong Kong, without regard to its conflict of laws principles.

Participants acknowledge that the choice of governing law provides predictability and consistency in the interpretation and enforcement of this Agreement.

13.2 Good Faith Resolution

Before initiating any formal dispute resolution procedure, the Participant agrees to attempt to resolve the dispute directly with the Company.

Participants must first submit a written notice describing the dispute to the Company's support or legal contact address.

The Company and the Participant shall make reasonable efforts to resolve the dispute in good faith within thirty (30) calendar days of the written notice.

13.3 Mandatory Arbitration

If a dispute cannot be resolved through good faith negotiations, the dispute shall be resolved exclusively by binding arbitration.

The arbitration shall be administered by the Hong Kong International Arbitration Centre (HKIAC) in accordance with its then-current arbitration rules.

The seat of arbitration shall be Hong Kong.

The arbitration proceedings shall be conducted in English.

13.4 Arbitration Procedure

The arbitration shall be conducted before a single arbitrator, unless the HKIAC rules require otherwise.

The arbitrator shall have the authority to determine:

The arbitrator's decision shall be final and binding upon both parties.

Judgment upon the arbitration award may be entered in any court having jurisdiction.

13.5 Waiver of Court Proceedings

By agreeing to this Agreement, Participants waive the right to resolve disputes in court, except where arbitration clauses are deemed unenforceable under applicable law.

Participants also waive the right to a trial by jury to the fullest extent permitted by law.

13.6 Class Action Waiver

Participants agree that any dispute shall be resolved on an individual basis only.

Participants waive the right to participate in:

No arbitration or dispute may be consolidated with claims brought by other Participants.

13.7 Limitation Period for Claims

To the maximum extent permitted by law, any claim arising out of or relating to this Agreement must be submitted within one (1) year from the date on which the claim arose.

Claims submitted after this period may be permanently barred.

13.8 Injunctive Relief

Notwithstanding the arbitration provisions of this Chapter, the Company may seek injunctive or equitable relief in any court of competent jurisdiction where necessary to protect:

13.9 Arbitration Costs

Unless otherwise determined by the arbitrator, each party shall bear its own legal fees and costs associated with the arbitration.

Administrative and arbitrator fees shall be allocated according to the applicable HKIAC rules.

Chapter 14 — Miscellaneous Provisions

14.1 Amendments to the Agreement

The Company reserves the right to amend or modify this Agreement at any time.

Any modifications shall become effective upon publication on the Company's website or Platform, unless otherwise stated.

Participants are responsible for periodically reviewing the Agreement.

Continued participation in the Program following the publication of amendments constitutes acceptance of the updated terms.

14.2 Relationship of the Parties

Nothing in this Agreement shall be construed to create any form of partnership, joint venture, employment relationship, or agency relationship between the Company and the Participant.

Participants acknowledge that they act solely as independent users of the Program.

Participation in the Program does not establish any employment, contractor, or fiduciary relationship with the Company.

14.3 Assignment

The Company may assign or transfer its rights and obligations under this Agreement to any affiliate, successor, or third party without prior notice to Participants.

Participants may not assign, transfer, or delegate any rights or obligations under this Agreement without the prior written consent of the Company.

Any unauthorized assignment by a Participant shall be considered void.

14.4 Severability

If any provision of this Agreement is determined by a court or arbitrator to be invalid, illegal, or unenforceable, the remaining provisions shall remain in full force and effect.

The invalid provision shall be interpreted or modified to the minimum extent necessary to make it enforceable while preserving the intent of the original provision.

14.5 Waiver

Failure by the Company to enforce any provision of this Agreement shall not constitute a waiver of that provision or of any other provision.

Any waiver of rights must be made in writing and signed by an authorized representative of the Company.

A waiver of one breach shall not constitute a waiver of any subsequent breach.

14.6 Notices

All legal notices under this Agreement must be provided in writing.

Participants may deliver notices to the Company through the contact channels provided on the Platform.

The Company may deliver notices to Participants via:

Electronic communications shall be considered legally valid notice.

14.7 Electronic Acceptance

Participants acknowledge that acceptance of this Agreement may occur through electronic means.

By clicking "Accept," registering an account, or accessing the Platform, the Participant confirms that they have read, understood, and agreed to be bound by this Agreement.

Electronic acceptance shall have the same legal effect as a physical signature.

14.8 Survival of Provisions

Certain provisions of this Agreement shall survive termination of participation in the Program.

Such provisions include, but are not limited to:

These provisions shall remain binding after termination of this Agreement.

Chapter 15 — Entire Agreement and Acceptance

15.1 Entire Agreement

This Agreement, together with the Company's Terms of Service, Privacy Policy, and any Program Rules incorporated by reference, constitutes the entire agreement between the Participant and the Company concerning participation in the Program.

This Agreement supersedes all prior or contemporaneous communications, discussions, negotiations, representations, or agreements, whether written or oral, relating to the subject matter hereof.

Participants acknowledge that they have not relied upon any representations, promises, or statements other than those expressly contained in this Agreement.

15.2 No Reliance on External Statements

Participants acknowledge that statements made through:

do not constitute contractual commitments unless expressly included in this Agreement or in the Company's official Program documentation.

15.3 Hierarchy of Documents

In the event of any inconsistency between documents governing participation in the Program, the following order of precedence shall apply:

  1. This Participation Agreement
  2. The Terms of Service
  3. The Program Rules or Platform Guidelines
  4. Any supplemental policies published by the Company

To the extent of any conflict, the document with higher precedence shall control.

15.4 Participant Representations

By accepting this Agreement, the Participant represents and warrants that:

Participants further confirm that they enter into this Agreement voluntarily and without coercion.

15.5 Electronic Acceptance and Binding Effect

Acceptance of this Agreement may occur through electronic means, including but not limited to:

Such actions shall constitute legally binding acceptance of this Agreement.

Electronic acceptance shall have the same legal force and effect as a handwritten signature.

15.6 Effective Date

This Agreement becomes effective on the date the Participant first accepts the Agreement through the Platform or otherwise enrolls in the Program.

Participation in the Program after such acceptance constitutes ongoing agreement to the terms contained herein.