Bullion FX Terms of Service

1.1 These Terms of Service (the "Agreement") form a legally binding contract between Bullion FX Markets Ltd, an International Business Company incorporated under the laws of St. Vincent and the Grenadines with registered office at Suite 305, Griffith Corporate Centre, P.O. Box 1510, Beachmont, Kingstown, St. Vincent and the Grenadines (the "Company," "Bullion FX," "we," "us," or "our"), and the natural person or legal entity who opens or maintains a trading account with the Company (the "Client," "you," or "your"). The Company and the Client are referred to together as the "Parties" and individually as a "Party."

1.2 By opening an account, depositing funds, or placing any order with the Company, you confirm that you have read, understood, and agreed to be bound by this Agreement, the Risk Disclosure Notice, the Privacy Policy, the Order Execution Policy, the Conflicts of Interest Policy, the Complaints Handling Policy, the Anti-Money Laundering Policy, and any product-specific schedules or addenda we publish from time to time (collectively, the "Client Documents"). The Client Documents are incorporated into this Agreement by reference.

1.3 This Agreement governs every transaction you place through the Company, every account you operate with the Company, and every interaction between you and the Company in connection with the services we provide. It supersedes any prior understanding, proposal, or communication between us on the same subject matter.

1.4 If you are entering into this Agreement on behalf of a legal entity, you represent and warrant that you have full authority to bind that entity, and references to "you" and "your" include both you and the entity.

1.5 You should read this Agreement carefully. If you do not understand any part of it, you should not open an account, and you should seek independent legal and financial advice before doing so. If, after opening an account, you decide that you no longer wish to be bound by this Agreement, your sole remedy is to close your account in accordance with Section 22 (Termination).

2.1 In this Agreement, capitalised terms have the meanings set out below unless the context otherwise requires:

• "Account" means any live trading account opened in your name on the Company's MetaTrader 5 server.
• "Applicable Law" means all statutes, regulations, rules, orders, codes, judgments, and other binding pronouncements of any government, regulator, court, or competent authority that apply to the Company or the Client in connection with this Agreement.
• "Balance" means the cash balance recorded in the Account at any given time, expressed in the Account Currency.
• "Bonus" means any promotional credit, deposit-match credit, or other incentive granted to you under a published promotional schedule.
• "Bullion VIP Account" means the trading account type offered by the Company on which no commission is charged and raw spreads are available.
• "CFD" or "Contract for Difference" means a cash-settled derivative contract under which the Parties exchange the difference between the opening and closing price of an Underlying Asset, without any right to physical delivery.
• "Client Funds" means money you have deposited with the Company, plus realised profit and minus realised loss, fees, charges, swaps, and Bonus clawbacks, less any amount you have withdrawn.
• "Dashboard" means the Bullion FX client portal accessible through the Company's website.
• "Equity" means Balance plus floating profit and minus floating loss on open positions.
• "Free Margin" means Equity minus Used Margin.
• "Instruction" means any order, request, or other communication submitted by you through the Trading Platform or the Dashboard.
• "KYC" means know-your-customer due diligence performed by the Company in accordance with the AML Policy and Applicable Law.
• "Leverage" means the ratio between the notional value of an open position and the Used Margin required to maintain it.
• "Margin Call" means the alert generated by the Trading Platform when your Margin Level falls to the Company's published Margin Call threshold.
• "Margin Level" means Equity divided by Used Margin, expressed as a percentage.
• "MT5" means the MetaTrader 5 desktop, web, or mobile trading application provided by MetaQuotes Software Corp., on which the Company maintains the server labelled fxc.
• "Order" means any market, pending, stop, limit, or other order placed on an Underlying Asset.
• "Restricted Jurisdiction" means each jurisdiction listed in Section 3.4.
• "Risk Disclosure" means the Risk Disclosure Notice published by the Company on the website, as amended from time to time.
• "Stop-Out" means the automatic closure of open positions when your Margin Level falls to the Company's published Stop-Out threshold.
• "Trading Platform" means MT5 and any other software the Company makes available for the purpose of placing Orders.
• "Transaction" means the opening and closing of a position on an Underlying Asset under this Agreement.
• "Underlying Asset" means the financial product or reference rate on which a CFD offered by the Company is based.
• "Used Margin" means the portion of your Equity that is committed as collateral against open positions.

2.2 Words in the singular include the plural and vice versa. Words denoting a gender include every gender. References to a person include a natural person, corporation, partnership, association, trust, or any other legal entity. References to a statute, regulation, or other instrument include any amendment, replacement, or re-enactment of it.

2.3 Headings are for convenience only and do not affect the interpretation of this Agreement.

3.1 To open an Account you must (a) be at least eighteen (18) years of age, (b) have full legal capacity in your jurisdiction of residence, (c) not be a resident or citizen of a Restricted Jurisdiction, (d) not be a Sanctioned Person within the meaning of Section 28, and (e) provide truthful, complete, and current information in your application.

3.2 The Company reserves the right, exercised in its sole discretion, to accept or reject any application without giving reasons. Acceptance is communicated by the Company in writing (which includes email) and is conditional on successful completion of KYC.

3.3 The services described in this Agreement are offered in more than eighty (80) countries. The Company actively markets its services only in jurisdictions where doing so is consistent with Applicable Law, and the Company does not solicit business in any Restricted Jurisdiction.

3.4 The Company does not offer services to residents, citizens, or persons present in the following Restricted Jurisdictions: the United States of America (including its territories and possessions). The Company also does not offer services to any person or entity that appears on a sanctions list maintained by the United Nations, the Office of Foreign Assets Control of the United States Department of the Treasury, or any other competent authority binding on the Company.

3.5 If at any time after your Account is opened you become a resident or citizen of a Restricted Jurisdiction, or if you become a Sanctioned Person, you must notify the Company without undue delay. The Company may suspend or close your Account in accordance with Sections 21 (Suspension) or 22 (Termination).

3.6 Each natural person or legal entity may hold only one Account unless the Company has approved an additional Account in writing.

4.1 The Company is required by Applicable Law to verify the identity of every Client and the source of funds used to operate every Account. To do so, the Company applies a tiered KYC framework.

4.2 Tier 0 ("T0") is the default tier on registration. T0 Clients may deposit and trade, but the lifetime cumulative withdrawal cap under T0 is USD 2,500.

4.3 Tier 1 ("T1") is reached when the Client submits a government-issued photographic identity document acceptable to the Company and that document is verified. The lifetime cumulative withdrawal cap under T1 is USD 10,000.

4.4 Tier 2 ("T2") is reached when the Client submits, in addition to a verified T1 document, a proof of address dated no more than ninety (90) days before submission. Acceptable documents include utility bills, bank statements, or government correspondence showing the Client's full name and residential address. The lifetime cumulative withdrawal cap under T2 is USD 50,000.

4.5 Tier 3 ("T3") covers withdrawals above the T2 cap and is unlocked only by manual administrative review. The Company may at its sole discretion require enhanced due diligence including, without limitation, source-of-funds and source-of-wealth documentation, video verification, and references from regulated counterparties.

4.6 The lifetime cumulative cap at each tier refers to the aggregate value of all withdrawals from the Account from registration to date, expressed in USD. The cap is independent of the deposit rail used and is not reset by closing and reopening the Account.

4.7 The Company may at any time request additional information or documentation to verify any aspect of your identity, residence, source of funds, source of wealth, beneficial ownership, or trading activity. Until you respond to a request to the Company's satisfaction, the Company may suspend deposits, suspend withdrawals, suspend trading, or any combination of the foregoing.

4.8 The Company is required to report suspicious activity to the competent authority in the jurisdiction of the Company's incorporation and to other competent authorities as required by Applicable Law. You acknowledge that the Company is under no obligation to notify you of such a report, and the Company has no liability arising out of action taken in good-faith compliance with a reporting or freezing obligation.

4.9 KYC documents you submit are stored securely on broker-controlled infrastructure. Specific details concerning storage, processing, and retention are set out in the Privacy Policy.

5.1 The Company provides electronic execution-only trading services in cash-settled Contracts for Difference. The Company is the contractual counterparty to every Transaction you open on an Account. The Company does not provide investment advice, portfolio management, tax advice, or legal advice, and nothing you receive from the Company should be construed as such.

5.2 The instruments offered by the Company at the date of this Agreement include:

• Forex CFDs: all G7 major currency pairs and most minor pairs;
• Cryptocurrency CFDs: BTC, ETH, BNB, SOL, XRP, DOGE, LTC, and ADA, each quoted against USD;
• Metals CFDs: XAUUSD (gold/USD), XAGUSD (silver/USD);
• Index CFDs: US500, NAS100, US30, GER40, UK100, FRA40, ESP35, JPN225, HKG33, and AUS200;
• Energy CFDs: USOIL (WTI crude) and UKOIL (Brent crude).

5.3 All instruments are settled in USD on the Trading Platform. All Transactions are cash CFDs only. There is no physical delivery of an Underlying Asset, no expiry of a cash CFD position (subject to swap and corporate-event adjustments), and no entitlement to dividends, voting rights, coupons, staking rewards, or any other right that a holder of the Underlying Asset itself would enjoy.

5.4 The Company may from time to time add, suspend, or remove instruments from its product catalogue. The current published list on the Trading Platform and the Dashboard is the binding list at any given time.

5.5 The Account Currency is USD. The Company does not currently offer Accounts denominated in any other currency. Where you fund an Account in a non-USD value (for example, Indian rupees via TheNetWallet or a stablecoin such as USDT), the funded amount is converted to USD at the exchange rate applicable at the time the deposit is credited, and any rounding is recorded in the Account ledger.

5.6 The Company is the counterparty to every Transaction. The Company may hedge, lay off, internalise, or warehouse the resulting market risk in any manner it determines appropriate. You are not entitled to be informed of, and you have no interest in, any such hedging or internalisation activity.

6.1 The Company provides access to MT5 through the server labelled fxc, together with the Bullion FX Dashboard. Use of the Trading Platform is governed by this Agreement and by the licence terms imposed by the platform vendor.

6.2 The Company grants you a personal, non-exclusive, non-transferable, and revocable licence to use the Trading Platform solely for the purpose of placing Orders and managing your Account. You may not copy, decompile, reverse-engineer, modify, distribute, or sublicense the Trading Platform or any part of it.

6.3 You are solely responsible for the configuration, security, and reliability of your own devices, internet connection, and access credentials. You must keep your username, password, and any second-factor codes confidential, and you must notify the Company without delay if you suspect that any of them has been compromised. The Company is entitled to treat every Order placed using your credentials as authorised by you, unless and until you give us notice to the contrary that we have had a reasonable opportunity to act on.

6.4 The Company may at any time, with or without notice, suspend access to the Trading Platform for maintenance, security, or any other reason it considers reasonable. The Company will make commercially reasonable efforts to restore access promptly but is not liable for losses caused by suspension or unavailability.

6.5 The Company does not warrant that the Trading Platform is free from defects, errors, viruses, or interruptions, and you accept that electronic trading involves the risk of system failure. The Trading Platform is provided on an "as is" and "as available" basis.

7.1 The prices displayed on the Trading Platform are the Company's own quoted prices. They are derived from external liquidity sources and adjusted by the Company in its commercially reasonable discretion. They may differ from prices observed elsewhere in the market.

7.2 Spreads on the Bullion VIP Account start from 0.6 pips on EURUSD majors. The current spread for each instrument is published on the Trading Platform per symbol. Spreads are not fixed; they fluctuate with market conditions, liquidity, volatility, and the time of day. They may widen significantly during news events, market openings, and periods of low liquidity.

7.3 You acknowledge that the price at which an Order is executed may differ from the price displayed at the moment the Order was submitted ("slippage"). Slippage may be positive or negative. The Company does not guarantee execution at any specific displayed price unless that price has been quoted as a firm, immediately executable quote.

7.4 In the event of a manifest error in pricing — for example, a feed error, a "fat-finger" error, or a price clearly inconsistent with the prevailing market — the Company is entitled to void the affected Transaction or to amend the price to a fair market price, retroactively if necessary. The Company will act in good faith and in accordance with reasonable market practice when invoking this clause and will notify you of the adjustment without undue delay.

8.1 The Company offers market orders, pending orders (buy stop, sell stop, buy limit, sell limit), and stop-loss and take-profit orders, in each case as configured on the Trading Platform. Available order types may change from time to time and the current list on the Trading Platform is binding.

8.2 The Company executes Orders in accordance with the Order Execution Policy. The Company may execute Orders in whole or in part, may aggregate Orders, and may use one or more liquidity providers or its own book. The execution venue is the Company itself, acting as principal counterparty.

8.3 Pending orders are valid for the period selected on the Trading Platform, or until cancelled. The Company may, in conditions where execution at the requested price is not possible, execute a pending order at the first available price after the trigger condition has been met, or decline execution if no commercially reasonable price is available.

8.4 The Company is not obliged to execute any Order. The Company may decline an Order if (a) accepting it would breach Applicable Law, (b) the Order is malformed or contains manifest error, (c) you have insufficient Margin, (d) the Account is suspended or restricted, (e) the Order forms part of conduct described in Section 12 (Market Conduct and Prohibited Practices), or (f) the Company has any other commercially reasonable basis for refusing.

8.5 Stop-loss orders are intended to limit loss but do not guarantee a particular outcome. In fast-moving markets, stop-loss orders may execute at a price materially worse than the level you specified. The Company is not liable for the difference.

8.6 An Order is treated as executed at the moment the Trading Platform confirms execution. Trade confirmations and statements are made available on the Trading Platform and the Dashboard in real time and are deemed received by you when so made available.

9.1 Trading CFDs on margin involves substantial risk. You may lose more than your initial deposit if negative-balance protection does not apply or has not been activated in your case. You should not trade with money you cannot afford to lose.

9.2 Maximum Leverage offered by the Company is up to 1:1000 on Forex majors, subject to per-instrument caps published on the Trading Platform and to any lower cap imposed by Applicable Law in the Client's jurisdiction. Leverage on cryptocurrency CFDs, indices, energies, and minor instruments is lower and is published per symbol. The Company may reduce Leverage at any time, with or without notice, including (without limitation) before scheduled news events, on the basis of Account activity, or in response to changes in market conditions.

9.3 You must at all times maintain sufficient Margin to support your open positions. You acknowledge that Margin requirements may change at any time.

9.4 A Margin Call is generated when your Margin Level falls to the threshold published on the Trading Platform. A Margin Call is a warning. The Company is not obliged to issue a Margin Call before invoking a Stop-Out, and the failure to issue one does not create any liability.

9.5 A Stop-Out is triggered when your Margin Level falls to the threshold published on the Trading Platform. On Stop-Out, the Trading Platform will automatically close one or more open positions, in an order determined by the Trading Platform, until the Margin Level returns above the Stop-Out threshold. You accept that Stop-Out may occur at prices materially worse than those available at the time of the Margin Call, and the Company is not liable for the difference.

9.6 If your Account shows a negative Balance after Stop-Out and subject to any negative-balance protection policy the Company has published, the Company may at its discretion absorb the negative Balance or pursue recovery of it as a debt due from you. The Company's policy on negative balances is published on the Dashboard and may be revised by the Company from time to time.

10.1 The Company accepts deposits via the following rails: (a) USDT-TRC20 (the Tron network), (b) USDT-ERC20 (the Ethereum network), (c) USDT-BEP20 (the BNB Smart Chain), (d) native Bitcoin, and (e) TheNetWallet (Indian fiat via UPI). The current list and any rail-specific instructions are published on the Dashboard.

10.2 There is no minimum deposit. The Company reserves the right to impose minimum or maximum deposit amounts for operational, risk, or compliance reasons, and will publish such limits on the Dashboard.

10.3 Each crypto deposit is allocated a per-invoice deposit address generated specifically for your Account. You must send funds only to the address shown on the open invoice and only on the network shown on the invoice. Funds sent to an address that has expired, to an incorrect address, on the wrong network, or using a token contract other than the published USDT contract for the network in question, may be unrecoverable. It is your responsibility to verify the address, the network, and the token before sending. The Company makes commercially reasonable efforts to recover misdirected funds but does not guarantee recovery and may charge an administrative recovery fee where recovery is possible.

10.4 Indian rupee deposits via TheNetWallet are processed against the verified Indian bank account or UPI handle from which the funds originate. Funds received from a third party will not be credited and may be returned net of any fees.

10.5 The Company processes withdrawals as follows:

• TheNetWallet payouts settle instantly, 24 hours a day, 7 days a week, subject to the operating availability of the Indian banking and UPI rails and the Company's compliance checks.
• Crypto withdrawals are reviewed and broadcast on-chain within 24 hours of request, subject to compliance checks. After broadcast, settlement is subject to the confirmation time of the relevant network and is outside the Company's control.

10.6 The Company applies a same-rail return policy: where reasonably possible, funds are returned via the same rail on which they were deposited. If you have funded the Account through multiple rails, the Company may apply a "first-in-first-out" or proportional rule when allocating a withdrawal between rails.

10.7 You may not request a withdrawal to a third-party wallet or bank account. Withdrawals must be paid to a wallet or account that you have demonstrated to the Company's satisfaction is owned by you.

10.8 Network fees, banking fees, and any other rail-specific fees are deducted from the withdrawal amount and disclosed before you confirm a withdrawal. The Company may also pass on bona fide costs imposed on it by third parties in connection with your withdrawal.

10.9 The Company may delay, suspend, or refuse a withdrawal if (a) KYC for the relevant tier is not complete, (b) the requested amount exceeds the cap for your current KYC tier, (c) there is a suspected breach of this Agreement, (d) a freezing order or court order applies to the funds, (e) the Company has reasonable grounds to suspect fraud or money laundering, or (f) any other compliance, sanctions, or risk-management ground applies. The Company will communicate the reason for the delay or refusal to the extent it is permitted by Applicable Law to do so.

11.1 The Company is compensated by spread on the Bullion VIP Account. No commission is charged on the Bullion VIP Account. The Company may offer other account types from time to time on which commissions or other charges do apply, and the terms of any such account will be published on the website.

11.2 Overnight financing ("swap") may be debited from or credited to your Account when a position is held past the daily rollover time. Swap rates are published per symbol on the Trading Platform and may change without prior notice.

11.3 Withdrawal fees, deposit fees (if any), inactivity fees (if introduced), and conversion charges are published on the Dashboard.

11.4 You are responsible for any taxes payable on your trading activity, including income tax, capital gains tax, withholding tax, or any equivalent tax under the law of your jurisdiction of residence. The Company is not a tax agent. The Company does not withhold tax on your behalf except where required to do so by Applicable Law. You should obtain independent tax advice if you are unsure of your obligations.

11.5 The Company may set off any amount owed by you to the Company against any amount owed by the Company to you, whether due, contingent, or future, and whether under this Agreement or otherwise, and may convert sums between currencies at a commercially reasonable rate to effect such set-off.

12.1 You undertake to use the Trading Platform and the Account in good faith and only for the purpose of placing genuine, market-facing Orders. You undertake not to engage in, and you warrant that no Transaction you place will form part of, the following prohibited practices:

(a) trading on the basis of latency, arbitrage, or feed errors, including taking advantage of stale prices, off-market quotes, or pricing inconsistencies;

(b) trading designed to abuse, circumvent, or exploit the Company's risk management, margin, leverage, swap, or Bonus terms;

(c) market manipulation, including spoofing, layering, painting the tape, and any other conduct described as market abuse under any recognised market-abuse regime;

(d) trading based on, or in coordination with, material non-public information about an Underlying Asset;

(e) any conduct designed primarily to extract Bonus credits, rebates, or other incentives without genuine trading intent;

(f) coordinated trading across multiple Accounts, or with third parties, to disguise the true beneficial owner of trading activity;

(g) any conduct that breaches Applicable Law in your jurisdiction or in the jurisdiction of the Company.

12.2 Where the Company has reasonable grounds to believe that a Transaction or pattern of Transactions forms part of conduct described in this Section 12, the Company may (i) void the affected Transactions, (ii) reverse profits or credit losses attributable to the conduct, (iii) suspend the Account, (iv) close the Account, (v) report the conduct to competent authorities, or (vi) take any combination of the foregoing actions. The Company will use commercially reasonable judgement when exercising rights under this clause.

12.3 The Company is the sole judge of what constitutes prohibited practice within the meaning of this Section, acting reasonably and in good faith.

13.1 The Company may from time to time offer promotional incentives, including a deposit-match welcome bonus of up to 100% of the deposited amount, capped at USD 2,500. Each promotion is subject to its own published terms in addition to this Agreement.

13.2 Bonus credit is unlocked into withdrawable cash only after the Client meets a trading-volume threshold equivalent to one (1) standard Forex lot traded per USD 2 of Bonus credited. The unlocked Bonus is not separately withdrawable; it is converted into cash Balance and forms part of your Equity.

13.3 Bonus credit that remains unlocked for sixty (60) consecutive days after the Bonus is granted is forfeited and the unlocked balance is removed from your Account. Inactivity, as defined in the promotional terms, may shorten this period.

13.4 Bonus credit is clawed back on withdrawal in accordance with the published Bonus terms. Without limitation, if you request a withdrawal before the volume threshold has been met, the unlocked Bonus, and any profit attributable to it on a pro-rata basis, may be deducted from your Balance.

13.5 The Company may amend, suspend, or withdraw any promotion at any time at its sole discretion. The Company may withhold or claw back Bonus credit where it has reasonable grounds to believe the promotion has been abused, including (without limitation) the use of multiple Accounts, coordinated trading, hedging across Accounts, or any conduct described in Section 12.

14.1 The Company holds client cryptocurrency receipts according to a hot-cold custody policy. Crypto deposits are received into hot wallets controlled by the Company. Balances above USD 500 per receiving address are swept to cold storage held by the Company on behalf of clients. The Company maintains aggregate hot-wallet exposure at no more than approximately one (1) day of receipts.

14.2 Fiat funds received via TheNetWallet and any other fiat rail the Company introduces are held in segregated banking accounts opened by the Company with reputable banking partners. Such accounts are designated for client funds and are kept separate from the Company's own operating accounts.

14.3 Notwithstanding clauses 14.1 and 14.2, you accept that Client Funds, while segregated from the Company's own funds, may be commingled with Funds of other Clients in pooled wallets or pooled bank accounts. Your interest in such pools is recorded on the Company's books as a pro-rata claim in USD against the pool.

14.4 The Company is not a bank. The Company does not pay interest on Client Funds. The Company holds Client Funds only for the purpose of supporting your trading activity and processing your deposits and withdrawals.

14.5 In the event of the Company's insolvency, Client Funds are intended to be returned to Clients ahead of the Company's general creditors, subject to Applicable Law in the jurisdiction of the Company. Clients have no statutory compensation right under any external investor compensation scheme.

15.1 The Company acts as principal counterparty to every Transaction. This means the Company's profit is, in part, your loss, and vice versa. This is a structural conflict of interest inherent in the business model.

15.2 The Company manages this conflict through (a) execution policies that aim to deliver fair and consistent pricing, (b) internal hedging and risk-management policies, (c) staff conduct policies, and (d) the Conflicts of Interest Policy published on the website. You are encouraged to review that policy.

15.3 The Company may from time to time pay or receive commissions, rebates, or other forms of remuneration from third parties, including introducing brokers, liquidity providers, payment partners, and technology vendors. Where required by Applicable Law, the existence and material terms of any such arrangement that materially affects you will be disclosed.

16.1 The Company offers a copy-trading service organised as a synthetic PAMM (Percentage Allocation Money Management) model. Under this model, a Client who is a manager ("Manager") trades only their own Account; the Company mirrors the Manager's percentage profit-and-loss return to investor allocations held in segregated trading sub-accounts ("Investor Allocations"). The Company is the counterparty to the mirrored P/L. Manager performance fees, allocation rules, and risk parameters are governed by the Copy Trading Addendum, which is incorporated by reference and prevails over this Agreement to the extent of any direct conflict on copy-trading matters.

16.2 By participating in copy trading as a Manager or as an Investor, you confirm that you have read and agree to the Copy Trading Addendum. You acknowledge that past performance of a Manager is not a reliable indicator of future performance, that investing in a Manager involves total risk to your Investor Allocation, and that the Company does not endorse, recommend, or warrant any Manager.

17.1 You acknowledge and accept that CFDs are complex, leveraged products carrying a high level of risk and may not be suitable for all investors.

17.2 You confirm that you have read, understood, and accept the Risk Disclosure Notice. Without limiting the Risk Disclosure, you specifically acknowledge: (a) you may lose all of your deposited funds; (b) prices, spreads, and Leverage can change rapidly; (c) trading on volatile instruments such as cryptocurrencies and equity indices entails additional risk; (d) operational risks include platform downtime, network latency, and data feed errors; (e) overnight gaps, weekend gaps, and "flash" moves can cause losses materially worse than the level set by a stop-loss order; (f) the Company is your counterparty and the Company's solvency is itself a risk to which you are exposed.

17.3 You confirm that you are trading using your own funds, that you can financially withstand the loss of those funds, and that you have made your own assessment of the suitability of CFD trading for your circumstances.

18.1 The Company's primary channel for individual communications with you is email. The Company will use the email address you have provided in your Account profile. It is your responsibility to keep that address current. The Company does not send SMS messages.

18.2 The Company provides support chat in English, Hindi, Arabic, and Spanish. The Company endeavours to provide a substantive answer in the language in which the question was asked but may, where necessary, respond in English.

18.3 You consent to receive electronic communications from the Company, including service messages, trade confirmations, statements, KYC requests, security notices, and amendments to this Agreement. Where Applicable Law permits, electronic communication satisfies any requirement that information be provided "in writing."

18.4 You consent to the recording of all telephone, video, chat, and other electronic communications between you and the Company, including chat support and any voice or video KYC interaction. Recordings are made for compliance, quality assurance, training, dispute-resolution, and evidentiary purposes. Recordings are the sole property of the Company, will be retained for the period required by Applicable Law, and may be disclosed to courts, arbitrators, regulators, auditors, or law-enforcement agencies as required or permitted by Applicable Law.

18.5 Account statements and trade confirmations are delivered electronically through the Trading Platform and the Dashboard. PDF statements are available on request and the Company will provide them within a reasonable time. The Company may charge a fee for repeated or excessive statement requests.

18.6 Any notice you wish to send to the Company under this Agreement should be sent by email to the support address published on the Dashboard, unless this Agreement requires a different method.

19.1 All intellectual property rights in the Bullion FX brand, the website, the Dashboard, the Company's market commentary, educational materials, charts, research, indicators, logos, designs, and any other content produced by the Company (the "Company Materials") are and remain the sole property of the Company or its licensors. The Trading Platform is the property of its respective vendor.

19.2 You are granted a personal, non-exclusive, non-transferable, and revocable licence to view and use the Company Materials and the Trading Platform solely for the purpose of operating your Account.

19.3 You may not reproduce, modify, redistribute, sublicense, sell, scrape, frame, mirror, or create derivative works of the Company Materials or the Trading Platform without the prior written consent of the Company.

20.1 The Company processes personal data about you in connection with your Account. The Company's processing of personal data is governed by the Privacy Policy published on the website, which forms part of this Agreement by reference. The Privacy Policy explains what data the Company collects, the legal bases on which the Company processes it, how long the Company retains it, with whom it is shared, and what rights you have in respect of it.

20.2 KYC documents and other personal data are stored securely on broker-controlled infrastructure. The Privacy Policy contains further information on data residency, security measures, and your rights.

20.3 Nothing in this Section 20 limits or duplicates the rights and obligations set out in the Privacy Policy. Where this Agreement and the Privacy Policy address the same matter, the Privacy Policy governs to the extent of any conflict.

21.1 The Company may suspend your Account, your access to the Trading Platform, your ability to deposit, your ability to withdraw, or your ability to trade, in whole or in part, with immediate effect and without prior notice, if (a) the Company has reasonable grounds to believe you are in material breach of this Agreement; (b) KYC for your current tier is incomplete or outdated; (c) the Company is required to do so by Applicable Law or by a competent authority; (d) there is suspected fraud, money laundering, sanctions exposure, or other compliance risk; (e) you are or become a resident of a Restricted Jurisdiction; (f) the Company suspects unauthorised access to your Account; or (g) the Company is investigating a complaint, dispute, or unusual activity.

21.2 The Company will notify you of a suspension as soon as it is permitted to do so under Applicable Law. The Company will lift the suspension as soon as the circumstances giving rise to it have been resolved to the Company's reasonable satisfaction. The Company is not liable for losses arising from a suspension imposed in accordance with this Section.

22.1 Either Party may terminate this Agreement at any time by giving written notice to the other. Termination by you takes effect when the Company has acknowledged receipt of your notice. Termination by the Company is effective immediately unless the Company specifies a later date in the notice.

22.2 The Company may terminate this Agreement immediately and without prior notice if (a) you commit a material breach of this Agreement that is not capable of being remedied or that you have failed to remedy within a reasonable period after the Company gave notice of the breach; (b) you become subject to insolvency proceedings; (c) you become a Sanctioned Person; (d) you become a resident of a Restricted Jurisdiction; (e) you have provided false or misleading information in connection with your Account; (f) you have engaged in conduct described in Section 12 (Market Conduct and Prohibited Practices); or (g) the Company is required by Applicable Law or a competent authority to terminate.

22.3 On termination, the Company will (i) close any open positions at the prevailing market price; (ii) calculate the closing Balance, including any Bonus clawback under Section 13; (iii) deduct any fees, charges, or sums owed to the Company; and (iv) return the residual Balance, if any, to you via a rail consistent with Section 10.

22.4 The following Sections survive termination: Section 2 (Definitions), Section 4 (KYC and AML — to the extent required by Applicable Law), Section 11 (Fees), Section 12 (Market Conduct), Section 13 (Bonuses, clawback), Section 18 (Communications and Recording), Section 19 (Intellectual Property), Section 20 (Privacy), Section 22.3 (Closing-out), Section 23 (Default), Section 25 (Liability and Indemnity), Section 26 (Force Majeure), Section 28 (AML and Sanctions), Section 30 (Governing Law and Dispute Resolution), and any other provision that by its nature is intended to survive.

23.1 Each of the following is an "Event of Default" by you: (a) failure to pay any amount due to the Company when due; (b) failure to maintain Margin; (c) any breach of a material term of this Agreement; (d) the inaccuracy of any representation or warranty you have given under this Agreement; (e) insolvency, bankruptcy, liquidation, or any analogous proceeding; (f) the death or legal incapacity of an individual Client; (g) the Company's reasonable belief that an Event of Default is imminent.

23.2 On the occurrence of an Event of Default, the Company may, without prior notice and at its sole discretion, do any one or more of the following: (i) close any or all open positions at prevailing market prices; (ii) suspend or terminate the Account; (iii) liquidate, set off, or net any obligation between the Parties; (iv) convert any Balance into USD; (v) retain Client Funds pending investigation; (vi) treat any contract or Transaction as voided ab initio; (vii) require additional Margin; (viii) take any other action the Company considers necessary or appropriate to protect itself or the Client.

23.3 The Company's exercise of any right under this Section is without prejudice to any other right or remedy the Company may have under this Agreement or at law.

24.1 You represent and warrant to the Company on the date of this Agreement, on each date on which you place an Order, and on each date on which you instruct a deposit or withdrawal, that:

(a) you are not under the age of legal capacity in your jurisdiction;

(b) you are not a resident or citizen of a Restricted Jurisdiction;

(c) you are not a Sanctioned Person;

(d) the funds you are using to fund your Account are lawfully yours, derived from lawful sources, and not the proceeds of crime;

(e) you are not acting on behalf of any undisclosed third party;

(f) all information you have provided to the Company is true, complete, accurate, and current;

(g) you are entering into this Agreement on your own account, not as agent or nominee for another, save where you have disclosed and the Company has approved such arrangement in writing;

(h) you have the legal capacity and authority to enter into this Agreement and to perform your obligations under it;

(i) you understand CFDs and the risks of leveraged trading and are capable of bearing the loss of your entire deposit;

(j) you are not relying on any statement made by the Company or any of its employees, agents, or affiliates other than what is set out in this Agreement and the Client Documents.

24.2 Each representation and warranty is repeated by you continuously while this Agreement is in force. You will notify the Company promptly if any representation or warranty becomes incorrect or misleading.

25.1 The services provided under this Agreement are provided on an "as is" and "as available" basis. To the maximum extent permitted by Applicable Law, the Company excludes all warranties, conditions, and representations that are not expressly set out in this Agreement, whether implied by statute, common law, or otherwise.

25.2 To the maximum extent permitted by Applicable Law, the Company is not liable to you for any indirect, consequential, special, exemplary, punitive, or incidental loss, including (without limitation) loss of profits, loss of opportunity, loss of business, loss of revenue, loss of goodwill, or loss of data, in each case howsoever arising.

25.3 The Company is not liable for any loss arising from: (a) market movement, slippage, volatility, gaps, or illiquidity; (b) failure, malfunction, latency, or unavailability of the Trading Platform, the Dashboard, internet connectivity, or any third-party system; (c) any act, omission, default, or insolvency of any liquidity provider, payment partner, blockchain network, bank, or other third party; (d) any action the Company takes in good-faith compliance with Applicable Law or with an order of a competent authority; (e) any Force Majeure Event; (f) any loss attributable to the Client's negligence, breach of this Agreement, or use of incorrect credentials, addresses, or networks; (g) any loss attributable to a third party with whom you have shared your credentials; (h) any tax or regulatory consequence of your trading activity; (i) any inaccuracy in market data, research, or other content the Company publishes.

25.4 If, despite the limitations in this Section, the Company is found liable to you in respect of any matter arising out of or in connection with this Agreement, the Company's aggregate liability to you for all such matters in any rolling twelve-month period is capped at the lower of (i) the total fees, commissions, and net swap charges actually paid by you to the Company in that period, and (ii) USD 50,000.

25.5 You agree to indemnify the Company, its affiliates, directors, officers, employees, and agents, and to hold them harmless, on demand against any and all claims, losses, damages, liabilities, costs, and expenses (including reasonable legal fees) arising from or in connection with: (a) your breach of this Agreement; (b) your breach of Applicable Law; (c) your fraud, wilful misconduct, or negligence; (d) any third-party claim attributable to your acts or omissions; (e) any tax payable by the Company on your behalf and not recoverable from you in the ordinary course.

25.6 Nothing in this Section excludes or limits any liability that cannot be lawfully excluded or limited under Applicable Law, including liability for fraud or for death or personal injury caused by negligence.

26.1 A "Force Majeure Event" is any event or circumstance beyond the reasonable control of the Company, including (without limitation) acts of God, war, civil unrest, terrorism, riot, pandemic, government action, emergency legislation, sanctions, exchange or liquidity-provider failure, currency restrictions, banking restrictions, blockchain network failure or congestion, fork events on a blockchain, internet outage, cyber-attack, data centre failure, power failure, labour dispute, regulatory suspension of trading, market closure, abnormal market conditions, or any event that materially impairs the Company's ability to perform its obligations under this Agreement.

26.2 On the occurrence of a Force Majeure Event the Company may, in its commercially reasonable judgement, do any one or more of the following: (a) increase Margin requirements; (b) restrict trading, deposits, or withdrawals; (c) close any open positions at the prevailing market price; (d) suspend or modify the application of any provision of this Agreement to the extent necessary; (e) refuse to accept new Orders; (f) revise spreads, swaps, or Leverage caps. The Company will notify you of action taken under this Section as soon as reasonably practicable.

26.3 The Company is not liable for any loss arising from the occurrence of a Force Majeure Event or from any action taken under this Section.

27.1 The Company may amend this Agreement, including the schedules and any of the Client Documents, by publishing the amended version on the website and the Dashboard. The Company will notify you of material amendments by email and provide a reasonable notice period before the amendment takes effect, unless an amendment is required to come into effect immediately to comply with Applicable Law, to respond to a security threat, or to address a regulatory direction.

27.2 The Company will indicate the date of the most recent amendment at the top of the amended document and maintain a revision history (see Section 33).

27.3 Your continued use of the Account or the Trading Platform after the effective date of an amendment constitutes your acceptance of the amended Agreement. If you do not accept an amendment, your sole remedy is to terminate this Agreement in accordance with Section 22.

28.1 The Company is committed to preventing the use of its services in connection with money laundering, terrorist financing, fraud, or the evasion of sanctions. The Company maintains an Anti-Money Laundering Policy that forms part of this Agreement by reference.

28.2 You undertake to comply at all times with all anti-money-laundering, counter-terrorism-financing, and sanctions laws applicable to you, including those of your jurisdiction of residence and citizenship.

28.3 You confirm that you are not a "Sanctioned Person" within the meaning of any sanctions list maintained by the United Nations Security Council, the Office of Foreign Assets Control of the United States Department of the Treasury, the European Union, the United Kingdom, or any other competent authority that the Company has determined to be binding on it.

28.4 The Company may freeze, restrict, or close an Account, and report the Account to a competent authority, where the Company has reasonable grounds to suspect a breach of this Section, without notice and without liability to you for any loss arising from such action.

29.1 The Company maintains a Complaints Handling Policy published on the website. If you have a complaint, you must submit it in writing to the support address on the Dashboard, stating the nature of the complaint, the relevant Account, the date and time of the events complained of, and the outcome you are seeking.

29.2 The Company will acknowledge receipt of a complaint within five (5) business days and will provide a substantive response within thirty (30) calendar days, unless a longer period is reasonably required because of the complexity of the matter, in which case the Company will inform you of the expected timeline.

29.3 If a dispute cannot be resolved by the Company's internal complaints process, the Parties will attempt in good faith to resolve the dispute through negotiation. Where negotiation has failed, the Parties may refer the dispute to an independent dispute-resolution body of competent jurisdiction, such as a recognised online financial dispute-resolution service.

29.4 If the dispute remains unresolved, the dispute will be referred to the International Chamber of Commerce (ICC) Rules of Arbitration for final and binding arbitration in accordance with the rules of that venue, unless either Party is required to commence court proceedings to enforce or preserve a right. The seat of arbitration is Singapore, and the language of arbitration is English.

29.5 You waive any right to participate in a class action, collective action, or other consolidated proceeding against the Company, except where such waiver is not permitted by Applicable Law.

30.1 This Agreement, and any non-contractual obligation arising out of or in connection with it, are governed by and construed in accordance with the laws of the laws of St. Vincent and the Grenadines, without regard to its conflict-of-laws rules.

30.2 Subject to Section 29 (Complaints and Dispute Resolution), the courts of the laws of St. Vincent and the Grenadines have exclusive jurisdiction to settle any dispute arising out of or in connection with this Agreement.

31.1 Entire Agreement. This Agreement, together with the other Client Documents incorporated by reference, constitutes the entire agreement between the Parties on its subject matter and supersedes all prior agreements, understandings, communications, and representations. No statement, promise, or representation made by the Company or any of its agents that is not set out in this Agreement or in the Client Documents will have any legal effect.

31.2 Severability. If any provision of this Agreement is found by a court or arbitrator of competent jurisdiction to be unenforceable, illegal, or void, that finding does not affect the rest of the Agreement, and the provision will be deemed modified to the minimum extent necessary to make it enforceable, or, if it cannot be so modified, deleted, with the rest of the Agreement continuing in full force and effect.

31.3 Non-exercise of rights / Waiver. A failure or delay by the Company in exercising any right under this Agreement is not a waiver of that right. A waiver is only effective if it is given in writing.

31.4 Assignment. You may not assign, novate, or otherwise transfer your rights or obligations under this Agreement without the prior written consent of the Company. The Company may assign, novate, or otherwise transfer this Agreement, in whole or in part, to any affiliate or to any third party in connection with a corporate restructuring, sale, or transfer of business, on giving you notice.

31.5 Third-party rights. No person other than the Parties has any right to enforce this Agreement.

31.6 No partnership. Nothing in this Agreement creates a partnership, joint venture, agency, employment, or fiduciary relationship between the Parties.

31.7 Language. This Agreement is published in English. The Company may translate it into other languages for convenience. In the event of a conflict between the English version and a translation, the English version prevails.

31.8 Currency. All references to "USD" or "$" are to United States dollars. Where this Agreement requires a calculation in USD of an amount denominated in another currency or in cryptocurrency, the conversion is made at the exchange rate the Company applies in the ordinary course of business.

31.9 Headings. Headings are for convenience only and do not affect the interpretation of this Agreement.

31.10 Counterparts and electronic signature. This Agreement may be entered into electronically. Your click-through acceptance, or any other electronic indication of acceptance recorded on the Company's systems, is binding on you. Each Party waives any defence based on the absence of a wet-ink signature.

32.1 An Account that has had no Client-initiated login, deposit, withdrawal, or Order for a continuous period of twelve (12) months may be marked as inactive. The Company may apply a published inactivity fee to inactive Accounts, deducted from the Balance, until the Balance is exhausted or the Account is reactivated.

32.2 An Account that has had no Client-initiated activity and no remaining Balance for a continuous period of twenty-four (24) months may be marked as dormant and closed. The Company will use commercially reasonable efforts to notify you before closure.

32.3 Where an Account is closed with a residual Balance that the Company has been unable to return to you despite reasonable efforts, the Company may apply the unclaimed balances treatment required by Applicable Law in the Company's jurisdiction.